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Gujarat Maritime Board
Republic of India
PREPARATORY SURVEY
ON
THE SHIP RECYCLING YARD IMPROVEMENT PROJECT
IN
INDIA
FINAL REPORT (DRAFT)
July 2017
JAPAN INTERNATIONAL COOPERATION AGENCY
JAPAN MARINE SCIENCE INC.

PADECO CO., LTD.
JAPAN DEVELOPMENT INSTITUTE CO. LTD.
PREPARATORY SURVEY ON THE SHIP RECYCLING YARD IMPROVEMENT PROJECT IN INDIA
CONTENTS
1. BACKGROUND AND HISTORY OF THE PROJECT .......................................... 2

1.1. BACKGROUND OF THE PROJECT .................................................................................... 2
1.1.1. REQUIREMENTS OF THE CONVENTION AND RELATION OF THE PROJECT ............. 2
1.1.2. SHIP RECYCLING CONVENTION ......................................................................................... 2
1.1.3. INTERNATIONAL SHIP RECYCLING SITUATION AND ITS ISSUES .............................. 4
1.2. SHIP RECYCLING INDUSTRY IN INDIA .......................................................................... 5
1.3. NATIONAL DEVELOPMENT PLAN RELATED TO THE PROJECT .............................. 6
1.4. BACKGROUND AND HISTORY OF THE RQUEST OF THE PROJECT ......................... 7
1.5. COOPERATION BY OTHER DONERS AND/OR INTERNATIONAL AGENCIES ......... 8
2. PRESENT CONDITION AND ISSUES OF THE INDUSTRY............................... 9

2.1. PRESENT CONDITION AND ISSUES OF SHIP RECYCLING PROCESS ....................... 9
2.1.1. PRESENT CONDITIONS OF THE SHIP-RECYCLING PROCESS IN ALANG /SOSIYA ... 9
2.1.2. CURRENT STATUS AND ISSUES OF SHIP RECYCLING FACILITIES IN ALANG /
SOSIYA ................................................................................................................................................... 13
2.2. PRESENT SITUATION AND ISSUES OF OCCUPATIONAL SAFETY AND HEALTH ...
............................................................................................................................................... 26
2.2.1. EXISTING OCCUPATIONAL SAFETY TRAINING & EDUCATION PROGRAM ........... 26
2.2.2. PRESENT CONDITION OF OCCUPATIONAL SAFETY AND HEALTH IN SHIP
RECYCLING PROCESS.......................................................................................................................... 27
2.2.3. EVALUATION OF CURRENT MEASURES EMPLOYED TOWARDS LABOR SAFETY
AND HEALTH AND ENVIRONMENTAL PROTECTION .................................................................. 32
2.3. CURRENT STATUS AND ISSUES ON ENVIRONMENTAL CONSIDERATION ......... 34
2.3.1. CURRENT SITUATION ON ENVIRONMENTAL CONSIDERATION .............................. 34
2.3.2. OUTLINE OF EXISTING FACILITIES .................................................................................. 36
3. PRELIMINARY DESIGN OF THE PROJECT ..................................................... 42

3.1. NATURAL CONDITION SURVEY AND TESTING ........................................................ 42
3.2. SCOPE AND CONTENTS OF THE PROJECT .................................................................. 47
1) Improvement of yard for protection of pollution to soil and intertidal zone ........... 51
3.2.2. IMPROVEMENT PLAN .......................................................................................................... 53
3.3. IMPROVEMENT OF SHIP RECYCLING YARD FACILITIES........................................ 54
3.3.1. IMPROVEMENT OF YARD FACILITIES ............................................................................. 54
3.3.2. PRELIMINARY DESIGN ........................................................................................................ 56
3.3.3. PROPOSAL FOR INTRODUCTION OF NEW MACHINES................................................. 69
3.4. IMPROVEMENT OF ENVIRONMENT FACILITY AND TSDF ...................................... 80
3.4.1. STUDY OF TREATMENT METHOD OF HAZARDOUS SUBSTANCES .......................... 80
3.4.2. OFFSHORE AND BEACH ENVIRONMENT FACILITY PLAN.......................................... 88
3.4.3. ENVIRONMENT FACILITY PLAN FOR HAZARDOUS MATERIAL TREATMENT ON
LAND ................................................................................................................................................... 97
3.4.4. MULTI PURPOSE WORK BOAT......................................................................................... 108
3.5. DEMAND FORECAST ...................................................................................................... 112
3.5.1. SHORT-TERM DEMAND FORECAST ............................................................................... 112
3.5.2. LONG-TERM DEMAND FORECAST ................................................................................. 112
3.5.3. CONSIDERATION ON THE SUTAINABILITY OF THE PROJECT ................................. 116
4. PROCUREMENT METHOD ............................................................................... 117

4.1. IMPLEMENTATION POLICY / PROCUREMENT POLICY.......................................... 117
4.1.1. IMPLEMENTATION POLICY .............................................................................................. 117
4.1.2. PROCUREMENT POLICY .................................................................................................... 118
4.1.3. IMPLEMENTATION PERIOD .............................................................................................. 119
4.2. CONSIDERATION ON CONSTRUCTION / PROCUREMENT ..................................... 121
4.2.1. CONSIDERATION ON CONSTRUCTION .......................................................................... 121
4.2.2. CONSIDERATION ON PROCUREMENT ........................................................................... 121

4.3. DEMARCATION OF CONSTRUCTION, PROCUREMENT & INSTALLATION ........ 121
4.3.1. DEMARCATION OF CONSTRUCTION ............................................................................. 121
4.3.2. DEMARCATION OF PROCUREMENT & INSTALLATOIN............................................. 123
4.4. CONSTRUCTION / PROCUREMENT SUPERVISION PLAN ....................................... 123
4.4.1. CONSTRUCTION / PROCUREMENT SUPERVISION PLAN ........................................... 123
4.4.2. QUALITY ASSURANCE PLAN ........................................................................................... 124
4.5. EQUIPMENT AND MATERIAL PROCUREMENT PLAN ............................................ 124
4.5.1. PROCUREMENT ITEMS ...................................................................................................... 124
5. CONSULTING SERVICES.................................................................................. 126

5.1. SELECTION OF CONSULTANTS FOR DETAILED DESIGN AND SUPERVISORY
SERVICES ............................................................................................................................................. 126
5.2. TERMS OF REFERENCES (TOR) OF THE CONSULTANT ......................................... 126
5.2.1. SCOPE OF WORK OF THE CONSULTANT ....................................................................... 126
5.3. SCOPE OF WORK OF THE CONSULTING SERVICES ................................................ 127
5.3.1. SCOPE OF THE WORK ........................................................................................................ 127
5.3.2. WORK SCHEDULE ............................................................................................................... 128
5.3.3. MANNING PLAN .................................................................................................................. 128
5.3.4. REQUIRE MON-MONTHS ................................................................................................... 131
5.3.5. TERMS OF REFERENCES (TOR) OF THE CONSULTANT ............................................. 132
6. PROJECT COSTS AND FINANCIAL PLAN ..................................................... 133

6.1. PROJECT COSTS .............................................................................................................. 133
6.1.1. CONDITIONS OF THE COSTS ESTIMATION ................................................................... 133
6.1.2. PROJECT COSTS .................................................................................................................. 133
6.2. STUDY ON FINANCIAL CASH FLOW .......................................................................... 136
6.2.1. PROJECT COST ESTIMATION FOR EACH PROJECT COMPONENTS ......................... 137
6.2.2. EXPECTED INCOME FROM PROJECTS ........................................................................... 138
6.2.2. EVALUATION OF PRICE SETTING ................................................................................... 140
7. FINANCIAL AND ECONOMIC ANALYSIS ..................................................... 145

7.1. FINANCIAL AND ECONOMIC ANALYSIS ................................................................... 145
7.1.1. FUND REQUIRED FOR INVESTMENT AND OPERATION COST ESTIMATE............. 145
7.1.2. PLANNING FOR REQUIRED FUND................................................................................... 147
7.1.3. OPERATIONAL PLAN ......................................................................................................... 148
7.1.4. PRICING PLAN ..................................................................................................................... 148
7.2. FINANCIAL RATE OF RETURN（FIRR） .................................................................... 150
7.2.1. METHODOLOGY .................................................................................................................. 150
7.2.2. RESULT.................................................................................................................................. 150
7.2.3. SENSITIVITY ANALYSIS OF FINANCIAL INTERNAL RATE OF RETURN ................ 153
7.2.4. RESULTS OF SENSITIVITY ANALYSIS ........................................................................... 154
7.3. ECONOMIC INTERNAL RATE OF RETURN (FIRR) .................................................... 154
7.3.1. ECONOMIC ANALYSIS ....................................................................................................... 154
7.3.2. CONVERSION FROM FINANCIAL COST TO ECONOMIC COST ................................. 154
7.3.3. ESTIMATE OF ECONOMIC BENEFIT ............................................................................... 155
7.3.4. ECONOMIC INTERNAL RATE OF RETURN .................................................................... 156
8. PROJECT IMPLEMENTATION SCHEDULE.................................................... 159
9. PROJECT IMPLEMENTING ORGANIZATION AND MAINTENANCE

MANAGEMENT SYSTEM ................................................................................................................. 161
9.1. OUTLINE OF THE PROJECT IMPLEMENTING AGENCY .......................................... 161
9.1.1. ORGANIZATION STRUCTURE FOR PROJECT IMPLEMENTATION AND
MANAGEMENT .................................................................................................................................... 161
9.1.2. EVALUATION OF FINANCIAL CAPABILITY OF IMPLEMENTING AGENCY AND

COUNTER MEASURES........................................................................................................................ 165
9.1.3. MAINTENANCE OF CONCRETE FLOOR ......................................................................... 173
9.1.4. EQUIPMENT AND PLANT .................................................................................................. 175
10. CAPACITY DEVELOPMENT PLAN ................................................................. 176

10.1. EVALUATION OF CURRENT SHIP RECYCLING PRACTICE IN CONFORMITY
WITH THE SHIP RECYCLING CONVENTION ................................................................................. 176
10.1.1. REQUIREMENTS TO COMPLY WITH THE SHIP RECYCLING CONVENTION ......... 176
10.1.4. EVALUATION OF CURRENT MEASURES EMPLOYED TOWARDS LABOR SAFETY
AND HEALTH AND ENVIRONMENT PROTECTION ..................................................................... 177
10.2. TRAINING PROGRAM ..................................................................................................... 179
1.1.2. IMPROVEMENT OF SHIP RECYCLING INDUSTRY IN CONFORMITY WITH THE
SHIP RECYCLING CONVENTION ..................................................................................................... 179
10.2.2. TRAINING PRESENTED IN GMB’S SAFETY TRAINING & LABOR WELFARE
INSTITUTE ............................................................................................................................................ 180
10.2.3. OUTLINE OF PROPOSED TRAINING COURSE FOR SHIP RECYCLING IN
COMPLIANCE WITH THE SHIP RECYCLING CONVENTION ...................................................... 180
10.2.4. PROPOSAL OF NEW TRAINING PROGRAM BASED ON THE SHIP RECYCLING
CONVENTION ...................................................................................................................................... 181
10.2.5. PROPOSED TRAINING COURSE UNDER THE CAPACITY DEVELOPMENT PLAN . 182
11. ENVIRONMENT AND SOCIAL CONSIDERATION ....................................... 188

11.1. PROJECT DESCRIPTION ................................................................................................. 188
11.1.1. BACKGROUND..................................................................................................................... 188
11.1.2. SHIP RECYCLING PROCEDURE........................................................................................ 188
11.1.3. PROJECT SCOPE .................................................................................................................. 189
11.1.4. RISKS OF CLIMATE CHANGE ........................................................................................... 198
11.1.5. CONSTRUCITON PLAN....................................................................................................... 198
11.1.6. STATUS OF EIA AND GAPS WITH JICA GUIDELINE .................................................... 200
11.2. REGULATORY FRAMEWORK ....................................................................................... 201
11.2.1. ENVIRONMENTAL LAWS AND REGULATIONS ........................................................... 201
11.2.2. ENVIRONMENTAL LAWS AND REGULATIONS ........................................................... 204
11.2.3. ENVIRONMENTAL STANDARDS ..................................................................................... 205
11.2.4. ENVIRONMENTAL GUIDELINES...................................................................................... 205
11.2.5. INTERNATIONAL CONVENTIONS ................................................................................... 206
11.3. CURRENT ENVIRONMENTAL STATUS....................................................................... 206
11.3.1. CLIMATE ............................................................................................................................... 206
11.3.2. HYDROLOGY ....................................................................................................................... 206
11.3.3. TOPOGRAPHY ...................................................................................................................... 206
11.3.4. POLLUTION .......................................................................................................................... 208
11.3.5. NATURAL ENVIRONMENT ............................................................................................... 234
11.3.6. SOCIAL ENVIRONMENT .................................................................................................... 239
11.3.7. WORKING ENVIRONMENT OF SHIP RECYCLING INDUSTRY ................................... 244
11.4. ANALYSIS OF ALTERNATIVES .................................................................................... 250
11.4.1. Without Project option ............................................................................................................ 250
11.4.2. Analysis of alternatives of ship breaking methods .................................................................. 250
11.5. SCOPING AND TOR OF THE EIA STUDY .................................................................... 253
11.6. IMPACT ASSESSMENT AND MITIGATION MEASURES........................................... 259
11.6.1. IMPACT ASSESSMENT ....................................................................................................... 259
11.6.2. MITIGATION MEASURES (CONSTRUCTION STAGE) .................................................. 264
11.6.3. MITIGATION MEASURES (OPERATION STAGE)........................................................... 267
11.7. ENVIRONMENTAL MANAGEMENT PLAN ................................................................. 274
11.8. ENVIRONMENTAL MONITORING PLAN .................................................................... 282
11.9. IMPLEMENTATION STRUCTURE ................................................................................. 292
11.10. STAKEHOLDER MEETING ............................................................................................. 294
11.11. Conclusion and recommendations ...................................................................................... 296
Appendix 1
Appendix 2
Appendix 3
Appendix 4
Appendix 5
Appendix 6
Appendix 7
Appendix 8
LIST OF TABLES
Table 2-1 Present Ship Recycling Process before the Hong Kong Convention .......................................... 9
Table 2-2 Main Requirements of the Ship Recycling Convention............................................................ 11
Table 2-3 IMO Convention Requirements on Ship Recycling Process and its Conformity in India ........ 12
Table 2-4 Result of the 36 Yards ............................................................................................................. 13
Table 2-5 Outlook of the Results of the Surveyed Yards......................................................................... 14
Table 2-6 Conformity of Requirements of the IMO Convention and Ship Recycling Facility ................ 25
Table 2-7 Training Courses provided in Safety Training & Laborer Welfare Institute ............................ 26
Table 2-8 Results of site investigation and status of conformity with the requirement of the Convention
............................................................................................................................................................... 32
Table 2-9 Type and Volume of wastes generated from Ship .................................................................... 34
Table 2-10 Outline of Landfill Site ........................................................................................................... 39
Table 3-1 Proposition of recommended facilities and equipment to comply with the Convention .......... 47
Table 3-2 Proposed scope of the Project and corresponding requirements of the Ship Recycle
Convention ............................................................................................................................................ 49
Table 3-3 Current situation of Ship breaking yard（plot）...................................................................... 55
Table 3-4 Renovation of number of Ship breaking yard (plots) ............................................................... 56
Table 3-5 Reference Values for the Action Conditions of Concrete Pavements used for the Yards ........ 60
Table 3-6 Reference Values for Base Course Thickness of Concrete Pavements .................................... 61
Table 3-7 Reference Values for Concrete Slab Thickness ........................................................................ 62
Table 3-8 Comparison of performance between Crawler crane and Wheel crane .................................... 71
Table 3-9 Past record of broken ships number in Alang-Sosiya ............................................................... 76
Table 3-10 Calculation for required number of Large Crawler Crane ...................................................... 77
Table 3-11 Calculation for required number of Beach Cleaning Machine ............................................... 80
Table 3-12 Removal and Handling Process Hazardous Substances.......................................................... 80
Table 3-13 Wastes to be treated ................................................................................................................ 81
Table 3-14 Volume of oily wastes generated from ship ........................................................................... 82
Table 3-15 Type and volume of wastes generated though the recycling process ..................................... 83
Table 3-16 Ship Recycle Volume ............................................................................................................. 84
Table 3-17 Wastes received at TSDF in 2015-2016 (unit: tons) ............................................................... 84
Table 3-18 Capacity of Environment Facility of TSDF ............................................................................ 85
Table 3-19 Planned Wastes Treatment Plant ............................................................................................ 86
Table 3-20 Basic Concept of the Oil Colleting Barge............................................................................... 91
Table 3-21 Specifications of Offshore Tank Cleaning Barge ................................................................... 92
Table 3-22 Comparison of MDS and Conventional Method .................................................................... 95
Table 3-23 Record of Wastes received TSDF ........................................................................................... 97
Table 3-24 Particulars of Multi-Purpose Vessel ..................................................................................... 109
Table 3-25 Average scrap age (by types of ship) .................................................................................... 114
Table 4-1 Relationship between temperature and precipitation in Ahmedabad. ..................................... 117
Table 4-2 Ideal Procurement Package ..................................................................................................... 118
Table 4-3 Demarcation of responsibility between Contractor and Gov. of Inida ................................... 122
Table 4-4 Quality control items of major works ..................................................................................... 124
Table 4-5 Suppliers of construction materials ......................................................................................... 124
Table 4-6 Suppliers of Construction Equipment ..................................................................................... 125
Table 4-7 Supplier of Plant equipment ................................................................................................... 125
Table 5-1 Main items of Consulting work .............................................................................................. 127
Table 5-2 Work Schedule of the Consultant ........................................................................................... 128
Table 5-3 Required works and qualification of Consultants (Professional A) ........................................ 128
Table 5-4 Required works and qualification of Consultants (Professional B) ........................................ 129
Table 5-5 Required Man-Months (Professional A)................................................................................. 132
Table 6-1 Total Project Cost (JPY) ......................................................................................................... 135
Table 6-2 Annual disbursement schedule of the Project (Million Japanese Yen)................................... 136
Table 6-3 Project Cost of each project components (Unit: JPY thousand) ............................................. 137
Table 6-4 Proposed tariff schedule to be imposed by GMB ................................................................... 138
Table 7-1 Required capital cost for each project..................................................................................... 145
Table 7-2 Annual O&M Costs ................................................................................................................ 146

Table 7-3 Annual Interest costs (Unit: JPY 1,000) ................................................................................. 147
Table 7-4 Planning for loans (unit US$ 1,000) ....................................................................................... 148
Table 7-5 Interest conditions ................................................................................................................... 148
Table 7-6 Rent price scheduling ............................................................................................................. 149
Table 7-7 Assumed revenue (Unit: JPY 1,000) ...................................................................................... 149
Table 7-8 The results of financial analysis for each project component ................................................. 150
Table 7-9 Financial internal rate of return (FIRR) and cash flow chart .................................................. 152
Table 7-10 Sensitivity analysis (%) ........................................................................................................ 153
Table 7-11 Export and import transaction of India (Unit: US$ million) ................................................. 154
Table 7-12 Conversion from Financial Cost to Economic Cost (Unit JPY 1,000) ................................. 155
Table 7-13 Comparison between With/Without the Project in Economic Benefit ................................. 155
Table 7-14 Cash flow chart for EIRR ..................................................................................................... 156
Table 7-15 Economic international rate of return ................................................................................... 157
Table 9-1 Major indicators of financial status (Unit: US$ million [Rs. million]) ................................... 162
Table 9-2 GMB’s Financial Statement (Profit and loss of ship recycling operation at Alang-Sosia)..... 165
Table 9-3 Balance Sheet (GMB) ............................................................................................................. 166
Table 9-4 Profit and loss statement (GMB) ............................................................................................ 167
Table 9-5 Income from ship recycling project ........................................................................................ 167
Table 9-6 Financial Soundness of GMB ................................................................................................. 168
Table 9-7 Projects List Performed by GMB in the Last Five Years ....................................................... 169
Table 9-8 Role of the relative organizations for the project implementation .......................................... 172
Table 10-1 Guidelines for Safe and Environmentally Sound Ship Recycling ........................................ 176
Table 10-2 Results of site investigation and status of conformity with the requirements of the
Convention (C: Complied, NC: Not Complied) .................................................................................. 177
Table 10-3 Summary of necessary improvements .................................................................................. 178
Table 10-4 Training Courses provided in Safety Training & Labor Welfare Institute ........................... 180
Table 10-5 Training Course I .................................................................................................................. 182
Table 10-6 Training Course II................................................................................................................. 183
Table 10-7 Training Course III ............................................................................................................... 184
Table 10-8 Proposed Training Courses (contd.) ..................................................................................... 185
Table 11-1 Main construction machines and equipment......................................................................... 198
Table 11-2 Type and number of construction workers ........................................................................... 199
Table 11-3 Construction schedule ........................................................................................................... 199
Table 11-4 Gaps between India’s EIA law and JICA environmental guideline and the Project’s policy to
fill the gaps .......................................................................................................................................... 203
Table 11-5 List of permits required from GPCB .................................................................................... 204
Table 11-6 List of national environmental laws/regulations relevant to this Project .............................. 205
Table 11-7 List of national environmental standards relevant to this Project ......................................... 205
Table 11-8 List of national environmental guidelines relevant to this Project........................................ 206
Table 11-9 Results of EIA air quality survey .......................................................................................... 209
Table 11-10 Ambient air quality standard of India and WHO ................................................................ 209
Table 11-11 Results of EIA air quality survey at recycling yard and TSDF........................................... 210
Table 11-12 Location of asbestos sampling sites .................................................................................... 210
Table 11-8 Results of asbestos survey .................................................................................................... 211
Table 11-14 Seawater quality standard of India ...................................................................................... 212
Table 11-15 Results of EIA seawater quality survey .............................................................................. 213
Table 11-16 Results of EIA groundwater quality survey ........................................................................ 216
Table 11-17 Results of groundwater quality analysis ............................................................................. 219
Table 11-18 Results of leachate quality analysis ................................................................................... 220
Table 11-19 Results of groundwater quality analysis (additional survey) .............................................. 222
Table 11-20 Results of leachate quality analysis (additional survey) ..................................................... 223
Table 11-21 Results of EIA noise survey................................................................................................ 224
Table 11-22 Results of soil quality analysis (ship recycling yard) ......................................................... 226
Table 11-23 Results of soil quality analysis (TSDF) .............................................................................. 227
Table 11-24 Results of sediment quality analysis (supplementary survey) ............................................ 229
Table 11-25 Results of sediment quality analysis (additional survey) .................................................... 231
Table 11-26 Type and volume of wastes received at TSDF and treatment and disposal methods ......... 233
Table 11-27 Results of component analysis of ship paints ..................................................................... 234
Table 11-28 Results of EIA flora survey ................................................................................................ 235
Table 11-29 Results of EIA fauna survey (mammals) ............................................................................ 235
Table 11-30 Results of EIA fauna survey (birds).................................................................................... 235
Table 11-31 Location of surveyed transects ........................................................................................... 236
Table 11-32 Results of phytoplankton survey......................................................................................... 237
Table 11-33 Results of zooplankton survey ............................................................................................ 237
Table 11-34 Results of benthos survey ................................................................................................... 238
Table 11-35 Results of nearshore benthos survey ................................................................................... 238
Table 11-36 Analysis results of heavy metal content inside Matuta lunaris .......................................... 238
Table 11-37 Demographic composition of Alang, Manar and Sosiya Village ....................................... 239
Table 11-38 Income level of interviewed villagers engaged in agriculture and ship recycling related
work..................................................................................................................................................... 240
Table 11-39 Literacy rate of Alang-Manar village and Sosiya village ................................................... 243
Table 11-40 Ratio of scheduled caste/tribes population in Alang-Manar village and Sosiya village ..... 243
Table 11-41 Position-wise Salary Level of Workers .............................................................................. 245
Table 11-42 Statistics of accidents during 2011-2015 ............................................................................ 246
Table 11-43 Results of medical checkup of workers in Alang Sosiya Ship Recycling Yard.................. 248
Table 11-44 Summary of patients visited Alang Hospital and Red Cross Hospital and ......................... 248
Table 11-45 Results of analysis of alternatives ....................................................................................... 251
Table 11-46 Results of scoping ............................................................................................................... 254
Table 11-47 Results of impact assessment .............................................................................................. 260
Table 11-48 Predicted 24-hour average ground level concentration at EIA air quality monitoring stations
(µg/m3) ................................................................................................................................................ 267
Table 11-49 Environmental Management Plan (Construction stage) ..................................................... 275
Table 11-50 Environmental Management Plan (Operation stage) .......................................................... 278
Table 11-51 Environmental Monitoring Plan (Construction stage) ........................................................ 283
Table 11-52 Environmental Monitoring Plan (Operation stage)............................................................. 285
Table 11-53 Main organizational responsibilities for implementation of EMP/EMoP........................... 292
Table 11-54 Main questions and opinions raised during the 1st meeting and responses from GMB/JICA
Study Team ......................................................................................................................................... 294
Table 11-55 Main questions and opinions raised during the 2nd meeting and responses from GMB/JICA
Study Team ......................................................................................................................................... 295
Table 11-56 Proposed specification of the baseline survey .................................................................... 296
Table 11-57 Main changes of the Project from the approved EIA and additional potential impacts ... 297
LIST OF FIGURES
Figure 1-1 .................................................................................................................................................... 4

Figure 1-2 Comparison of ship recycling volume by major ship recycling countries................................ 6
Figure 2-1 Waste oil spill in the ship recycling process (2011) ................................................................ 13
Figure 2-2 Refinery of the FO ................................................................................................................... 24
Figure 2-3 TSDF Existing Facility ............................................................................................................ 37
Figure 2-4 Layout of TSDF....................................................................................................................... 37
Figure 2-5 Existing Incinerator of TSDL .................................................................................................. 38
Figure 2-6 Incineration Process ................................................................................................................ 38
Figure 2-7 FET Flow of TSDF.................................................................................................................. 40
Figure 2-8 Effluent Treatment Process ..................................................................................................... 40
Figure 2-9 Wastes coming to TSDF.......................................................................................................... 41
Figure 3-1 Topographic Survey Area.................................................................................................... 43
Figure 3-2 Geological Map in Bhavnagar District .................................................................................... 44
Figure 3-3 Borelog Example with N-value Constant Regardless of Depth .............................................. 45
Figure 3-4 Borelog Example with N-value Increasing propostional to Depth .......................................... 46
Figure 3-5 Boring at Seashore................................................................................................................... 47
Figure 3-6 .................................................................................................................................................. 55
Figure 3-7 .................................................................................................................................................. 58
Figure 3-8 .................................................................................................................................................. 59
Figure 3-9 .................................................................................................................................................. 60
Figure 3-10 ................................................................................................................................................ 61
Figure 3-11 Longitudinal Construction Joint Figure 3-12 Transverse Shrinkage Joint ......................... 63
Figure 3-13 Transverse Construction Joint Figure 3-14 Transverse Expansion Joint............................ 63
Figure 3-15 Image of the Improved Yard ................................................................................................. 65
Figure 3-16 Oil Collecting Ditch .............................................................................................................. 66
Figure 3-17 Jetty for the mooring of Waste Oil Collection Barge ............................................................ 68
Figure 3-18 ................................................................................................................................................ 70
Figure 3-19 ................................................................................................................................................ 72
Figure 3-20 ................................................................................................................................................ 73
Figure 3-21 ................................................................................................................................................ 74
Figure 3-22 Temporary Bridge ................................................................................................................. 74
Figure 3-23 ................................................................................................................................................ 75
Figure 3-24 ................................................................................................................................................ 80
Figure 3-25 Process of recycle ................................................................................................................. 81
Figure 3-26 Treatment Flow of Environment Facility in TSDF ............................................................... 85
Figure 3-27 Comprehensive plan of wastes treatment process ................................................................. 87
Figure 3-28 Process Flow of the Tank Cleaning Barge ............................................................................ 89
Figure 3-29 Cleaning process of Crude oil tanker .................................................................................... 89
Figure 3-30 Oil Collection Barge .............................................................................................................. 93
Figure 3-31 Flow of the Mobile Decontamination System ....................................................................... 94
Figure 3-32 Detailed Image of Mobile Decontamination System............................................................. 96
Figure 3-33 Bailer for general wastes ....................................................................................................... 99
Figure 3-34 Flow of the Small High Temperature Incinerator................................................................ 102
Figure 3-35 Entire flow of the improved waste treatment system at TSDF ............................................ 107
Figure 3-36 .............................................................................................................................................. 111
Figure 3-37 Short term demand forecast of ship recycling volume ........................................................ 112
Figure 3-38 Long term demand forecast of ship recycling volume ........................................................ 113
Figure 3-39 Major Fleets by Vessel Type in 2016 .................................................................................. 113
Figure 3-40 Projected Ship Recycling volume by types of ship, 2017-2030 .......................................... 114
Figure 3-41 Long-term demand forecast................................................................................................. 115
Figure 4-1 Implementation Schedule ...................................................................................................... 120
Figure 4-2 Extent of Work ...................................................................................................................... 123
Figure 6-1 Four project components for the Yen Loan project ............................................................... 137
Figure 6-2 Each project component ........................................................................................................ 138
Figure 6-3 Lease fee and revenue sharing of O&M cotract .................................................................... 140
Figure 6-4 Vessel having dismantled and weighted average LDT per year at Alang/Sosia .................. 141
Figure 6-5 Cash flow of Offshore tank cleaning ..................................................................................... 142
Figure 6-6 Cash flow of Hazardous waste treatment .............................................................................. 143
Figure 6-7 Cash flow of Heavy Crane & Beach Cleaning ...................................................................... 144
Figure 7-1 Integrated Cash Flow............................................................................................................. 153
Figure 8-1 ................................................................................................................................................ 160
Figure 9-1 GMB jurisdictional item summary ........................................................................................ 161
Figure 9-2 Organization chart of GMB ................................................................................................... 163
Figure 9-3 Project Implementation Structure .......................................................................................... 173
Figure 9-4 Repair by polymer cement..................................................................................................... 174
Figure 9-5 Repair with Epoxy resin ........................................................................................................ 174
Figure 9-6 Repair with sealing material .................................................................................................. 175
Figure 11-1 Location of ASSRY and TSDF .......................................................................................... 188
Figure 11-2 Example layout of an improved recycling yard................................................................... 190
Figure 11-3 Cross-section design of concrete flooring ........................................................................... 191
Figure 11-4 Image of improved recycling yard....................................................................................... 192
Figure 11-5 Existing layout of TSDF...................................................................................................... 193
Figure 11-6 Image of baler ...................................................................................................................... 194
Figure 11-7 Wastewater treatment process of improved TSDF .............................................................. 195
Figure 11-8 Approximate location and layout of the new unloading jetty and access road .................... 197
Figure 11-9 Basic design of the new unloading jetty .............................................................................. 197
Figure 11-10 Main procedures required for acquiring EC ...................................................................... 202
Figure 11-11 Nautical chart around the Alang/Sosiya area..................................................................... 207
Figure 11-12 Coastal assessment of the Alang/Sosiya area .................................................................... 208
Figure 11-13 Comparison of Alang coastline between years 2000 and 2008 ......................................... 208
Figure 11-14 Location of EIA air quality sampling sites ........................................................................ 209
Figure 11-15 Location of asbestos sampling sites at the ship breaking yard .......................................... 211
Figure 11-16 Location of EIA seawater quality sampling sites .............................................................. 212
Figure 11-17 Location of EIA groundwater sampling sites .................................................................... 215
Figure 11-18 Location of groundwater/leachate sampling sites around TSDF ....................................... 217
Figure 11-19 Location of groundwater sampling sites at ship recycling yards ....................................... 218
Figure 11-20 Location of groundwater/leachate sampling sites around TSDF ....................................... 220
Figure 11-21 Location of soil sampling sites (ship recycling yard) ........................................................ 225
Figure 11-22 Location of sediment sampling sites ................................................................................. 228
Figure 11-23 Volume of wastes received at TSDF and the number of beached ships ............................ 233
Figure 11-24 Land use around the Project site ........................................................................................ 241
Figure 11-25 Causes of fatal accidents in Alang Sosiya Ship Recycling Yard ....................................... 246
Figure 11-26 Workers’ residential facilities located behind the ship recycling yard .............................. 249
Figure 11-27 Process of excavated soil reuse ......................................................................................... 265
Figure 11-28 Location of EIA air quality monitoring stations ................................................................ 268
Figure 11-29 Image of fuel tank before and after cleaning by MDS ...................................................... 270
Figure 11-30 Implementation and reporting/feedback structure of EMoP (construction stage) ............. 293
Figure 11-31 Implementation and reporting/feedback structure of EMoP (operation stage).................. 294
Abbreviations and Acronyms

ACMs Asbestos Containing Materials
(ACM)
AERB Atomic Energy Regulatory Board
AFS Anti-fouling Systems
ASF Asian Shipowners’ Forum
BAN Basel Action Network
BANI Ban Asbestos Network
bbl Barrel
BDI Baltic Dry Index
BIMCO Baltic and International Maritime Council
BIS Bureau of Indian Standards
BOD Biochemical oxygen demand
BRICs Brazil, Russia, India and China
CFC ChloroFluoroCarbon
Class NK Class Nippon Kaiji Kyokai
CO Carbon Monoxide
CO2 Carbon Dioxide
COD Chemical Oxygen Demand
CP Cutting Permission
CRZ Coastal Regulated Zone
CPCB Central Pollution Control Board
CZMA Coastal Zone Management Administrative bureau
CRZMA Coastal Regulated Zone Management Administrative bureau
DASR Document for Authorization to conduct Ship Recycling
DISH Director of Industrial Safety and Health
DL Datum Line
DPR Detailed Project Report
DO Dissolved Oxygen
DSA Danish Shipowners’ Assosiation
DWT Dead Weight Tonnage
EAC Expert Appraisal Committees
EC European Community
ECSA European Community Shipowners' Associations
EIA Environmental Impact Assessment
EMP Environmental Management Plan
EPRP Emergency Preparedness and Response Plan
EU European Union
EUSRR EU Ship Recycling Regulation
FPSO Floating Production, Storage and Offloading system
F/S Feasibility Study
g Gravitational Acceleration
G7 Group of Seven
GCRZMA Gujarat Coastal Regulated Zone Management Administrative bureau
GDP Gross Domestic Product
GEPIL Gujarat Enviro Protection and Infrastructure Limited
GMB Gujarat Maritime Board
GMS Global Marketing System

GPCB Gujarat Pollution Control Board
GPS Global Positioning System
GSHAP Global Seismic Hazard Assessment Program
GT Gross Tonnage
Hcl Hydrochloric Acid
HEPA High Efficiency Particulate Air Filter
HKC Hong Kong International Convention for the Safe and Environmentally Sound
Recycling of Ships, 2009
HM Hazardous Materials
HP Home Page
HSS heavy grains(=wheat, maize/corn, rye,etc) and/or sorghum(s) and/or
soyas(soybeans)
HTL High Tide Level
HHWL Highest High Water Level
ICRR International Certificate of Ready for Recycling
ICS International Chamber of Shipping
IHM Inventory of Hazardous Materials
ILO International Labor Organization
IMD India Meteorological Department
IMDG International Maritime Dangerous Goods Code
IMF International Monetary Fund
IMO International Maritime Organization
INR India Rupee
IRRC International Certificate of Ready for Recycling
ISO International Organization for Standardization
JETRO Japan External Trade Organization
JICA Japan International Cooperation Agency
JSA The Japanese Shipowners' Association
LDT Light Weight Ton
LEL Lower Explosion Limit
LFL Lower Flammable Limit
LPG Liquefied Petroleum Gas
LT Long Ton
LTL Low Tide Level
MHWN Mean High Water Neap
MHWS Mean High Water Spring
MLWN Mean Low Water Neap
MLWS Mean Low Water Spring
MoEF Ministry of Environment and Forestry
MOU Memorandum of Understanding
MSZ Makran Subduction Zone
NABET National Accreditation Board for Education and Training
NDMA National Disaster Management Authority
NGO Non-Governmental Organizations
NH3 Ammonia
NO3 Nitrate
NOx Nitrogen Oxide

O3 Ozone
ODA Official Development Assistance
ODs Ozone Depleting substances
OECD Organization for Economic Co-operation and Development
PAH Polycyclic Aromatic Hydrocarbon
PCBs Polychlorinated Biphenyl
PCHM Potentially containing Hazardous Materials
PESO Petroleum and Explosives Safety Organization
PGA Peak Ground Acceleration
pH Potential Hydrogen
PM Particulate Matter
PPEs Personal Protective Equipment
PPP Public-Private Partnership
ppt Parts Per Thousand
PSC Port State Control
r correlation coefficient
R² coefficient of determination
REIA Rapid Environmental Impact Assessment
RO Registered Organization
RORO Roll-on/Roll-off ship
RSPM Respirable Suspended Particulate Matter
SBC Ship Breaking Code
SEIAA State Environmental Impact Assessment Authority
SHE Safety Health and Environment
SO2 Sulphur Oxide
SO4 Sulfate
SOC Statement of Compliance
SPCB State Pollution Control Board
SPM Suspended Particulate Matter
SRF Ship Recycle Facility
SRFP Ship Recycle Facility Plan
SRFMP Ship Recycle Facility Management Plan
SRIA Ship Recycling Industries Association
SRP Ship Recycling Plan
SSRP Ship Specific Recycle Plan
TBT Tributyltin
TOR Terms of Reference
TSDF Treatment Storage Disposal Facility
UNEP United Nations Environment Programme
US$ United States Dollar
VHS Video Home System
VLCC Very Large Crude Oil Carrier
Web World Wide Web
x Variable x
y Variable y
4TC 4 average total cost
σ Sigma
μ Mu
1
1. BACKGROUND AND HISTORY OF THE PROJECT

1.1. BACKGROUND OF THE PROJECT
1.1.1. REQUIREMENTS OF THE CONVENTION AND RELATION OF THE PROJECT
In India, Pakistan and Bangladesh, all located in South West Asia, ships were broken up at inter-tidal
zones in a so-called “Beaching Method” way that enjoyed heydays in the 90’s.
In the beginning of the 90’s, ships were being demolished without sufficient cleaning works, stripping
of residual oils and waste water, once they were grounded in the inter-tidal zone. Because of this, fatal
accidents of explosions/fire by flammable gas, fall from high places, etc., were taking place. Serious
environmental pollution by the hazardous materials such as various kinds of oil, scientific substances
and heavy metals onboard the ships became a big concern. Moreover, health hazard was created because
workers did not use enough protective equipment/gear and worked under cruel working conditions.
With this backdrop, environmental and human rights groups pointed out issues of the industry and
criticised the major shipping countries and shipbuilding countries that they were exporting pollutions to
these ship breaking countries.
Under this situation, ship recycling countries as well as shipping and shipbuilding countries were
required to response to these issues and the guidelines were made as under.
a. IMO Guidelines on Ship Recycling (IMO Resolution A962(23) December 2003)
b. Safety and Health in Ship-breaking: Guidelines for Asian Countries and Turkey (ILO May
2003)
c. Technical Guidelines for the Environmentally Sound Management of the Full and Partial
Dismantling of Ships (UNEP Basel Convention May 2002)
Although there will be environmental issues and labor safety issues in the process of ship recycling,
ILO guideline is focused on labor safety and Basel guideline on preservation of the environment. Both of
the guidelines have specified that facilities need to be provided in the ship recycling yard and the
recycling process of the ship, but no requirements on the ships to be recycled.
Besides the above, Guideline of International Maritime Organization (IMO) points to the requirements
to be taken by the stakeholders (shipbuilders, operators, ship recycling yards, etc.) from cradle (building)
to grave (recycling) of ships comprehensively in various phases. The draft final guideline was adopted at
49th MEPC in July 2002 and resolved at 23rd plenary meeting in December 2003 as Resolution
A.862(23).
Thereafter, drafting of the international framework on ship recycling discussed whether the Basel
Convention (the Basel Convention on the Control of Transboundary Movements of Hazardous Wastes
and their Disposal) can be applied to internationally navigating ship or not. Thereafter, IMO took the
initiative to draft the convention for ship recycling and The Hong Kong International Convention for the
Safe and Environmentally Sound Recycling of Ships, 2009 was adapted.
1.1.2. SHIP RECYCLING CONVENTION
The Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships,
2009 (hereinafter referred to as “the Convention”) was adopted 15th May 2009 and regulated following
requirements.
Applied to ：Ships (commercial ship more than 500GT)
：Ship Recycling facilities (place of ships to be recycled)
2
(1) Requirements to Ships
・ Restrict to use Asbestos, Polychlorinated Biphenyl: (PCBs ） , Ozone Depleting

Substances, Hazardous paints for the new building ship
・ Provision of Inventory of Hazardous Materials (IHM) which indicate name and type,
location and volume of hazardous materials.
・ Periodical inspection by competent agency of the flag nation or recognized
organization
(2) Requirements to Ship Recycling Facilities
・ Sound operation and management to mitigate environmental pollution and industrial

accident is required
・ Provision of Document for Authorization of Ship Recycling Facility (DASR) by the
competent authority or recognized organization of recycling nation and periodical
inspection
(3) Requirements to Ship Recycling Process
・ Ship owner shall finalize the Inventory of Hazardous List and based on the
information from ship owner, ship recycler shall provide Ship Recycling Plan (SRP)
・ Approval of SRP by Ship Recycling nation
・ Final Inspection by flag nation (Conformity of IHM and actual ship’s condition and
confirmation of approved SRP)
・ Issue of International Certificate of Ready for Recycling (ICRR)
・ Recycling
・ Notation of completion of recycling to the flag nation and recycling nation.
Ship recycling process in accordance with the requirements of the Convention is shown below.
3
Figure 1-1Ship Recycling Process in accordance with the Convention
(4) Entry into force the Convention

This Convention shall enter into force 24 months after the date on which 1) not less than 15 States
have either ratified, acceptance or approval, 2) the combined merchant fleets of the States constitute
not less than 40 per cent of the gross tonnage of the world’s merchant shipping, and 3) the combined
maximum annual ship recycling volume of the States during the preceding 10 years constitutes not less
than 3 per cent of the gross tonnage of the combined merchant shipping of the same States.
Looking at the requirements of entry into force at the present time, the total volume of world merchant
fleet at the end of 2014 is 1,167 million gross tons, required total tonnage of the contracting and ratifying
countries is 466.8 million tons.
In addition, the ship recycling record is the peak in 2012, then 14 million tons in the year become basic
figure, but India alone has a record of 12.21 million gross tons. If either "China", "Bangladesh" or
"Pakistan" ratifies and India ratifies it, it can satisfy the entry into force requirement for the ship
recycling country
1.1.3. INTERNATIONAL SHIP RECYCLING SITUATION AND ITS ISSUES
After adoption of the Convention in May 2009, only France, Norway, Congo Rep., have ratified the
convention as of February 2016. Thus, it will require some years to satisfy the entry into force conditions
to become effective. On the other hand, EU published their Ship Recycling Regulation in 2013
(hereinafter referred to as “EUSRR”) tacitly to exclude ship recycling facilities by “beaching method” to
become effective at the end of 2018. The EUSRR also recommend the member states to ratify the
Convention which may accelerate other countries to ratify the Convention and expected to satisfy the
4
entry into conditions within a few years from now..

However, EUSRR is explicitly aimed to eliminate ship recycling by the beaching method. The EU
regional regulation is a comprehensive amendment that shifts to the Ship Recycling Convention-
compliant procedure from the Basel Convention-compliant procedure, which has been the basis of the
comprehension to ship recycle so far. Although the provisions of the Recycling Convention are
incorporated to the EU regional regulation as they are, some requirements to be satisfied by Ship
Recycling Facilities as a requirement is added to the Ship Recycling Convention. In case of facilities
outside the EU, in addition to the approval by the recycling country, the EU regional regulation are
subject to approval by the EU after application by the facility, review by the application by EU and
review by field survey, whereby the facility unless it is posted in the EU List, vessels of EU flags cannot
be recycled at the facility.
This additional requirement was expanded in the process of coordination with the EU Council which
has a strong influence by the Basel Convention, and the EU Parliament Environment Committee passed
a draft amendment prohibiting beaching on March 2013. Subsequently, the EC and the EU board of
directors concerned with such amendment, has coordinated with the EU Executive Committee, working
with Japan, etc., impermeable floor and appropriate drainage facilities were stated instead of banning of
beaching.
If the EU SRR is applied before the Ship Recycling Convention, EU-registered ships may not be
recycled in the three countries of India, Bangladesh and Pakistan, which hold more than 70% of the
world's ship recycling capacity. Ship recycling is not simply an industry for recycling, but also has roles
such as adjustment of supply and demand of ships in international shipping, promotion of elimination of
sub-standard ships, and the situation where the ship recycling capacity of the world is drastically reduced
must be avoided internationally.
Ship Recycle Convention requires Safe and Environmentally Sound Ship Recycling regardless ship
recycling method. Japan has the stance that requirements of the Convention can be achieved by
“beaching method” with further improvement of the facilities, management method, ship recycling
process, education and training for workers, etc., then considering the assistance to India world largest
ship recycling nation.
India also made "Ship Breaking Code" in 2013, and some private ship recyclers have aggressive efforts
such as starting environmental measures. In addition, ship owners' associations in Asia, Japan and
Europe have expressed opposition to the exclusion of beaching and expressed support for securing safe
and environmentally appropriate ship recycling capability through improved beaching.
1.2. SHIP RECYCLING INDUSTRY IN INDIA

While 2006 to 2015, India, Bangladesh, China and Pakistan shares 92.7% of total tonnage broken.
Among these India ranks top with about 29.4% of total tonnage broken followed by Bangladesh 27.2%,
China 22.1%, and Pakistan 14.0% and many of ship owners in the world are heavily rely on India for
recycling of their ship.
5
Ship Recycling Volume (Uniti: 10,000 GT)

Country 2015 2006-2015
Spain 8 8
Korea 6 3
Pakistan 4,598 2,797
China 4,036 4,422
India 4,558 5,889
Bangladesh 7,517 5,445
Turkey 752 733
Others 330 727.7
Average share by country 2006-2015

Figure 1-2 Comparison of ship recycling volume by major ship recycling countries
Ship recycle in India began in the 1960s for the recovering/reusing mainly for steel scraps. Kolkata
and Mumbai were the centers, but in the 1980 's, they moved to the Alang / Sosiya district of Gujarat
State, and maintaining the world' s largest recycling capacity. The ship recycling facility has 167 yards
covered by the Gujarat Maritime Board (GMB) along the about 9km long coast. 130 ship recycling
companies are leasing yards from GMB. The width of the plot is 30 meters minimum to 120 m, but there
are also some operators who own and operate adjacent plots.
Along the yards extending north to south, four lanes of access roads are provided, which is convenient
for transportation of product goods and equipment. Also along the road to the Alang / Sosiya district
spcialized warehouses ranging from dishes removed from the ship to diesel main engines are lined up.
These are also operated with GMB approval. Public utilities and facilities are provided with water
service, Red Cross Hospital, firefighting facility, police station, post office, bank, customs office, and
also training facilities for workers. The steel supplied from ship recycling covers about 3% of the
domestic consumption. The industry has been greatly contributing the regional industry with employing
directly about 20 thousand workers and 500 thousand indirectly.
In response to the labor and environmental issues mainly pointed out by foreign organizations and
NGOs, etc., the Gujarat Maritime Board Ship Recycling Regulations (2003) established regulations on
ship recycling. For strengthening regulations, prior to the acceptance of ships, removal of hazardous
mterials in advance, gas free of tanks before recycling work, issuance of inspection and certificate of
explosives management department of Gujarat State Pollution Control Board are included. Regarding
the implementation of safety measures against asbestos removal during recycling work, implementation
of safety and health training for worker, and as to the management of waste, improvements have been
made taking measures such as newly constructing and managing waste treatment storage facilities called
“Treatment, Storage, Disposal Facility (TSDF) in the same area.
In India, the Supreme Court Order concerning ship recycling was issued on September 6, 2007. Based
on this Supreme Court Order, Ship Breaking Regulation 2013 was formulated in March 2013.
1.3. NATIONAL DEVELOPMENT PLAN RELATED TO THE PROJECT

Government of India (GOI) set forth the promotion of Ship related industry including shipbuilding and
others in their 12th Five Years Development Plan (April 2012 to March 2017) targeted to promote the
creation of 2.5 million work opportunities with ship related industries by promoting further development
of the infrastructures. Also, GOI claimed to provide regulatory framework corresponding to the
international conventions adopted by the International Maritime Organization (IMO).
6
1.4. BACKGROUND AND HISTORY OF THE RQUEST OF THE PROJECT

Ship recycling industry has already been established as an important industry in the province of
Bhavnagar province of Gujarat state and is expected to develop in the future as a basis of important
industries in the district, while improving environmental and occupational safety is urgent and then Ship
Breaking Code 2013 (SBC) was established and its contents are more severe than those of GMB's ship
recycling rules, including 1) preparation and approval for anchorage and beaching, 2) ship recycling
Enhancement of the licensing and approval system of the ship owners, 3) gas-free obligation provisions
for safe for hot work to the owner, and 4) strengthening removal of hazardous materials substances in
advance.
However, compared with China and Turkey, which have facilities complied to the Convention
facilities that complied the Ship Recycling Convention are not being developed well. Ministry of
Shipping, of India which is the regulatory agency, intends to increase and maintain ship recycling orders
by recognizing the trend of ratification of the global ship recycling convention and developing the
facility comply with the Convention
On the environmental aspect, hazardous materials generated by ship recycling may deteriorate the
coastal environment and put the workers in danger. Therefore, it is expected that it will contribute to
solving problems such as environmental conservation and labor safety, by improving facilities
complying with the convention and appropriately managing and processing.
The world total dismantling tonnage in 2014 is 22.77 million gross tons, and India is the No. 1 (6.8
million tons) in the world, with about 30% of the world share, 97% of which are processed in Alang /
Sosiya in Gujarat
However, there are problems in the operational process of ship recycling and the method of removing,
storing and treating various hazardous materials, etc. generated in the ship recycling process, and for
example, 1) explosion / fire accident caused by flammable gas etc. and high- occurrence of a serious
accident such as a worker's fall from high place, 2) serious environmental pollution due to residual oils,
chemical substances, heavy metals etc. onboard the ship, 3) concern of workers' health damage due to
the poor work environment of workers, etc. is enlisted.
To address these issues, not only the countries where the ship recycling facility is located, but also the
shipping countries using it and international maritime agency, as the international framework to be
tackled together, "The Ship Recycling Convention” which Japanese government is the major proponent
was adopted. This Convention is a treaty for obliging vessels to be sent to facilities where ship recycling
is being carried out in an appropriate process that does not pollute the environment and secure the safety
of workers.
Although the Indian government has not ratified the Convention, has been working to modernize ship
recycling facilities based on the expected increase in demand for environmental recycling facilities
comply with the Convention adopted by the Convention and the importance of shipping and recycling
industry in India.
On the other hand, for ship recycling facilities, as of the end of February 2016 out of 167 yards, 4 yards
was received the Statement of Compliance (SOC) from a classification society as a facility complied
with the Convention. However, in order to implement ship recycling in safe and environmentally sound
manner in the global shipping, it is necessary to further secure improvement, including the necessity to
secure a yard with SOC and the importance of maintaining the industry in the Bhavnagar, Gujarat
including the maintenance at the remaining yards and waste disposal facilities. With these background,
improvement of existing ship recycling yard by “Ship Recycling Yard Improvement Project”
(hereinafter referred to as “the Project”) is required by the Indian government.
Based on the request from the Government of India concerning Improvement of Ship Recycle Yard,
and the opportunities of the Japan-India Summit Meeting in September 2014 and December 2015, this
7
survey is aimed at to survey the objective of the Project, outline, project cost, project implementing
organization, operation / maintenance system, environmental and social consideration necessary for
examination to be implemented as Japanese Yen Loan Project.
1.5. COOPERATION BY OTHER DONERS AND/OR INTERNATIONAL

AGENCIES
As to the improvement of the ship recycling industry in India, no other doners and/or international
agencies are recognized in so far. It is however, Japan Federation of Basic Industry Worker’s Unions
(JBU) of Japan that has decided to assist Indian workers in Ship recycling industry by the resolution that
IndustiALL will support earliest ratification and entry into force the Convention at IndustrALL Global
World Conference was held in November 2014 in Nagasaki, Japan.
After that, JBU concluded the support agreement with the Steel, Metal & Engineering Workers’
Federation of India (SMEFI, Mumbai) and Alang Sosiya Ship Recycling and General Workers'
Association (ASSRGWA). Contents of the cooperation are as follows.
(1) Contents of the Cooperation
Duration : 3 years , Total cost 5 Million Japanese Yen

1st Year, to assist to build training center in Alang
2nd Year, to train workers
3rd Year, to supply training equipment
JBU’s cooperation is the continuation of the overseas activity of FNV Bondgenoten, Netherlands,
for exclusive cooperation in Alang related to ship recycling. Training center is under construction at
the site FNV owned, with a cost component of 3 Million Japanese Yen.
(2) Target of Training and its Implementation

Target group of the training are the workers belonging to SMEFI and ASSRGWA and the first
training given to the trainers and then the workers. Training material such as video, will be
provided by the Indian labor union.
8
2. PRESENT CONDITION AND ISSUES OF THE INDUSTRY

2.1. PRESENT CONDITION AND ISSUES OF SHIP RECYCLING PROCESS
In Alang / Sosiya, ship recyclers initiated their business from the early 1980’s by the beaching method
which recycling works has been done by the process of ship is grounded at the intertidal zone and
primary dismantling at the same area, then large block is pulled up to the recycling yard. Early in 1990s
GMB adopted the 1993 Ship-breaking Regulations and started to put emphasis on labor safety and the
environment. Furthermore, as the Ship-Breaking Code of India 2013 is established, further improvement
of the ship recycling facilities and method to establish safer recycling process by the beaching method is
initiated, and workers’ safety education and training is carried out for the labors and more
environmentally friendly.
2.1.1. PRESENT CONDITIONS OF THE SHIP-RECYCLING PROCESS IN ALANG

/SOSIYA
(1) Current Ship Recycling Process

Ship-recycling operations conducted in the Alang/Sosiya district are shown in Table 2.1. The recycling
consists of 11 stages; the beaching process starts from ship-anchoring at an offshore point 12km away
from the beach, followed by inspections carried out by several authorities and government offices then
ship will be beached. The ship grounded in the intertidal zone is started the recycling work of the hull in
this intertidal zone. As recycling work progresses, the hull with increased buoyancy is gradually drawn
to the land side by the winch, and proceeds to recycling work on the coast. This flow is shown in the
following Table 2-1 Process of Ship Recycling Project
Table 2-1 Present Ship Recycling Process before the Hong Kong Convention
1 Inspection Preparation of Certificates 1) Ships for recycling anchor 12km off the Bhavnagar Port
2) GMB, SPCB、Port Authority ,GPCB, Customs office carry
out inspection
2 Beaching 1)Procedure to obtain beaching permit

(Depends on the High Tide and Ship 2) Detailed inspection by the Customs Office , GMB, GPCB。
Type) 3) Issuance of beaching permit upon passing inspections
4) Beaching
3 1) Recovery of heavy Oil & 1) All the tanks shall be subject to preliminary checking.
Remaining Oil 2) Upon completing inspection by the customs office, radar,
2)Cleaning of oil tank & fuel tank GPS, VHS satellite communication system, antenna shall be
3)Disconnecting fuel & lubricant oil destroyed
pipes and removed from the ship
4) Inspection for gas-free checking 3) Cleaning and disposal of all oil and oily waste
4 Recovery of un-used materials or 1) Marking on the cylinder by the Safety officer.

remainder. The remaining gas in the cylinder shall be discharged to the
unless they are toxic.
2) The empty cylinders shall be taken out of the ship and
stored in the designated stock yard.
9
5 Collection of bilge water and other 1) Inspection of the bilge tanks.

related waste materials 2) Collection of bilge water by means of tank lorry to carry them
to the treatment plant at Alang.
3) Thorough cleaning of the bilge tank required
6 Obtaining “Free from Contamination 1) As the result of GPCB’s Inspection Free From Contamination
Certificate” from GPCB. Certification issued.
2) Fire Safety Inspection and Obtaining Cutting permission from
GMB.
7 Recovery of reusable and recyclable 1)Draft an inventory list of the reusable materials prepared by the
materials Safety Officer and the owner of the ship recycle Yard. Then the
owner of the recycling yard places the salable materials and
equipment to an auction.
2) All the materials shall be taken out of the ship.
8 Disposal of asbestos and other 1) Checking the inventory list and actual situation of asbestos
insulation material. within the ship by the safety officer.
2) Cleaning of all spaces where asbestos may be stocked or
transported to avoid any chemical reaction of asbestos or glass-
wool.
3) The work shall be carried out by well trained experts wearing
specialty protective gear and equipment such as masks, glasses,
and helmets.
4) Discharge of asbestos and or glass wool out of ship and
transportation of them to TSDF.
9 1) Cutting big size blocks on the ship 1) Cutting hull of the ship to big size blocks, then dropping the
and transporting them to the yard or block to the inter-tidal zone using winch or cranes.
dropping them to the inter-tidal zone. 2) When the tide is low to be a workable zone, the workers cut
2) Transporting the dropped blocks on the blocks to smaller sizes to transport by winches or crane.
the land or on the beach by means of 3) Paint chips or oil stains on the blocks are wiped and cleaned
winches. At the recycle yard these before the blocks are transported to the recycle yard.
blocks are cut and sliced to smaller size
to enable transportation to the Ship
Recycling Facilities
1 1) Ship breaking at the Beach. 1) As the ship loses total weight by being cut into blocks at the
0 inter-tidal zone, it is gradually pulled to the beach which allows
2) Ship breaking at the beach enables cranes to transfer material on board to the recycling yard directly.
usage of additional equipment 2) The heavy equipment of the ship, such as the main engine and
generator is unloaded using crawler cranes.
1 Blocks transported to the recycle yard 1) Big size blocks are cut to smaller size blocks.
1 using crane or winches are cut, sliced, 2) The blocks are cut, sliced to the suitable size for delivery
and sold. 3) Delivery
Source; JICA Survey Team
(2) Fundamental Requirements of the Ship Recycling Convention
10
Ship recycling process under the Convention requested to the ship recycling facilities to provide Ship
Recycling Facility Plan in advance, to demonstrate the establishment of the worker’s safety system and
management system for the Hazardous Materials, then ship recycling facilities are also required to
prepare a ship recycling Plan (SRP) for each ship they recycle. Furthermore, the recycling facilities are
requested to ensure safe for entry and safe for hot work. Recyclers are also requested to prevent adverse
effects to human health and the environment, making the most use of the inventory list of asbestos and
other hazardous materials.
Table 2-2 Main Requirements of the Ship Recycling Convention
1 Application of the Commercial ships engaged in international voyage not less than 500 GT
Convention and ship recycling facility
2 Requirement on a） Prohibited to install Asbestos, PCBs, Ozone depleting substances,
Ships anti-fouling compound and system to new ship
b） Provision of Inventory of Hazardous Materials (IHM) which
includes definition, location, and quantity of Hazardous Materials
(HMs) onboard.
c） Periodic inspection of ships by competent authority of the flag
state or an organization recognized by them
3 Requirement on a） Sound operation and facilities to minimize environmental pollution
Ship Recycling and workers injury
Facilities b） Approval of ship recycling facilities by competent authority or a
recognized organization of the recycling state. Document for
Authorization of Ship Recycling Facility and periodical inspection
of them.
4 Ship Recycling a） Finalization of IHM by ship owner and provision of Ship
Procedure Recycling Plan (SRP) by Ship Recycling Facility with the
cooperation of the ship owner.
b） Approval of SRP by the recycling state.
c） Final inspection by the Flag state (inspection of IHM with actual
ship and confirmation of approved SRP)
d） Issue of the International Certificate of Ready for Recycling
(ICRR) by the Flag state.
e） Ship recycling
f） Information of completion on ship recycling by the ship recycling
facility to the flag state and recycling state.
Source; Summarized by the Survey Team based on HKC
(3) Evaluation and tasks for requirements of Ship Recycling Convention

In response to the requirements of the Ship Recycling Convention, items necessary for dealing with the
Convention are summarized by studying the current state of the Indian laws and regulations concerning
ship recycling and the current state of recycling process as follows. In the Ship Recycling Convention,
technical guidelines for facilities were not described, and tasks and necessary improvements were
evaluated from the recycling method and facility aspects according to the requirements of the Ship
Recycling Facility Plan (SRFP).
1) Issues of the recycling process
In the ship recycling process, work procedures, environmental measures, safety measures, facilities,
etc. are managed and remarkably improved by SBC etc., in recent years. In particular, the process at the
recycling preparation stage required by the Ship Recycling Convention and the current applicable laws
of India can be compared as follows and it can be seen that the requirements are satisfied
11
Table 2-3 IMO Convention Requirements on Ship Recycling Process and its Conformity in India
Ship Recycle Convention Status of India Conformity

Ship owner shall provide and maintain Confirm ship owner’s inventory and Conformed
Inventory of Hazardous materials obtain Gas Free certificate for Man
Recycle facility shall have approval and Entrance & Hot Work
periodical inspection by the authority
Ship owner shall finalize the Inventory
Recycle facility shall provide Ship Recycle facility shall provide Recycle Conformed
Recycle Facility Plan (SRFP) Facility Management Plan (RFMP)
Recycle country shall approve SRFP State Pollution Control Board (SPCB) Conformed
will approve RFMP
Ship owner and recycle facility shall Recycle facility shall provide Ship Conformed
cooperate to provide Ship Recycle Plan Recycle Plan (SRP)
(SRP)
Recycle country shall approve SRP State Maritime Board (SMB) will Conformed
approve SRP
Flag state shall carry out final State Maritime Board with evaluation Conformed
inspection(Inventory and ship condition with relative organization and inspect
with confirmation of approved SRP) jointly, then Non Objection Certificate
Recycle country shall provide ( NOC) for ship recycling will be issued
International Certificate of Ready for
Recycling (ICRR)
However, contrary to establishment of documentation and inspection and approval systems related to
the preparation stage, actual beaching methods still have many points to be improved in terms of
environmental and occupational safety considerations. Particularly in the beaching method, it can be
pointed out that it is difficult to completely remove various hazardous materials as work before
recycling. In response to the requirements of the Convention, it should be addressed the following points
as a particular issue.
a. Safety and adequate removal of residual oil, explosive / flammable gas in the tank after
beaching, before recycling;
b. Safe removal of harmful paint after beaching and prevention of intertidal zone and soil
contamination;
c. Prevention of falling of contaminated hull block into intertidal zone in dismantling process in
intertidal zone:
d. Prevention of soil, groundwater and air pollution in recycling processes on land; and
e. Further improvement of safety and health of workers in recycling process
Currently, in India, with respect to residual oil, explosion / flammable gas, it is requested to carry out
gas-free at the shipowner's responsibility, but securing fuel necessary for moving the ship to beach and
grounding from the point of view, it is difficult for the ship owners to pre-clean the tank completely.
Regarding the hazardous toxic paint of the bottom, measures to prevent these paints from contaminating
the ocean or soil during the process of recycling are necessary in order to direct the beaching directly to
the coast.
The Ship Recycling Convention prohibits the use of antifouling system (AFS) including tributyltin
(TBT), etc. However, for paints containing TBT, "International Convention on the Control of Harmful
Anti - fouling system on Ships, 2001"(hereinafter referred to as the" AFS Convention) came into force in
2008, but many vessels have ceased using it before 2000. For these hazardous and flammable paints, it is
recommended in the Ship Recycling Convention Guidelines that hazardous paints and paints with high
flammable should be removed prior to cutting if available.
12
In the current ship recycling process, it is impossible to completely prevent the paint piece from falling
off when the hull block is cut off, but measures to prevent the block from falling into the intertidal zone
and thoroughly refurbish the paint piece with the yards shall be considered in this project.
Figure 2-1 Waste oil spill in the ship recycling process (2011)
2.1.2. CURRENT STATUS AND ISSUES OF SHIP RECYCLING FACILITIES IN ALANG /

SOSIYA
At Ship Recycling Facilities in the Alang / Sosiya by considering needs of the shipping industry for
internationally safe and environmentally sound facilities such as HKC and SBC etc., some recyclers
have already started concrete paving etc., by themselves.
Also, the Nippon Kaiji Kyokai (ClassNK) has issued Statement of Compliance (SOC) to the ship
recycling facility in China in 2012 and furthermore, in September 2015 SOC is given to the four
advanced recycling facilities in Alang / Sosya. Thereafter, further improvement work is under way to
acquire certification from such as ClassNK and RINA (Italian classification society) etc.
These yards are clearly segregated the demolition area of the hull, concrete pavement (t = 25 cm to 35
cm), drainage (pipes) for taking in rainwater containing oil etc., and oil recovery tanks are installed then
taken out oils or waters periodically. However, construction of improvement work is carried out
independently by recyclers, and records of design books (stress calculation documents, etc.) are not
maintained.
(1) Condition of Improvement of Ship Recycling Yards

In this survey, 36 yards in Alang/Sosiya were visited and investigation on facilities and equipment
made. As a result, out of 131 yards in total in operation, 6 yards were found as certified yards (as HKC
compliant) with the Statement of Compliance (SOC) issued by the third party (Classification Society)
and 11 yards under the process of making request for the certification.
Table 2-4 Result of the 36 Yards
HKC Compliant Yards information Total Plot 131

Yard that has SOC issued by Class NK as HKC Compliant 4 plots
Yard that has SOC issued by other than Class NK (i.e. RINA) as HKC 2 plots
Compliant
Yards that are under the process to have SOC or about to start the process for 5 plots
Class NK certification
Yards under the process that have SOC or about to start the process for other 2 plots
13
Classes such as RINA etc.

Already provided 11 plots
Under preparation or about to start 5 plots
As to the floor structure, there are 11 yards already provided with concrete impermeable floor and 16
yards, including yards under construction (concrete floor). All these yards have been constructed with
investments by the recyclers themselves.
Table 2-5 Outlook of the Results of the Surveyed Yards

No. Plot Recycler Remarks Other Observation
No. HKC Concrete
Floor
1 2 Leela Ship Recycler NK completed
Ltd.
2 5 Shubh Arya Steel Pvt. RINA+H6:K6 completed Concrete Pavement 22.5cm
Ltd. thickness Construction
Cost: US$ 160k
Plot W=90m
15m deep well for oily water
Geo-membrane required for the
yard
3 19 R.I. Kalthia Ship NK completed First plot awarded SOC by Class
Breaking Pvt. Ltd. NK
LABO was suggested as a
necessary facility
4 30 J.R.D. Industries under NK completed Number of workers 150
Consulting
5 36 Shib.Ship Breaking Co. completed Concrete Floor Completed
6 55 HATIMI STEELS
7 59 Y.S. Investments(Plot under Concrete Floor under construction
24-E) construction Yard: 54.5m x 120m
8 68 Saumil Impex Pte. Ltd.
9 78- Shree Ram Vessels NK completed Plot 60mw
M Scrap Pvt. Ltd. Beach side used as Temporary
Stock yrd
M= Merged Plots( 78+79
Concrete Floor Ready (Ready
mixed con )
10 V-1 Priya Blue Industries NK completed Concrete Floor : 120m w x 50m D
Pvt. Ltd. (Best Oasis) Workers : 500 ns workers
8 winches / 9 crawler Cranes
Cleaning Oil: wipe
11 V-5 Mahavir Inductoment
Pvt. Ltd.
12 V-6 Shree Ram Group Under NK Completed Concrete Floor 120m w
Company Consulting Concrete thickness 30 cm
6 months for Concrete work
13 V-7 Shree Ram Group Under NK Completed Concrete Floor 120m w
Company Consulting Concrete thickness 30 cm
R.K.Industries Unit II Took 6 months for Concrete work
14 V-8 Shree Ram Group Under NK Completed Concrete Floor 120m wx 45m
Conpany Consulting Concrete thickness 30 cm
R.K.Industries Unit II 6 months for Concrete work
Oily water well 10Fx1Fx 10 inch
15 V-9 Rajendra Ship Breakers
14
No. Plot Recycler Remarks Other Observation

No. HKC Concrete
Floor
16 4 Panchvati Ship
Breakers
17 20 Panchvati Ship
Breakers
18 84-F Mahavir Metal The owner does not know about
Corporation HKC
Yard 45m x 50m+G2:L4
19 84- Salwag Shipping RINA Concrete Concrete Floor under construction
D Services Pvt.Ltd. in process Floor under The thickness of the concrete
construction floor : 74 cm
20 84- Under GMB's The Plot is vacant No trace of
C administration operation
21 84- Capital Steel Preparation Under
B Corporation Stage Constructio
n
22 84- Lucky Steel Industries
A
23 72 Bohra Exports Under Boring not conducted. The site
Pvt.,Ltd. construction was under construction
24 83 Mercury Industries Under RINA The site closed for 2 years
Consulting Plot W=30m
25 54 Rushil Industries Co. No HKC
26 74 PVR Ship
27 81- Shree Ram Under Completed
M preparation
28 73 Pure Enterprises Pvt. Not in Operation
Ltd. The Plot has been closed for more
than 1 year
29 77 Shree ram NK Concrete Concreting Started
work started
30 82 Kiran Ship Breaking 30m w plot
Co. The Owner is at the same time the
owner of V-6
31 153 GMB The Plot has not been developed
as Recycle Yard.
For the Recycle yard earth work is
necessary (Sandy and deserted
land at present)
32 143 GMB The Plot has been abandoned for
33 155 GMB years.
34 156 GMB Need Earth work to use it as a
Recycling Yard
35 V-6 GMB The Plot is located at the mouth of
river. Need land filling to obtain
certain level above the water level
36 V- GMB The Plot is located at the end of
10 Sosiya
At present Abandoned beach
Need earth moving work to
arrange as a recycle yard.
(2) Current Condition of the Ship Recycling Yards
15
Main equipment and facilities installed commonly in the yards, which the survey team visited, are as
follows:
1) Equipment for handling ships’ blocks
Heavy equipment commonly used in each yard are as follows:

i. Equipment for handling cut block
① Winches (for dragging ship’s hull or blocks)
• Every yard has installed 75ton load winches fixed in the yard（middle class yards of 60m
width has four winches and large class yards of 120m width has eight winches）.
• All winches are reused from the windlasses of broken ships.
• Each winch is surrounded with fence of steel bars at its back and both sides in order to
protect the workers when the wire accidentally snaps and rebounds.
• Storage space is set up behind the fence at the rear of a winch. The space is fitted with a
roof to prevent the greased wires that may be washed by rain, and its base is sunken or
surrounded with coaming to prevent oily rain water to flow out.
• A ship’s hull body is dragged by the winches (the dragging operation is carried out at high
tide to utilize its buoyancy) periodically during the ship breaking procedure.
• Even large ships can be dragged, provided that the stern blokes are cut down on the inter-
tidal zone to reduce its hull weight. 【P.○○ in each photo indicates plot No 】
P.78 75ｔWinch with fence P.19 75ｔWinch with fence
P.5 wire storage space with roof behind a P.5 wire storage space is sunken in ground
winch
16
P.V-7 rear half of hull body to be dragged P.V-7 4 folds sheave
② Crawler Crane（for carrying large blocks or equipment）

• There are various load capacity cranes: namely 12tons of small crane, 25 t, 35 t, 50t and
75 t of the biggest crane.
• 3～4 cranes are provided in medium class yard of width 60m、6～8 cranes in large
class yard of width 120m.
• These Cranes are from TATA, H&M, P&H, and ESCORT make.
The big crane is operated in the front beach of the yard to carry large blocks into the yard, and
the medium size crane is operated to shift the smaller blocks to final cutting area.
P.V-5 loading plates on truck, and carrying P.78 many cranes are working along
a plate on worker's shoulder the shore line
③ Wheel Crane
• A wheel crane is operated to carry steel plates or angles / pipes cut out from blocks for
distributing them by each grade (classified by thickness of plate) in the storage area, that
is located near the entrance gate.（each yard has one or two wheel cranes）
• It is fitted with 4 tires, which make it easy for turning and suitable for distributing work.
• Each yard has the same type one (12t load)
17
P.68 wheel crane distributing plates P.30 wheel crane
④ Tractor
A tractor, towing with a flat floor trailer, to carry short pipes, valves, mooring fittings, electric
equipment, etc. (each yard has 1 or 2 units)
P.19 tractor P.78 tractor
ii. Equipment for cutting works
① Liquid oxygen tank

• Most yards have installed liquid oxygen tanks of cooling type, and supply oxygen gas for
cutting works through the pipes fixed in the yard.
• The tank capacity is 20 ㎥、and each yard has the same capacity tank.
• LPG gas is supplied with cylinder bottles.
P.30 liquid oxygen tank P.5 fixed supply pipe of oxygen gas and
LPG gas bottles
18
② Air plasma cutting machine ( mobile type)

This machine is used for cutting stainless steel plates, which are fitted in chemical tankers
P.V-1 Air plasma cutting machine P.78 Air plasma cutting machine
③ Others
Hand burners are only used for steel cutting works. No Automatic cutting machines or no
large cutter, fitted on heavy construction machines, are used.
④ Equipment for cleaning oily dirty blocks
• Compressor：to supply fresh water to washing nozzles with high pressure

• High pressure nozzle：to wash oily dirty blocks by hand in washing area
• Fresh water tank：for storage fresh water for washing
P.78 Oily block washing area P.78 various tanks
19
P.V-7 washing blocks P.V-7 washing blocks

(phot provided by yard ) (phot provided by yard )
iii. Equipment for handling of hazardous material
① For Asbestos
• Mobile exhaust ventilating device (with HEPA filter）;

For preventing asbestos to scatter outside in the working site. Not confirmed real
equipment,
• Mobile vacuum cleaner ( with HEPA filter）;
For gathering asbestos scattered in the working site. Not confirmed real equipment.
*Remark: Some yards do not have above devices, and outsource the treatment works of
asbestos to outside company.
• Negative pressure chamber
This chamber, fitted with exhaust ventilator, is prepared for preventing asbestos to scatter
into open air while workers change their clothes
P.V-5 entrance of negative pressure chamber P.V-5 inside of negative pressure

chamber
② Ozone Depleting Substances (Freon, etc.)

• Mobile Freon collecting device:
Used for collecting Freon gas contained in an air conditioning machine or a refrigerating
machine without emitting it into open air.
20
P.V-7 collecting freon gas P.V-7 collecting freon gas

(phot provided by yard) (phot provided by yard)
③ Floating barge
• In order to carry light equipment, furniture, fitting, utensils, etc., collected from engine
room and accommodation to the yard, a floating barge (rectangle shape in length 5-6m,
width 3m, height 50-60cm ) is provided.
• The barge is made by shell plate of broken ship, and is pilled on the inter-tidal zone ( for
coming and going ) by a winch with a wire rope that connects the barge to the winch
through a pulley fitted at aft shell of the broken ship.
• Both ends of the barge are curved like a sled to be dragged smoothly on the beach even at
low tide
• A certain yard (plot No.V-7) has a large barge (60t load capacity).
P.V-7 barge with sled shape P. V-7 large barge
④ Fire Fighting Equipment

• Emergency Fire pump in yard
A diesel engine driven emergency fire pump is fitted at the fire station in the yard.
• Mobile fire pump on board
An engine driven mobile emergency fire pump is provided on board.
• Portable fire extinguisher
Suitable number of portable fire extinguisher are allocated in the yard and on board
P.36 Fire Station P.V-7 Fire Station
21
P.V-7 Mobile fire pump onboard P.V-5 Mobile fire pump
⑤ Storage tanks for treatment of waste water

• Oily water stowage tank; to stowage Oily water gathered from oily block area
• Bilge water stowage tank; to stowage Bilge water except oily water gathered from the
yard.
• Rain water tank; to stowage Rain water running over the yard in storm.
P.V-7 Dirty oily water tank(5,000 liter) P.V-7 Rain Water tank (15,000 liter)
P.V-7 Bilge water tank (45,000 liter) P.19 Tank truck for Oily Bilge
iv. Other Facilities
22
P.78 Light Post (target for beaching) P.68 Weigh Bridge for truck
P.78 stores for waste materials P.78 good workers wears
(3) Oil Removal and Cleaning

Actual situation of the stripping and cleaning of residual oils in tanks after beaching is
confirmed at fuel oil tanks inside the ship. Observation is show on the Table.
1) Current situation of FO Tank cleaning
The process of the FO Tank cleaning is after beaching, residual oils are stripped with pumps to
tankers (vehicle) and saleable oil will be sold to the refinery and the remaining sludge inside
the tank is absorbed and cleaned with saw dust or sand and collected.
This collected oil sand or saw dust is treated as industrial wastes and transferred to TSDF.
2) Refinement of the collected oil
Refinement of the collected oil is also processed with the recycler or its affiliates
The refined heavy fuel oils and waste oils
collected from ship recycling yards or auto
garages with the distillation method and are sold
as Medium Heavy FO.
The process of the refinement of FO is as
follows.
The oil refinery is located about 15 minutes
from city of Bhavnagar and there are 7
companies to buy used oil in Alang / Sosiya.
23
Figure 2-2 Refinery of the FO
① Buying residual FO from beached ships and directly collected FO is from ships.
(No sludge is bought)
② Transport to factory
Storage Tank 8,000kl x 3Storage Tank
Distiller (120Deg C)
Water
Distiller (340Deg C)
Filtering Product Tank Drum
Capacity 7,000 KL / year Drum for sale

Product Tank after 1st distillation
i. Pricing
Buying : 22 Indian Rupees/Lit.

Selling : 35 Indian Rupees/Lit.
There are 7 companies who buy residual FOs in Bhavnagar.
24
(4) Issues of Ship Recycling Facilities

As a result of comparison of the requirements of the Ship Recycling Convention and the recycling
facility in the current Allan / Sosiya area, except for the yard where SOC has already been acquired, in
terms of prevention of environmental pollution etc., oil leakage, plastic waste, etc., there was concern
about the possibility of groundwater contamination due to outflow of hazardous materials to the sea and
soil contamination at the recycling site of the contaminated block and it was judged that there is a need
for facility improvement for environmental measures.
Table 2-6 Conformity of Requirements of the IMO Convention and Ship Recycling Facility
Stat Requirements of the Current Situation Judgement of

us Convention Conformity
Identification of HMs, Advanced yards confirmed drastically based Conformed
labeling of their location, on IHM provided by Ship owner
etc.
Before Anchoring
Gas free for safe Entry Before enter the anchoring area of Alang, Actually No tanker is
inspection is obliged by rule for tanker, etc. accepted
Prior removal of HMs Residual oils, Bilge is confirmed the quality Spillage risk depend
and then after beaching pumped out it. on the method.
Cleaning with saw dust, etc. Oils are transferred to
authorized dealer
Treatment of Asbestos wests ACM is safely removed by wetting method of Some are conformed
in the negative chamber (trained worker is at
work)
Removal of AF paint such as There is a case to remove paints of cutting Some are conformed
In recycling facility
TBT line at intertidal zone.

Paint chips are processed at TSDF in
Alang/Sosiya
Ozone Depleting Material Specialized subcontractor will handle Conromed
PCBs No detailed handling manner (no facilities Need to investigate
around)
HMs management, Storage in facilities. TSDF outside the yard Conformed
Treatment has final reclamation plot.
Bilge, Oily Water treatment 10 tons /day small ETP（Effluent Treatment Conformed
Plant） is under operation by GEPIL
Yards other than the yard that has the SOC has been still recycling the contaminated block, oil
containing equipment, etc. on the soil. In addition, blocks are fall into the intertidal zone. Therefore,
there is a risk of marine pollution, soil contamination, groundwater pollution, and air pollution. The
following points should be dealt with especially as issues among other requirements of the Convention.
The facility guidline of the Ship Recycling Convention provides guidance on how to safely remove
each harmful substance. However, in the recycling method by beaching in India, it is difficult to prevent
completely falling the antifouling paint such as TBT to the intertidal zone at the time of cutting the
bottom and to prevent falling to the soil, and it is important to focus on cutting off the block to the
intertidal zone and improving the process of recovering paint pieces as much as possible on land. Also,
with regard to PCB-containing substances, since there is no PCB treatment facility near Alang / Sosiya,
high-concentration PCB-containing substances should be delivered to authorized dealers and low
concentration PCB-containing substances should be thoroughly handled for incineration and other
measures.
In either case, it should be considered how to recover hazardous substances to the intertidal zone or
soil, and also to consider the process of recovering hazardous substances as much as possible. In order to
25
prevent discharge of harmful paint, PCB, oil, etc. to the environment, among other requirements of the
Convention, the issues to be addressed are the followings.
① Prevent leakage of waste generated in the process of oil leakage, plastic waste and other
dismantling into the sea
② To prevent marine pollution, prevention of hull block cutting before contaminants and harmful
substances are removed to the intertidal zone
③ Safely remove the residual oil in the tank and cleaning after recycling work is started
④ Prevention of soil, groundwater and air pollution in recycling process of contaminated hull
blocks and equipment on land
⑤ Prevention of outflow of pollutants and other oil from the demolition site when rain, storms, etc.
occurred
The points to be improved by Indian ship recycling facilities in order to conform to the Convention
from the recognition of the current problems and problems are as follows. Plan for improvement of
facilities is proposed from this issue and measures.
① It is necessary to manage oil and other hazardous materials in vessels under recycling either in
the intertidal zone or in the facility shall not to flow to the sea in the rain and storm or normal
condition.
② Ensure that the vessel can be pulled as close as possible to the shore and cut the hull as far as
possible on the shore side, and cutting work at sea and cut off of blocks should be prevented.
③ The recycling zone should be covered with an appropriate impermeable floor structure, and a
drain ditch and drain recovery means should be provided at an appropriate position between the
coastline and the facility.
④ Secure safe access to the ship should be ensured
2.2. PRESENT SITUATION AND ISSUES OF OCCUPATIONAL SAFETY

AND HEALTH
2.2.1. EXISTING OCCUPATIONAL SAFETY TRAINING & EDUCATION PROGRAM
Alang/Sosiya has a Safety Training & Laborer Welfare Institute established by GMB in 2003,
providing training courses for workers engaged in ship recycling. Training Courses offered are shown
below.
Table 2-7 Training Courses provided in Safety Training & Laborer Welfare Institute
Duratio
Name of Training Trainee
n
Basic Course( 7days training course)
Basic safety for all All workers 3 days
Cutter men Training Cutter men 2 days
All literate and young
Basic Firemen Training 2 days
workers
Special Course
26
Training for cutter men Cutter men 3 days

Safe Rating I II Supervisors, Safety Officers 1 day
Half
Disaster Management Training Supervisors, Safety Officers
day
Crane Drivers Training Crane Operators 2 days
Personal Protective Equipment Training Supervisors, Safety Officers 1 day
Hazardous Waste Management Supervisors, Safety Officers 2 days
1 day Safety Training All workers 1 day
Safe Removal and Handling of Asbestos
All workers 2 days
Materials
Source: Study for Establishment of an Environmentally Sound Ship Recycling Project in Gujarat, India, 2010
Contents of the present Training Courses at GMB’s Safety Training & Laborer Welfare Institute are
mainly guidance of knowledge, technique and safety measures related to the basic ship recycling and
handling hazardous material. The initial training for the newly engaged workers is important and in
addition to such initial training, periodical Operators’ training courses such as cutters’, welder’s and
crane operators’ courses should be held.
2.2.2. PRESENT CONDITION OF OCCUPATIONAL SAFETY AND HEALTH IN SHIP

RECYCLING PROCESS
(1) Facility management and operation (Document confirmation)

According to Ship Breaking Code 2013, the yards are required to prepare Ship Recycling Facility
Management Plan (SRFMP) which contains facility layout, equipment, licenses and permits required to
conduct ship recycling, etc. The yards are also required to prepared ship specific Ship Recycling Plan
(SRP) which contains recycling method, permits and certificates required in the recycling processes and
hazardous material removal plan, etc. The requirement of Ship Recycling Convention includes the
preparation of SRP.
NK certified yards are equipped with documents compatible to SRP including facility layout, ship
recycling method and procedures, organization structure, training plan. Also, workers’ records and
necessary permits and certificates (decontamination certificate, cutting permit, etc.) were confirmed. On
the other hand, normal yards were only equipped with SRFMP which does not cover all the necessary
information required in SPR. In specific, ship recycling method and procedures, training plans and
various permits and certificates are either not developed or could not be confirmed by the documents.
For normal yards, training shall be provided to yard owner and HSE officer for the preparation of SRP
in compliance with Ship Recycling Convention. At the same time, periodical monitoring shall be carried
out by regulatory agency and/or inspection agency to confirm the actual operation.
Organization Structure Training plan in yard Worker’s training certificate

(NK certified yard) (NK certified yard) (Normal yard)
(2) Safe-for-entry and safe-for-hot-work procedures
27
Followed by beaching, safe-for-entry procedures is being conducted by removing hazardous materials

in loose form and oils and gas in engine room and pipelines and Decontamination Certificate is issued by
GPCB after the confirmation from competent authorities. Also, safe-for-hot-work procedure is
conducted by HSE officer confirming gas and oxygen content inside the ship with gas detector and
Cutting Permit is issued by GMB prior to dismantling. Some NK certified yard performs double-
checking of confined atmosphere with gas detector before the cutting operation to avoid any possibilities
of fire and explosion accidents.
In NK certified yard, those procedures were confirmed by certifications and permits as well as from
the photos, whereas in normal yards, the same was confirmed by interview but not by documents nor
onboard inspection.
Since dismantling operations in engine rooms and pipelines are the major causes of explosion, safety
confirmation procedures shall be strictly followed.
Confirmation on gas Entry after safe for entry

Gas cutting permit issued content in closed spaces procedure confirming the
by GMB (NK certified yard) (yard in process of label (yard in process of
verification) verification)
(3) Safety measures for the working at height

Basic safety measures including wearing safety belts and application of warning tapes at the deck edges
shall be performed while working at height. The implementation of those safety measures were
confirmed in NK certified yard through interview with the manager and HSE officer as well as from the
photos. It was also mentioned from HSE officer that majority of the accidents occur on board (in inter-
tidal zone), therefore the work on board is assigned to experienced workers having worked over 10
years. Employment of those safety measures in the normal yards are considered to be limited based on
the yard observation and from the interview with yard supervisors.
According to accident statistics, relatively high number of accidents is caused by falling from heights.
The application of those safety measures shall be ensured by raising the awareness of skilled workers
and site supervisors.
Wearing safety belt during Warning tape to indicate the risk

working at height (NK certified yard) of working at height (NK certified
28
yard)
(4) Safety measures for the operation of heavy equipment

Main heavy equipment used in current ship recycling operation are winches and cranes. Especially,
braking of winch line during the salvage of ships is one of the causes of serious accidents. As a safety
measure, all the observed yards have installed fences around the winch to minimize the accidents and the
risk of injury. However, equipment inspection of heavy machinery, wince line, etc. was not satisfactory
in some yards which shall be made as a routine task of HSE officers.
According to Ship Recycling Industries Association (SRIA), lack of safety consideration of crane
operators towards the helpers supporting their operation is one of the issues for the related accidents.
Therefore, safety education including accident prevention measures shall be provided to heavy
machinery operator together with their skill development training.
Fence around the winch for Lack of routine check of fixtures Lifting large blocks by crane
safety (All yards) including winch line (Normal yards) (NK certified yard)
(5) Personal Protective Equipment (PPE)

In NK certified yards, basic PPEs including helmet, shoes, clothes and gloves were worn in all the
recycling process. For gas cutting operation, masks and safety goggles were additionally worn.
However, in normal yards, there were some workers wearing cloths instead of mask during gas cutting
operation and some without gloves during glass wool removal operation.
Especially during cutting the paint coated steel, workers must apply masks as there is a potential
exposure to toxic fumes including heavy metals. During glass wool removal, potential temporary skin
irritation may be caused from glass wool fiber which potentially be the causes of skin dermatitis with
repeated or prolonged contact. Therefore application of masks and gloves shall be a must and washing
and changing after the work should be instructed.
Proper PPE during gas cutting No gloves duirng glasswool Wearing cloths instead of
(NK certified yard) removal (Normal yards) mask during gas cutting
(Normal yards)
(6) Medical monitoring on workers
29
According to India Factory Act 1948 and Gujarat Factories Rules 1963, it is made mandatory for the
employers to conduct medical examination of their workers. In Alang / Sosiya ship recycling yard,
medical doctors certified by Directorate of Industrial Safety and Health (DISH) who are employed by
SRIA are conducting medical examination both at pre-employment stage and periodically in every six
months. A periodical examination only covers simple physical and medical examination items. Some
NK certified yards are conducting occupational specific examination which is additional to periodical
ones, such as pulmonary test for gas cutters and pulmonary, sputum and chest X-ray test for asbestos
handlers.
Since it is considered insufficient to grasp the health hazard of workers by current examination items, it
is recommended that occupational specific items shall be included.
Periodical medical examination Medical examination form

(All yards) (All yards)
(7) Zoning of the yard and sorting of materials in the yard

NK certified yards have clear zoning in the yard dividing oil contaminated block storage zone, gas
cutting zone, non-ferrous disassembly zone and etc. Also, recycled materials are segregated and well
organized. On the other hand, normal yards do not have clear boundary of different zones in the yards
where oily block and cutting plates are stacked together and LPGs are stored in close proximity to gas
cutting area.
Proper zoning in the yard and segregation of dismantled blocks and parts are basic but important
method to reduce the risk of any accidents during the operation. Thus, zoning and sorting shall be
practiced with the initiative of yard owner and under the supervision of HSE manager and site
supervisors.
Proper zoning in the yard reduces Oily parts and steel plates are LPG is stored close to cutting
operational risk (NK certified yard) stacked together (Normal yards) zone (Normal yards)
(8) Fire accident measures

Firefighting facilities are equipped in all the observed yards. It was also confirmed that fire
extinguishers were carried on board for the gas cutting operation. Mock drills for fire fighting and
emergency evacuation were carried out in in-house training program under the supervision of HSE
officer.
30
Fire fighting facility (Normal A fire drill (NK certified yards)

yards)
(9) Identification and removal of hazardous substances

For the identification of hazardous substances on the ships, NK certified yards are outsourcing
preparation of Inventory of Hazardous Materials (IHM) to external expert agencies. In the case of
normal yards, identification of hazardous substances is done without IHM. Considering the difficulty of
thorough investigation of hazardous substance without IHM, there may be a possibility of hazardous
substance remaining unidentified.
In order to minimize the exposure risk to hazardous substances, knowledge of hazardous identification
and removal procedures shall be improved among competent authorities who will confirm SRP and issue
the decontamination certificate and hazardous material handling workers from each yards.
Identification of hazardous Asbestos removal on board (NK

substance including asbestos on certified yard)
board (NK certified yard)
For the removal of hazardous substances, especially for asbestos, some NK certified yards are equipped
with their own asbestos removal facilities with negative pressure chamber and shower room and trained
workers perform the removal within those facilities with proper PPE. Other normal yards are
outsourcing the removal operation to authorized external agency using mobile decontamination unit.
With this method, untrained workers will not be in direct contact with hazardous substances.
Mobile decontamination unit Asbestos removal by mobile

(All yards) contamination unit (All yards)
31
Other hazardous substances such as Ozone Depleting Substances (ODS), radioactive devices,
remaining oil, PCB contained device and equipment are removed and collected by authorized external
agency on the ship. In case of paint removal, if it is difficult to remove the paints prior to cutting, cutting
process shall be done in a control manner with the application of PPE and stored in the designated
storage facility.
Some HSE officers pointed out the lack of expertise on PCB handling which shall be incorporated in
the training programme.
(10) Hazardous waste management

Each yard is equipped with temporary storage of hazardous wastes and non-hazardous wastes. The
storages have separate rooms for different types of wastes such as asbestos, paint chips, batteries, glass
wools etc. Collection and disposal of hazardous waste is following the manifest system base on the
hazardous management rule (revised in 2003). At first, the ship recyclers shall fill out written
applications indicating types and quantity of wastes including potentially containing hazardous
substances. Based on the application, authorized agency (GEPIL) collects hazardous and non-hazardous
wastes from each yards with designated van and disposed at industrial waste disposal facility (TSDF) by
fee based services.
Temporary storage of wastes Asbestos contained parts are Waste management follows
(All yards) sealed and stored (NK yard) Manifest system (movement
document) (All yards)
2.2.3. EVALUATION OF CURRENT MEASURES EMPLOYED TOWARDS LABOR

SAFETY AND HEALTH AND ENVIRONMENTAL PROTECTION
The result of site survey is summarized in the following table. The evaluation was separately done for;
yards already certified by NK, yards in the process of verification and normal yards. The target yards of
the Project will be the similar status of normal yards.
Table 2-8 Results of site investigation and status of conformity with the requirement of the Convention
(C: Complied, NC: Not Complied)
Facility management
Document C C NC
management (documents not confirmed)
Training plan C C NC
(room for (room for (training courses are not prepared /
improvement on improvement on conducted)
32
training content) training content)

Facility operation
SRP development C C NC
Ship recycling C C NC
methodology (block dropping and cutting done in
inter-tidal zone)
Worker safety and health compliance approach
Key safety and C C C
health personnel (no adequate training obtained in
some cases)
Safe-for-entry / C C NC
Safe-for-hot-work (prior confirmation by HSE officer
procedures has not been thoroughly done)
Prevention of C C NC
working at height (confirmed with (not confirmed)
documents)
Housekeeping C C NC
(zoning is not properly done, yard
not organized)
Health and C NC NC
sanitation (under (no adequate facilities equipped incl.
construction incl. resting room, shower rooms etc.)
resting room)
PPE C C NC
(lack of proper PPE identified in
some yards)
Medical monitoring C C C
(additional (additional occupational wise
occupational wise checkup advised)
checkup advised)
Emergency C C C
preparedness
Fire and explosion C C C
prevention (inspection of equipment and
fixtures incl. fire-fighting
equipment required)
Environmental compliance approach
Environmental C NC NC
monitoring (additional (periodical (not performed)
monitoring item monitoring will
recommended) start)
Management of C C NC
Hazardous Materials (untrained workers are engaged in
the removal activity not by
specialized agencies)
Prevention of C NC NC
adverse effects to (concrete and pit (not improved)
the environment are under
construction)
Source: Survey Team
In some yards which have SOC by ClassNK etc, the implementation of training of workers, use of
appropriate PPE etc. are reviewed and monitored and improved based on the SRFP. However, in other
33
yards, the following occupational health and safety issues were revealed except for the facility operation
and management method.
① insufficient inspection and safety confirmation before entering the compartment, before fire
use
② Insufficient safety measures such as fall prevention during high altitude work
③ Insufficient workers' sanitation facilities (rest rooms, showers, etc.)
④ insufficient use of PPE properly
⑤ Periodic health checkup and management of workers is inadequate
⑥ Inadequate handling and education of harmful substances
2.3. CURRENT STATUS AND ISSUES ON ENVIRONMENTAL

CONSIDERATION
2.3.1. CURRENT SITUATION ON ENVIRONMENTAL CONSIDERATION
(1) Wastes generated from Ship

In this survey, investigation of the type and amount of waste generated from the ship during the
recycling process for two ships of bulk carriers and container ships is made. The results are shown in the
following table.
As a result, one vessel is confirmed the usage of asbestos, but PCB, TBT paint, etc., are not detected.
Asbestos is prevented from being discharged to the atmosphere by trained specialized workers, removed,
managed by the manifest, transferred to the TSDF and landfilled. PCB was not detected even in
inventory and sample analysis, but it may be contained in insulation of electric wire etc., and PCB waste
cannot be stored or processed in case there is as waste. Similarly, TBT paints have not been applied for
two vessels, but harmful paints other than TBT (such as lead) have not been removed in advance. The
paint pieces are cleaned at the disassembling place on land and sent to the TSDF.
On the other hand, although, waste oil, sludge, etc., should be disposed by incineration under the Indian
national regulation, these are collected by the contractor and resold after being processed, ship recycler
asked the contractor for washing. Cleaning of the tank is carried out by sawdust, oil sand etc. Therefore,
there are cases where insufficient washing oil leakage from the cut block to the sea or soil. The treatment
of oil sands is also an issue.
Although the amount of waste discharged from the ship is 0.1-0.3% per LDT, glass wool occurs in
large quantities in waste from the ship. These are packed after bagging and landfilled with TSDF.
Volume reduction of glass wool is an issue.
Table 2-9 Type and Volume of wastes generated from Ship
Type Approx. Quantity

no. Type Disposal Mode
of waste B.C. Panmax Container
1 Asbestos HW 538 kg - kg Solidification/Incineration
2 Glass wool/Mineral wool HW 8,280 kg 10,650 kg Secured Landfill Site
3 PUF/Poly styrene 220 kg - kg Incineration
4 Waste oil 21,000 L 400 L Incineration
Used oil 30,000 L Sale for recycle
5 Oily Sludge 650 kg 32,000 L Incineration
6 Plastics HW 70 kg 200 kg Incineration
7 Paint Chips 2,972 kg 4,480 kg Incineration
34
Type Approx. Quantity

no. Type Disposal Mode
of waste B.C. Panmax Container
8 Iron scale NHW - - Sale for recycle
9 Fiber glass/Rexene NHW - - Sale for recycle
10 Food Waste NHW 75 kg 250 kg Secured Landfill Site
11 Card boards & Packages NHW - - Sale for recycle
12 Glass NHW - - Sale for recycle
13 Bilge Water HW 5,500 L 50 MT Bilge Water Treatment Plant
14 Rubber NHW 200 kg - kg Sale for recycle
15 Lubricating Oil HW 1,008 L 92,000 L Authorized Recycler
16 Grease HW 345 L 300 kg Authorized Recycler
17 Paints HW 200 L 160 L Authorized Recycler
18 H.F.O. HW 2,000 L 407 MT Authorized Recycler
19 Engine Oil HW 110 L 5,000 L Authorized Recycler
20 Slop Oil HW 4 L 200 L Authorized Recycler
21 Hydraulic Oil HW 400 L 11,300 L Authorized Recycler
22 Cylinder Oil HW 1,600 L 60 L Authorized Recycler
Oily-Chemical
23 HW 50 kg 150 kg Incineration
contaminated rags
(2) Ship recycling process in inter-tidal zone

In NK certified yard, in order to avoid oil leakage in intertidal zone and into the sea, the primary cutting
process will be performed on the ship by leaving the bottom of the ship to receive dismantled blocks. In
principle, non-oily blocks are permitted to be dropped in intertidal zone according to the ClassNK’s
certification standard. In normal yards, cutting process was carried out in the inter-tidal zone and blocks
and materials were scattering in the inter-tidal zone.
In this Project, Large crane will be introduced for carrying large blocks or equipment to avoid the fall
of oily blocks to the inter-tidal zone.
Blocks being dropped inside the Blocks being dropped in the sea / Cutting is done in the inter-tidal
ship not to the inter-tidal zone in the inter-tidal zone (Normal zone (Normal yards)
(NK certified yard) yards)
(3) Potential impact in inter-tidal zone (fuel tank)

During site investigation, oil sludge were identified in the fuel tank after the cleaning process.
Therefore while the ship was waiting for the cutting operation in inter-tidal zone, sea water goes into the
fuel tank during high tide which may cause a risk of oil spillage into the sea.
In order to prevent potential impact in inter-tidal zone, the Project will propose introduction of fuel tank
cleaning units and its cleaning method.
35
Oil still remaining inside fuel tank Water coming inside the fuel tank
after cleaning (yard in process of while the ship is waiting in inter-
verification) tidal zone (yard in process of
verification)
(4) Pollution prevention measures on the yard

NK certified yards have laid concrete floor for second cutting area to avoid spillage of oil and other
hazardous substances. Moreover, the pit was installed at the edge of the concrete yard in order to collect
rain water containing leaked oil and other hazardous materials which may run down from the concrete
yard. The concrete yard and pit was connected to the bilge collection tank which was also equipped on
the yard. Also oil contaminated parts were stored on the concrete floor designated area to avoid direct
contact with soil. On the other hand, normal yards do not have concrete pavement so cutting operation is
done on the ground. Some normal yards, however, also stored oily parts on the steel plates to prevent oil
spillage on the soil.
In this project, yard improvement to prevent possible pollution will be planed which is similar to NK
certified yards.
Concrete floor on the yard (NK Drainage pit to prevent pollution Oily parts storing space (All
certified yard) on the soil and sea (NK certified yards: only some yards have
yard) the roof)
2.3.2. OUTLINE OF EXISTING FACILITIES
TSDF is located 2km away from Alang and mainly consist of Incinerator (5 tons/day capacity),
Effluent Treatment Plant (30m3/day capacity), Landfill site for hazardous materials (70,000m3) and
Landfill site for general wastes (30,000m3). It was constructed by GMB in 2005 and a private operator
(GEPL) as the consignee started its operation from 2006. Layout of TSDF is shown on the Figure 319
Layout of TSDF below.
36
Asbestos Landfill
Incombustible Glass
Wool
Combustible Incinerator
Wood, Rubber Ash
5t/d
Bilge, Oily Water Effluent Treat.

Treated Water Watering
30t/d
Collect Oil Sludge

Sun dry
Sold
Figure 2-3 TSDF Existing Facility
Effluent Treat Plant
Incinerator
Landfill site
Office
Figure 2-4 Layout of TSDF
Remarks: Area shown in color green is site for expansion.

color pink shows existing facilities
Source: GMB (2015), EIA of Proposed Upgradation of Existing Ship Recycling Yard at Alang / Sosiya
(1) Incinerator
The incineration facility can handle solid, semi-solid, and liquid harmless / hazardous waste with a
caloric value of 2500 Kcal / kg or more and has incineration capacity of 5 tons / day. The main
hazardous waste currently incinerated is oil sludge, cloth / sand containing oil, paint / coating material,
rubber gasket, polyurethane foam, polystyrene foam, waste plastic, etc.
Incinerator consists of primary kiln and secondary kiln and is designed to incinerate wastes more than
850 deg. C and 1100 deg. C respectively in accordance with the guidance of Central Pollution Control
Board (CPCB). Exhaust gas is released to the air after treated with wet scrubber. Scrubber water is
treated in the waste water treatment facility in TSDF and ash is reclaimed in the Landfill site of TSDF.
Incineration process is shown on the figure.
37
Figure 2-5 Existing Incinerator of TSDL
Solid Waste Primary Kiln (>850 Deg.C)
Liquid Waste Secondary Kiln (>1100 Deg.C)
Scrubber Water Cooling Exh. Gas with Wet Scrubber&

Cleaning of Gas
Waste water treatment Plant Blower

TSDF
Cleaning of particulate in the Exh. Gas by

HEPA Filter
Release Exh. Gas through Chimney (32.5m h)
Figure 2-6 Incineration Process

Source: GMB (2015), EIA of Proposed Upgradation of Existing Ship Recycling Yard at Alang Sosiya
38
(2) Management type landfill disposal facility

There are four landfills of TSDF. In 2005, 1) landfill sites for asbestos and glass wool (43,000 m 3), 2)
for industrial waste (10,200 m 3), for general waste (8 700 m 3) was constructed. Two of them are
already full and covered. Cell No. 4, which was newly prepared as a managed landfill disposal facility,
has a capacity of 100,000 m 3, of which 70,000 m 3 is industrial waste and 30 000 m 3 is general waste.
The outline of each repository is shown in the following table
Table 2-10 Outline of Landfill Site
Cell No. Name Total Total waste Start Stop Current Status
Capacity volume (MT) operation operation
Cell-1 Asbestos & 43,038 m3 28317.770* Oct. May
Glasswool 2005 2013
Cell
Cell-2 Ind.Solid & 10,212 m3 4844.575* Oct. Dec.
Chemical 2005 2011
Waste Cell
Cell- Hazardous 70,000 m3 12574.673* May Under operation
4.1 Waste Cell 2013 operation
Cell-3 MSW 8,723 m3 6704.165* Oct.2005 Under operation
operation
Cell- MSW 30,000 m3 Not yet Not yet Not yet
4.2
(3) Effluent Treatment Plant

Effluent treatment plant has a capacity of 30m3/day and treated bilge water, scrubber water from
incinerator, leachate from landfill site. Waste water is treated coagulating sedimentation and
biodegradation method and is not released to outside but utilizing water for greenery in TSDF. Sludge is
reclaimed at landfill site after it is dried up at a drying bed. Effluent treatment flow is shown on the next.
39
Figure 2-7 FET Flow of TSDF
Oily Water, Bilge
Collecting Oil Separate Oil & Water
Scrubber water Control of PH (7.5 8.5) Leachate from Landfill
Coagulating sedimentation at Sludge

Primary Sediment Tank
Biodegradation at aeration tank Sludge Drying Bed
Sludge
Secondary sediment tank Dry Sludge
Reserve tank of treated water Landfill
Watering TSDF
Figure 2-8 Effluent Treatment Process
40
(4) Issues of TSDF Facility

1) Effluent treatment equipment
Current Effluent Treatment Plant (wastewater treatment equipment) processes waste water
containing low concentration oil by static separation and chemical dosage. Therefore, it cannot
deal with wastewater etc. containing high concentration of oil. Also, it cannot cope with the
treatment of sludge generated by fuel oil tank cleaning work after beaching and offshore
tanker washing operation. For this reason, it is necessary to have a processing device capable
of treating high oil content drainage and sludge.
2) Incinerator
Regarding the detoxification of PCB-containing substances, according to the "Waste Disposal and
Public Cleaning Law" of Japan, technical standards and maintenance standards for PCB waste
incineration facilities shall be followed this regulation and it is said that 1,100 ° C is the standard
regardless of the concentration of PCB waste according to the regulations.
On the other hand, it is said that "it is appropriate to set the permissible requirement of industrial
waste disposal facility to 850 ° C or more for 2 seconds or more only in case of trace PCB
contaminated insulating oil".
Although the incinerator currently declares the performance of 1100 ° C in the secondary furnace,
due to the calorie of the waste actually burned is low and the characteristics of the fixed furnace, it
is possibility the temperature of the secondary combustion is lower than the specification. For this
reason, an incinerator capable of stably exhibiting high-temperature incineration at 1100 ° C or
higher is necessary.
3) Management type landfill disposal site
More than 62% of volume brought into managed landfill sites is glass wool and since it cannot be
incinerated, it is landfilled. Landfill sites have limitations, and there are no plans for expansion at
present. For this reason, reducing the volume of industrial waste is an issue.
Wastes received TSDF
Oily Sludge
Termocol
Glass Wool
Bilge
Figure 2-9 Wastes coming to TSDF
41
3. PRELIMINARY DESIGN OF THE PROJECT

3.1. NATURAL CONDITION SURVEY AND TESTING
(1) Topographic Survey
In order to obtain design data which is necessary for construction of structures such as concrete floors
to improve ship recycling yards, topographic survey was carried out across a range of areas from a road
alongside ship recycling yards to a shore line in a width of 130m to 200m and stretched over 9.4km from
South to North at Alang/Sosiya. Control point survey and detail survey were carried out by total stations.
Contour lines were developed by measuring spot heights every 7m grid. Topographic map is drawn on a
scale of 1 to 1,000 with a contour interval of 25cm. On the map, boundaries between each plot and major
structures such as buildings and storages are indicated. An elevation of each spot is referred to Chart
Datum Level (CDL). The concrete floors are planned to be constructed above high water level.
According to GMB tidal levels are shown as below:
Mean High Water Spring (MHWS) CDL +7.80m
Mean High Water Neap (MHWN) CDL+6.30m
Mean Low Water Neap (MLWN) CDL+3.00m
Mean Low Water Spring (MLWS) CDL+1.60m
A coastal road outside the yards is indicated on the map, which can be used for rain drainage plan too.
Figure 3-1 indicates outline of Topographic Survey Area.
42
Figure 3-1 Topographic Survey Area
Source: Survey Team
(2) Soil Investigation

Purpose of the soil investigation is to obtain soil data which are necessary for designing concrete floors
and its pertinent facilities at the ship recycling yards. Soil properties in the area consist of deposited sand
due to tidal current or wave. Figure 27 indicates Geological Map in Bhavnagar District
43
Figure 3-2 Geological Map in Bhavnagar District

Source：Commissionerate of Geology and Mining Industries and Mines Department, Government of Gujarat
Seventy (70) borings were performed to investigate soil properties from surface to 10m depth in the
survey area. Location of the borings is indicated in the topographic map. In the process of boring
Standard Penetration Tests (SPT) and taking undisturbed samples were performed. According to the
boring some silty clay was found beneath the deposited sand. N-value obtained from the SPT is
generally more than 30 at almost boring locations. However at several locations loose sand is deposited
to 10m depth. There are two types of N-value tendency, one is constant N-value throughout whole 10m
depth and another is increasing N-value proportional to depth. Figure 28 and Figure 29 indicate example
of Constant N-value regardless of depth and increasing N-value proportional to depth respectively.
Laboratory soil testing were performed as follows:
Grain Size Analysis/ Atterberg Limits test/ Density Test of Soil Particle (2.51-2.69g/cm3)/ In-place
Moist Unit Weight Test (1.73-1.86g/cm3 for 10 pcs. of undisturbed samples)/ In-place Dry Unit Weight
Test (1.58-1.70g/cm3 for 10 pcs. of undisturbed samples). The results of those tests are within ranges of
the soil properties of normal soil, hence soil in the area seems to be usable for construction of the
structures.
Taking possible pavement on the soil into consideration, CBR tests were performed. Ten (10) samples
were taken from each plot and laboratory CBR tests were carried out. The results of the tests indicate
that the soil can be used as a subgrade for the pavement. Furthermore the topographic map and the soil
boring data will accompany the Draft Final Report.
44
Figure 3-3 Borelog Example with N-value Constant Regardless of Depth
Source: Survey Team
45
Figure 3-4 Borelog Example with N-value Increasing propostional to Depth
Source: Survey team
46
Figure 3-5 Boring at Seashore
3.2. SCOPE AND CONTENTS OF THE PROJECT

As the result of the comparison between the Requirements of the Ship Recycling Convention and
Indian Regulation and Ship recycling process facility, labor and environment etc. of beaching method in
Alang / Soya area, prevention of environmental contamination of intertidal zones and soils by oil and
other hazardous materials generated during ship recycling operation and the recycling process
emphasizing the safety of workers and the necessity of facility improvement to implement this are again
recognized.
(1) Required Project Contents

The issues to be addressed in the previous chapter are reviewed and facilities and work procedures that
need to be considered in order that ship recycling facility to become compliant to the Convention are as
follows. These measures are mainly focused on how to prevent environmental pollution in the ship
recycling process in the intertidal zone. The outline of the required measured is explained with basic
design including contents, quantity, etc.
Table 3-1 Proposition of recommended facilities and equipment to comply with the Convention
Measures need to Items of Facility or Recommended Contents of the Project

be considered Process
Safe and closer Improvement of Yard to Improvement of yard with concrete floor and oil
grounding to the prevent pollution of correcting drain for the recycling works with
shore for large intertidal zone and soil Hazardous materials and contaminants.
vessel Heavy equipment for the Heavy lifting equipment for steel plate and hull
work in intertidal zone block. (currently only winches)
Introduction of Large Crawler cranes for the
recycling work in intertidal zone. The crane will be
time base rent scheme with operator for all yards
who may be needed. (Large block will directly
transferred from ship to shore or by lightning after
47
Measures need to Items of Facility or Recommended Contents of the Project

be considered Process
part of ship, avoid pollution of the sea)
Wheel Loader for beach Bucket ㎥ for the purpose of 10km beach cleaning
(cleaning of debris) of Alang/Sosiya
Bunker oil tank cleaning Cleaning of double bottom FO tank. Introduction of
device mobile high pressure cleaning device. Equipment
shall be 1 TEU size and make available for all
yards.
Acceptance of Oil Afloat Tanker Cleaning One cargo oil tank, slop tank cleaning and
Tanker (Large Barge transportation barge
Tanker) Multi-purpose vessel For the purpose of oil combatting, firefighting and
monitoring during tanker cleaning operation at sea.
One multi-purpose work boat.
Reinforcement of Reinforcement of oil As the result of the improvement of yards and other
capability of treatment and project, it is expected to increase the volume of
Hazardous incineration capacity of wastes and HMs.
Materials and TSDF Improvement of Incineration performance.
wastes treatment. Improvement of Oil treatment performance.
Improvement Improvement of living Improve living condition of workers and provide
ofwork condition safe and hygiene housing thus promote inhabitant
environment workers
Source: JICA Survey team
Proposed scope of the Project and corresponding requirements of the Ship Recycle Convention is shown
on the table next.
48
Table 3-2 Proposed scope of the Project and corresponding requirements of the Ship Recycle Convention
Requirements of Ship Recycling Convention Contents to Item to Cope in Facility and Project Scope
Correspond Procedure
Regulation 17 – General requirements  Provision of  Provision of SRFP by  Technical Cooperation (Capacity
• Authorized SRF shall establish management systems, SRFP & SRF Development)
procedures and techniques not pose health risks to the monitoring  Identify risks to Expedite understanding to HKC and
workers and prevent, reduce, minimize adverse effects on  Approval of SR safety and provision of SRFP by conducting
the environment caused by Ship Recycling, taking into Facility by environment and Management Level Staff Training
account guidelines developed by the Organization. GMB establish required Course To Build Awareness of
• Authorized SRF shall, only accept ship comply with this management system, Hazardous and Risks, Recycler Top
Convention; or meet the requirements of this Convention techniques, improve Management Course
and accept ships which they are authorized to recycle. facilities and have • Expedite acquisition of SOC by
approval from CA or improving yards.
Regulation 18 – Ship Recycling Facility Plan (SRFP)
RO.
1. Authorized SRF shall prepare a SRFP including a
policy ensuring workers’ safety and the protection of Training Course Ⅰ Initial Training
(CA: Competent Agency
human health and the environment including; Course For All Workers
(RO: Recognized
2. a system for ensuring implementation of the Training Course Ⅱ Initial Training Course
Organization)
requirements set out in this Convention For Skilled And Special Workers
3. identification of roles and responsibilities for Training Course Ⅲ Managers And
employers and workers Management Level Staff Training Course
4. a programme for providing appropriate information To Build Awareness Of Hazardous And
and training of workers Risks
5. an emergency preparedness and response plan; Recycler Top Management Course (Hkc)
6. a system for monitoring the performance of Ship Recycler Top Management Course
Recycling; (Training Course In Japan）
7. a record-keeping system showing how Ship Recycling Training Course (Trainees)
is carried out; Trainer Course (Crane Operators)
8. a system for reporting discharges, emissions, incidents Other Trainings
and accidents causing damage, to workers’ safety, 
human health and the environment; and
9. a system for reporting occupational diseases,
accidents, injuries and other adverse effects on
workers’ safety and human health,
Regulation 21 – Emergency preparedness and response
49
Authorized SRF shall establish and maintain an emergency
preparedness and response plan, including information of
necessary equipment, the necessary information &
communication Competent Authority(ies), the neighbourhood
and emergency response services.
Regulation 19 – Prevention of adverse effects to human  Oil et., removal  Caution for use of fire in  Technical Cooperation (Capacity
health and the environment before fire the cutting work Development)
• Prevent explosions, fires by ensuring that Safe-for-hot works To deepen safety hot work, risks in
work conditions and procedures are established, the work place, occupational injuries
throughout Ship Recycling and environment risks by
• prevent harm from dangerous atmospheres by ensuring implementing Training Course Ⅰ
that Safe-for-entry conditions and procedures are Initial Training Course for All
established in ship spaces, including confined spaces and Workers, Training Course Ⅱ Initial
enclosed spaces, throughout Ship Recycling Training Course for Skilled And
• prevent other accidents, occupational diseases and
Special Workers, Training Course Ⅲ
injuries or other adverse effects on human health and the
Managers.
environment; and
• prevent spills or emissions throughout Ship Recycling
which may cause harm to human health and/or the
environment,
Regulation 20 – Safe and environmentally sound

management of Hazardous Materials
• Authorized SRF shall ensure safe and environmentally
sound removal of any Hazardous Material contained in a
ship, actively use the IHM and the Ship Recycling Plan,
prior to and during the removal of Hazardous Materials.
• ensure that all Hazardous Materials detailed in the IHM
are identified, labelled, packaged and removed prior to
cutting by properly trained and equipped workers.
Regulation 22 – Worker safety and training

• Authorized SRF shall provide for worker safety by
measures including training programmes prior to any
ship recycling operation.
50
• Authorized SRF shall provide and ensure the use
of personal protective equipment for operations
requiring such use.
Regulation 19 – Prevention of adverse effects to human Study of safe and 1) Improvement of yard for At the shore plot where hazardous,
health and the environment closer to shore protection of pollution to polluted wastes may be released,
• prevent accidents, occupational diseases and injuries or beaching of large soil and intertidal zone improvement by providing impermeable
other adverse effects on human health and the ships floor and oil correcting ditch etc.
environment; and 2) Mitigation of negative Invest 5 (Five) Larger large crawler
• prevent spills or emissions throughout Ship Recycling impact to environment by cranes for the recycling work at intertidal
which may cause harm to human health and/or the fallen cut block at zone.
environment, intertidal zone By transferring large block from ship
directly to shore yard and/or lightening
Regulation 20 – Safe and environmentally sound weight at aft, avoid pollution to the sea.
management of Hazardous Materials 3) Protection of pollution in Invest 3 ‘Three) Beach cleaning wheel
• Authorized SRF shall ensure safe and environmentally intertidal zone by loader with bucket capacity of 2m3 for
sound removal of any Hazardous Material contained in a
cleaning debris & wastes cleaning 10km length of Alang /Sosiya
ship, actively use the IHM and the Ship Recycling Plan,
coast
prior to and during the removal of Hazardous Materials.
• ensure that all Hazardous Materials detailed in the IHM 4) Protection of oil leakage Invest 5 (five) High pressure mobile
are identified, labelled, packaged and removed prior to to sea by bunker oil tank decontamination system for bottom FO
cutting by properly trained and equiped workers. cleaning tank cleaning. Make sure residual oil
• All wastes generated from the recycling activity shall cleaning to protect spill to environment
be only transferred to a waste management facility and fire, explosion.
authorized to deal with their treatment and disposal.
Regulation 19 – Prevention of adverse effects to human Reception of Oil 1) Cleaning and gas freeing Invest 1 (one) Offshore tank cleaning
health and the environment Tanker (VLCC) for cargo oil tank of barge which can clean cargo oil tank and
• Prevent explosions, fires by ensuring that Safe-for-hot offshore tankers. slop tank of VLCC at offshore, and
work conditions and procedures are established, transfer oily water to shore.
throughout Ship Recycling Protection of oil spill from cargo tank of
• prevent harm from dangerous atmospheres by ensuring tanker and establish safe for entry and
that Safe-for-entry conditions and procedures are safe for hot work
established in ship spaces, including confined spaces and 2) Cleaning work above and Invest 1 (one) Multipurpose vessel to
enclosed spaces, throughout Ship Recycling
protection of marine monitor and act against offshore tank
51
• prevent other accidents, occupational diseases and environment cleaning works, oils spill while recycling ,
injuries or other adverse effects on human health and the fire , etc.
environment
Regulation 20 – Safe and environmentally sound Reinforcement of 1) Reinforcement of oily By the improvement of yard, introduction
management of Hazardous Materials treatment capacity of water treatment and of Mobile decontamination system,
• Authorized SRF shall ensure safe and environmentally Hazardous and incineration capacity at improvement of recycling process, wastes
sound removal of any Hazardous Material contained in a wastes TSDF volume may be increased. To cope with
ship, actively use the IHM and the Ship Recycling Plan, the increased wastes and hazardous,
prior to and during the removal of Hazardous Materials. reinforce the treatment capacity of existing
• ensure that all Hazardous Materials detailed in the IHM TSDF facility
are identified, labelled, packaged and removed prior to 1. Increase incineration capacity
cutting by properly trained and equipped workers. 2. Increase bilge and oily water
• All wastes generated from the recycling activity shall
treatment capacity
be only transferred to a waste management facility
authorized to deal with their treatment and disposal.
52
As the results of the review and investigation above mentioned, the Project consists of the following
components:
1) Improvement of existing 70 ship recycling yards
2) Introduction of Mobile Decontamination Units
3) Introduction of Large Mobile Cranes and Beach Cleaning Wheel Loaders
4) Introduction of Tank Cleaning Barge
5) Introduction of Multi-Purpose Vessel
6) Improvement of environment facilities of TSDF
Detail of the above project component is explained hereafter.
3.2.2. IMPROVEMENT PLAN
(1) Improvement of existing ship recycling yards

Under the Project, in order to protect any releases of hazardous materials to the inter-tidal zone while
the ship recycling process is going on, provide impermeable floor (concrete paved floor) with drainage
at shore yards where demolishing hull block and equipment including hazardous materials, aimed at
complying the requirements of the Convention.
(2) Improvement of environment facilities of TSDF

Under the Project, the following new facilities will be introduced aimed at extending the life of the
landfill site and to improve the negative impact by the process of oil cleaning and collection.
1) Bailer
Compress the volume of solid wastes not suitable for incineration such as Glass wool.
2) Sludge Treatment Plant
Recover residual oils contained in oily sludge as much as possible and sell it. Oily sludge,
after treatment, will be land filled in stabilized condition.
3) Oil Separation Tank
Separate low density oily water (such as bilge water) to oil and water with heating device.
4) Oily Water Separator
Oily water, of comparatively low density, will be separated into oil and water. Recovered oil
will be sold.
5) High Temp Incinerator
About 1400 deg. C with for the Low-concentration PCB waste (unintentionally mixed very
small amount of PCB contaminated electric parts and wastes with PCB concentration:
5,000ppm or less)
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3.3. IMPROVEMENT OF SHIP RECYCLING YARD FACILITIES

3.3.1. IMPROVEMENT OF YARD FACILITIES
In the ship recycling yard, cutting area for cutting hull block, storage area for steel plates and removed
parts, towing winches, temporary storage of hazardous materials, office, warehouse, workers’ rest space
are arranged depending on the size of the yard. However, as the cutting area and storage area is an
exposed area, there will be risk of contaminating ground water or soil in the yard by pollutant and also
the chance to pollute marine environment by washing rain water with the pollutant. Therefore, the
following improvement of the existing yard facilities will be implemented under the Project in order to
comply with the requirements of the Convention.
1) Provision of high rigidity concrete floor for the cutting area and storage area for the pollutant
2) Provision of collecting rain water (including drainage and oil collecting tank foundation)
3) Provision of the foundation of towing winches
The following works are not under the scope of the Project yet but to be provided by the recycler as
appropriate.
1) Temporary storage of Hazardous materials
2) Storage of LPG cylinders
3) Asbestos handling facility (not required in case it will be outsourced)
4) Sanitary, Drinking water, shower facility
5) Workers’ changing room
6) First aid facility
7) Firefighting facility
8) Sewage treatment facility (Septic tank)
Improvement of the yard facilities with the concrete pavement has been started by recyclers
themselves, and audit process for the acquisition of SOC by the Class NK or RINA is under progress.
Although detailed design of the improved facilities was not available from the ship recyclers, concreted
impermeable flooring will be provided considering improvement of safety and protection of
environmental pollution and preliminary design is developed based on the investigation and analysis of
the current issues.
Preliminary design is made as standard design by the different width of the yards of 45m, 60m, 90m, &
120m and this design could be utilized further for individual detailed design at the time of the
construction. The above fore mentioned facilities such as temporary storage of hazardous materials, etc.,
will not be covered by the Project, however, required facility will be further confirmed with ship
recyclers and appropriate recommendations made to the recyclers.
As to the technical guideline, Class NK’s comprehension to the Convention and the guideline of the
State Pollution Control Board for the impermeable structure will be considered and protection of soil and
ground water pollution and also to protect any spill of the hazardous materials to the inter-tidal zone to
be considered in compliance to the requirements of the Convention.
54
Figure 3-6 Impermeable Floor Structure by CPCB Guideline
The dismantling method is equivalent to the current method and renovation for environmental
improvement (prevention of diffusion of hazardous substances and securing of occupational health and
safety) shall be carried out. In the current method, the target ship is beached on the surface of the
recycling yard using a difference in tide (high tide at spring tide), and it is pulling up into the recycling
yard by a large winch then cut, removed, and transferred the materials (product or material).
(1) Number and Basic plan of the Yards to be improved

Ship recyclers are operating at yards (working place) on lease basis from GMB. Therefore the yards
(the size, winch and office building, etc.) are different respectively, and there are no standard facilities
available. The scope of the improvement work of the facility is defined as the concrete pavement areas
in the yard and areas where installation of oil water treatment tank is placed and winch foundation with
reaction force block. Therefore the Office building and the Parking lots, Weigh Bridge facilities and an
equipment ridge for toxic substance depository are excluded from the scope of work.
As shown in Table 3-3 there are 131 yards in total including 24 yards certified by the classification at
the end of 2016. According to SRIA, it is assumed that the number of the yard to be approved by the
classification and that is going to invest in the near future for the improvement of their facilities by
themselves will be 60 yards by 2017, and 60 yards or more in 2018. Assuming that the commencement
of the project is 2019, if more than 60 yards have already been improved and classification certification
is received, the remaining less than 70 yards will be subject to the project. Meanwhile, the willingness of
investment by the private sector depends on recycling demand, scrap price, etc. There is a possibility that
it is less than 60 yards are improved before the commencement of this project. In that case more than 70
yards are subject to renovation. On the other hand, if the number of non-operating yard possessed by
GMB is included, it will be about 150 yards in total then there will be a necessity to improve more than
70 yards.
Although it is basic policy of India that the whole yard shall be improved without discrimination for
each yard, ship recycler shall lease land by contract from GMB and prepares for operation by themselves
then only their business can be started. For this reason, it is unlikely that new businesses will enter the
empty yard before this project is commenced and also it is not expected to strengthen the recycling
capacity due to the sharp rising demand for ship recycling, it is decided to cover 130-60=70 yards under
the project.
For the Ship recycling yards, as width for each plot is different, hence a set of the width of the yard, as
standard, is shown in Table 32, with the total of 70 yards.
Table 3-3 Current situation of Ship breaking yard（plot）
Width of the yards Number

30m ～ 50m 72
51m ～ 70m 54
71m ～ 90m 16
> 91m 11
55
Total 153
source：JICA Study Team
Table 3-4 Renovation of number of Ship breaking yard (plots)
Width of the yards Number

45m 25
60m 30
90m 10
120m 5
Total 70
source：JICA Study Team
It is found that the yard which GMB owned and is not currently used is 7 yards and that required earth
work such as replacement of sand and earth when using it as a recycling yard. Therefore further
examination is require to the temporary improvement of each yard at the time of project implementation
to use it as a substitute place. Also, if the yard will be used as a joint storage of hazardous waste, a
maintenance shop for donated equipment, etc., as well as earth work, internal paving, other facilities etc.
should be considered.
3.3.2. PRELIMINARY DESIGN
(1) Technical Interpretation of Class NK

Based on the apprehension that prevention of the spillages of hazardous materials into the intertidal
zone is of vital importance for compliance with the requirements of the Convention for the ship
recycling with beaching method, compared to the other Dry dock method, Afloat method and Landing
method against Regulation 19.4 of the Convention, “The ship recycling facilities shall prevent spills or
emissions throughout Ship Recycling which may cause harm to human health and/or the environment”,
the following points to improve beaching method has been studied:
1) Technical Requirements
・ Preparation before cutting ship

・ Cutting work at the intertidal zone
・ Infrastructures
・ Emergency preparedness and response
・ Environmental monitoring and reporting
① Preparation before cutting ship

Ship recycling facility shall minimize a risk of spill before start cutting work of ship at intertidal
zone by providing the following measures.
a） Preparation of IHM Part 1 to Part 3(not only by ship owner but ship recycling facility)
b） Minimize residual oils to a maximum extent before beaching
c） Identify the location of hazardous materials on board by actively utilizing IHM
d） For the tanker, Safe for Hot Work certificate shall be obtained
e） Hazardous materials such as residual oils and cargo residues shall be removed from ship.
f） Ballast water treatment as per national norm
g） Permanent provision of oil spill preventing equipment during ship recycling work
② Ship cutting process at Intertidal zone

a） As much as possible, cutting shall be done in a controlled manner to ensure that paint chips
56
and other wastes shall not to fall into the intertidal zone. (Ship breaking code has prohibited
direct throw of these wastes to sea)
b） Assess whether hazardous materials are removed from the cut block and if the block is judged
unclean then it shall not fall into the intertidal zone and/or surface without an impermeable
floor. Dirty blocks should fall in to the hull.
c） Prevent any leakages from cut section of hull
d） These processes shall be managed by the competent person.
③ Emergency Preparedness and Response

The Ship Recycling facility shall establish and maintain the Emergency Preparedness and
Response Plan (EPRP) including oil spill solution measures for the intertidal zone.
④ Environmental Monitoring and Reporting

a） The ship recycling facility shall provide and maintain an Environmental monitoring program
including monitoring of intertidal zone.
b） The ship recycling facility shall establish a reporting process for incidents of oil spills to the
intertidal zone.
At present, apprehension of the requirements of the Convention by Class NK is sole and publicized
with same understanding by the Ministry of Land Infrastructure Transport and Tourism of Japan.
Therefore, this apprehension can be the basic requirement to improve ship recycling facilities in India
and can be deployed / introduced as the Project.
(2) Preliminary Design

1) Basic Design Policy
In India, design criteria and design procedure of the port structure on ship recycling yard has not yet
been established. In addition, the design process of a unified scrapping yard does not exist. Therefore,
"Technical Standards and Commentary for Port and Harbor Facilities in Japan” as a design criteria is
applied for the design.
a. Performance Criteria of Ship Recycling Yards
The performance criteria of aprons shall be as specified in the subsequent items:
① Width
Yard widths shall be properly set to allow safe and smooth ship breaking operation. The
pavement is made of about 60 % of size to a margin in the yard and other areas shall not be
paved (as the road).
② Gradient
Gradient of Yard shall be properly set to drain water and other surface waters taking into
consideration of the ship recycling operation at the yard with backyards, and hence cross slopes
need to be properly determined. Yards normally have a down slope of 1 - 2% toward the sea. In
some cases, reverse slopes are used depending on the conditions of yards and environmental
consideration. Since the settlement of backfilling may cause slopes to be reversed, construction
should be carefully performed.
③ Pavement Materials
Yards shall be paved with proper materials taking account of the surcharges and the conditions
of use of mooring facilities. The form of the pavement considers the soil quality situation of the
roadbed, building, workability, the cost performance and a maintenance, etc., and a concrete
pavement is selected.
ii. Load Condition
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In the design of the pavement structure, design load is determined taking the conditions of material
to be used, load of heavy equipment, cranes which handles hull blocks so as determine the thickness
of the pavement.
The performance verification of yard pavements shall be confirmed such that pavement structures
are stable under the load of vehicles and related equipment. Figure 32 shows an example of the
performance verification procedures of yard pavements.
Setting of design conditions
Assumption of pavement section
Evaluation of actions
Performance verification
Variable states on surcharges
Verification of pavement stability
Determination of pavement section
Figure 3-7 Example of Procedures for the Performance Verification of Yard Pavements
Actions to be considered in the performance verification of yard pavements are generally the load of
trucks, truck cranes, rough terrain cranes, all terrain cranes, forklift trucks, straddle carriers, etc.,
depending on the types of steel blocks and ship breaking methods.
Here, truck cranes, rough terrain cranes, and all terrain cranes are denoted as the movable cranes.
The performance verification of yard pavements normally takes account of the ground contact areas
on which loads are applied, setting the maximum load and the ground contact pressures to determine
the pavement thickness.
iii. Design of Concrete Pavement
a. Procedure of Performance verification

Figure 3-8 shows an example of the procedures of the performance verification for concrete
pavements. It is preferable to perform the verification of concrete pavements both on base course
thickness, and concrete slab thickness considering, cyclic numbers of actions, conditions of the
bearing capacities of roadbeds. The yard considers the steel block weight and gas cutting works, and
does a rigid pavement.
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Setting of design conditions
Verification of base course thickness
Assumption of concrete slab thickness
Evaluation of actions
Performance verification
Variable states on surcharges
Verification of concrete slab thickness
Determination of pavement section
Consideration of structural details
Figure 3-8 Example of the Procedures of Performance Verification for Concrete Pavements
b. Design Conditions
① Procedure of performance verification

The design conditions considering the performance verification are generally as follows:
i. Design working life
The design working life of concrete pavements shall be properly set considering the
conditions of use and other related conditions of mooring facilities. The design working
life of concrete pavements used for the yards of winch foundation and other facilities may
be generally set at 20 years.
ii. Conditions of Action
iii. Cyclic numbers of actions
iv. Sub grade bearing capacity
v. Materials used
The design action conditions are those requiring the maximum concrete slab thickness among the
types of actions to be considered. The characteristic values of actions may be set referring to Table
33.
59
Table 3-5 Reference Values for the Action Conditions of Concrete Pavements used for the Yards
Action Type of action Action Ground contact

classification (kN) radius (cm)
CP1 Fork lift truck 2t 25 10.6
Tractor trailer for 20ft, 40ft 50 17.8
Fork lift truck 3.5t 45 13.8
CP2 Fork lift truck 6t 75 17.8
CP3 Truck 25 ton class 100 17.8
Fork lift truck 10t 125 22.2
Straddle carrier 125 22.2
CP4 Mobile crane (truck crane, rough Type 20 220 19.9
terrain crane, all terrain crane)
Mobile crane (truck crane, rough Type 25 260 20.3
terrain crane, all terrain crane)
Source : Technical guideline of Port Facilities (The Ports and Harbours Association of Japan)
② Pavement Structure
It is preferable to prepare a test base course and set base course thickness at value which makes
the bearing capacity coefficient equal to 200N/cm3. In the cases where the preparation of a test base
course is difficult, the base course thickness may be directly set using the design curves shown in
Figure 34. The minimum base course thickness is generally set at 15cm.
Figure 3-9 Design Curves of Base Course Thickness
The base course thickness of concrete pavements may be set referring to Table 34 prepared based
on the past records.
60
Table 3-6 Reference Values for Base Course Thickness of Concrete Pavements
Design condition Base course thickness (cm)
Design bearing Upper sub-base course Lower sub-base course Total base
capacity coefficient of Cement Graded Graded Crusher course thickness
base course K30 stabilized grain grain run
(N/cm3) base material material etc.
50 or more and less – 40 – 20 60
than 70 20 – 20 – 40
25 – – 30 55
70 or more and less – 20 15 – 35
than 100 – 20 – 20 40
15 – 15 – 30
15 – – 15 30
100 or more – 20 – – 20
15 – – – 15
Source : Technical guideline of Port Facilities (The Ports and Harbours Association of Japan)
(a) Verification of concrete slab thickness

The bending strengths of concrete slabs may be set at 450N/cm2 for 28 days test piece.
Figure 35 shows the relation between concrete slab thickness and bending stress. The bending
stresses are calculated using an equation called Arlington formula. The symbols CP1 - CP4 in Figure
35 are the classification names needed for using (d) Empirical method of setting concrete slab
thickness.
Figure 3-10 Relation between Concrete Slab Thickness and Bending Stress
(b) Setting of concrete slab thickness

The method of setting the thickness of concrete slabs in compliance with the concept of Pavement
Design and Construction Guide has been proposed. In this method, the fatigue characteristics of
concrete slabs are calculated based on the wheel load stresses imposed on concrete slabs and their
61
cyclic numbers during design working life. And the relation between the above mentioned
characteristics and the degree of fatigue as a failure criterion is proposed to set the thickness of
concrete slabs.
(c) Empirical method of setting concrete slab thickness
a. The concrete slab thickness set referring to the empirical values given in Table 35
may be considered to have the same performance as the one set using the method of Setting
Concrete Slab Thickness.
Table 3-7 Reference Values for Concrete Slab Thickness

Action classification Concrete slab thickness (cm)
CP1 20
CP2 25
CP3 30
CP4 35
Applied to piled pier slab 10
iv) Structural details
➢ Iron mesh
(a) It is effective to bury iron mesh in a concrete slab structure to prevent cracking.
(b) It is preferable to overlap the junctions of reinforcing bars. The overlap length and the depth of the
reinforcing bars from the surface need to be properly set considering the thickness of the concrete slab.
➢ Joints
It is preferable to place joints on concrete pavements to allow the concrete slabs to expand, shrink, and
warp freely to some extent, reducing stresses.
(a) Joints of the concrete pavement of apron shall be arranged appropriately, considering the size of
yard, structure of mooring facilities, the type of joint and load condition. In addition, joints shall have a
structure that is appropriate for the type of joint.
(b) Longitudinal joint
① Longitudinal construction joints shall generally be press-type structured and made of tie
bars.
② Tie-bars are provided to prevent adjoining slabs from separating, and sinking / rising of
either slab at joints. Tie-bars also serve as a reinforcement to transfer the sectional force. Because
the yard pavement has a relatively small width and is physically constrained by the main structure
of the sheds, separation of yard concrete slabs at joints rarely occurs. However, it is necessary to
provide tie-bars at longitudinal construction joints to prevent sinking / rising of either slab at joints
due to differential settlement of layers below the base course, and to accommodate a wide variety
in the directions of traffic load that is not observed on ordinary roads.
(c) Transverse joints
①Transverse shrinkage joints

Transverse shrinkage joints shall generally be dummy-type structured and made of dowel bars.
62
② Transverse construction joints

Transverse construction joints shall generally be press-type and made of dowel bars. Transverse
construction joints are placed at the end of daily work or inevitably placed due to rain during
construction or the failures of construction machines or other equipment. It is preferable for
transverse construction joints to fit position with transverse shrinkage joints.
③ Transverse expansion joints

It is preferable for transverse expansion joints to generally have a structure using both joint
sealing compounds and joint filers in upper and lower parts and use dowel bars. On piled pier
slabs, however, dowel bars are not used. It is preferable to set transverse expansion joints at proper
intervals depending on construction conditions. Expansion joints are the weakest points of
pavements; hence, consideration is needed for reducing the number of their placement points as
much as possible.
④ Dowel bars
Dowel bars have a function to transfer loads and prevent the unevenness of adjoining slabs. In
either case of transverse shrinkage joints, transfer construction joints, or transfer expansion joints,
dowels bars are placed to fully transfer loads.
(d) Joint structures
Figure 3-11- 3-14 show standard joint structures.
Figure 3-11 Longitudinal Construction Joint Figure 3-12 Transverse Shrinkage Joint
Figure 3-13 Transverse Construction Joint Figure 3-14 Transverse Expansion Joint
➢ Tie bars and dowel bars

(a) Tie bars and dowel bars shall be properly selected considering the traveling loads imposed on apron
pavements in all directions.
63
(b) The specifications and placement intervals of tie bars and dowel bars may refer to the values shown
in Table 36.
Table 36 Reference Values for the Specifications and Placement Intervals of Tie Bars and Dowel Bars
Action Slab Tie bar Dowel bar
Classification thickness Diameter Length Interval Diameter Length Interval
(cm) (cm) (cm) (cm) (cm) (cm) (cm)
CP1 20 25 80 45 25 50 45
CP2 25 25 100 45 25 50 45
CP3 30 32 100 40 32 60 40
CP4 35 32 100 40 32 60 40
Note: The values of tie bars and dowel bars are those of SD295A (deformed steel bar) specified in JIS G 3112 and of
SS400 (round steel bar) specified in JIS G 3101, respectively.
➢ End protection
An end protection work along the landward side of pavement shall be provided at a location where
there is a risk of destruction of the base course due to infiltration of rain water or destruction of the
concrete slab and base course due to heavy loading.
iv. Facility Drawings
See Figure XX ~ XX of annexed. Yard width of W = 45m, and for W = 60m shown in the figure. In
addition, since the position and status of the renovation plot is unknown, for W = 90m and W = 120 m
carry out the quantity calculated as W = 45m * 2, 60m * 2.
As for the dismantling place, as it is on the concrete floor slab as shown in Fig. 3-15, collecting water
flowing from the side groove into the water collecting pit is sent to the oil / water separation tank for
collection. The recovered water containing oil is transferred to the treatment plant and processed in a
predetermined procedure.
For wastewater other than the dismantling place (concrete floor slab), wastewater due to rainfall is
discharged using natural infiltration, spontaneous falling, or nearby rainwater drainage facilities.
64
Figure 3-15 Image of the Improved Yard
65
Figure 3-16 Oil Collecting Ditch
66
(3) Jetty for Mooring Waste Oil Collection Barge

In this project it is planned to introduce an offshore tank cleaning barge to wash the cargo oil tanks and
to collect oily water after clean up the tanker at sea in the environmental plan for offshore and shore as
described in Section 3.4.2. This offshore tank cleaning barge is moored on the jetty in Alang, and the
waste oil is transferred on land. Figure 3-17 shows a jetty design drawing for mooring of offshore tank
cleaning barge.
The construction site is the southernmost part of the Arang, and the structure is as shown in the Figure 3-
17. Jetty is an RC construction, the foundation is a direct foundation with rock cuts, launched a peer at 5
m pitch, and a concrete slab of 1 span 5 m × 10 span is placed, the extension is 50 m.
As a mooring facility, install pits, fenders, and car stops. From the road part to the abutment position,
embankment structure with stone and earth and sand is used, and asphalt pavement is applied.
67
Figure 3-17 Jetty for the mooring of Waste Oil Collection Barge
68
(4) Work Procedure

When considering the current state of yard ownership (user) of recyclers, it is judged that it is difficult
to change the plot (move), so it is considered to improve (renovate) at the current position.
It is also confirmed that the material supply area (quarry) such as sand, stone etc., is available near the
site (within 15 km), and local purchase of rebar (D 10 ~ 16), cement (ordinary Portland tare 40 kg)is
possible (price).
3.3.3. PROPOSAL FOR INTRODUCTION OF NEW MACHINES
(1) Improvement for facilities of ship recycle yard

In considering for current situation of facilities and concerned issues in recycling yards, the following
two kinds of machines would be proposed on this project from the aspect of improving environmental
preservation, safety and working efficiency in the yards.
① Large Crawler Cranes (120t) five(5) machines
② Beach Cleaner three(3) machines
1) Large Crawler Cranes（120ｔ）
In the procedures of breaking a ship after beaching, the ship is broken from bow part toward aft part.
When the hull breaking work proceeds to some proportion, usually to No.1 or No.2 hold, the
remaining hull body should be dragged to the shore side by the winches fixed in the yard. In case of a
large ship, however, the dragging works by the winches (75t x4 sets) is very tough because the ship’s
weight is very heavy (for example, P’max bulker’s weight is about 12,000t), even if the ship is
dragged with assistance by own buoyancy in high tide. Therefore, to reduce the weight, some blocks
of the stern part or accommodation structure are cut down into the inter-tidal zone.
Especially, since aft part of ship arranged with engine room and accommodation is very heavy and is
slim in the lower hull shape, the bottom of aft part sinks in the sand of beach. Therefore, the friction
between the bottom of ship and the surface of beach is very large. In order to reduce the friction, some
stern blocks of the aft portion of the ship should be cut down. There is some risk of polluting the inter
tidal zone where the blocks are dropped down and dragged to the shore by winch. This risk should be
eliminated for keeping environmental preservation.
If the accommodation structure and machinery in engine room, which are main heavy portions of aft
part, can be broken and dismantled in early stage by use of a big crane, the stern blocks and some
parts of accommodation structure need not to be cut down in order to reduce the hull weight for the
dragging. In the case of P’max Bulker of which gross ship’s weight is about 12,000 ton
(=12,000LDT), its total weight of the accommodation structure (approximately 500t) and the
machinery in engine room (approximately 700t) is 1,200t, which accounts for a 10% of the gross
ship’s weight. Furthermore, since the equipment, machinery and furniture in engine room and in
accommodation, which are valuable and resalable goods, can be removed carefully and smoothly by
use of the crane without damages, the working efficiency may be increased.
For above purposes, the big crane gets onboard into the hold just before engine room in the early
stage, and works to break the accommodation structure and dismantle the machines in engine room. In
Turkish recycle yard, there is a similar example that a big crane gets on the double bottom to break the
accommodation and engine room in the late stage of breaking procedure.
69
Figure 3-18 Example of cranes operating on board in Turkey
2) Beach Cleaning Machine for inter-tidal zone
As cutting works of breaking ship’s hull are done in the inter-tidal zone, trash and debris (wooden
chips, concrete blocks, heat insulation materials, plastic materials, electric cable, and steel cutting
chips, etc.) in the breaking works are scattered over the beach.
Currently the trash and debris are gathered up by hand of workers in respective yards at their
discretion. The cleaning works, however, would be made more efficiently and widely with the
machines.
(2) Specification, Number and Operation for New Machines

Required specifications of new machines with its operational method are as follows.
1) Large Crawler Crane
a. Specifications
• The crane should retain adequate lifting capacity at the top of boom which is angled and
extended just above the zone of accommodation and engine room, in order to break efficiently
accommodation structure and quickly dismantle machines in engine room.
• Because the crane lifting ability is decreased steeply in reverse proportion to the outreach
radius (which is depended on the boom length and its angle), the nominal crane capacity is
required to be about 120 ton in order to exercise the necessary lifting ability (10-25 ton) just
above the accommodation zone and engine room zone. (See Figure 314 crane operation chart
regarding to the relation between outreach and lifting ability)
• On the other hand, the gross weight with loads lifted should be less than the limitation in the
strength of the double bottom structure.
• The crane must have a telescopic boom because it gets onboard and is operated in the narrow
hold.
• The telescopic boom should be capable to extend up to 47m in length for breaking large
ships, such as a cape size bulk carriers (200,000DW) and a panamax size container ships. (See
Figure 3-9 and 3-10 Crane operation chart in detail).
70
• The crane should have the traveling mechanism which is fit for running on sand beach in front
of the yard and does not damage the double bottom in the holds when it gets on board.
• The traveling mechanism of mobile cranes is divided roughly into a wheel type with tires and
a crawler type with caterpillar.
• The tires of wheel type might lose traction on sand beach, and damages the inner bottom plate
of double bottom structure because each of tires touches the plate with heavy weight
concentrated into one point.
• On the other hand, the crawler touches ground with plane surface, which does not lose traction
on sand beach and does not damage the inner bottom plate.
• Therefore, the crawler type should be chosen for the crane.
• Furthermore, the crawler crane can easily adjust its own position while being maneuvered in
narrow space, and exercise better performance in other operating activities. See Table3-1 for
the detail.
• Accordingly, the crawler crane should be satisfied with the specifications as follows;
➢ maximum load capacity 120 ton or over
➢ own weight less than 125 ton
➢ a telescopic boom (maximum length 47m or over)
➢ crawler type for traveling
Table 3-8 Comparison of performance between Crawler crane and Wheel crane
Concerned items Crawler Wheel
Mobility for × Damages the pavement of Can drive on public road by itself,
transportation from public roads by crawlers. but restricted by the regulation ( in
plot to plot Required to be transported on a case the axis load exceeds 10.2t,
long trailer prior permission is required)
Mobility on sand ○ Stable drive even on sand area × Once wheel loses traction on sand
area in plot area, it cannot move at all
Double bottom is ○ Bearable against touch by flat × Heavy load concentrated at one
bearable ? surface of crawlers, point may dent /damage the top
plate of double bottom
Heavy load at the ○ No Out- riggers × Leg fixing points on double
point of Out-rigger Crane weight to be supported bottom should be reinforced with
legs on double by crawlers surface thick plates against concentrated
bottom load at one point
Adjustment of ○ As revolving motion is △ As only turning motion is
setting at the best possible with crawlers driving in possible, adjusting movement is
position in last hold reverse each other ( left crawler difficult in narrow space of the last
forward and right one hold.
backward ), adjusting movement
is quick and easy.
Pick &Carry ○ Capable to move while lifting △ Move while lifting only small load
heavy load
71
Figure 3-19 Crane (TADANO GTC-1200) in detail
b. Operational Procedures
• Starting breaking works from the bow part after beaching, and after collision bulkhead (fore
bulkhead of No.1 hold) is removed, an opening square hole (width abt.4m, height abt.5m) is
made by cutting the lowest part of each of bulkheads to create a passage for the crane on the
double bottom leading to the hold just adjacent to the engine room.
• Setting a temporary bridge at the front cutting edge of double bottom, the crane gets on the
double bottom and travel to reach the last hold.
• In the last hold, the crane extends its telescopic boom through the hatch opening and starts
lifting works. Firstly the accommodation structure is broken and removed, secondly the
machines and other equipment contained in engine room are dismantled.
72
• Besides the crane in the hold, a trailer (20t load with a towing tractor ) is prepared. Cut blocks
and dismantled equipment / machines are put on the trailer by the crane. The trailer carries
them outside along the passage and returns back to the last hold.
Elevation
Plan
Figure 3-20 Crane Operation in Panamax Bulker
73
Figure 3-21 Crane traveling on board and Trailer
Angle of bridge
is estimated 7-8
degree. The
crane is desirous
to climb up more
than 16degree.
Strength of
double bottom of
ship is last for
crane load by
calculation
Figure 3-22 Temporary Bridge for boarding
74
Figure 3-23 Crane operation for Cape size Bulk Carrier
c. Ships to be adopted
It is a bulk carrier and a container ship that the crane can works effectively. Regrettably, an oil
tanker, gas carrier, pure car carrier, ferry, and passenger ship are not suitable for the crane due to their
hull structures. General cargo ship (handy size) is also not suitable because its hold space is small and
the strength of its double bottom is not enough for the crane’s weight. Handy size ships, however, are
relatively light and need not to reduce their ship’s weight by cutting the stern blocks for the dragging.
Therefore, the effectiveness of the crane cannot be performed for the handy size ships. According to
the record for past eight years regarding the number of each kinds of ship broken in Alang-Sosiya
district (see Table 3-2), total number of bulk carriers and container ships accounts for 40% (annual
average 125 ships / 313ships in all).
Focusing the latest three years, the number accounts for 58% (annual average 191ships / 331ships in
all) and total LDT is supposed to account for approximately 80%. Even if only two kinds of ship are
suitable for the crane, the crane can contribute to improve total working efficiency in the yards
75
Table 3-9 Past record of broken ships number in Alang-Sosiya
d. Owning・Operating scheme
Since the procurement cost of crane is expensive, it should be used only during limited days in
concentrated works for breaking accommodation and dismantling machines in engine room in early
stage in order to attain the good efficiency for its cost.
Therefore it should be shared among many yards as a common use. The cranes are owned by GMB
(or SPV), who rent it to respective yards during a certain days on the rental scheme. GMB (or SPV)
appoints an appropriate private company and outsource the management job of the rental scheme
(including reception, making contract, collection of rental fee, etc.), maintenance and transportation of
the cranes.
The temporary bridge and the trailer (20 t load with tractor), which are used for supporting crane
operation, are also handled on the rental scheme. The same company should be appointed to manage
the rental scheme and maintenance for them. As the cranes are shared among many yards, they need
to be transported from plot to plot. A long trailer with truck for transporting the crane should be
provided. The maintenance of it and the transportation service of the cranes are outsourced to the
same company.
The appointed private company should prepare the warehouse to store the spare parts for the cranes,
the 20t trailers, the long trailer and temporary bridges, and arrange the parking space for the cranes
and others, if necessary.
Although operators of the cranes are not required any special skill higher than usual operating skill,
the exclusive operators are designated to avoid accidental damages caused by miss operations in the
case that any unaccustomed operator handles the crane. The private company employs the exclusive
operators and it rent the cranes with the exclusive operators to respective yards.The exclusive
76
operators should take training course prepared by the crane maker and improve their operating skill to
achieve high working efficiency without any accidental damages.
e. Required number of cranes
In case of common use among many yards, the required number is calculated from how many ships
are broken with the carne per year and how many working days with the crane are taken for a ship.
Average number of ships in past eight years is 125 as mentioned above, and necessary working days
are supposed to be 25days for a ship.
According to the hearing from several yards, working terms for breaking accommodation is 10 to15
days and dismantling engine room is 15 to 20 days provided that the preparation works, such as
cutting main parts of accommodation structure, unfixing equipment in accommodation area, and
loosening bolts/nuts of machines, removing pipes in engine room, are executed in advance, the lifting
works by the crane may be completed in approximately 25 days.
On the assumption that the 25 days per ship are taken for 125 ships per year, the necessary number
of the cranes is calculated to ten (10) cranes according to Table3-3. However, actual introduced
number would be reduced to five (5) cranes by half of ten, because all yards may not always use the
crane with additional expense of the rental fee and some yards might hesitate to apply the new
procedure by using the crane.
Table 3-10 Calculation for required number of Large Crawler Crane
Annual ships No. a 125

Crane working days per ship b 25
Total crane working days per year c=axb 3,125
Actual working days of yard per year d 300
except Sunday/Holiday
Required number of cranes c/d 10.4
The 20t trailer (with a towing tractor) is also required five (5), which is used together with the crane,
provided that the crane is transported every 25 days from plot to plot (the transportation can be done
in just one day), total transportation frequency for 5 cranes is 60 times per year, which means 60days
per year, <(300/25) x5=60 >.
So, one (1) Long Trailer (with a head truck) is enough for transportation service.
f. Contribution to streamline the working procedures
The cranes may contribute to reduce the working hours in following procedures;
• Collecting equipment and furniture in accommodation
• Dismantling machines (particularly, heavy machines like diesel generator) in engine room.
• Dragging ship’s hull body by winches due to reducing weight in aft part of ship
• Omitting cleaning work for the blocks which are dropped into the inter tidal zone (if the blocks
are dirty)
In total, 3-4 days may be streamlined due to above items.

In consideration of the merits as follows;
• No risk of polluting the inter tidal zone due to no block to be dropped down,
• Improving safety when heavy machines/equipment are removed,
• Receiving cash earlier due to collecting saleable/valuable machines and equipment in early
stage,
77
• The crane may be highly appreciated by the recyclers.

As European side especially is much concerned that the beaching method in India has a risk to
pollute the inter-tidal zone when blocks drop down, the recyclers who aim to receive more ships from
European ship owners want to avoid the risk. The crane will contribute to make a merit in business.
g. Turning a corner of the long trailer at the entrance of a yard
There are entrance gates of the yards along the service road of which width is 14m (one way 7mx2).
The gate is positioned about 4.5m back from of the road, and the width of gate is about 6m (in the
case of plot No.30). The central reservation of the road is not set in front of the gates. (The gate size
and gate position to the road are almost same for all yards. And particularly there is no central
reservation along the north and south end portion of the road)
On these conditions, there is no problem for the long trailer to turn the corner at the gate and enter
into the yard.
v. Beach Cleaner
a. Specification of the beach cleaner

• A usual wheel loader on the market should be utilized and an attached bucket is specially
ordered. While the wheel loader runs in the inter-tidal zone, the bucket sweeps on the surface
of the beach.
• The wheel loader of which bucket capacity is about 2 ㎥ and engine power is 120-130 HP
should be chosen. The bucket is specially ordered with modification from the original shape
(length extended to abt.2.5m, but width 2.5m and height 1.3m as same as original one).
• The bucket has a guide plate on the bottom which smoothly scoops the trash and debris, and
storage pocket for them in the rear. The bottom is grid structure through which sand drop
down and only trash and debris are retained. The bottom of the storage pocket can be open
with hinge (by hand) to discharge the trash and debris gathered in full.
• Additionally an electric magnet in the shape of rectangular box (length abt.2.5m as same as
width of the bucket, width abt.40cm, height abt.15cm) is fitted on the back of the bucket. The
magnet can catch trash of iron material (small cutting pieces, melting chips, steel wire, etc.)
• The electric magnet can be switched to ON /OFF position by a remote switch in the operator
cabin.
• If necessary, an electric generator should be installed additionally in the wheel loader to supply
the electric power to the magnet.
• The material of the bucket should be anti-wearing and anti-corrosion against sand beach.
b. Operational procedures
• During low tide, the beach cleaner sweeps all over the inter-tidal zone continuously while the
wheel loader moves ahead and the bucket scoops trash and debris with sand.
• After a certain amount of trash and debris with sand is scooped, once the wheel loader stops,
the bucket is raised up and inclined backward to shift the trash and debris into the storage
pocket and simultaneously to drop the sand.
• The electric magnet catches iron trash, traveling horizontally on the surface of beach with a
small clearance.
78
• When the storage pocket is full with the trash and debris, the bottom plate is opened just above
a trash box and all trash drops down into the box. At the same time, the iron material trash
drops down by switching the magnet off.
• The beach cleaner is basically operated by one operator, however, another worker may be
arranged, if necessary, to help the smooth flow of trash into the bucket.
c. Common share scheme
The beach cleaners should be treated by the same scheme as the big crane for the rental and
maintenance scheme. It is preferable to outsource them to the same private company. However, the
operator (and the helper) is arranged by respective yards.
d. Required Number
Presently the respective yards carry out cleaning their inter-tidal zone in way of picking up the
trash and debris by the hands of several workers who are employed by them. It is recommended to
use the cleaning beach cleaner to clean thoroughly the inter-tidal zone in front of their yards with
only one or two workers in shorter time.
• The thorough cleaning works with the beach cleaner should be carried out for the interval from
finishing breaking a ship to beaching a next ship
• On the assumption that the inter-tidal zone area in width 50m and up to 500m from the shore is
affected under works of breaking a ship, required number is calculated to be three (3) beach
cleaners according to Table 3-11.
< Machine outline> < Bucket in dedail>
79
Figure 3-24 Beach Cleaning Machine
Table 3-11 Calculation for required number of Beach Cleaning Machine

Cleaning area for one ship a 25,000 ㎡
=50ｍwidthｘ500ｍ offshore
Cleaning capacity＝2km/hrｘ2.5ｍ b 5,000 ㎡／/hr
Average traveling speed × bucket width
Required times c=a/b 5hrs（remark 1)
Annual required working days for 313 ships d 313 days
(remark 2)
Annual available working days (remark 3) e 150days
Required number d/e
2.1
→3 beach cleaners
(remark 1) the thorough cleaning operation including preparation works can be
performed in one day
(remark 2) average annual ship number is 313 broken in past 8 years（maximum 415
ships in 2011）
(remark 3) although annual working days of a yard is 300 days (except Sunday/
Holiday), actual possible working days are reduced to 150days by half, because the
beach cleaner can be used only during low tide in working hour (9:00～17:00）
The required number would be 3 beach cleaners with some allowance for calculation result 2.1 in
case the breaking ships increase in future.
3.4. IMPROVEMENT OF ENVIRONMENT FACILITY AND TSDF

3.4.1. STUDY OF TREATMENT METHOD OF HAZARDOUS SUBSTANCES
(1) Estimation of the Wastes to be Treated

In Alang / Sosiya, in accordance with the Ship Breaking Code (2013), ship to be recycled is started
beaching process after the documents review by GMB, GPCB, Custom Department and anchoring
permission is given, inspection by GMB, GPCB, Custom Department & AERB, followed by paying
import duties then title of the ship will be transferred to recycler. These standard processes are shown in
Figure 3-24.
The process of removal and handling of hazardous substances in this process is mainly following 3
process.
Table 3-12 Removal and Handling Process Hazardous Substances
Process Substances Process in the Figure

1: Removal of Hazardous Stores not in the ship structure such as gas ①
before beaching bottle, paints, chemicals, etc.
2: Identification and removal of Hazardous in hull structure and equipment ③ ⑦,⑧
Hazardous after beaching including asbestos, toxic paint, PCB, ODS,
80
3: Temporally storage and oils. ⑩

transportation of Hazardous to
TSDF
Figure 3-25 Process of recycle
Source: Ship Breaking Industry at Alang / Sosiya, May 27, 2015 by GMB
As hazardous waste discharged in the process of recycling of the ships, there are fuel oil remaining in
the ship itself, oil water such as bilge, asbestos, glass wool etc., as solid wastes. The types,
characteristics of these are shown in the following table.
Table 3-13 Wastes to be treated
Type of waste Characteristics Treat/Process

Waste Oil Residual oil in FO tank Good waste oil is corrected ×
and sold.
Slop Oil Slop oils reside in the Supernatant(quality oil) of ○
Slop oil tank of tanker slop oil tank after tank
Liquid cleaning will be collected
and sold.
Waste oil in lower part (high
density oily water) is
remained.
Oily Sludge Silted oily sludge on the Oily sludge contains crude ○
tank bottom contains oil may cause of fire and
rust, other impurities. explosion
81
Type of waste Characteristics Treat/Process

Bilge Water Waste water contains It maybe emulsified with ○
(Bilge wastes oil) L.O. and F.O. in the detergent. It is generated
bottom of engine room while voyage and at port.
Ballast Water Sea Water (Mud and it Ballast water is obliged to ×
may contain marine exchange at high sea.
growth)
Tank Cleaning Water Cleaning water of cargo Cargo oil tank will be ○
oil tank of tanker and cleaned at offshore and
Bunker oil (FO bunker oil tank will be
cleaned after beaching by
High pressure MDS and
collected
Cleaning water for Waste water with red Cleaned and collected ○
bottom and machine rust accumulated on the
room bottom
Rain Water Rain water on the Rain water will be collected ○
recycle yard may by drain and separated at
contaminated by oil etc. EFT and water will be
discharged to sea.
Separated oil will be
collected and incinerated.
Oily wastes Oily wastes in the To be incinerated ○
Solid engine room and used
Wates for recycling work.
Other oily wastes Waste painting, grease, Recyclable wastes will be ○
Chemicals LO, and other residuals collected. Others will be
on board ship wasted to TSDF
Asbestos Used for heat insulation, To be landfilled ○
etc.
Garbage, Sewage Wastes generated until To be collected and solid ○
last voyage wastes will be incinerated.
Sewage will be treated.
(2) Estimation of Wastes Volume Generated

In general, volume of oily wastes generated from ship is estimated as follows.
Table 3-14 Volume of oily wastes generated from ship

Oily Waste Generated ratio of wastes
Bilge With 1,000 GT ship, abt. 100 tons of bilge will be Bulge water
generated in a year Oil content abt. 1~2%
Collect Oil
Oil content abt. 50%
Tank Cleaning Water With 100,000 DWT tanker, about 12.5% of DWT will Oil content abt. 2.4%
be generated. In case of ship recycling less volume is
expected.
Slop Oil With 100,000 DWT tanker, about 2% of DWT will be Oil content abt. 15%
generated.
82
Oil Sludge 0.1 % of DWT depend on type of tanker and cargo Calorie
4,000～5,000kcal/kg
In this study, type and volume of wastes generated though the recycling process is investigated with
two (2) types of ships one of bulk carrier and the other a container ship and the results of the study is
shown on the table below. Due to the fact that the number of subjects to be surveyed was limited, the
number of days after the beaching and the state of cleaning work were different, the total amount of each
waste is different but it shows the residual amount of hazardous waste in the ship for processing.
In the table, the asbestos of the bulk carrier is the total amount of gaskets, packings, etc., that may
contain asbestos. Residual fuel oil, lubricating oil are sold as they are and cannot be processed.
Table 3-15 Type and volume of wastes generated though the recycling process
no Type Type of Approx. Quantity Disposal Mode

. waste B.C. Panamax Container
1 Asbestos HW 538 kg - kg Solidification/Incineration
2 Glass wool/Mineral wool HW 8,280 kg 10,650 kg Secured Landfill Site
3 PUF/Poly styrene 220 kg - kg Incineration

4 Waste oil 21,000 L 400 L Incineration
Used oil 30,000 L Sale for recycle
5 Oily Sludge 650 kg 32,000 L Incineration
6 Plastics HW 70 kg 200 kg Incineration
7 Paint Chips 2,972 kg 4,480 kg Incineration
8 Iron scale NHW - - Sale for recycle
9 Fiber glass/Rexene NHW - - Sale for recycle
10 Food Waste NHW 75 kg 250 kg Secured Landfill Site
11 Card boards & Packages NHW - - Sale for recycle
12 Glass NHW - - Sale for recycle
13 Bilge Water HW 5,500 L 50 kL Bilge Water Treatment Plant
14 Rubber NHW 200 kg - kg Sale for recycle
15 Lubricating Oil HW 1,008 L 92,000 L Authorized Recycler
16 Grease HW 345 L 300 kg Authorized Recycler
17 Paints HW 200 L 160 L Authorized Recycler
18 H.F.O. HW 2,000 L 407 ｋL Authorized Recycler
19 Engine Oil HW 110 L 5,000 L Authorized Recycler
20 Slop Oil HW 4 L 200 L Authorized Recycler
21 Hydraulic Oil HW 400 L 11,300 L Authorized Recycler
22 Cylinder Oil HW 1,600 L 60 L Authorized Recycler
23 Oily-Chemical HW 50 kg 150 kg Incineration
contaminated rags
Ship recycling volume in Alang / Sosiya is 2,872 vessels and 25 million LDT in the past 10 years as
shown in the table below. An average of 287 ships and 2.5 million LDT a year, the average LDT per
vessel was 8,631 tons. The maximum recycling amount in the past is 415 ships and 3.85 million LDT in
2012.
Also, in the current situation, it takes about 3 months to 4 months to recycle a single ship, so it will
become same number as 390 ships in 2012 if recycle 3 ships / yard in a year with full number of yards of
about 130. In 2012, a large number of ships after the Lehman shock were recycled.
83
Table 3-16 Ship Recycle Volume
year No. of Ship LDT recycled

recycled
2006-07 136 760,800
2007-08 136 643,437
2008-09 264 1,944,162
2009-10 348 2,937,802
2010-11 357 2,816,236
2011-12 415 3,847,000
2012-13 394 3,847,566
2013-14 298 3,059,891
2014-15 275 2,490,152
2015-16 249 2,431,752
Total 2,872 24,778,798
Based on this statistics, it is assumed that about 300 vessels are recycled annually in this project and
estimated the hazardous waste volume of the ship using the average ship LDT of about 8000 LDT. Table
3-18 shows the types and amounts of waste received in 2015 by TSDF for reference.
Table 3-17 Wastes received at TSDF in 2015-2016 (unit: tons)
No. Type of Wastes Volume Classification of

Treatment
1 Asbestos 22.715 S/S
2 Bilge Water 1,600.395 W/W
3 Documents 34.270 INC
4 Ceramics 10.030 SLF
5 Polluted Sand 106.000 INC
6 Cooling Powder 106.320 S/S
7 Garbage 34.050 SLF
8 Glass 6.505 SLF
9 Glass Wool 2362.790 S/S
10 Incinerated Ash 7.825 S/S
11 Oily Sludge 1.220 INC
12 Oily Waste 42.885 INC
13 Oily Water 1.970 W/W
14 Paint and Coating 24.520 INC
15 Puff 41.955 INC
16 PVC and Plastic waste 1.230 INC
17 Residuals 516.890 INC
18 Treated Residuals 7.950 INC
19 Rubber Packing, Insulation 27.100 INC
20 Clay 4.420 INC
21 Thermocol 35.350 INC
From above record, annual volume of wastes is classified by the process as follows.
W/W Waste Water Treatment 1,602.275 t/year

S/S Stabilization & Solidification 2,499.650 t/year
84
SLF Secured Landfill 50.585 t/year

INC Incinerable Treatment 843.800 t/year
Total 4,996.310 t/year
These wastes are currently treated in TSDF as shown on the Figure 3-26. Present capacity of the
environment facility of TSDF is shown on the Table 3-19.
Asbestos Landfill
Incombustible Glass
Wool
Wood, Rubber Ash
5t/d
Bilge, Oily Water Effluent Treat.

Treated Water Watering
30t/d
Collect Oil Sludge

Sun dry
Incinerate
Figure 3-26 Treatment Flow of Environment Facility in TSDF
Table 3-18 Capacity of Environment Facility of TSDF
No. Facility Capacity Specifications

１• Incinerator • 5t/d • 1t/h • Fixed bed Type
2• Effluent Treatment Plant• 30m /d •
3
4m /h 3
DAF＋Bio treatment
3• Landfill • 100,000m 3
• Sanitary Landfills
(3) Treatment Plan of Hazardous Wastes

Safe extraction and disposal of a large amount of waste oil, oil sludge, waste liquid etc. are required at
ship recycling by the beaching method in Alang / Sosiya. The plan is an improvement and construction
for environmentally compatible facilities that properly treat the wastes generated in the process of ship
recycling.
In the past, the waste generated during the tanker repair work has been treated in Japan. This plan is
applied to the treatment of the waste generated in the process of ship recycling. Also, this plan aims at
to treat ship recycling waste, but it is also planned to respond adequately to the proper treatment of other
industrial waste.
In addition, as shown in Figure 3-23, the waste disposal process begins at the time when the ship is
anchored offshore, so not only the onshore waste facility, but also the cargo oil washing process of the
crude oil tanker and the collecting oil sludge, waste oil etc., from ships will be planned.
1) Structure of Wastes Treatment Plant
Proposed planned plant consists four (4) parts.
85
Table 3-19 Planned Wastes Treatment Plant
Process of Hazardous Wastes Treatment Wastes Treatment Plant

1. Before Beaching, at Anchoring : Tank cleaning and waste oil collecting plant
Cargo oil tank cleaning and gas free Transfer oily water after cleaning tanks and sludge
works of Crude oil tanker at offshore at offshore to onshore.
2. After Beaching : Tank cleaning plant by high pressure water.
FO tank cleaning and gas free before With mobile high pressure cleaning system, work
cutting work inside the yard.
3. While Recycling : Oily Water treatment plant
Treatment of liquid wastes such as bilge, By Oil collecting tank, Oily water separator, and
waste oil, oily water Sludge treatment plant, waste water will be
treated.
Treatment of solid wastes such as PCB : Incineration Plant
contained materials, ODS, etc. Detoxifying of hazardous substances by high
temperature incinerator
4. Final Treatment : Compressor (Bailer)
Landfill of solid wastes Reduce landfill wastes
Since ships to be recycled is required to remove hazardous material before anchoring and beaching
permission is issued by the Ship Breaking Code 2013, ships generally collect and sell residual oils to
mitigate their volume and then beached. Ships are normally beached by their own power, FO & LO
required for propulsion and other waste oils remain after the beaching.
On the other hand, Crude Oil Tanker as “Special Concerned Ship” under the Ship Breaking Code, is
required to have Safety for Hot Work certificate before anchoring and beaching. Therefore, Crude oil
tanker (except product tanker) was not recycled in the last couple of years in Alang.
With this backdrop, after the beaching, FO tanks of ships are cut after gas freeing is confirmed and
residual oil is pumped out and then cleaned with saw dust or sand manually. Although the FO tanks are
cleaned, sludge on the tank wall cannot be wiped out perfectly, thus oil contained in sludge may possibly
be distilled by washing sea water when the cut block is sunk at high tide.
Under the circumstances, more severe cleaning process is introduced before cutting is started and the
following measure is investigated.
2) Flow of the wastes and target of the improvement of TSDF
Figure 3-24 shows the flow of waste treatment and the waste disposal facility to be rehabilitated in
TSDF.
86
Ship Recycle Yard 1 Improvement of TSDF

Objectives : Elongation of life of landfill site
Reduction of environmental burden
Improvement of economy
MDS
2
A. High Temp. Incinerator
B. Oily Water/Sludge treatment plant
C. Waste water treatment plant
D. Waste oil colleting plant
Tanker Cleaning E. Bailer
Oil collect
barge 3
Figure 3-27 Comprehensive plan of wastes treatment process
(4) Volume of Wastes Generated (Planned Volume)

The volume of generated oily water is calculated as 10 vessels / year for offshore cleaning of crude oil
tankers, and 360 vessels / year for washing by mobile high-pressure cleaning equipment for all vessels
as follows. Also, due to the improvement of the yard with concrete flooring then drain recovery will be
carried out, and illegal dumping of bilge etc. will be monitored more severely when the project is carried
out, presumed that the amount of oily water generated from the recycle yard will be increased in the
recycling process the volume of waste generated is planned as follows.
1) Generated from Tanker cleaning
① Oily water
• Number of cleaning tanker 10 ship/year

• Oily wastewater (Low concentration) 0 kL/ship
(Processing on the ocean using a built-in cleaning vessel (Barge) equipment)
• Oily wastewater (High concentration) 1,000 kL/tanker
• Annual generated volume 10,000 kL/year (estimate)
• Oil contents of oily water 10 %
② Oil Sludge
• Number of cleaning tanker 10 ship/year

• Oil sludge volume 200 m3/tanker (estimate)
• Annual generated volume 2,000 m3/year (estimate)
• Oil contents of oil sludge 5%
2) Generated from MDS
① Base Conditions
• Number of breaking ship 360 ship/year

• Cleaning water volume 50 kL /time/ship
• Oil contents of cleaning water 10 %
• Oil sludge contents of cleaning water 2%
Wastes volume form oil separator installed on MDS (Consider recycling use of cleaning water)
• Annual generated volume oily water 15,000 kL/year (estimate)
87
• High concentration oily water 4,500 kL/year (estimate)

• Oil Sludge 1,000 m3/year (estimate)
3) Wastes volume generated from ship recycle yard
① Oily wastewater
• Average LDT of breaking ship 8,000 T/ship

• Generated volume 0.34 % of LDT per Ship
• Volume of Oily wastewater 9,400 kL/year
• Oil content of wastewater 3%
② Incinerable waste
• Average LDT of breaking ship 8,000 T/ship

• Generated volume 0.20 % of LDT per Ship
• Volume of Incinerable waste 5,700 T/year
• Amount of waste requiring 2,850 T/year
for high temperature incineration
③ Direct landfill waste (glass wool etc)
• Volume of direct landfill waste 2,500 T/year
Based on the above estimation of wastes volume capacity of Incinerator, waste water (oily water)
treatment plant is set as follows.
3.4.2. OFFSHORE AND BEACH ENVIRONMENT FACILITY PLAN
(1) Hazardous wastes treatment in offshore or at anchorage area

At anchorage area, ship owner is required to establish gas free condition for cargo oil tanks for tankers
to have an anchoring permission and other practical inspection will be carried out onboard. Ship owner
can clean the cargo oil tanks before entering sea of India. However, in this project, cargo oil tank
cleaning and discharge of slop and sludge to offshore tank cleaning barge exclusively for tanker prior to
anchoring.
With this offshore tank cleaning barge, cargo oil tank of Crude oil tanker will be cleaned at offshore
and accept about 10 VLCCs per year by securing the safety.
VLCC is currently recycled mainly in Bangladesh, Pakistan. With recycling results in 2013, there were
64 vessels including 39 crude oil tankers and 25 crude oil and product tankers. On the other hand, there
were 33 vessels in 2016. In November 2016, a catastrophic accident occurred due to a tanker fire in
Pakistan and due to this it is supposed that regulations such as tank washing and gas-free will be applied
in the future, Although it is expected that most of VLCCs can be recycled in India and Bangladesh, we
plan to accept VLCC recycling demand of about 10 vessels in 3 countries for the time being, and this
project also planned to accept ten (10) vessels a year.
The flow of wastewater treatment by offshore tank cleaning barge is as follows.
88
Waste W. Tank Clean Tanker

To TSDF High Oil Tank Barge
Water 1,000m3
Oily Sludge
Low Oily
Water
Waste water
To TSDF Oily Sludge Treated Release
Treat Water
5m3/h
Figure 3-28 Process Flow of the Tank Cleaning Barge
1) Process of Cargo oil tank cleaning of Crude oil tanker
Process of the cargo oil tank cleaning of crude oil tanker is as follows.
No.4 No.3 No.2 No.1

４３
Sludge before cleaning

: tank to be cleaned
: slop tank
Figure 3-29 Cleaning process of Crude oil tanker
1) Preparation before cleaning
① Sea water is filled up to slop tank (one side a) with about 1,000kL
② Heat up the sea water up to 60 deg. C utilizing ship’s boiler
③ Clean the tank with Butterworth machine (installed onboard) and portable machines as
necessary
Start the cleaning from foreside tank and lastly slop tank.
89
Fixed Buterworth
Cleaning ﾊﾞﾀﾜｰｽﾏｼﾝ
洗浄 Machine
（固定式）
Ship’s Butterworth machine

Capacity : 70~80tons/hr
Range : 10m
Pressure : 7～8 kg/ cm2 Portable
Buterworth
ﾊﾞﾀﾜｰｽﾏｼﾝ
Machine
（ﾎﾟｰﾀﾌﾞﾙ）
Portable machine 投入ﾏﾝﾎｰﾙ
Capacity : 30ton/hr
Range : 10m
Pressure :8kg/cm2
2) Cargo tank cleaning works (in case of Handy size tanker)
Cleaning order Fixed Machine Capacity (No.) Cleaning time Cleaning water
No.1(P&S) 6（3/one side） 60～70 kL／H 2～3hrs Abt. 1,260 kL
Total 15hrs Abt.6,300 kL
Tank cleaning water will be accumulated to slop tank (side B) temporally. Water other than the
supernatant (oil）will be circulated to other side of slop tank (side A) and reused for the tank cleaning
water.
Therefore, waste oily water volume needed to transfer and treat at the shore waste water treatment plant
is as follows.
• Tank cleaning water (for Cargo oil tank) : abt. 1,000kL
• Slop oil tank (oils) : 100=300kL
3) Slop Tank cleaning
Cleaning of Slop tank(side B) accumulated tank cleaning water.
Slop tank (one side) No. of Machine Capacity, No. Cleaning time Clean water
2/ one side 60～70 kL／H 2 hrs. Abt. 280L0 kL
• Tank cleaning water (for slop tank) :280kL
4) Sludge removal works
90
Inert gas and fresh air purging

Tanks which can be safely enter will be cleaned by order.
• Worker : 27 workers (9 workers x 3days)
(specialized entity)
• Sludge volume : 10~30 tons
Offshore tank cleaning barge will be berthed along the tanker and transfer waste water, sludge. Waste
oils transferred to the offshore tank cleaning barge at offshore will be transferred to the shore waste oil
treatment facility and tanks in the TSDF.
(2) Specifications of Offshore Tank Cleaning Barge

1) Offshore tank cleaning barge
Offshore tank cleaning barge will be introduced to collect oily water and sludge which is generated as
waste oily water for the cleaning of residual sludge in the cargo oil tank of crude oil tanker and oily
water and sludge in the slop tank. The jetty to moor the barge will be used. In order to have Gas Free
for Hot Work which is the condition of crude oil tanker for anchoring, offshore cargo oil cleaning and
sludge removal work by the specific company. Also, the barge will be provided oily water separator is
able to discharge water below the regulatory level of oil contents.
The basic concept and outline of the offshore tank cleaning barge is as follows. Basically its function
is the transfer of cleaning water and sludge to the offshore tank cleaning barge after washing with high
pressure water at the cargo oil tank.
Table 3-20 Basic Concept of the Oil Colleting Barge
Function Storage of collected waste oily water (collecting oil tank 250 m3x4)
Oily water separator
Regulation Ship safety laws and relative regulations
Regulations of transport and storage of dangerous goods
Ship Certificate Non self propelled, bulk oil (dangerous goods) carrier
Gross ton Abt. GT
Voyage area Coastal
Hull structure Small steel ship structure regulation (classNK)
Structural regulation for small oil tanker (A type)
NK（(steel barge) Equipment Type 4 classified
Max. complement Crew 0 p. Passenger 0 p, others 0 p.
Others Anchoring
2) Maneuvering
Basically, the offshore tank cleaning barge is to be towed by the multipurpose work boat or a working
boat as non-self-propulsion.
If long distance operation is required, weather must be taken into consideration. In Japan's petroleum
base which owns the same type of barge, as the operational criteria of holding the barge to ship side,
the effective wave height is set to 0.7 m and the wind speed is set to 8 m / s or less. The wind waves
have not a big influence, but in the case of swells, the offshore tank cleaning barge and the
multipurpose work boat collide with each other. Also, it may roll each other and make intense contact
91
with each other when stopping rather than they are voyaging. Therefore, it is required to provide
operation criteria and always remind to operate the barge safely.
Table 3-21 Specifications of Offshore Tank Cleaning Barge
Hull Shape Tank Barge

Hull Structure As per Steel ship hull structure, Small tank hull structure (Type
A)regulation
Gross Ton Abt. 160 t
Loa x Breadth x Depth Abt. 50 m × 13 m ×4.0 m
Draft Abt. 2.5 m
Propulsion Self propulsion (onboard engine with propeller)
Anchor winch Installed
Store Provided
Complement n.a.
Rooms n.a.
Firefighting Equipment n.a.
Crane n.a.
Diving Equipment n.a.
Oil dispersant n.a.
Oil Boom Can be installed
Oil colleting equipment n.a.
Oil collecting tank Abt. 250 m3×4
Oil transfer pump Yes
Ballast tank Fore tank abt. 32.8 m3×2 Aft Tank. Abt 31.6 m3×2
Bollard 12 tons bollard, 198tons cross bid
92
Figure 3-30 Oil Collection Barge
93
(3) Hazardous waste treatment after the beaching

After the beaching, ship recycler shall obtain gas free for hot work certificate and remove wastes and
hazardous materials as per regulated and then “Free from Contaminants Certificate” from GPCB. After
this “Cutting Permission” is issued by GMB, then, removed wastes and hazardous materials shall be
transferred to TSDF and treated as appropriate.
For the removal process of hazardous material at beaching stage, in order to attain the issue to protect
offshore and beach pollution, it is important to protect oil spill from tanks while cutting works at beach
and intertidal zone.
In order to have a Cutting Permission, bunker oil (FO) tanks of ships have been cleaned with saw dust
or sand manually. Although the FO tanks are cleaned, sludge on the tank wall cannot be wiped out
perfectly, thus oil contained in sludge may possibly be distilled by washing sea water when the cut block
is sunk at high tide.
Under the circumstances, more severe cleaning process is introduced before cutting is started and
introduction of Mobile High Pressure Cleaning Unit for cleaning bunker oil (FO) tanks is planned.
1) Mobile Decontamination System
Mobile decontamination system is the system to mechanically and effectively collect and clean
these tanks. It cleans inside of the tank with high pressure water and collect washed water and
residual oil by the vacuum unit. The recovered washing water and residual oil are separated in oil
and water by a centrifugal separator. The separated water is reused as washing water, and the oily
water and sludge are finally processed with TSDF. Process is explained as follows.
Oily water Sep Water Tank Waste water

2m3/h×1 5m3 Suction
5m3/h
Waste Water Waste Cln

To TSDF Tank Water
20m3×2 Collect Cleaning Water
Water
Oily waste Cleaning Cleaning FO Tank, others

To TSDF water tank Device Water
2m3 1m3/h×5
Oily Sludge
To TSDF 0.2m3×5
Figure 3-31 Flow of the Mobile Decontamination System
By the introduction of the Mobile Decontamination System, the following advantages can be
expected compared with the conventional cleaning method.
94
Table 3-22 Comparison of MDS and Conventional Method
Item High Pressure water clean (MDS) Saw dust, / Oil sand clean
Required time 4~7days 6 – 14days
Oil collection Fuel oil and other oils can be Oily sand and saw dust contained oils and
collected and sold. sludge cannot be reused . To be treated at
TSDF which required cost.
Safety No fire will be used since water In case cleaning is not enough, it may
pressure cleaning system possibly ignited
2) Specification s of Mobile Decontamination System : MDS
a. Planned number to be cleaned : 360 ships/ year

b. *1
Required cleaning day : 7 days/ ship
c. Possible working day / year : 52 times /year /MDS
d. Number to be introduced : 5 sets
e. Possible number of ships to be cleaned : 260 ships / year
*1 including preparation
3) Detail of the Mobile Decontamination System
For the working tools followings are supplied.

• Personal Protective Equipment for workers (PPE)
• Gas detecor
• Berathing apparatus
• Others
High Pressure Cleaning Device

• Water / Air mixed jet cleaning device
• Air pressure 0.6~0.7Mpa
• Discharge water vol. & pressure 16L/min 8Mpa
• Pump 20L/min
95
Centrifugal Separator
• Oily water after cleaned is separated to water and oil
by centrifugal separator installed to MDS.
• For the emalsion oil, heating device will be
included.
Pressurized water supply device.

• By air compressor, high presuure water tank is
provided.
Figure 3-32 Detailed Image of Mobile Decontamination System
4) Operation and Maintenance of Dynamic Oil Cleaning System
Five (5) units of Mobile Decontamination System will be introduced and it is planned to outsource
its operation to private enterprises selected by GMB.
This cleaning operation will be carried out in a land side and it is distinguished from a sea
cleaning operation. Expected private operators are among the ship recyclers, but also some
companies that conduct the waste oil recovery business as described in Chapter 2. These business
operators have oil recovery pumps, explosion-proof equipment, protective clothing for workers,
etc., and have experience in washing tasks inside the ships, so there is no issues in carrying out the
cleaning work.
In maintaining of the equipment, it is important to manage a centrifugal separator that performs

wastewater treatment with a mixture of oil and water, especially after washing. In the case of using
an emulsifier in washing, it may be difficult to properly separate oil and water in the centrifugal
separator, so it is necessary to pay attention to handling the centrifugal separator and bowl inside.
96
Therefore, guidance from suppliers with regard to necessary attention to separable oil and
maintenance of centrifugal separator is required. For other high pressure pumps also need to explain
such as exchange of consumable parts, replacement to spare parts etc.
3.4.3. ENVIRONMENT FACILITY PLAN FOR HAZARDOUS MATERIAL TREATMENT ON

LAND
(1) Improvement of TSDF

In order to sustain its operate of ship recycling industry in Alang / Sosiya, it is important to use landfill
site of TSDF where the hazardous and wastes are process in a safe manner and in a long term. For this
purpose, following measures are studied.
Against the capacity of 70,000m3 of Cell-4 for hazardous material landfill, it is estimated that from the
start of its operation in May 2013 up to the end of 2016, 22,000MT are landfilled and the remaining
capacity is 48,000MT. Assumed that 7,000 MT of wastes which is correspond to about 0.2% of LDT
will be processed, the cell will become full before 7 years from now. Considered that about 62% of
wastes are Glass Wool, compression of this volume can be expected for elongation of the usage of
landfill site.
Table 3-23 Record of Wastes received TSDF
Year No. of LDT Wastes

Ship recycled MT Kg /LDT %/LDT
recycled
2006-07 136 760,800 1,032.861 1.357 0.13%
2007-08 136 643,437 2,017.025 3.134 0.31%
2008-09 264 1,944,162 5,027.841 2.586 0.25 %
2009-10 348 2,937,802 5,418.040 1.844 0.18 %
2010-11 357 2,816,236 8,215.310 2.917 0.29 %
2011-12 415 3,847,000 8,318.979 2.162 0.22 %
2012-13 394 3,847,566 10,555.355 2.743 0.27 %
2013-14 298 3,059,891 7,505.890 2.45 0.24%
2014-15 275 2,490,152 7,279.395 2.920 0.29%
2015-16 249 2,431,752 4,996.310 2.05 0.20%
2016-17 30 298,838 564.595 1.88 0.18%
(Ap-16)
1) Reduce Volume of wastes not for Incineration such as Glass Wool
As mentioned above, by compressing wastes with low specific gravity with volume, elongation of
its life of landfill site is planned. By using Bailer, it can be simply compress to 1/10 of volume thus
10 times of capacity at landfill site may be expected. Exclusively for glass wool, landfill site may
be expected to use another years as follows.
Assumed that about 62% =4,340MT out of 7,000 MT / year is glass wool. Rest of 38% = 2,600
MT, by the compression of glass wool annual volume of wastes can be reduced to 3,094 MT thus
another 15.5 years of operation of landfill site is expected.
2) Treatment of wastes not suitable for landfill
a. Since Oily sludge is not stabilized condition, it is not suitable for landfill. It may
incinerate, however oily sludge is not high calorie and required pre –treatment for
filtering particulars, it is recommended to recover waste oil as much as possible and then
97
stabilized (remove water, oil and make it minimum volume of sludge) by introduction of
oil sludge treatment and then land filled.
b. Incombassibles representing such as asbestos cannot be incinerated with incinerator with

normal temperature and it shall be landfilled.
(2) Bailer
In order to reduce the volume of waste to be landfilled above, a compressed packing machine (Baler)
will be introduced. The amount of waste to be landfilled is 2500 tons per year as follows, but since glass
wool is the main material and its specific gravity is light, the capacity is increased.
• Planned volume 2,500 tons /year
• Average specific gravity 0.05 tons /m3
• Volume to be dealt 50,000 m3/ year
1) Specifications of Bailer
*1
a. Volume of glass wool ： 50,000 m3/ year
*2
b. Running hour ： 8 h/day
c. Running day ： 240 d/y
d. Required capacity ： 26.0 m3/h
e. Safe margin ： 20 %
f. Say ： 31.3 m3/h
*3
g. Selected capacity ： 65.0 m3/h
h. Number to be introduced ： 2 Sets (100% backup)
Remarks
*1 As a glass wool itself, the specific gravity is 0.02 t / m 3, but it is supposed to be 0.05 t / m 3
considering that it is bagged at the time of shipping from the yard. (From reference values of
similar cases in Japan)
*2 Considering that the input work becomes manual work.
*3 Selected model capacity is selected from the standard capacity table of hydraulic jumbo press
machine (standard capacity 65 m 3 / h).
98
Figure 3-33 Bailer for general wastes
(3) Small High Temperature Incinerator

1) Planning of Small high Temperature Incinerator
For incineration of waste, incineration treatment is indispensable to reliably prevent environmental

contamination by oil based waste while preventing easy disposal of landfill waste. At the final
disposal site, there is a possibility of generating methane gas CH4 due to anaerobic fermentation of
landfilled organic waste, and by appropriately incinerating organic wastes such as oil sludge, it can
be suppressed generation of methane gas which is 21 times higher greenhouse effect coefficient
than carbon dioxide.
In studying the incineration process, the use of waste heat as a measure to control emission of
global warming gas is actively considered. The process is planned ad it is able to recover heat
effectively and to use hot water as technically possible.
The incineration of waste should adopt a combustion method that matches the waste properties,
but as a model that can incinerate a wide variety of waste as far as is possible based on the type of
waste from the ship, small fluidized bed + water cooled stoker system is adopted.
In this small incinerator, waste including ship oil sludge is also planned as a suitable incineration
system, and the average calorific value of the incineration target including ship oil sludge is set to
about 4,000 kcal / kg. Although the waste is not limited to marine-based waste but its composition
fluctuate greatly, it can be said that it is sufficiently safe to set about 4,000 kcal / kg as the average
calorific value of oil based waste.
The incinerator of this project is planning a fluidized bed, and that can handle a wide variety of
wastes, from liquids such as waste oil and waste liquid to sludge, sludge such as oil sludge, and
even solid waste.
Waste incineration involves emission of flue gas, insufficient exhaust gas treatment will become a
cause of air pollution. The combustion gas is re-incinerated in a second chamber with a temperature
of 1,100 ° C. or more for a retention time of about 2 seconds or longer for the re-incinerate
unburned in the exhaust gas sufficiently. With this re-incineration, dioxins can be reduced and
environmental impact can be reduced. High-temperature exhaust gas is rapidly cooled by spraying
cooling water to prevent re-synthesis of dioxins. The proposed exhaust gas treatment employs a wet
type exhaust gas scrubber system.
99
Through this exhaust gas treatment, the value of the dioxin concentration in the exhaust gas
discharged from the stack becomes 0.1 ng · TEQ / m 3 N or less. The advantage of the wet exhaust
gas treatment is high removal efficiency of harmful substances in exhaust gas such as sulfur oxide,
hydrogen chloride etc.
Wet type exhaust gas treatment is effective in case crude oil containing heavy sulfur and waste oil
of heavy fuel oil are many as an oil based waste. The exhaust gas is treated with a wet electrostatic
precipitator as a final stage and then discharged to the atmosphere from the chimney. It is planned
to reuse treated water for washing water of exhaust gas scrubber and electrode of wet type electric
dust collector.
2) Incineration Capability
As a result of the survey, the amount of waste to be incinerated now is 5,700 tons / year. PCB
contains substances (including plastics) that require internal high temperature incineration are
halved.
• Planned generation volume 5,700 t / year

• High temperature incineration processing amount (50%) 2,850 t / year
• Low temperature incineration processing amount (50%) 2,850 t / year (8.0 t / d)
The low temperature incineration amount shall be corresponding with the extension of the
operation time of the existing incinerator.
3) Specifications of Small High Temperature Incinerator
In order to stably incinerate PCBs at 1400 ° C or higher and to secure an outlet temperature of
1100 ° C by a small fluidized bed furnace this incinerator is sets the furnace temperature to 1400 °
C.
In order to render the PCBs harmless, it is necessary to secure at least 2 seconds at 1200 ° C in the
relative regulations however with the design of 1200 ° C it may be lower than the calorific value of
the burned matter, therefore it is set at 1400 ° C.
The nominal capacity of this incinerator is 0.6 ton / hour as follows and the capacity at the time of
8 hours operation is 4.8 ton / day ≒ 5 ton / day. Since the amount of incinerated wastes fluctuates,
if the amount of incinerated material increases, extend the operation time to respond.
However, based on the operation of 240 days a year, it is decided that maintenance in the furnace
can be taken.
a. Planned Volume : 2,850 t/year

*1
b. Running hour : 24 hr/day
*1
c. Running day : 240 Day/year
d. Required capacity : 0.5 t/hr
e. margine : 20 %
f. Say : 0.6 t/hr
g. Capacity of selected incinerator : 1.0 t/hr
h. Number to be introduced : 1 Set (back up parts to be supplied)
Remarks
100
*1 Although, automatic operation is possible, it is planned operating hours taking into

consideration of periodical maintenance time and days.
Although only one (1) incinerator is planned, it is possible to carry out sufficient maintenance by
providing the spare parts etc., and to continue demonstrate the initial performance continuously. The
furnace needs to periodically repair refractories, and it is required to implement necessary maintenance
on the entire incineration facility systematically, and to have the necessary maintenance know-how to
this planning facility.
101
Figure 3-34 Flow of the Small High Temperature Incinerator
102
(4) Improvement of Effluent Treatment Plant (EFT)

1) Planning of Oily water separator
a. Waste oil colleting (Oily Water separation) system
Waste oil generated at the time of recycling a ship contains moisture (seawater) and sludge, and
cannot be used as it is as a fuel oil. In the waste oil recovery (oily water separation) equipment,
after waste oil is heated, water and sludge components are separated by natural sedimentation,
then the remaining moisture and sludge in the centrifugal separator are removed and finished as
recovered fuel oil. Recovered fuel oil can be sold as necessary.
The separated oil-containing waste water generated during the recovering process of the waste
oil is treated in a wastewater treatment facility and then drained as clear treated water. Oil sludge
generated during recovery process of waste oil is treated with a sludge treatment plant.
Although the proposed plan utilizes centrifugal separation as a treatment system for waste oil,
treatment, with strong emulsion waste is not suitable for centrifugation. Waste oil may be in an
emulsified state in the engine room or in case detergent is used for the tank cleaning. In such a
case, it is difficult to recover the waste oil by the centrifugal separation method. As a method of
treating waste oil, there are distillation method and filtration method other than centrifugation
method, but the centrifugal separation method is technically stable and have an advantages in
economic efficiency. In the case of waste oil with strong emulsion not suited for centrifugation,
choose incineration and recovery heat from waste oil. Also, for mineral type highly viscous oil
and heavy oil heavier than water, it is not suitable for treatment of waste oil recovery process by
centrifugal separation method but incineration.
Moisture contained in ship-based waste oil is often seawater, and corrosion of the centrifuge by
the seawater may occur. In order to effectively treat the waste oil, it is necessary to raise the
temperature of the waste oil to 90 ° C or higher, and corrosion resistance against high
temperature seawater is required for the centrifugal separator. The centrifuge is a high-speed
rotating machine with thousands rpm, and if corrosion occurs in the rotating body, accidents of
scattering of the rotating body may happen. Therefore, it is necessary to adopt a high-grade
seawater resistant stainless steel for the material of the wetted part of the centrifugal separator.
b. Waste water treatment system
Water treated with waste oil recovery system is discharged to the sea through rivers. Therefore,
a higher performance of oil-water separation is required for the waste water treatment system.
The planned treatment process is divided into "physical / chemical treatment" and "biological
treatment". The characteristics of wastewater to be treated are that the concentration of oil in the
wastewater is high and the concentration fluctuates drastically. Another feature is that the SS1 is
included in addition to the oil content, and the waste water is mainly the sea water. Due to the
characteristics of such wastewater, it is adopted the physical / chemical treatment method also in
wastewater treatment of this plan.
Physical / chemical treatment is a combined treatment method of gravity separation by specific

gravity, agglomeration pressurized float separation, filtration treatment and adsorption treatment.
Ship oil-containing waste water (slop oil, tank wash water, ballast water, bilge, etc.) is accepted
in a storage tank (separation tank). Separate the oil-containing wastewater by the tank and
separate the oil content in the wastewater naturally floating and separated on the tank top. The oil
1
SS: Suspended Solids, is a generic term for insoluble substances having a particle diameter of 2 mm or less
suspended in water.
103
separated at the top of the tank is transferred to the waste oil recovery system and recovered as
fuel oil.
Since the waste water at the bottom of the tank contains oil, it is necessary to treat it to remove
oil, and the oil containing waste water is first treated with TPI 2 Oil Separator. The TPI Oil
Separator is an apparatus for effectively floating and separating oil using the difference in
specific gravity by the inclined plate, required smaller installation spaces compared with the API3
Oil Separator, and has high oil separation performance.
Characteristics of marine oil-containing wastewater are that is often formed in oil emanation by
high-pressure washing of a tanker cargo room or chemical cleaning. Therefore, an emulsion of
oil and water is formed in the waste water of the lower aqueous layer of the slop tank where the
tank washing effluent containing the high concentration oil is stored. In addition, an oil emulsion
is formed in the bilge at the bottom of the engine room due to heavy use of detergent for engine
maintenance.
This project incorporates agglomerated pressurized floatation device into the treatment process,
since marine oil - containing wastewater forms an emulsion of oil and water. The agglomeration
pressurizing floatation device is a system in which fine oil droplets in waste water are coagulated
as a large floc by a coagulant and the floes are floated and separated together with fine air
bubbles. By treating with agglomerated pressurized floatation device, oil content in waste water
can be reduced to about 10 to 20 ppm.
In order further to clarify the wastewater, the waste water is treated with a sand filtration device.
By treating with sand filtration, it is also possible to reduce the oil concentration in the waste
water to 5 ppm or less. Regarding the discharged water after processing, measure and record the
water quality continuously. The item to be continuously measured is the oil concentration value.
The planned water quality of the discharged water is with oil content of 5 ppm or less and SS 50
ppm or less. The SS content of discharged water is not measured continuously, but it can be
judged visually. In actual operation, because it is required to manage by the oil concentration, if
the oil content is 5 ppm or less, it is considered that the SS content satisfies 50 ppm or less。
2) Capacity of Oily Water Treatment (ETP) system
a. Sludge treatment plant
• Planned generation volume 2,360 t / year (yard generation amount + tanker

generation amount)
• Purification treatment volume 2,360 t / year
b. Wastewater treatment plant
• Planned generation volume 34,700 t / year (yard + MDS + tanker generation

volume)
• Average oil content 5% (as the amount of high-oil-containing wastewater
withdrawn)
• Throughput 33,000 t / year
c. Oily water separator

• Planned generation volume 1,750 t / year (wastewater treatment receiving
separated oil-containing wastewater)
2
TPI: Tiltable Plate Interseptor
3
API: American Petroleum Institute
104
1,800 t / year (generated from MDS)

• Average oil content 40%
• Throughput 3,550 t / year
• Oil sales volume 1,420 m 3 / year
3) Specification of oil-water treatment equipment
The specifications of each device corresponding to the above processing volume are as follows.
a. Sludge treatment plant
i. Planned volume : 2,360 t/y

*1
ii. Running hour : 8 h/d
*1
iii. Operation days : 240 d/y
iv. Required capacity : 1.23 t/h
v. Margin : 20 %
vi. Say : 1.48 t/h
vii. Selected capacity : 1.0 t/h
viii. Number to be introduced : 2 Sets (100% backup)
Remarks
*1 inputs will be made mannually.
b. Waste water treatment plant

i. Planned volume : 33,000 m3/y
*1
*1
iv. Required capacity : 4.2 m3/h
v. Margin : 20 %
vi. Say : 5.0 m3/h
vii. Selected capacity : 5.0 m3/h
viii. Number to be introduced : 1 Set (spare parts to be supplied)
Remarks
*1 Because of automatic run can be made, running hour, days are set.
c. Oily water separator (oil recovery)
i. Planned volume : 3,550 m3/y

*1
*1
iv. Required capacity : 0.6 m3/h
v. Margin : 20 %
vi. Say : 0.8 m3/h
vii. Selected capacity : 1.0 m3/h
viii. Number to be introduced : 2 Sets (100% backup ）
Remarks
*1 Because of automatic run can be made, running hour, days are set.
105
Entire flow of the waste treatment system at TSDF and its material balance is shown on the figure next.
106
Incombustible Bailer Landfill

Glass Wool After
40m3/d×2
Incombustible High temp Incinerator

Asbestos Ash
5/d×1set
Wood, Rubber 5t/d Ash
Scrub Water
Bilge , Oily Water Collect Tank Effluent Plant

From yard 200m3 Low % Treated water Watering
30t/d
Sludge
High % Collect oil
Oily Water Sun dry
From MDU Low %
High % Oily Water Sep

Collect oil Sold
Oily Water 2m3/h×2
From barge
Sludge
Water Treatment
Waste Water 20t/d Collect oil Release
Sludge
From MDS Sludge
Dehydration
Sludge Waste Water
Treatmentm3/h×5 Treated Sludge
Sludge
From barge
Collect oil Sold
Figure 3-35 Entire flow of the improved waste treatment system at TSDF
107
3.4.4. MULTI PURPOSE WORK BOAT
In Alang / Sosiya, ships are necessary to anchor offshore and get necessary inspection, such as customs
inspection, before obtaining the permission of beaching. In particular, tankers are required to be gas-free
of cargoes before anchoring as vessels requiring special attention. For this reason, cleaning with a
offshore offshore tank cleaning barge explained in the previous section is performed. In this work, it is
necessary to prevent accidents such as oil spill and fire from the ship, but in the event that these
accidents happen, introduce a multipurpose work boat that can be used for recovery of spilled oil,
firefighting, rescue operation etc..
The roles and required functions of this multipurpose work boat can be roughly classified into the
following three, but in the anchorage off the coast of Alang/ Sosiya, the outline specification was
examined in consideration of the natural conditions of the monsoon season.
• Role-1: Role as disaster prevention vessel at the time of disaster
Required functions: firefighting, oil boom deployment, oil recovery, offshore tank cleaning
barge towing
• Role-2: Tanker cargo oil cleaning work and role as a work ship performing safety
management during anchorage
Required functions: Tanker's hull posture securing (tug boat function), warning ship /
communication function
• Role-3: role as a work vessel performing rescue activities

Required functions: rescue to the deck of a falling person, transportation of injured persons
to land
For multipurpose work boat, ship type and equipment that aim for safe, efficient operation and
operation, high economy, environmentally friendly vessel is studied.
(1) General Plan

Hull shape : single deck with long forecastle deck
Application : Multipurpose working vessel, oil fence extension ship, oil recovery offshore tank
cleaning barge towing etc.
Navigational area: coastal area
Qualification : Indian Classification Association (IRS), etc. (equivalent to JG 4th type ship)
a. The vessel shall have necessary equipment for as a work vessel, and sufficient stability, good
propulsion, sea worthiness and maneuverability.
b. As described above, make structures and facilities that can work safely, smoothly and
efficiently for different applications and functions.
(2) Principal Particulars

1) Deck part
a. Hull shape without stepped deck at stern deck and lowered ship side height, hull outfitting
shall be of that the visual angle of the bridge can take a viewing angle of 360 degrees as much
as possible, to improve the visibility of the whole work area and rear deck work. Other main
specifications are as follows.
b. Equipped with a rotating propulsion device and a controlable pitch propeller (CPP) to improve
maneuverability during ship maneuvering and berthing.
108
c. For the stern deck, without steps on the deck, lower the ship side to improve the workability
on the deck and the stern side
2) Water spraying capacity
The firefighting capacity required for multipurpose work boat is defined in the "Petroleum
Complex Disaster Prevention Law" and "Fire Law" against the oil storage base in Japan, and the
foam spraying capability is regulated as the sum of on-site firefighting capacity and maritime
firefighting capacity. On the other hand, the ship is a solitary firefighting activity on the sea, and
because there is no regulation, it is planned that sprayed water to reach the height of a tanker
anchored by empty load, and the same level of firefighting capacity as ships of the same size
firefighting function in Japan Respectively.
a. Foam extinguishing agent
It is advisable to avoid installing "synthetic surfactant foam" on an alternative disaster

prevention ship according to the new technical standards, and to load a required amount of
water-based foam extinction agent or AGF foam extinguishing agent. The capacity shall be
6,000 liters / minute.
a. Extinguishing nozzle height
By the new technical standard of Japan it is required to have effective height (about 33 m
above the sea level) even in the case of light condition of the maximum tanker that can be
berthed to the relevant country base.
(3) Engine part

a. By installing multiple generators, it is possible to select the number of generators to be
operated according to the load. It is also enable to select the number of operating units
suitable for low load.
b. If shore power supply during anchorage is not available, by installing one sound-proof
radiator cooling generator as a port use generator, is can be ensured operation while low load
power during anchorage, with low vibration and low noise environment.
c. By providing one spare port generator with the same specification it can be replaced at the
time of trouble occurrence and regular maintenance.
d. Machinery cooling system shall be a fresh water central cooling system and reducing the
seawater cooling heat exchanger and seawater piping. Also, by using central cooling, the
number of pumps can be reduced.
Table 3-24 Particulars of Multi-Purpose Vessel
Hull Shape Mono hull

Navigation Area Coastal
Gross Tonnage Abt. 199 GT
L xB x D 31.50m x 9. Bollard 0m × 4.80m
Main Engine Mid Speed 4 stroke Diesel x 2sets
Maine Generator Engine 2 sets
Propulsion System Z Type Propeller x 2 sets or equivalent
draft 3.50m
109
Ship Speed Abt. 11.0Knots

Compliment 17 Crews
Officers 3 officers + 6 Crews
Rooms 5 rooms
Public Space Salon for 12
Kitchen yes
Firefighting Equipment Pump output(abt.1200 ps) Height Range
Foam/Water nozzle Abt.4,000 L/min x1 Abt.17～33m Abt.70m
Foam/Water nozzle Abt.18,000L/min x 1 Abt.15m Abt.120m
(max)
Foam/Water nozzle Abt. 1,800L/min x1 abt.11m abt.60m
Foam Tank 22,000L (11,000Lkn
Crane
Fresh Water Generator n.a.
Oil dispersant equipment Yes
Oil dispersant nozzle Yes
Oil dispersant tank to be onboard whenever necessary
Oil Boom To be onboard whenever necessary (Type B)
Oil Collecting Equip To be onboard whenever necessary
Outrigger Yes
FO Tank abt.40ｍ3
F.W. Tank n.a.
Portable W. Tank Abt.20ｍ3
Towing bollard 50tons
(4) Operation plan of the Multi-purpose work boat

The ship shall be organized to operate by GMB or a shipping operator selected as the private contractor
at any time in accordance with Indian domestic law. If workers are required to onboard in addition to
crews, stakeholders shall decide how many workers to be onboard.
1) Standards for navigation (operation) of multipurpose work boat
In general, "wind speed 15 m / sec, wave height 1.5 m or less", however the final decision
shall be judgment of the harbor master. Basically, it does not work at night.
2) Tanker Fire
This vessel equipped with firefighting equipment will engage the initial firefighting activity.
Also, if other tug boat or warning ship is in the sea area, receive assistance according to
circumstances.
3) Oil spilled from tanker (oil boom)
Oil boom does not expand when tanker anchoring.
When cleaning the cargo oil tank, expand 200 m as a pre-deployment on the tanker side.
In case of spilled oil, the protective oil boom 400 m - 800 m of land kept (GMB arrangement)
will extend, and if necessary, enter the expansion work of the oil boom stored on land.
110
4) When a tanker is not anchored at the time of non-accident work
During daytime, the main duties are support for anchorage of various ships waiting for
beaching, monitoring, monitoring of marine pollution, and so on.
Figure 3-36 An Example of Multi-purpose vessel
111
3.5. DEMAND FORECAST

In this report, as a demand forecasting survey of the global ship-recycling volume, a multiple
regression equation used in the preceding JICA information collection study, where the explanatory
variables of GDP (emerging markets), charter rate, and shipping tonnage (year-on-year base)) were used,
was reviewed. This attempt was made to create a more accurate multiple regression equation with
updated data to be published in October, 2016, so that better regression coefficient describing the global
ship recycling volume in the future shall be obtained.
3.5.1. SHORT-TERM DEMAND FORECAST
The following table is expected to show a short-term demand forecast of ship recycling volume as a
theoretical value, by conducting multiple regression analysis to obtain a multiple regression equation
consisting of the updated data of GDP, charter rate and shipping tonnage.
Figure 3-37 Short term demand forecast of ship recycling volume
Based on the result, the demand forecast for short-term ship recycling volume until 2021 was
analyzed to be in the downward trend, although there would be an increase toward 2016 at peak. The R
value for the multiple correlation of the multiple regression equation was obtained as 0.88, and the
coefficient of determination (R2 value) was 0.77. Thus it was judged to be a sort of reliable regression
model.
3.5.2. LONG-TERM DEMAND FORECAST
By using the theoretical values of explanatory factors (GDP (emerging markets), charter rate, and
shipping tonnage (year-on-year base)) with a linear regression analysis technique. the long-term demand
trend forecast analysis up to 2040, was also carried out by using the multiple regression equation which
are obtained from the above demand forecast model.
112
Figure 3-38 Long term demand forecast of ship recycling volume
Based on this analysis result, a trend was obtained in that the demand forecast for ship recycling
volume is expected to reach about 20 million gross tons by 2020, and reach about 30 million gross tons
by 2040. On the other hand, it is necessary to keep in mind that these figures show only the trend as a
likeliness, and it is very difficult to make long-term demand forecasts.
(1) Ship recycling volume by the types of ship

It was considered that it is possible to analysis the ship recycling volume by the types of ship by
utilizing the shipping tonnage data with the year of construction by the types of ship at the time of 2016,
together with the average recycling age of ships by types. Tonnage data of construction by year for types
of ship was referred from the dataset provided by the HIS Fairplay, and for the average age of ship
recycling by types of ship, the past performance data as shown in the table below was used.
Figure 3-39 Major Fleets by Vessel Type in 2016

Source: HIS Fairplay
113
Table 3-25 Average scrap age (by types of ship)
Types of ship Average scrap age

Dry bulk carriers 26 year
Combined carriers 23 year
Oil tanker 27 year
Chemical carriers 26 year
LPG carriers 29 year
LNG carriers 40 year
Other tanker types 27 year
Other dry cargo 27 year
Container ships 26 year
Reefers 26 year
RO-ROs 24 year
Passenger/ferries 33 year
Offshore vessels 29 year
Others 31 year
Source: JICA Study Team
Based on these data, a ship recycling demand forecast by types of ship was analyzed from 2017 to
2030, and the result is shown in the figure below.
Figure 3-40 Projected Ship Recycling volume by types of ship, 2017-2030

From this result, scrapping demand for oil tanker and container ships, which were built a lot in the
second half of 1990, shall begin to be apparent around 2020, and the scale of ship recycling volume for
oil tanker in 2020 is expected to reach 3,187 thousand DWT (about 1,958 thousand gross tons). When
114
we look at the whole ship recycling demand in 2020, it is expected to reach to the scale of 19,283
thousand DWT (about 14,864 thousand gross tons4), which also suggests that is in the expanding trend.
Regarding the number of ships to be recycled in India (Alang/Sosiya), as a base of financial analysis,
3 vessels per yard in a year was used. Hence 130 yards × 3 vessels = 360 vessels are assumed to enter
into the ship recycling yards (In the project, 70 yards × 3 vessels = 210 vessels) in a year. Since the
average LDT per vessel is calculated as 8,826.17 LDT from the weighted average of past data, We
estimated the ship recycling demand volume for 130 yards and 70 yards to be about 3.44 million LDT
and about 1.85 million LDT respectively. Therefore, in view of the demands for ship recycling volume
of the world as a whole, it is assumed that Alang/Sosiya would be able to capture 51.3% of the world
market as of 2020, assuming 1 GT is calculated to be 0.45 LDT.
The following illustration shows the actual value of the ship recycling volume in the past, as well as the
dataset of the short-term and long-term demand forecasting of several analysis results, with which
models made by the report is also shown in comparison.
Figure 3-41 Long-term demand forecast

Regarding the number of ships to be recycled in India (Alang/Sosiya), as a base of financial analysis,
3 vessels per yard in a year was used. Hence 130 yards × 3 vessels = 360 vessels are assumed to enter
into the ship recycling yards (In the project, 70 yards × 3 vessels = 210 vessels) in a year. Since the
average LDT per vessel is calculated as 8,826.17 LDT from the weighted average of past data, We
estimated the ship recycling demand volume for 130 yards and 70 yards to be about 3.44 million LDT
and about 1.85 million LDT respectively. Therefore, in view of the demands for ship recycling volume
of the world as a whole, it is assumed that Alang/Sosiya would be able to capture 51.3% of the world
market as of 2020, assuming 1 GT is calculated to be 0.45 LDT.
4
The Conversion factor between DWT and GT is subject to the types of ship, and for the oil tanker, for instance, the
factor of 1 DWT = 0.61 GT was used. Consequently for calculation of total GT of the whole ship to be dismantled, the
coefficients for each ship types were calculated then the total value was calculated using each respective conversion
factors depending on the types of ships.
115
3.5.3. CONSIDERATION ON THE SUTAINABILITY OF THE PROJECT
In consideration of the viewpoint as to whether ship recycling business will be continued in India in
the future, it is important not only to analyze the demand side of ship recycling volume but also to
consider the supply side where the dismantling business takes place at the ship recycling yards. In other
words, as stated above, although demand for ship recycling as a whole in the world tends to increase in
consideration of the existing volumes of fleets, which will be dismantled sooner or later in any case in
the future, if the profits arising from ship recycling activities (by manufacturing and selling scrap iron) is
not appreciated as a business, it cannot be considered sustainable. Even though it is a positive effect that,
as a policy-driven force, the number of supply of certified ship recycling yards is going to be restricted
worldwide by the international ship recycling conventions, for ship recyclers in India, they may enjoy
more bargaining power against shipowners / cash buyers in terms of ship-purchasing price, but it is
considered that evaluation of continuity of the business can be depending on the comparative advantages
of producing scrap steel from the industries in comparison to products in electric furnaces.
The production cost of scrap steel in the ship recycling business in 2016 was US $ 288.7 / LDT on the
assumption that ship purchase could be made at US $ 250/LDT, and compared with the manufacturing
cost in the electric furnace, it is about 44% lower cost compared to crude steel made in Japan5 and 13%
lower cost compared to thick plates made in China6. Even if the ship purchase cost increases by US
$ 50/LDT, it is considered to be still competitive in comparison to the Japanese crude steel about 35%,
and almost equivalent to the manufacturing cost of the plates in China.
It is still difficult to evaluate the continuity of ship recycling business only with a focus on
manufacturing cost alone, and yet crude steel production in India gets strong, by referring to the
economic stability and infrastructure related development, together with well-performing automotive
sector. The steel demand has been steady increased by 6.1% from the last year, 2016 and this year's steel
demand amount will be 88.6 million tons, which is the world's second largest and it overwhelms Japan,
and it is still expected to increase in the future. Therefore, it seems that scrap steel demand from local
steelmakers is likely to increase with the expansion of facilities, and demand for scrap steel from ship
recycling yards is also expected to remain steady in the future.
5
Average production cost per ton of crude steel produced by Asahi Kogyo, Tokyo Iron and Steel, Joint Steel,
Osaka Steel, Co-British Steel, Hokuetsu Metal, Tokyo Steel Iron, Chubu Kohan Kohm
6
RMB 2,255.76/tone (China Iron & Steel Production Cost Index, www.custeel.net)
116
9. PROJECT IMPLEMENTING ORGANIZATION AND

MAINTENANCE MANAGEMENT SYSTEM
9.1. OUTLINE OF THE PROJECT IMPLEMENTING AGENCY
9.1.1. ORGANIZATION STRUCTURE FOR PROJECT IMPLEMENTATION AND
MANAGEMENT
(1) Jurisdictional items

GMB is responsible for all the major ports management excluding Kandla Port, and supervision of all
minor ports under BOOT scheme. The main jurisdiction of works stipulated in the Gujarat Maritime
Board Act 1981 is described below.
• Develop and promote 1,600km shoreline.
• Develop ports and related infrastructure
• Plan transport (railroad and road network etc.) connecting directly with the ports
• Strengthen the share of Gujarat state in world trade
• Promote port -related industries
Furthermore, administrative services are offered as under mentioned.

• Develop cooperation with key port infrastructure
• Offer services for hinterland of ports and development cooperation
• Specify ports development candidate areas in green field
• Propose linkages with the road, railroad and the port connection
• Work for the modern maritime affairs formation in Gujarat
• Shipbuilding and ship recycling operations.
GMB
Ports and harbors Environmental control and Others
development waste disposal Commercialization of
Modern private port port service
Container port equipment Inter coast transport
Energy base port service
Modern fishing port facility Development of minor port Rivers transport
and major port Vessel Traffic
Management System
Seaside industrial (VTMS)
development Maritime affairs training
Special Economic Zone and marine preservation Marine transport
(SEZ） education industry
Road railroad linkage Shipbuilding
Container, freight station Ship repair
Seaside industrial Provide port facilities to Ship recycling
development inland state Refuelling facility
Figure 9-1 GMB jurisdictional item summary
(2) Organizational structure

Organizational structure of GMB is as shown below. Chief Secretary of Gujarat State is placed as the
Chairman of GMB. CEO and Vice Chairman is placed under Chairman and specific departments are
reported to CEO. The total number of staff is 2,700. The Board functions as the decision making body.
Members consist of officials from the Finance Department, Commissioner Fisheries, Gujarat
161
Infrastructure Development Board, Road & Building Department, Industries Commissioner, Naval
Officer, Kandla Port Trust, Ports & Transport Department and Western Railway, and Coast Guard.
At the Alang/Sosia ship recycling yard, the license and related administrative authority is officially
provided by CEO. With respect to substantive policy making and its practical implementation,
Environmental Cell of GMB is the responsible unit for the regulatory and supervision works of GMB for
overseeing Alang/Sosia ship recycling yard operation. In these days Alang Office and GMB headquarter
at Gandhinagar are directly connected with the information circuit called Alang Information System
(AIS) so that licensing and other regulatory activities become quickly proceeded in transparent manner.
As far as Directorate General of Shipping (DG Shipping) is concerned, the organization is supposed to
be an intermediary body between the central government and state maritime board like GMB. With
regard to the ship recycling operation, DG shipping has little functions of supervision, yet the body is
responsible for maritime policy making, maritime traffic safety, prevention of the sea from pollution,
maritime education and training. However in the sense of international maritime affairs, DG Shipping is
the focal point and represents India for IMO and thus it is considered as the window unit for any
maritime issues.
(3) Financial status

GMB has shown strong balance sheet. When we look at fiscal year up to 2014, favorable balance had
been steadily made in that operating profit raised by the pace of around 40% in fiscal year of 2012 and
2013, yet in 2014, the earning was torn-down. Consequently it is presumed the financial status of GMB
stands for very strong and healthy position. When GMB face the necessary credit requirement at the time
of the project implementation at Alang, it seems rather possible from the balance sheet analysis that
GMB is regarded to have component financial strength to make a Yen credit arrangement.
Table 9-1 Major indicators of financial status (Unit: US$ million [Rs. million])
Financial status 2012-137 2013-148 2014-159

Income 62.4 [3,411.7] 80.6 [4,912.7] 86.4 [5,401.0]
Expenditure 22.6 [1,234.3] 22.7 [1,384.9] 25.9 [1,621.8]
Operating surplus/deficit 39.8 [2,177.4] 57.9 [3,527.8] 60.5 [3,779.2]
Non-operating income 11.1 [607.7] 12.6 [766.4] 12.1 [758.5]
Pension fund and gratuity trust fund 2.4 [129.9] 2.1 [129.7] 4.0 [250.0]
Depreciation 3.3 [180.7] 4.2 [258.5] 4.3 [271.1]
Net surplus 45.3 [2,474.5] 64.1 [3,906.0] 64.3 [4,016.7]
(Source: Administration Report 2012-15, GMB)
7
INR 1 = USD 0.0183, monthly average in March 2013, OANDA Corporation
8
9
162
Chairman
Personal Assistant to Chairman
Vice Chairman &

CEO
Personal Assistant to CEO
Financial Supdt. Eng. Supdt. (Eng. Dy. Collector (land Exe. Eng. (Pvt.
OSD (ADM) Traffic Manager Chief Engineer Nautical Officer P.R.O. Marine Engr. Enver. Cell
Controller (Mech.) (Dreg.) Acq.) Cell)
Dy. Financial
Dy. Secretary Traffic Officer Supdt. Eng. (C ) Asst. Port Officer Exe. Eng. (M) Exe. Eng. (M)
Controller
A/C. Officer
Adm. Officer (Est.) Research Officer Exe. Eng. (C ) Exe. Eng (M) Dy. Exe. Eng. (M)
(Pay/Tre./Bud.)
Adm. Officer A/C. Officer

Dy. Exe. Eng. (C )
(Reform Cell) (Comp.)
A/C. Officer
Welfare Officer
(Pen./Ins.)
Asst. Labour A/C. Officer (GPF

Officer & Audit)
Port Establishment
Bedi Okha Porbandar Pipavav Bhavnagar Alang Magdalla

Navlakhi Veraval Bharuch
Port Officer Port Officer Port Officer Port Officer Port Officer Port Officer Port Officer
Adt. Port Officer Port Officer Port Officer
Pilot Officer( Sikka) Pilot Officer (Sikka) Pilot Officer (Sikka) (Jafrabad) Marine Engineer Add. Port Officer Pilot Officer
Asst. Port Officer Training & Welfare Asst. Port Officer

Asst. Port Officer Traffic Officer Traffic Officer Traffic Officer Asst. Port Officer Asst. Port Officer
(Adm.) Director
Asst. Port Officer Acct. Officer

Acct. Officer Acct. Officer Acct. Officer Asst. Officer
(T)
Acct. Officer
Figure 9-2 Organization chart of GMB
163
(4) Present status of income source and expense, and verification of collection of tariff
About the current state of the income source and expense, annual report of GMB issued by annual
base was scrutinized. Also interview survey was conducted with financial controller and accountant of
GMB. The study reveals that main sources of income for GMB are generated from Shipping Fees and
Waterfront Royalty to be paid by private port operation in the scheme of BOOT like in Mundra port.
With two respective sources of income, 40% of the total income of GMB was being covered.
As for the income and expense structure from the operation of Alang port facility, the income from
Alang port facilities in FY 2012 accounts for 19.1% of the entire income of GMB, and 10.0% and 7.6%
in FY 2013 and FY 2014 respectively. The income in FY 2012 from the port facility operation at Alang
was Rs. 652.7 million (US$ 11.95 million), whereas the operating surplus was dropped by about 45%
into Rs. 412.87 million (US$ 6.61 million) in FY 2015.
The reason behind such a decline can be accrued from the decrease of vessels approached into Alang
for dismantling and decline of plot rent charge due to the idling yards can be a reason. According to the
income and expense structure at Alang port facility management, as shown in the table below, in 2006
and 2007 the expenditure of GMB excluding the distribution of profits to the state government was 29.5
million rupees and 25.9 million rupees respectively, and it can be interpreted that the same level of
operating expenses were occurred, and it was confirmed that its profitability depends on the number of
vessels to be dismantled there, then the business structure can be illustrated to be a fixed amount of
expense compared with the up-and-down of the income. Consequently, the operating surplus is highly
fluctuated which is depending on the prospect of ship recycling business. Moreover the collection
system of the plot rent and other charges are strictly practiced as in the regulation that the penalty of the
delay of payment was mentioned.
164
Table 9-2 GMB’s Financial Statement (Profit and loss of ship recycling operation at Alang-Sosia)
(Unit: [Rs. million])
ALANG - BALANCE SHEET AS ON 31ST MARCH, 2007-08 ALANG - INCOME & EXPENDITURE ACCOUNTS FOR THE YEAR ENDED ON 31st MARCH, 2007-08
Particulars Sch. Year Year Perticular Year Year
2007-2008 2006-2007
2007-2008 2006-2007
(Rs. million) (Rs. million)
[A] SOURCES OF FUND (Rs. million) (Rs. million)
I Head Office Account (Conttra) 403.8 (A) Income
Add: Receipt during the year 47.0 596.2 1 Port Infrastructure Facilities 1 30.3 87.0
Less: Transfer during the year 315.2 192.4 2 Marine Services 2 6.0 8.3
Closing Balance 135.6 403.8 3 Clearing, Forwarding and Stevedoring 3 38.6 1.0
4 Storage Area and Land Rentals 4 13.4 27.6
II Reserves & Surplus
5 Equipment & Harbour Craft Rental 5 9.6 4.7
Revenue Reserves & Acc. Surplus A 341.7 75.5
Capital Reserves B 6 License Fees 6 0.4 0.3
General Reserves C 7 Income From Other Port Services 7 220.4 48.1
Total 318.7 177.0
III Loan Funds D (B) Expenditure
Secured 1 Payments to and Provisions for employees 8 16.5 15.6
Unsecured
2 Administrative & Other Charges 9 4.7 7.2
Total 477.3 479.3 3 Repairs & Maintenance 10 4.3 4.2
4 Port Operational Charges 11 0.2 2.3
[B] APPLICATION OF FUNDS 595.3 582.9 5 Finance Charges 12 0.2 0.2
IV Fixed Assets 186.2 165.3 6 GOG Charges on Revenue 6.4 53.9
General Block 409.1 417.6 Total 32.3 83.4
Less: Depreciation 75.7 75.7
Net Fixed Assets 484.8 493.3
Capital work in Progress
(C) Operating Surplus before depreciation (A-B) 286.4 93.6
Less: 1) Contribution - Pension Trust
V Investment F Less: 2) Contribution - Gratuity Trust Fund
Long Term Less: 3) VRS Payment
Short Term Less: 4) Depreciation 21.0 20.6
(D) Operating Surplus after depreciation before interest 265.4 73.0
VI Current Assets and Loans and Advances
Add: Financial Income 0.2 0.2
Stores G
Sundry Debtord H 36.0 13.6 Other Income 0.5 2.3
Deposit works for other Departments I Less: Interest on Loan
Loan & Advances J 0.3 0.0 (E) Net Surplus Before Tax 266.1 75.5
Cash & Bank Balances K 24.6 20.4 Less: Provision of Tax
Total Current Assets 60.9 34.0 (F) Net Surplus After Tax 266.1 75.5
Less:
Less: Appropriations
VII Current Liabilities & Provisions L 67.2 47.2
Current Liabilities M 1.2 0.8 (G) Balance Transfer to Revenue Reserve 266.1 75.5
Provisions 68.4 48.0
Total Current Liabilities
NET CURRENT ASSETS -7.5 -14.0
VIII Miscellaneous Expenditure N

(to the extent not written off)
TOTAL 477.3 479.3
(Source: Annual Account 2006-2008, GMB)
9.1.2. EVALUATION OF FINANCIAL CAPABILITY OF IMPLEMENTING AGENCY AND

COUNTER MEASURES
(1) GMB financial analysis (profit and cost structure and financial solvency etc.)
1) Financial analysis of GMB (analysis of profit, cost structure, financial soundness etc.)
The latest available financial statement of GMB is shown below, and profit and cost structures
are described. For this analysis, balance sheet, and profit and loss and its structure are duly studied
together with interviewing with person in financial and accounting department.
165
Table 9-3 Balance Sheet (GMB)
BALANCE SHEET AS ON 31ST MARCH, 2012-15

Particulars Sch. Year Year Year Year
2014-2015 2013-2014 2012-2013 2011-2012
(Rs. million) (Rs. million) (Rs. million) (Rs. million)
[A] SOURCE OF FUND
I Head Office Account (Contra)
II Reserves & Surplus

Revenue Reserves & Accumulated Surplus A 20,096.3 16,079.6 12,173.6 9,699.1
Premium, Grant & Capital Receipt B 5,755.4 5,909.4 4,929.4 3,009.4
General Reserve C
III Loan Funds D
TOTAL 25,851.6 21,989.0 17,102.9 12,708.4

[B] APPLICATION OF FUNDS
V Fixed Assets E
Gross Block 8,689.9 8,438.4 6,990.6 6,790.0
Less: Depreciaton 2,574.5 2,333.2 2,085.8 1,951.8
Net Fixed Assets 6,115.4 6,105.1 4,904.8 4,838.2
Capital work in Progress 1,761.9 1,792.0 1,971.3 958.9
7,877.2 7,897.1 6,876.1 5,797.1
VI Investments F
Investment in Equity Shares 1,545.0 1,545.0 1,394.5 1,394.5
Investment in Bonds & Deposits 251.7 251.7 273.5 273.5
1,796.8 1,796.8 1,668.0 1,668.0
VII Currrent Assets and Loans and Advances
Stores G 18.3 21.7 23.1 26.8
Sundry Debtors & Receivables H 7,644.4 5,795.9 4,445.7 3,358.2
Deposit works for other Departments I 102.6 96.9 99.1 52.7
Loans & Advances J 119.7 32.7 35.6 39.0
Cash & Bank Balances K 11,176.3 9,650.3 6,768.7 5,047.9
Total Current Assets 19,061.3 15,597.6 11,372.2 8,524.6
Less:
VIII Current Liabilities & Provisions
Current Liabilities L 2,835.5 3,248.5 2,610.2 2,690.6
Provisions M 48.1 54.1 203.0 590.6
Total Current Liabilities 2,883.7 3,302.5 2,813.3 3,281.2
NET CURRENT ASSETS 16,177.6 12,295.1 8,558.9 5,243.4

IX Miscellaneous Expenditure N
(to the extent not written off)
TOTAL 25,851.6 21,989.0 17,102.9 12,708.4
X Notes to Accounts O 0.0 0.0 0.0 0.0
Source: Annual Accounts 2011-15, GMB, summarized by the Study Team
166
Table 9-4 Profit and loss statement (GMB)

INCOME & EXPENDITURE ACCOUNTS FOR THE YEAR ENDED ON 31st MARCH, 2012-15
Perticulars Year Year Year Year
2014-2015 2013-2014 2012-2013 2011-2012
(A) Income
1 Port Infrastructure Facilities 1 866.9 779.1 641.3 321.9
2 Marine Services 2 1,342.5 1,141.7 911.3 510.8
3 Clearing, Forwarding and Stevedoring 3 2.5 2.6 2.5 2.8
4 Storage Area and Land Rentals 4 197.5 188.4 137.0 142.5
5 Equipment & Harbour Craft Rental 5 90.9 76.1 60.2 45.0
6 Ship Recycling Yard (SRY) 6 412.9 493.7 652.7 609.8
7 Ship Building Yard (SBY) 7 8.3 14.2 9.8 24.9
8 Income From Other Port Services 8 1,366.4 1,261.7 130.4 153.9
9 GOG Administrative Charges @15% 11 1,113.1 955.3 866.5 680.2
Total 5,401.0 4,912.7 3,411.7 2,491.8
(B) Expenditure
1 Payments to and Provisions for employees 12 841.6 799.1 765.2 679.6
2 Administrative & Other Charges 13 304.0 229.5 195.8 176.7
3 Repairs & Maintenance 14 372.0 214.8 194.8 160.8
4 Port Operational Charges (Incl ISPS Compliance) 15 44.0 54.7 42.4 84.6
5 ISPS Compliance Charges 16 60.1 86.6 35.4 0.0
6 Finance Charges 17 0.1 0.3 0.8 0.2
Total 1,621.8 1,384.9 1,234.3 1,102.0
(C) Operating Surplus /(-) Deficit before depreciation (A-B) 3,779.2 3,527.8 2,177.4 1,389.8
Less: Contribution - Pension Trust 250.0 - - 475.0
Less: Contribution - GTF / Gratuity Trust Fund - 129.7 129.9 -
Less: Depreciation 18 271.1 258.5 180.7 163.6
(D) Operating Surplus s /(-) Deficit after depreciation before interest3,258.2 3,139.7 1,866.8 751.2
Add: Other Income 9 38.5 23.5 40.8 60.1
Financial Income 10 720.0 742.8 566.9 434.8
(E) Net Surplus s /(-) Deficit Before Tax 4,016.7 3,906.0 2,474.5 1,246.1
Less: Provision of Tax
(F) Net Surplus s /(-) Deficit After Tax 4,016.7 3,906.0 2,474.5 1,246.1
Less: Appropriations
(G) Balance Transfer to Revenue Reserve 4,016.7 3,906.0 2,474.5 1,246.1
Table 9-5 Income from ship recycling project
SCHEDULE -6 SHIP RECYCLING YARD

Particulars Sch. Year Year Year Year
2014-2015 2013-2014 2012-2013 2011-2012
Port Dues - (SRY) 70.4 90.7 92.2 55.6

Beaching Fees (SRY) 0.0 0.0 0.5 2.6
Recycling Charges (SRY) 250.7 306.0 382.8 388.9
Plot Development Fees (SRY) 69.3 73.8 151.1 138.8
Plot Rent (SRY) 20.0 19.3 20.8 20.8
Transfer Fees - Plots at Alang (SRY) - - - 0.5
Vehicle Entry Fees (SRY) 2.5 3.8 5.2 2.6
Visiting Charges (SRY) 0.0 0.0 0.0 0.0
Fresh Water Supply Charges (SRY) - - 0.0 -
Ship Breaking Charges - - 0.2 -
TOTAL 412.9 493.7 652.7 609.8
167
For evaluation of financial state of GMB, the latest financial statements (balance sheet,
income statement) of the past 4 years were referred and analyzed. The major financial analysis
ratios are shown below.
Table 9-6 Financial Soundness of GMB
Financial ratios 2011- 2012-13 2013-14 2014-15

12
Operating surplus to operating income ratio 55.8% 63.8% 71.8% 70.0%
Net surplus to operating income ratio 50.0% 72.5% 79.5% 74.4%
Net surplus to income 41.7% 61.6% 68.8% 65.2%
In accordance with balance sheet (2014-15), the current ratio used for the evaluation of debt
service capacity of the short-term debt tells the value of 611%, which is healthy situation. And yet it
can be interpreted that there may be idle asset. There is no borrowed capital, therefore the equity
capital ratio is 100%, which means there is no interest to be incurred (principal of all loan has been
paid back already). While ROA is 15.5%, because there is no borrowed capital, ROE is also 15.5%.
Consequently, taking this extremely sound financial status into consideration, it could be suggested
that financial leverage may be considered as a tool to maximize the financial return from the
coming new project investment and operation.
In accordance with income statement, the gross sales of 5,401 million rupees (about 86 million
US$) was raised in FY 2014, whereas 1,621 million rupees (about 26 million US$) of expenses was
incurred. Operating profit of the same period was 3,779 million rupees (about 61 million US$).
Interest coverage ratio (Index in order to measure the payment ability of interest of the loan) was
not obtained due to no borrowed capital. But the total asset turnover (index which shows effective
use of fund) was obtained as 20.9%. In addition an analysis of comparing total borrowing amount
after deduction of cash and bank balance (net borrowing) and value added amount was attempted so
as to evaluate the cash flow problem, however, since GMB has no borrowing the analysis was
uncompleted. Yet, value added amount was obtained as 4,925 million rupees (79 million US$),
which can be interpreted that GMB is endowed with extremely cash-rich financial situation,
revenue, and cost structure.
The analysis using cash flow statement was undertaken in that operating, financial and
investment cash flows are investigated, and analysis on the availability of free cash flow was
focused. The free cash flow can be obtained from the balance between operating income and
necessary expense to be incurred for maintenance of the business. In this study, it is revealed that
GMB has sufficient amount of free cash flow which is being steadily generated in the past 4 years.
Furthermore the amount of free cash flow has been larger than the amount of depreciation in that
GMB has left the stage of financial stabilization yet now in the stage of future investment and
expansion of its operation. The main use of free cash flow has been a cash deposited for the future
business development, and it is analyzed there is adequate financial soundness when a new
development project in Alang was considered.
2) Verification of technical implementation capability of yen loan
As for Yen Loans, an official agreement and signing between the two central governments are
essential. In this section the previous yen loan projects in India are reviewed. Technical and
financial cooperation from Japan on Indian maritime project began by providing assistance to
petroleum natural gas public corporation supply port plan in Hardiers (1986), followed by Hugri
shipyard modernization project (1988), Pipavav port development plan for ship breaking (1995),
168
Choline port dredging project (1997) and Bishyakapatnamu port extended business (2005-2006). So
far six projects and seven credit line projects which are all related to port have been supported by
Yen loan. A grant based technical cooperation for a training kits and equipment supply for
seaman’s training program was also undertaken by JICA as a technical cooperation.
State government of Gujarat, on the other hand, has received a technical assistance on forestry
and environmental improvement for poverty reduction plan (17.5 billion yen) as well as financial
assistance on Pipavav port development project for ship recycling yard in 1995 (7 billion yen) and
Ahmedabad Metro Project (I) (8.2 billion yen). Yet GMB has no experience in dealing with Yen
Loan so far. Hence once the project started, it would need to increase coordination capability with
the Japanese government by its own and also, most probably, through the support from line
ministries.
In the process of evaluating the organizational capability of GMB from the point of ODA project
management and financial control, a technical assessment by means of interview survey with
various relevant officers and directors were carried out, and especially with the officer from the
environmental cell and administrative and account department were duly undertaken. The findings
to be shared in this report are that GMB has no liability to outside, even from the state and central
government. In other words, GMB is standing on financially very strong bases and consequently
there comes no need so far for loan arrangement for carrying out new projects. However GMB has
a flexible joint venture policy for new projects in that TSDF facility at Alang/Sosia was developed
under the financial scheme of 50 % from state government and the remaining 50% from Ministry of
Steel. Likewise, there is a regional development plan at Dahej where ship building industrial cluster
development is pursued in collaboration with GIDC. In this regards, GMB is most likely that the
capability of coordination and collaboration with outside agencies is at competent level. In addition,
from the point of Directorate General of Shipping, the administrative and even policy enforcement
measures at Alang/Sosia should be initiated by GMB. Consequently it is presumed that GMB’s role
and responsibility in the context of ship recycling business and development plan are supposed
indispensable for this project.
3) Verification of financial capability of proposed project owner
The project counter partner agencies of yen loan pledge is considered to be either (1) Economic
Bureau of Ministry of Finance, (2) Ministry of Shipping, and (3) Ministry of Steel, (4) Ministry of
Environment and Forest. As an implementation agency, GMB is considered the most appropriated
in the sense of reasoning described above, thus the financial and management capability of GMB
should be examined.
GMB has implemented projects as shown in the table below, and the amount of execution for
each fiscal year is less than INR 1 billion per year, except for the most recent fiscal year 2016.
Table 9-7 Projects List Performed by GMB in the Last Five Years
2012-13
No. Name of Projects Rs.
1 16,170,885
Construction of Bela Masonaty Hall around land acquired as Sosiya ship breaking yard
2 Design construction and delivery of a dumb grab dredger 47,219,000

3 Design construction and delivery of a twin screw and self propelled hopper barge 127,000,000
(sphb) 2500 cmm capacity
4 Construction of hard surface road & c. c. surface for loading area & drainage for the 19,193,625
project of development of minor fishery harbour at Dholai
5 Renovation of road divider of approach and service road at s. b. y. Alang 13,187,670
169
6 Renovation of service approach road to improve riding surface at s. b. y. Alang 25,154,940

7 Improvement of stacking platform on dwb at Porbandar port 14,080,381
8 Construction of old port office road and Bapa Sitaram road at port Porbandar 10,107,490
9 Construction of service road at Rozi port 10,499,738
10 Special repairs to road from weight bridge at Rozi port 20,482,000
11 Providing footpath along service road at s. b. y. Alang 15,248,130
12 Widening Manari bridge at ship breaking yard Alang 78,878,690
13 Improvement and strengthening of elevator of GMB complex at Gandhinagar 15,328,200
14 Providing auditorium facilities at ground floor of GMB complex at Gandhinagar 13,610,342
15 Renovation internal road by c. c. pavement at new port Bhavnagar 73,805,435
Total 499,966,526
2013-14
1 Construction of new office building at port Veraval 15,384,267
2 Upgrade rigid pavement road at port Magadalaa 52,731,270
3 Widening r. c. c. jetty at new port Bhavnagar 209,923,019
4 Construction of administrative office complex of GMB at Surat 28,662,936
5 Extension of steel sheet piled wharf 120 m length at port Okha 110,073,140
6 Development of labour housing colony at Alang Sosiya recycling yard Alang 204,835,141
Total 621,609,773
2014-15
No. Name of Projects Rs..
1 Construction of compound wall for coal yard at port Navalakhi 18,337,110
2 Resurfacing the existing c. c. pavar block at port Navalakhi 23,697,840
3 Providing c. c. pavar block platform coal yard & internal concrete road part c on 92,199,999
Varshamedi side at port Navalakhi
4 Development of marine base for bsf at Koteshwar Kutch 13,500,000
Total 147,734,949
2015-16
1 Upgrade main gate & related road for two way traffic at port Navalakhi 10,643,807
2 Upgrade existing compound wall at Besi port 42,032,150
3 Upgrade existing compound wall at new Bedi port 17,229,160
4 Providing internal road in suctom notified area at Porbandar 24,455,458
5 Construction paving block type stacking platform in new jetty area at Bedi port 55,094,930
6 s. r. to r. c. c. jetty by approach type fendering system at Magdalla port 12,031,200
7 Upgrade service road by providing c. c. pavement from plot no. 24 - j to 87 at ship 13,582,510
breaking yard Alang
8 Development of minor fisheries harbour at port Jafrabad providing r.c.c. jetty with 209,188,474
approach part A
9 Construction paving block type stacking platform at new Bedi port 57,299,486
10 Providing & improving stacking platform at new port Bhavnagar 15,187,325
11 Providing stacking area behind finger jetty for bulk cargo at new port Bhavnagar 26,226,698
Total 482,971,198
170
2016-17
1 Providing c. c. paver block platform at coal yard & internal road part -b on Varshamedi 79,071,915
side at port Navalkahi
2 Upgrade of existing platform by providing precast concrete paving near scrap yard at 12,516,275
Bedi port
3 Upgrade stacking platform no. 13 near Akwada wharf at new port Bhavnagar tender 14,437,465
4 providing & upgrade security wall as ISPS requirement at new port Bhavnagar 56,962,171
5 Construction of protection rock bund at Ro-Ro terminal Dahej 14,690,125
6 Upgrade stacking platform no. 09 near north quay at new port Bhavnagar 27,481,867
7 Providing north quay side reclamation bund at new port Bhavnagar 12,944,380
8 Providing road near helipad on north quay side at new port Bhavnagar 17,000,821
9 Construction of paving type stacking platform near electric substation at new Bedi port 11,283,480
10 Set fender and wearing coat to the GMB jetty at Navlakhi port 14,451,696
11 Ro -Ro ferry service Dahej-Ghogha terminal (Dredging work) 6,150,000,000
Total 6,410,840,195
(Source: GMB)
(2) Observation of operation system and performance of the proposed project owner
GMB’s main administrative operation is the management and regulatory works of the state port
facilities in the Gujarat. The annual freight handling quantity of its ports in 2015-16 was 339.78
million ton, showing 1.1% annual increase. It is 122.35% increase in comparison with the figure
recorded in 2008-2009 when international financial crisis occurred. While India’s whole non-major
port handing volume was 470.87 million ton, ports under jurisdiction of GMB account for 71.38%
of the whole annual freight handling at the non-major ports of the entire country. GMB recorded
high performance of port operation in comparison with other Indian states.
The roles of GMB on the ship recycling activities in relation to the project are mainly for
providing license and authorization for ship recycling operation to ship recyclers at the yards,
monitoring of their operation, and providing training and education on safety and environmentally
sound operations. Those activities were observed during the field survey at Alang/Sosia area and
the training service provision was duly undertaken at their Training & Welfare Complex. As for the
safety training, there have been 3,181 participants in 2015, and the accumulated number reaches
117,103 since its opening in 2003.
In addition, GMB has provided infrastructure development service at Alang in that drinking
water facility, fire-fighting equipment as well as access road improvement have been implemented
with the investment cost of 700 million Rupees between 1982 and 2016. However, additional
technical knowledge for management and supervision is to be required for overseeing the new
common facility like hazardous material removal, as well as reinforcement of manpower staff for
upgrading ship recycling yards as well as road widening works to improve productivity at the plots
need to be emphasized.
In this ODA loan project, it is necessary to clarify the roles of the executing agencies in terms of
development, operation, and maintenance of each of the four business components, and preparation
of bidding documents through a project implementation support survey (SAPI) needs to address the
issues of the responsibilities and role sharing among GMB, yard borrower, O&M company, and
equipment leasing company, who will be involved in the negotiation for project agreement.
171
Table 9-8 Role of the relative organizations for the project implementation
Development Operation Maintenance

Upgrade of recycle GMB through ODA Ship recyclers for yards Large-scale repair of
yards Loan Multi-purpose vessel yards, multipurpose
(GMB) work boat etc. are
carried out by GMB.
Minor repair (concrete
floor etc.) is carried out
by yard borrowers
Offshore tank cleaning GMB through ODA O&M company Renewal of equipment
Loan selected by GMB and facilities are carried
out by GMB. Minor
repair is carried out by
O&M company
Large crawler crane and GMB through ODA O&M company Renewal of equipment
etc. Loan selected by GMB and facilities are carried
out by GMB. Minor
O&M company
Hazardous waste GMB through ODA O&M company Renewal of equipment
treatment Loan selected by GMB and facilities are carried
out by GMB. Minor
O&M company
As an example, considering the operation and maintenance structure of environmental facilities, the
facility development is supposed to be carried out by GMB and an O&M system is supposed to be
entrusted by a private operator who shall cater for the needs of normal operation and maintenance of the
facilities then the large-scale renovation cost after the useful life (in the case of environmental facilities,
15 years) will be expended by the owner, GMB. In addition, the price setting of the related services like
oil water treatment and waste disposal will be determined by consultation between GMB and a O&M
operator, which may address an issue as to how to escalate the price at annual rate.
(3) Project implementation structure of this ODA loan project

When implementing this ODA loan project, it is decided within the Government of Gujarat to
establish the following committees and an operational structure to implement the project.
172
State Level Project Monitoring Committee Chief Secretary

Additional Chief Secretary, Finance
State Level Project Monitoring Committee Department
Additional Chief Secretary, Industries and
Mines Department
Principal Secretary, Labour and
Employment Department
Vice Chairman and Chief Executive Office, GMB Principal Secretary, Ports and Transport
Department
Vice Chairman and Chief Executive
Officer, GMB
Deputy General Manager, Environment
Cell, GMB
GMB Steering Committee
Vice Chairman and Chief Executive Office, GMB
Project Management Unit (PMU)
GMB Steering Committee Chief Engineer, GMB

Financial Controller and Chief Account
Project Implementation Unit (PIU)
Officer, GMB
Superintending Engineer (M), GMB
Superintending Engineer (C), GMB
Deputy General Manager (Env), GMB
Project Management Unit (PMU)

Project Management Consultant (PMC)
Dy. Executive Engineer (M) Dy. Executive
Nodal Officer (Project Director) Dy. Engineer (C) Manager Finance Manager
General Manager (Env) (Env) Manager (Welfare) Marine Engineer
Assistant Engineer (M) Assistant Engineer (C)
Dy. Financial Controller cum Chief
Account Officer/Accounts Officer
Project Implementation Unit (PIU)

Executive Engineer (M) Dy Executive Engineer (M)
Assistant Engineer (M)
Additional Assistant Engineer (M)
Executive Engineer (C) Dy Executive Engineer (C)
Assistant Engineer (C)
Additional Assistant Engineer (C)
Figure 9-3 Project Implementation Structure
On the state government side, the Monitoring Committee is established. The committee is composed
of the Chief Secretary as the chairman, and the department head from the Department of Finance, the
Department of Industries and Mine, the Department of Port and Transportation, the Vice Chairman and
CEO of the GMB, and the Environment Cell. as a member. In working level, under the direction of the
Vice Chairman and CEO of GMB, the Steering Committee is established, and a Project Management
Unit (PMU) and a Project Implementation Unit are established under its management.
(4) Proposition of project support initiative in terms of the management

Modernization measures of Alang/Sosia ship recycling yards are aiming for attracting new market for
green ship recycling industries. The recycling scale at the yards is deemed to be increased up to millions
of LDT per year. In order to increase its capacity and competence of the ship recycling yards operation
in compliance with new stringent ship recycling convention, it is still required for GMB to have the staff
trained with the capacity development program, which could eventually address the upgrade of
manpower resources at GMB. Hence GMB’s operation and financial assistance to the area is very
important. As for the capacity development, strengthening in both quantity and quality of the personnel
by steps will be therefore to be attained in the course of JICA technical assistance organized in Japan or
through third country training like South-South Cooperation including the dispatch of the dedicated staff
in each subject, and let them trained in other countries to learn the best practice of the operations.
9.1.3. MAINTENANCE OF CONCRETE FLOOR
Cracks will occur in concreted impermeable floor of yard when it is used. As a standard repair
method, it is possible to deal with the classified repair materials as the follows in India.
173
(1) Polymer cement

Repair material suitable for filling method which restores large cross section of concrete structure
with polymer cement type injection mortar material composed of special cement powder and acrylic
emulsion.
Figure 9-4 Repair by polymer cement
(2) Epoxy resin

A method of cutting cracks such as concrete and mortar into a U shape with a diamond cutter and
filling with flexible epoxy resin and elastic sealing material. It is excellent in waterproof performance
and also follows the movement of cracks. A method of automatically injecting epoxy resin into cracks of
concrete structures continuously at low pressure and low speed.
Figure 9-5 Repair with Epoxy resin
(3) Acrylic resin

A method for injecting and filling an acrylic resin type adhesive into the crack width of 0.2 to 5 mm
using a low pressure injection jig for the recovering the integrity of the concrete
(4) Sealing material
174
Figure 9-6 Repair with sealing material
(5) Reparing cost (for reference)

• Epoxy resin injection method
Crack 0.2 mm or more · Instrument installation · After sealing · Injection · Removal, m / 6,600
yen
* Repair work is 200 m or more
• Sealing method
Width 10mm Depth 10 mm or more, U cut · Sealing material filled · Resin mortar, m / 3400 yen
* However, the construction scale is over 200 m2
9.1.4. EQUIPMENT AND PLANT
175
10. CAPACITY DEVELOPMENT PLAN

10.1. EVALUATION OF CURRENT SHIP RECYCLING PRACTICE IN
CONFORMITY WITH THE SHIP RECYCLING CONVENTION
In order to comply with Hong Kong Convention (HKC), ship recycling operation and management
shall be improved along with the improvement of yard and facilities. This section will clarify required
improvement in current safety measures and environmental protection measures employed in the yard
and find the gap between HKC requirement. The evaluation is based on field investigation conducted in
6 yards included two Class NK certified yards, one yard in the process of verification by ClassNK and
three normal yards in Alang Sosiya Ship Recycling Yard.
10.1.1. REQUIREMENTS TO COMPLY WITH THE SHIP RECYCLING CONVENTION
Evaluation criteria used by ClassNK to issue Statement of Compliance (SOC) was based on
“Guidelines for Safe and Environmentally Sound Ship Recycling (Ship recycling facility guideline)”
which is in the annex 4 of the HKC. In this survey, assessment was conducted based on the same criteria
to identify the gap between current practice and the requirement of the HKC. Following table shows the
requirement mentioned in the guideline.
Table 10-1 Guidelines for Safe and Environmentally Sound Ship Recycling
1.
2.
3. Ship Recycling Facility Plan (SRFP)
3.1 Facility management
3.2 Facility operation
3.3 Worker safety and health compliance approach
3.3.1 Worker health and safety
3.3.2 Key safety and health personnel
3.3.3 Job hazard assessment
3.3.4 Prevention of adverse effects to human health
3.3.4.1 Safe-for-entry procedures
3.3.4.2 Safe-for-hot-work procedures
3.3.4.3 Welding, cutting, grinding and heating
3.3.4.4 Drums, containers and pressure vessels
3.3.4.5 Prevention of falling from heights and accidents caused by falling objects
3.3.4.6 Gear and equipment for rigging and materials handling
3.3.4.7 Housekeeping and illumination
3.3.4.8 Maintenance and decontamination of tools and equipment
3.3.4.9 Health and sanitation
3.3.4.10 Personal protective equipment
3.3.4.11 Worker exposure and medical monitoring
3.3.5 Emergency preparedness and response plan (EPRP)
3.3.6 Fire and explosion prevention, detection and response
3.4 Environmental compliance approach
3.4.1 Environmental monitoring
3.4.2 Management of Hazardous Materials
3.4.3 Environmentally sound management of Hazardous Materials
3.4.4 Prevention of adverse effects to the environment
Source: Guidelines for Safe and Environmentally Sound Ship Recycling, adopted by resolution, 2012 MEPC.210(63)
176
Under the study total 6 yards were visited, of which, 2 yards have already undergone NK certification,
1 yard under review for NK certification, and 3 normal yards. Based on the items of the above
guidelines, the evaluation of occupational safety and environmental measures at the inspection yard will
be described below.
10.1.4. EVALUATION OF CURRENT MEASURES EMPLOYED TOWARDS LABOR

SAFETY AND HEALTH AND ENVIRONMENT PROTECTION
The result of site survey is summarized in the following table. The evaluation was separately done for;
yards already certified by NK, yards in the process of verification and normal yards. Considering that the
target yards of the Project will be of similar status as normal yards.
Table 10-2 Results of site investigation and status of conformity with the requirements of the
Convention (C: Complied, NC: Not Complied)
Check item NK certified yards Verification in process Normal yards
Facility management
Document C C NC
management (documents not confirmed)
Training plan C C NC
(room for (room for improvement (training courses are not
improvement on on training content) prepared / conducted)
training content)
Facility operation
SRP development C C NC
Ship recycling C C NC
methodology (block dropping and cutting
done in inter-tidal zone)
Worker safety and health compliance approach
Key safety and C C C
health personnel (no adequate training
obtained in some cases)
Safe-for-entry / C C NC
Safe-for-hot-work (prior confirmation by HSE
procedures officer has not been
thoroughly done)
Prevention of C C NC
working at height (confirmed with (not confirmed)
documents)
Housekeeping C C NC
(zoning is not properly done,
yard not organized)
Health and C NC NC
177
Check item NK certified yards Verification in process Normal yards

sanitation (under construction (no adequate facilities
incl. resting room) equipped incl. resting room,
shower rooms etc.)
PPE C C NC
(lack of proper PPE
identified in some yards)
Medical monitoring C C C
(additional occupational (additional occupational wise
wise checkup advised) checkup advised)
Emergency C C C
preparedness
Fire and explosion C C C
prevention (inspection of equipment
and fixtures incl. fire-
fighting equipment required)
Environmental compliance approach
Environmental C NC NC
monitoring (additional (periodical monitoring (not performed)
monitoring item will start)
recommended)
Management of C C NC
Hazardous Materials (untrained workers are
engaged in the removal
activity not by specialized
agencies)
Prevention of C NC NC
adverse effects to (concrete and pit are (not improved)
the environment under construction)
Source: Survey Team
Based on the result of above evaluation, items which require necessary improvement are summarized
as follows. Proposed training courses are further described in the next section.
Table 10-3 Summary of necessary improvements
Item Necessary improvements (in relation to capacity building)

Facility management • Understanding SRP requirements (ship recycling method, certificates and
and operation permissions, safety and environmental measures, etc.) by yard owners.
• Periodical monitoring by the competent agency (CA) / recognized
organization (RO) to check the implementation of ship recycling activities
in compliance with the Convention.
• Continuous in-house training to develop basic skills and safety awareness
of seasonal workers.
178
Workers health and • Ensure the implementation of safety procedures and safety measures (hot
safety work, working at height, etc.) by HSE officers and skilled workers.
• Improve risk and safety awareness of heavy machin operators along with
their skill development.
• Improve risk awareness among workers to understand the importance of
PPE.
• Instruction shall be provided by HSE officers and site supervisor to ensure
the application.
• Improve workers’ health and safety environment by ensuring their access
to facilities including rest rooms and showers, etc (*hard component).
Hazardous material • Training on the identification of hazardous substances based on IHM and
handling removal method (Asbestos, PCBs, paint chips, etc.) towards competent
agency and HSE officer.
• Improve knowledge on the potential health hazards from hazardous
material handling process to ensure that only trained workers are allowed
in the process with proper PPE.
Prevention of • Environmental pollution control by yard improvement and introduction of
adverse effects to facilities to avoid intertidal zone (*hard component).
the environment • Continuous environmental monitoring
• Understanding of necessary environmental facilities and recycling method
to comply with the Convention by yard owner, HSE officer, site
supervisor.
Source: Survey Team
10.2. TRAINING PROGRAM

1.1.2. IMPROVEMENT OF SHIP RECYCLING INDUSTRY IN CONFORMITY WITH THE
SHIP RECYCLING CONVENTION
At Alang / Sosiya district, there are 159 plots along the 10 km of coast line, which is the biggest
recycling yard in the world, where 130 recyclers are engaged in the Ship Recycling Industry. For the
past couple of years, in this district of Alang / Sosiya, some of the leading ship recyclers started
improvement of their ship recycling yards and their management of ship recycling business in
compliance with the HKC.
No sign of ratification was shown nor was mentioned with the intention for ratification by Indian
Government. However on the other side of India, at the center of ship recycling industry, the
improvement of ship recycling industry in compliance with HKC is now gradually heading in that
direction. As a matter of fact, this move, started by some forward thinking and influential ship recyclers,
became more evident and presently Class NK and other Certification bodies provide them with the
guidance for improvement of their ship recycling business. Recently, not only Class NK but RINA
(Italy) and IR (India) started their consultancy to assess ship recyclers for the improvement of their ship
recycling business. Present situation of the ship recycling yards at Alang / Sosiya in relation to HKC is
as follows;
1) SOC (Statement of Compliance) issued by Class NK 6 yards
2) SOC applied. Ready for final checking by certification body 18 yards
3) Scheduled to start improvement of ship Recycling Yard in 2016. 20~25 yards
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According to the recent information given by SRIA (Ship Recycling Industry Association / HQ in
Bhavnagar)、there are some ship recyclers wishing to start improvement of their Yards, on their own
account in the earliest opportunity possible even before JICA starts improvement.
10.2.2. TRAINING PRESENTED IN GMB’S SAFETY TRAINING & LABOR WELFARE

INSTITUTE
Alang/Sosiya has a Safety Training & Labor Welfare Institute established by GMB in 2003
providing training courses for workers engaged in ship recycling. Training Courses offered are shown
below.
Table 10-4 Training Courses provided in Safety Training & Labor Welfare Institute
Name of Training Trainee Duration

Basic Course( 7days training course)
Basic safety for all All workers 3 days
Cutter men Training Cutter men 2 days
Basic Firemen Training All literate and young workers 2 days
Special Course
Training for cutter men Cutter men 3 days
Safe Rating I II Supervisors, Safety Officers 1 day
Disaster Management Training Supervisors, Safety Officers Half day
Crane Drivers Training Crane Operators 2 days
Personal Protective Equipment Training Supervisors, Safety Officers 1 day
Hazardous Waste Management Supervisors, Safety Officers 2 days
1 day Safety Training All workers 1 day
Safe Removal and Handling of Asbestos Materials All workers 2 days
Source: Study for Establishment of an Environmentally Sound Ship Recycling Project in Gujarat, India, 2010
Contents of the present Training Courses at GMB’s Safety Training & Labor Welfare Institute are
mainly guidance of knowledge, technique and safety measures related to the basic ship recycling and
handling hazardous material. The initial training for the newly engaged workers is important and in
addition to such initial training, periodical Operators’ training courses such as cutters’, welder’s and
crane operators’ courses should be held.
As we mentioned above, many ship recyclers in the district of Alang and Sosiya are looking for the
improvement of their recycling yards and at the same time improvement of their management of ship
recycle business pursuant to HKC. HKC requires not only establishment of the system, but also keeping
the system, i.e., continuous improvement for the safe, healthy and environmentally sound ship recycling,
including prevention from harmful spills or emission in the process of recycling. In order to be
compliant with HKC, training of all manpower from the top management level to the workers on site
should be organized to maintain continuous improvement system in conformity with the HKC.
10.2.3. OUTLINE OF PROPOSED TRAINING COURSE FOR SHIP RECYCLING IN

COMPLIANCE WITH THE SHIP RECYCLING CONVENTION
The increasing number of ship recycling yards which have been already issued the Statement of
Compliance ( SOC) or en route for such Statement of compliance, may bring some problem of shortage
of experienced key persons for HKC, such as General managers, supervisors, HSE Managers etc. Once
certified as a ship recycling yard compliant with HKC, all the requirement of HKC should be strictly
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fulfilled. Thus need for such experienced managers and officers, supervisors arise. Further, for the
training of their staff and workers, each recycler should secure following SRF managers and key-staff
with much experience in HKC.
• General Manager,
• Assistant General Manager,
• Production Manager,
• HSE Manager
• Health & Safety Officer,
• Environmental Officer,
• Hazardous Material Expert
10.2.4. PROPOSAL OF NEW TRAINING PROGRAM BASED ON THE SHIP RECYCLING

CONVENTION
In order to develop ship recycling Industry compliant with HKC, over all the ship recyclers in the
Alang and Sosiya district, improvement of all ship recycling yards according to the requirement of HKC
which is so to speak for improvement of hard items.
At the same time, development of soft items which include Facility management , Facility operation,
workers safety and health compliance approach and environmental compliance approach will be
necessary for this project to ensure proper ship recycling operation pursuant to the Ship Recycle
Convention such as training and education of the personnel and preparation of work procedure
instruction or enhancement of operation and management or maintenance and administration system that
should be conducted by GMB.
In case many recyclers take action for the HKC, they will have to arrange all the procedures within the
recycle yard, and in most of the cases, all the personnel in the yard have to learn it and put it in practice.
Ship Recyclers have to respond to it and at the same time, the recyclers have to keep the person
necessary for the ship yard and after all he has to bring such person up front. From that point of view
following training courses are proposed and to make them in detail, the followings will be important.
1) Open the Training course at the GMB’s Safety Training & Labor Welfare Institute: Class
room :As for the OJT or the field work, training will be carried out at the recycling yard
where each one of the trainee belongs to.
2) The Lecturer will be Trainer or Instructor or Moderator, on the other hand for some Courses
for the common workers, the lecturer will be given by GMB’s Instructor in consideration of
common language.
3) As to the teaching material, the material for the course will be prepared in the form of Video
Tape, photos or OHP to make it easier for the trainees to understand. For the preparation of
such teaching material, the Instructors will prepare it by asking the opinion of other
instructors and develop it in collaboration.
4) Among the courses, if some of the course is good in English, help from Indian or foreigner
specialist may be asked.
5) With regard to the Theme ”SRP in Practice”, this theme may be handled by some of the site
manager or safety officer of some ship recycling yards which has already experienced SRP.
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10.2.5. PROPOSED TRAINING COURSE UNDER THE CAPACITY DEVELOPMENT PLAN
Following Training courses are the proposed courses, most of which are prepared on the basis of the
Convention..
I. TRAINING COURSE Ⅰ Initial Training Course for All Workers
II. TRAINING COURSE Ⅱ Initial Training Course for Skilled and Special Workers
III. TRAINING COURSE Ⅲ Managers and Management Level Staff Training Course to
Build Awareness of Hazardous and Risks
IV. RECYCLER Top Management Course (HKC)
V. RECYCLER Top Management Course (Training Course In Japan）
VI. TRAINING COURSE (Trainees)

VII. TRAINER COURSE (Crane Operators)
VIII. Other Trainings
Table 10-5 Training Course I
1. Training Course TRAINING COURSE -Ⅰ

Initial Training course for all workers
2. Trainee (All workers in SRY)
Steel Cutter helper, Fitter helper, Wire rope handler, Loader
Hazardous Material Cylinder handler, Plate handler, Other unskilled
worker
(Other worker)
Security Guard, Record Keeping, Cleaner , Cook, Office staff, Others
3. Course Framework 3-1Ship Recycling Administration and Regulative Framework
3-2Job Hazard Awareness
3-3Environmental awareness
3-4Hazardous materials
3-5Personal Protective Equipment
3-6Workers wellbeing
3-7Awareness and Handling of Hazardous Materials
3-8Vocational Education and Training
4. Objective 4-1Understanding Regulative Framework of Ship Recycling, particularly
OHS training & Administration
4-2Creating job Hazard Awareness among workers-hazard and Risk
mitigation
4-3Creating awareness about Environmental Impact & Protection
measures
4-4Understanding the use of Personal Protective Equipment
4-5Knowledge about Worker Wellbeing & Health surveillance procedure
4-6Understanding management of Hazardous Materials
4-7Understanding Vocational knowledge in the use of tools &
machineries
and their maintenance in work activities and their maintenance in work
activities and teaching emergency preparedness & response
5. Participant Max 30 pers.
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6. Course Certificate An attendance certificate will be issued after successful completion of full
–length training
7. Course length 1.Theoretical Training in Class Room 48 hours (= 8 days)

2.OJT 7 days (Conducted at SRY of the employer) (Total 15 days)
3.Onsite activities of 7 days additional training = 1day Emergency escape,
rescue and entry in enclosed space2 days Firefighting 2 days on first aid,1
day on chemical/ oil spill management
8. Others 1.Organizer: GMB & SRIA , + Consultant appointed by JICA/GMB
2.Others: Teaching Mat. (VIDEO, OHP)/ Trainers / Language
Table 10-6 Training Course II
1. Training Course TRAINING COURSE - II

Initial Training Course for Skilled and Special Works
2. Trainee Foreman, Cutter, Welder, Fitter, workshop manager, Operators (Winch,
Crane, heavy Equipment), Electrician Emergency team
3. Course Framework * This Course is designed mainly for all skilled workers and workers of
Special Team handling Hazardous Materials
3-1Ship Recycling Administration and Regulative Framework

3-2Job Hazard Awareness
3-3Environmental awareness
3-4Inventory of hazardous materials(* Additional Curriculum)
3-5Personal Protective Equipment (*Additional Curriculum)
3-6Workers wellbeing
3-7Awareness and Handling of Hazardous Materials(*)
3-8Vocational Education and Training(*Additional Curriculum)
4. Objective 4-1Understanding Regulative Framework of Ship Recycling, particularly
OHS training & Administration
4-2Creating job Hazard Awareness among workers-hazard and Risk
mitigation
4-3Creating awareness about Environmental Impact & Protection
measures
4-4Understanding the use of Personal Protective Equipment
4-５Knowledge about Worker Wellbeing & Health surveillance
procedure
4-5Understanding management of Hazardous Materials
4-6Understanding Vocational knowledge in the use of tools &
machineries and their maintenance in work activities and their
maintenance in work activities and teaching emergency preparedness &
response
5. Participant 31 pers. MAX
7. Certificates An attendance certificate will be issued after successful completion of full
–length training
7. Course length 1.Theoretical Training in Class Room 54 hours (= 9 days)
2.OJT 6 days (Conducted at SRY of the employer) (Total 15 days)
3.Onsite activities of 7 days additional training = 1day Emergency escape,
rescue and entry in enclosed space2 days Firefighting 2 days on first aid,1
day on chemical/ oil spill management
8. Others 1.Organizer: GMB & SRIA , + Consultant appointed by JICA/GMB
2.Others: Teaching Mat. (VIDEO, OHP)/ Trainers / Language
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Table 10-7 Training Course III
TRAINING COURSE III

Manager & Manager Level Staff Course
Management of Ship Recycling & Legal Framework
1-1Understanding National and International Regulations and frameworks.
Knowledge about national and International regulations, such as, but not limited to, ILO, Basel
Convention, IMO HKC, EU Ship Recycling Rules, Ship Breaking Code 2013 and Factory law
1-2 Understanding the relationship between employer and employee

1-3 Understanding the importance of OHS management principles.
1-4 Knowledge about accidental hazards and associated diseases.
1-5 Keep recorded OHS Management Policy on the SRF(Ship Recycling Facilities) and perform
them accordingly.
1-6 Facility Operations. Understanding general administrative procedure of ship recycling
1-7 Training of workers requirements
Awareness of Occupational Hazards
2-１ Understanding hazards
2-2 Identify common accidents and protection measures
2-3 Main hazards in a ship recycling yard and preventive measure
2-4 Behavior Based Safety （BBS)
2-5 Principles of risk and risk management
Awareness of Environment
3-1 Environmental Impacts of ship recycling activities
3-2 Waste management
3-3 pollution prevention
Inventory of Hazardous (IHM)
4-1 Understanding the use of IHM（Inventory of Hazardous Material）
4-2 Interpretation of IHM.to prepare SRF Plan and organize SRFs activities.
Personal Protective and Safety Equipment (PPE）
5-1 Understanding PPE.
5-2 The use of PPE and safety equipment.
5-3 Consequences of not using PPE
Workers Wellbeing and Health(OSH)
6-1 Understanding OHS(Occupational Health and Safety Practices)
6-2 Understanding importance of Hygiene and health Practices
6-3 Medical health surveillance & welfare support
6-4 Psychological health
Vocational Education and Training
8-1 Risks related to simultaneous activities occurring during ship recycling process.
8-7 Understanding and applying hot work safety of workers.
8-9 Safety and environmental training, practical training
8-10 Maintenance of the equipment.
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Table 10-8 Proposed Training Courses (contd.)
Training Course Contents

IV TOP MANAGEMENT COURSE 1) Organizer：GMB ＆ SRIA
（Course No. IV） 2) Consultant: Class NK
3）Trainee
Special Course for the Top ①Management of Ship Recyclers at Alang/ Sosiya
Management of 70Plots , SOC by Class NK（70）
Guidance of HKC ②GMB Administration
③SRIA Board members
What is HKC & What is SBC for ④Officer from DISH
the Ship Recyclers In case participants more than 80 shall be divided into
two Group
4) Contents of Study:
Hong Kong Convention
Introduction of the HKC
Improvement of the Yard
SRF and Required Facility Preparation of SRFP
Health and Safety of the workers Environment
Management Policy for the new ship Recycling
5）This course expected consultancy of Support of Class
NK
V TOP MANAGEMENT COURSE Organization: GMB/ JICA (Consultant nominated)
(Training in Japan) Participants:
Top Management of Recyclers (Alang Sosiya) 20 nos.
GMB, SRIA,DASH etc.5 nos. Total 25 nos.
Contents of Training:
1) Training total 10days inclusive travel
2) Venue: JICA Facility Class Room+ Dormitories
3) Program
3-1 Present situation of world shipping ind. + focus on
future
3-2 Meeting with MLIT Maritime Board (Project,
HKC)
3-3 Meeting with Japanese Ship Owners Association
3-4 Meeting with a group of shipping companies
3-5 Meeting with JICA(Project )
3-6 Treatment of Hazardous material in Japan(Asbestos
etc)
3-7 Site visit disposal of Haz MAT
3-8 Discussion Building up Japan-India Collaboration
Scheme
3-9 Presentation of Study Report / Group Discussion
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V TRAINING of Middle 1) Organization：GMB & SRIA

Management 2) Training Items
Middle management of Ship Understanding National Regulation and International
Recyclers Ship Recycling Convention
Safety and Health of workers on site
Training and Development of Manpower
Detail Understanding of Requirement of HKC
Detail Study of contents:
1) Improvement of Recycling Yard
2) Improvement of management of Recycling Yard
3) Understanding of HKC
4) Detail Requirement of SRF and SRFP
5) Role of Middle management of Recycler：
Expected Trainee
①Site manager , Safety Manager of the Ship Recyclers
at Alang/ Sosiya
②General manager、Administration Manager
Officer in charge of Training
③GMB Instructor of Alang Training Center /GMB
SRIA Member of Board
DISH Officer in charge
Note: This Training course is a good opportunity for the
people to understand ship Recycling Industry and HKC
VII TRAINING COURSE OF HKC Requires continuous Training course
TRAINERS 1) Instructors of GMB and Recyclers Instructors shall
organize across Alang/ Sosiya Safety committee to
promote and to enhance safety environment. Under the
guidance of Safety Management Specialist.
2) To undertake following activity , safety GMB
Instructors and officers of each ship recyclers shall have
a training course to make sure with their fundamentals as
the safety Officers
-Understanding of HKC
-Understanding laws rules related to the Ship Recycling
industry.
3) Safety Officers shall meet periodically with each other
and discuss to find improvement of safety management
of the recycling Yard or Alang/ Sosiya District in
general.
4) Safety officers shall conduct safety training courses at
their own ship recycling yards and at the GMB’s training
Center as well
5) Safety officers and GMB Instructors shall produce
promotion video or CD to use them as Training Material
or their site and any opportunity where such safety
promotion opportunity is available. * Since most of
workers in Alang / Sosiya are migrant and low literacy
and language problem exists therefor VIDEO Or OHP or
Animation Film would be the best means to have their
attention.
8 TRAINING COURSE OF CRANE Introduction of big Crane and Operation Training
OPERATORS Operation , Maintenance Safety Instructions
Safety Operation of Crane on board of vessels
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9 TRAINING COURSE OF Promotion of Horizontal Relationship amongst the

SAFETY OFFICERS Safety Officers of the Ship Recyclers
Safety Instruction of the concerned authority
Improvement of safety Equipment
Safety Patrol by the Safety Officers
Panel Discussion to ensure safe work site and healthy
working Environment
Source: JICA study team
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11. ENVIRONMENT AND SOCIAL CONSIDERATION

11.1. PROJECT DESCRIPTION
11.1.1. BACKGROUND
Alang / Sosiya ship recycling yard (hereinafter “ASSRY”) stretches over a 10 km stretch of coastline
along the western shore of Gulf of Khambat in the state of Gujarat. The ASSRY started its operation in
1983, mainly to serve the rising demand for steel melting scrap in the north/west region of India. The
Alang / Sosiya area was selected as an ideal location for ship recycling due to the unique geographical
features of the area including a high tidal range and wide intertidal area, which makes any size ships to
be beached easily during high tide. With the increasing growth of ASSRY, the Alang / Sosiya area was
designated as Industrial Notified Area in year 2000 covering an area of around 1,252 ha. Presently, most
of the ship recycling activity in India is undertaken in ASSRY.
The ASSRY is divided into 153 plots. These plots are owned by Gujarat Maritime Board (GMB) and
are leased to private ship recycling operators for them to carry out ship recycling activities (around 130
plots are currently in operation). Out of these plots, only around 35 plots are presently certified with
Statement of Compliance (SOC) under the Hong Kong Convention (HKC), hence improvements and
certification of other plots are in urgent need before HKC enters into force. GMB is in process of issuing
compulsory provision to make all the yards improved in one-year time till July 2018, and beyond GMB
will carry out yard improvement through JICA’s loan. In addition, other related facilities such as the
existing waste treatment, storage, disposal facility (TSDF) and occupational safety measures will need
further improvement so to make ship recycling activities in Alang / Sosiya more environmentally
sustainable and safer. Figure 11-1 shows the location of ASSRY and TSDF.
Figure 11-1 Location of ASSRY and TSDF

Source: JICA Study Team (prepared with Google Earth)
11.1.2. SHIP RECYCLING PROCEDURE
Ship recycling in ASSRY is conducted by “beaching method” where the ships are dismantled in the
inter-tidal zone after grounding the ship during high tide. The main recycling procedures are as follows:
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 Ship bound for ship recycling initially anchor at a designated offshore anchoring point (Ghoga)
after obtaining Anchoring Permission.
 The anchored ship is then inspected onboard and if cleared, ship will be issued Beaching
Permission which allows the ship to be beached at the recycling yard.
 Once the ship is beached, ship breaking can proceed once all onboard hazardous substances (e.g.
residual oil, bilge, asbestos) are removed and necessary permits are obtained (e.g.
Decontamination Certificate, Breaking Permission).
 The dismantled ship parts are moved to the recycling yard cutting area with winch and crane,
which will be cut further into smaller pieces by gas cutting.
 Steel plates and other sellable materials will be delivered to recyclers and the remaining wastes
(around 0.01% of LDT) will be transported to TSDF for treatment/disposal.
11.1.3. PROJECT SCOPE
(1) Improvement of existing ship recycling yards

Seventy existing ship recycling plots will be improved to the standard as per requirement of the Hong
Kong Convention (HKC). The target plots will be determined in the ensuing stages through discussions
between GMB, SRIA, recyclers and other stakeholders. Improvement works will mainly consist of the
following:
 Construction of impermeable concrete floor at ship-parts cutting areas, oily-machinery storage

areas and winch operation areas. The concrete floor will be a three-layered structure, consisting
of crushed stone foundation, geomembrane and concrete layers.
 Construction of rainwater collection ditch and tank to collect rainwater runoff from the concrete
floor areas.
 Construction of winch foundation.
In addition, the following facilities will be installed at each recycling plots by the yard operators.
 Temporary storage house for hazardous wastes
 Storage house for LPG cylinders
 Asbestos handling facility (not required if asbestos handling is outsourced)
 Sanitary, drinking water and shower facilities
 Workers changing room
 First aid facility
 Firefighting facility
 Sewage treatment facility (e.g. septic tank)
Figure 11-2 shows an example layout of an improved recycling yard. Figure 11-3 shows cross-section
design of the concrete flooring. Figure 11-4 shows image of an improved yard
189
Figure 11-2 Example layout of an improved recycling yard

190
Figure 11-3 Cross-section design of concrete flooring

Note: Upper diagram is cross-section of concrete flooring and rainwater collection ditch. Lower diagram is cross-section
of rainwater collection tank.
191
Concrete-floored cutting zone Concrete-floored storage zone
Rainwater collection ditch Rainwater collection tank
Figure 11-4 Image of improved recycling yard

(2) Improvement of TSDF

1) Overview of existing TSDF facilities
TSDF is located around 2 km inland from the ASSRY. The facilities include incinerator
(capacity: 5 t/day), effluent treatment plant (ETP) (capacity: 30 m3/day), landfill for hazardous
wastes (capacity: 70,000 m3), landfill for non-hazardous wastes (capacity: 30,000 m3) and
temporary waste storage area. There is also fire-fighting system having one underground reservoir
of 200 m3 and two over ground reservoir of 5 m3. TSDF was constructed in 2005 and upgraded in
2011 by GMB. In 2005, initially, GMB constructed three cells i.e. disposal for asbestos & glass
wool wastes (43,000 m3), disposal for industrial hazardous wastes (10,200 m3) and disposal for
municipal solid wastes (8,700 m3) and started operation from 2006. Than after, the TSDF facility
was upgraded by developing two more landfill cells for hazardous wastes (capacity: 70,000 m3),
landfill for non-hazardous wastes (capacity: 30,000 m3) and incinerator (capacity: 5 t/day), effluent
treatment plant (ETP) (capacity: 30 m3/day) and firefighting system. TSDF was constructed in 2005
by GMB and started operation from 2006. The facility is currently operated by a private operator
(GEPIL). Figure 11-5 shows the existing layout of TSDF.
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Figure 11-5 Existing layout of TSDF

Note: The green colored area is currently not used and is the candidate sites for expansion.
2) Overview of TSDF improvement plan
The TSDF will be improved by installing baler, sludge treatment plant, oily water collection
tank, oily water separation system, effluent treatment plant (ETP) and high-temp incinerator. These
facilities will contribute in extending the life-span of the TSDF landfill, stabilization of hazardous
wastes and enhance oil recovery. Brief descriptions of each facility are provided below.
a. Baler
Two balers (capacity: 40 m3/day) will be installed to reduce the volume of wastes unsuitable of
incineration such as glass wool.
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Figure 11-6 Image of baler

b. Sludge treatment plant

Sludge treatment plant (capacity: 8 tons/day) will be installed to recover oil from oily sludge
generated from recycling activities. The recovered oil can be sold and the remaining sludge will
be disposed in the TSDF controlled landfill after drying.
c. Oily water collection tank

Oily water collection tank (capacity: 200 m3) will be installed to collect and separate low-oil
content oily water (e.g. bilge water) generated from recycling activities. The tank applies heat to
enhance oil/water separation. The separated water, which will still contain some amount of oil,
will be sent to existing ETP for final treatment. The separated and more concentrated oily water
will be sent to oil/water separation system for further treatment.
d. Oil/water separation system

Oil/water separation system (capacity: 16 tons/day) will be installed to separate high-oil
content oily water generated from recycling activities. The recovered oil can be sold and the
remaining sludge will be sent to the new oil sludge treatment plant for further treatment. The
separated water, which will still contain some oil, will be sent to ETP for final treatment.
e. Effluent treatment plant (ETP)

A new ETP (capacity: 120 m3/day) will be installed to treat the additional wastewater that will
be generated through this Project. The treated effluent will be reused inside TSDF or if necessary
discharged outside TSDF as per Indian effluent discharge standard. The remaining sludge will be
sent to the landfill for hazardous wastes after drying. Figure 11-7 shows the wastewater treatment
process of the improved TSDF.
194
Figure 11-7 Wastewater treatment process of improved TSDF
Note: Dotted boxes indicate new facilities that will be installed through the Project.
195
f. High-temp incinerator
A high-temp incinerator (treatment capacity: 5 tons/day, incineration temp.: 1,400 °C) will be
installed to thermally treat persistent hazardous wastes including PCB containing materials. The
incinerator will also contribute to waste reduction and stabilization of hazardous wastes disposed
at the TSDF landfill. Flue gas will be treated through gas cooler and dust collector system prior
to discharge. Bottom ash can be used as recycling material and fly ash will be disposed at the
landfill.
3) Introduction of Mobile Decontamination System (MDS)
Mobile Decontamination System (MDS) will be introduced to mechanically and efficiently

remove residual oil and sludge remaining inside beached ships, which currently are removed by
hand using wood chips/sand. Five MDS units will be introduced and their operation will be
consigned to a private operator.
4) Introduction of large crawler crane and beach cleaner
Large mobile crane (120 t telescopic boom crawler crane) will be introduced to employ an
alternative way for dismantling ships, specifically for large bulk carriers and container ships.
Currently, to reduce the weight of large ships and enable easier winching, the heavy stern section of
the ship is initially cut off from the ship body and dropped on to the intertidal zone. However, such
practice may lead to oil spills/leakages which can be avoided by using large mobile crane. This is
because heavy blocks and engines parts in the stern section can be removed from inside the ship by
employing large mobile cranes, hence preventing the need of cutting-off of stern section. Five large
mobile cranes will be procured and their operation will be consigned to a private operator.
Beach cleaning wheel loader will be introduced to remove debris left over in the beach area
through ship dismantling works. Three units will be procured.
5) Introduction of offshore tank cleaning barge
Offshore tank cleaning barge will be introduced to remove oily water and sludge from oil
tankers. The collected oily water and sludge will be transported to TSDF for treatment and disposal.
However, to reduce the volume of oily water treatment at TSDF, low-oil content oily water will be
discharged to sea from the barge after treatment through onboard ETP. Operation of the offshore
tank cleaning barge will be consigned to a private operator.
The collected oily water and sludge will be unloaded via a new jetty (50 m length x 10 m width)
that will be constructed at the southern end of the recycling yard next to plot 84. An access road of
approximately 50 m length will also be constructed by expansion and pavement of existing dirt
road. Figure 11-8 shows the approximate location and layout of the new unloading jetty and access
road. Figure 11-9 shows the basic design of the new unloading jetty.
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Figure 11-8 Approximate location and layout of the new unloading jetty and access road
Figure 11-9 Basic design of the new unloading jetty

6) Introduction of multi-purpose work boat
A multi-purpose work boat will be procured to use for oil spill recovery, firefighting, rescue and
so on.
197
11.1.4. RISKS OF CLIMATE CHANGE
A possible risk on this Project due to climate change is the inundation of the ASSRY by rise in sea level.
According to the IPCC’s Fifth Assessment Report, global average sea level is predicted to rise by around
10-20 cm by 2040. However, since the lowest point of the ASSRY is approximately 1.5 m higher than
the mean spring tide high tide level (CDL+7.05), the risk of inundation can be considered negligible at
least until 2040.
11.1.5. CONSTRUCITON PLAN
(1) Construction method

1) Ship recycling yard
Following is a brief description of the construction process of ship recycling yard improvement
works:
 Excavation and compaction of concrete flooring area
 Laying of crushed stone as foundation of concrete flooring area
 Laying of geomembrane on top of stone foundation layer
 Placement of concrete floor on top of geomembrane layer
(2) Temporary facilities

A temporary concrete batching plant (approx. area: 2,500 m2) and pre-casting yard will be established
near the Project site. The location will be determined by the construction contractor. A temporary
material storage yard (approx. area: 2,800 m2) will also be established to store construction materials
such as stones and metal bars. It is planned to use one of the empty plots for this purpose.
(3) Construction materials

Main construction materials required will be soil, sand/aggregates stone, metal bars, cement,
geomembrane, wood, steel and so on. All these materials will be procured from local suppliers.
Development of a new quarry will not be required.
(4) Construction machines

Table 11-1 shows the main construction machines and equipment required.
Table 11-1 Main construction machines and equipment
Backhoe (0.6 m3) Macadam roller (10～12 t)

Dump truck (10 t) Wheel loader (2.1 m3)
Bulldozer (21) Excavator (0.7 m3)
Truck crane (25-50t) Hydraulic breaker (1 t)
Breaker (600-800kg) Concrete mixer (7.0 m3)
Concrete cutter Welder (300 A)
Compressor (3.5～3.7 m3/h) Road roller (0.8～1.1 t)
Motor grader (3.1 m) Generator (45 KVA)
(5) Construction workers
198
Table 11-2 shows the type and number of construction workers required, which assumes simultaneous
construction of 4 plots.
Table 11-2 Type and number of construction workers
Type No.
Site Engineer 4
Surveyor 4
Foremen 4
Carpenter 8
Re-bar Vendor 8
Plaster 12
Skilled Worker 8
Unskilled Worker 60
Total 108
(6) Construction schedule

Table 11-3 shows the construction schedule. Construction will take around 2 years from start to
completion.
Table 11-3 Construction schedule

Y 1 2
Item Quant. Remark
M 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24
Preliminary work set
Yard renovation 5Plot 5Plot 5Plot 5Plot 5Plot
W = 45m 25Plot 4Month/Plot
work (1)
Yard renovation 8Plot 7Plot 8Plot 7Plot
work (2)
Construction
Yard renovation 5Plot 5Plot

work (3)
Yard renovation 3Plot 2Plot
W =120m 5Plot 8Month/Plot
work (4)
New Jetty L = 50m set
TSDF set
Demobilization work set
Selection & Ordering set

Production &
Procurement
set
Inspection
Shipping &
set
Transportation
Loading &
set
Installation
Adjustment &
set
Commissioning /
Others
(7) Construction waste

Construction waste will include among others the following:
 Used formwork (wood): approx. 5 t
 Concrete debris: 160 m3
 Metal scrap: 4 t
 Domestic waste: 35 t
199
11.1.6. STATUS OF EIA AND GAPS WITH JICA GUIDELINE
(1) Status of the existing EIA

GMB contracted MECON Ltd for the preparation of the EIA of this Project. Environmental Clearance
(EC) was obtained from MoEFCC in November 2nd, 2016. Following is a brief summary of the
processes taken until obtaining EC:
 GMB submitted project application to MoEFCC in September 2014.

 TOR of EIA was reviewed at the EAC meeting on December 2014 and final version issued to
GMB on December 2014.
 GMB submitted EIA report to MoEFCC in June 2016.
 EIA report was reviewed at the EAC meeting in July 2016. Submission of additional information
was requested to GMB.
 After submission of additional information, the EIA report was again reviewed at the EAC
meeting in September 2016. EAC recommended issuance of EC to MoEFCC under 19
conditions.
 MoEFCC issued EC dated November 2nd, 2016 under 33 specific conditions and 8 general
conditions (EC is attached as Appendix xx)
(2) Gaps with JICA guideline and supplementary EIA study

The JICA Study Team initially reviewed the EIA (November 2015 version) prepared by GMB, taking
into account the requirements of JICA Guideline for Environment and Social Consideration (2010). The
following gaps and issues were identified in the process:
 The scope of the Project has changed from the approved EIA. Main changes are as follows:
 Construction of dry dock and associated capital dredging are not included in the updated
Project scope.
 Construction of 15 new ship recycling yards are not included in the updated Project scope.
 Mobile decontamination system, tank cleaning barge and associated jetty/access road, large
mobile crane and multi-purpose vessel are new additions to the Project and hence not
included in the EIA.
 The treatment capacity of the new effluent treatment plant (ETP) in TSDF has changed
from 30 t/day to 120 t/day.
 The treatment capacity of the new incinerator in TSDF has changed from 25 t/day to 5 t/day.
 Although the approved EIA covered wide range of baseline data to be sufficient for being
appraised by MOEF&CC, the JICA survey team proposed additional baseline survey on
sediment quality, soil quality (around TSDF and yard area), air quality (asbestos) and
groundwater quality (around TSDF and yard area).
 Under the JICA Guideline, it is necessary to illustrate impacts during the construction as well.
A public hearing was conducted at the draft EIA stage in accordance with Indian regulation,
however the JICA Guideline stated holding consultations is highly desirable, especially when
the items to be considered in the EIA are being selected (scoping stage), and when the draft
report is being prepared.
Considering the above points as well as recommendations from the JICA Environmental Advisory
Committee (EAC), the JICA Study Team conducted a supplementary EIA study as per the updated
scope of the Project. In summary, the following study was conducted as part of the supplementary EIA
study.
 Implementation of baseline environmental survey for sediment quality, soil quality, air quality
(asbestos) and groundwater quality. As per recommendation of JICA EAC, TBT accumulation in
benthos was also studied. All the surveys were subcontracted to Chola MS Risk Services.
Laboratory analysis was conducted by Chennai Testing Laboratory Private Limited (CTL), a
200
National Accreditation Board for Testing and Calibration Laboratories (NABL) and ISO/IEC
17025:2005 certified laboratory.
 Impact assessment for the construction stage based on the construction plan and preparation of
construction EMP and EMoP.
 Impact assessment for the operation stage based on the updated Project scope and preparation of
EMP and EMoP.
 Stakeholder consultation in the scoping and draft final reporting stages.
(3) Amendment of the existing EIA

The approved EIA study commissioned by MECON is required to be updated since the scope of the
Project has changed from the approved EIA as per JICA’s Preparatory survey. This process will be done
during the detailed design stage of the Project.
11.2. REGULATORY FRAMEWORK

11.2.1. ENVIRONMENTAL LAWS AND REGULATIONS
(1) EIA system

1) EIA procedure
India’s EIA system is prescribed in detail under EIA Notification 2006. Projects prescribed under
EIA Notification must obtain Environmental Clearance (EC). The Ministry of Environment and
Forest and Climate Change (MoEFCC) issues EC for Category A projects, and the State
Environment Impact Assessment Authority (SEIAA) for Category B projects. Ship recycling
projects are classified as Category A regardless of the project scale.
In India’s EIA system, Expert Appraisal Committee (EAC) play’s an important role in the EIA
procedure. They determine the TOR of the EIA and also review and make recommendations to
MoEFCC on the submitted EIA. Public hearing is required in the draft EIA stage which is held by
SPCB. Information on the EIA is disclosed to the public at key stages. Figure 11-10 shows the main
procedures involved for acquiring EC.
201
Submission of project application and draft TOR of EIA
Finalization of TOR of EIA by EAC (within 60 days)
Preparation of draft EIA
Disclosure of draft EIA

Disclosure through through SPCB website
Application for public hearing
MoEFCC website
Disclosure of minutes of
Holding of public hearing by SPCB (within 45 days) public hearing through
SPCB website
Finalization and submission of EIA report
Review of EIA by EAC and submit recommendations to MoEFCC (within 60 days)
Decision of MoEFCC to whether issue EC based on EAC recommendations (within 45 days)
Issuance of EC
Source: EIA Notification 2006
Figure 11-10 Main procedures required for acquiring EC
2) Contents of EIA
The EIA report is required to include the following contents as per EIA Notification 2006:
 Project description
 Description of the environment
 Anticipated environmental impacts and mitigation measures
 Analysis of alternatives
 Environmental monitoring program
 Description of the environment
 Additional studies (public consultation, risk assessment, social impact assessment)
 Project benefits
 Environmental management plan
3) Gaps between JICA environmental guideline
There are no major gaps between India’s EIA system and JICA environmental guideline.
However, there is no requirement to conduct stakeholder consultation in the scoping stage, which is
required under JICA environmental guideline. Table 11-4 shows gaps between India’s EIA law and
JICA environmental guideline and the Project’s policy to fill the gaps.
202
Table 11-4 Gaps between India’s EIA law and JICA environmental guideline and the Project’s policy to
fill the gaps
JICA Environmental Guideline India EIA law

No. Gap Project policy
(2010) (EIA Notification 2006)
1 When assessment procedures It is required to obtain None －
already exist in host countries, and Environmental Clearance
projects are subject to such (EC) for projects prescribed in
procedures, project proponents etc. the EIA Notification. Ship
must officially finish those recycling projects are subject
procedures and obtain the approval to EC.
of the government of the host
country.
2 EIA reports must be written in the Summary of draft EIA is None －
official language or in a language required to be prepared in
widely used in the country in English and local language
which the project is to be and disclosed prior to public
implemented. When explaining hearing.
projects to local residents, written
materials must be provided in a
language and form understandable
to them.
3 EIA reports are required to be TOR of EIA, summary of None －
made available to the local draft EIA, minutes of EAC are
residents of the country in which required to be disclosed
the project is to be implemented. through website. Draft EIA
The EIA reports are required to be must also be available for
available at all times for perusal by viewing if requested.
project stakeholders such as local
residents and copying must be
permitted.
4 In preparing EIA reports, Public hearing is required at None －
consultations with stakeholders, the draft EIA stage. Minutes
such as local residents, must take of the meeting is disclosed at
place after sufficient information SPCB website.
has been disclosed. Records of
such consultations must be
prepared.
5 Consultations with relevant Stakeholder consultation is No Stakeholder
stakeholders, such as local required only in the draft EIA requiremen meetings will be
residents, should take place if stage. t at scoping held at the
necessary throughout the stage. scoping and draft
preparation and implementation EIA though the
stages of a project. Holding JICA Preparatory
consultations is highly desirable, Survey.
especially when the items to be
considered in the EIA are being
selected, and when the draft report
is being prepared
6 It is desirable that EIA reports EIA is required to include the None －
cover the items enumerated in the following:
following:  Project description
 Executive summary  Baseline data
 Project description  Impact assessment and
 Baseline data mitigation measures
 Environmental impacts  Analysis of alternatives
203
JICA Environmental Guideline India EIA law

No. Gap Project policy
(2010) (EIA Notification 2006)
 Analysis of alternatives  Environmental monitoring
 Environmental Management plan
Plan  Other studies (public
 Consultation consultation, risk
assessment, social impact
assessment)
 Project benefit
 Environmental Management
Plan
(2) CRZ Notification

As per CRZ Notification 2011, ship breaking projects are required to obtain CRZ clearance from
MoEFCC. The main procedures for obtaining CRZ clearance are as follows:
 Submission of Project documents (e.g. EIA report, CRZ map) to state Coastal Zone Management
Authority (CZMA).
 Review of documents by CZMA and submit recommendations to MoEFCC within 60 days.
 Decision of MoEFCC to issue CRZ clearance based on recommendations of CZMA within 60
days.
CRZ clearance of this Project has been acquired from MoEFCC in November 2nd, 2016, together with
the issuance of EC. Recommendation letter issued by CZMA to MoEFCC is attached as Appendix xx.
(3) GPCB permits

Table 11-5 shows the permits required from GPCB for this Project.
Table 11-5 List of permits required from GPCB
Responsible Timing of
Component Type of permit
organization acquisition
Consolidated
Consent and Before
Improved TSDF GMB/TSDF operator
Authorization operation
(CC&A)
Consolidated
Consent and Before
Improved yard Yard operator
Authorization operation
(CC&A)
Consent to
Temporary concrete plant for Construction Before
Establish (CTE)
construction contractor construction
and CC&A
11.2.2. ENVIRONMENTAL LAWS AND REGULATIONS
Table 11-6 shows the national environmental laws/regulations relevant to this Project.
204
Table 11-6 List of national environmental laws/regulations relevant to this Project
Category Name
Basic law Environment (Protection) Act 1986
Environment (Protection) Rules 1986
Natural Forest Conservation Act 1980
environment Wildlife (Protection) Act, 1972
CRZ CRZ Notification 2011
EIA EIA Notification 2006
Pollution Air (Prevention and Control of Pollution) Act 1981
Water (Prevention and Control of Pollution) Act 1974
Noise Pollution (Regulation and Control) Rules 2000
Central Motor Vehicles Rules, 1989
Waste Hazardous Waste (Management Handling and Transboundary
Movement) Rules 2008
Municipal Solid Wastes (Management and Handling) Rules 2000
Construction and Demolition Waste Management Rules 2016
Plastic Waste Management Rules 2016
Batteries (Management and Handling) Rules 2001
E-Waste (Management and Handling) Rules 2016
Labor safety Factories Act 1948
Gujarat Factories Rules 1963
11.2.3. ENVIRONMENTAL STANDARDS
Table 11-7 shows the national environmental standards relevant to this Project.
Table 11-7 List of national environmental standards relevant to this Project
Category Name
Ambient air quality National Ambient Air Quality Standards 2009
Stack emission gas Environment (Protection) Rules 1986: Common Hazardous
Waste Incinerator
CPCB Norms for Stack monitoring.
Noise Noise Pollution (Regulation and Control) Rules 2000
Seawater quality Environment (Protection) Rules 1986: Primary Water
Quality Criteria
Drinking water quality Drinking Water Specification IS:10500 (2012)
General discharge standard Environment (Protection) Rules 1986: General Standards for
Discharge of Environmental Pollutants
Discharge standard from ETP Environment (Protection) Rules 2015: Treated Effluent
Quality of Common Effluent Treatment Plant
11.2.4. ENVIRONMENTAL GUIDELINES
Table 11-8 shows the national environmental guidelines relevant to this Project.
205
Table 11-8 List of national environmental guidelines relevant to this Project
Category Name Organization

EIA Technical EIA Guidance Manual for Ship Breaking Yards 2009 MOEF
Waste Guidelines for Common Hazardous Waste Incineration 2012 CPCB
Guidelines for Storage of Incinerable Hazardous Wastes by the Operators CPCB
of Common Hazardous Waste Treatment, Storage and Disposal Facilities
and Captive HW Incinerators 2008
Protocol for Performance Evaluation and Monitoring of the Common CPCB
Hazardous Waste Treatment Storage and Disposal Facilities including
Common Hazardous Waste Incinerators 2010
11.2.5. INTERNATIONAL CONVENTIONS
Following is a list of relevant international conventions ratified by India.

 Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their
Disposal
 Stockholm Convention on Persistent Organic Pollutants
 International Convention on the Control of Harmful Anti-fouling Systems on Ships
 International Convention for the Prevention of Pollution from Ships
11.3. CURRENT ENVIRONMENTAL STATUS

11.3.1. CLIMATE
The climate in Alang/Sosiya is broadly separated into three seasons: hot summer season (March-June),
mild winter season (December-February) and south-west monsoon season (June-September). Average
maximum temperature in summer and winter are around 40 °C and 30 °C respectively. Annual rainfall is
about 700 mm, which falls mainly in the monsoon season. Wind direction is predominantly from north-
west to south west.
11.3.2. HYDROLOGY
(1) Marine area

Alang/Sosiya area has a tidal difference of over 6 m during spring tide. Coastal currents are strong due
this large tidal difference. Coastal wave action is limited partly due to the attenuation effects of the
offshore reefs.
(2) Surface water

There are two rivers in the Alang/Sosiya area namely Manar and Pasvivali rivers. The river mouths of
these rivers are blocked by a fixed weir. There is also a river (Kathodi river) adjacent to TSDF but is
mostly dry except the monsoon season.
11.3.3. TOPOGRAPHY
A shallow rocky reef of approximately 500-1,500 m width extends along the coastal area of
Alang/Sosiya. Mud and sand accumulates on top of these reefs to create mud flats. A sandy beach of
206
approximately 25-200 m width runs along the shore. Figure 11-11 is a nautical chart around the
Alang/Sosiya area.
Source: JICA (2015), The Data Collection Survey on Ship Recycling in India
Figure 11-11 Nautical chart around the Alang/Sosiya area
MoEFCC assesses the coastal erosion/accretion status along the Indian coastline through the National
Assessment of Shoreline Change program. Figure 11-12 shows the coastal assessment made for the
Alang/Sosiya area.
Source: National Assessment of Shoreline Change
207
Figure 11-12 Coastal assessment of the Alang/Sosiya area
The EIA compares the coastline along the Alang area by using satellite image of years 2000 and 2008
(see Figure 11-13). No significant erosion or accretion are identified, which is consistent with the
assessment of National Assessment of Shoreline Change.
Figure 11-13 Comparison of Alang coastline between years 2000 and 2008
11.3.4. POLLUTION
(1) Air quality

1) Ambient air quality
Air quality survey was conducted through the EIA during March-May 2015 at 5 sites around
Alang/Sosiya. Surveyed parameters were PM10, PM2.5, SO2, NOx and CO. Figure 11-14 shows
the sampling sites. Table 11-9 shows the survey results. Table 11-10 shows the Indian and WHO air
quality standards.
208
Figure 11-14 Location of EIA air quality sampling sites
Table 11-9 Results of EIA air quality survey
PM10 (µg/m3) PM2.5 (µg/m3) SO2 (µg/m3) NOx (µg/m3) CO (µg/m3)

Max Min C98 Max Min C98 Max Min C98 Max Min C98 Max Min C98
A1 114 56 98 63 26 58 11.2 4.5 9.6 45.5 20.2 44.0 1.32 0.08 1.06
A2 111 48 98 66 22 58 10.5 4.5 10.2 32.2 12.2 32.2 0.99 0.08 0.80
A3 98 45 97 56 23 55 9.6 4.2 9.6 34.5 12.2 31.2 0.88 0.07 0.82
A4 94 31 87 45 14 44 9.2 4.2 8.5 34.8 13.1 31.2 0.99 0.06 0.75
A5 97 48 96 52 22 50 8.5 4.5 7.9 30.2 14.2 27.5 0.92 0.06 0.75
Table 11-10 Ambient air quality standard of India and WHO
National ambient air quality standard

2009*1 WHO ambient air quality guideline
Unit
(Industrial, residential, rural and other (Interim target 2*2)
area)
PM10 µg/m3 100 (24 hour) 100 (24 hour)
PM2.5 µg/m3 60 (24 hour) 50 (24 hour)
SO2 µg/m3 80 (24 hour) 50 (24 hour)
NO2 µg/m3 80 (24 hour) 200 (1 hour)
CO mg/m3 2 (8 hour) -
Following are the main findings of the survey:
209
 For PM10, C98 values of all sites satisfied the 24 hour Indian standard.
 For PM2.5, C98 values of all sites satisfied the 24 hour Indian standard.
 For SO2, NOx and CO, C98 values of all sites satisfied the 24 hour Indian standard.
2) Air quality inside recycling yard/TSDF
Air quality survey was also conducted through the EIA at two yards and inside TSDF. Surveyed
parameters were PM10, PM2.5, SO2, NOx and CO. Table 11-11 shows the survey results.
PM10 exceeded Indian standard at all the sites. PM2.5 exceeded Indian standard at one yard and
at TSDF. Fugitive dust emission from yard activities are likely cause of high PM levels. CO levels
exceeded Indian standard at one yard. SO2 and NOx were under Indian standard at all the sites.
Table 11-11 Results of EIA air quality survey at recycling yard and TSDF
3) JICA supplementary survey (asbestos)
Since the EIA lacked baseline asbestos data (as no asbestos removal works were done during the
course of EIA), asbestos survey was conducted in October 2016. Asbestos sampling was
implemented at plot 66 (non-certified yard) when asbestos removal works were ongoing on the ship
(ship name: MV Suchada Naree, ship type: bulk carrier) and inside the ship breaking yard with
mobile asbestos decontamination system. Asbestos was also sampled at TSDF’s asbestos disposal
site. Sampling was conducted for 30 minutes at each site, during which air was drawn at a rate of 2
liters/minute. Table 11-12 shows the location of the asbestos sampling sites. Figure 11-15 shows
the location of the asbestos sampling sites at the ship breaking yard. Sampling and analysis were
conducted in accordance to OSHA method ID-160.
Table 11-12 Location of asbestos sampling sites
Location Latitude Longitude

A Outlet of Mobile Asbestos Decontamination Unit 21º23’08.05”N 72º10’12.13”E
B Outlet of Mobile Asbestos Decontamination Unit 21º23’08.05”N 72º10’12.13”E
C Inside ship breaking yard 21º23’08.43”N 72º10’12.44”E
D Inside ship breaking yard 21º23’07.20”N 72º10’11.63”E
E Outside ship breaking yard 21º23’08.68”N 72º10’11.58”E
F Outside ship breaking yard 21º23’08.24”N 72º10’11.17”E
G Near TSDF asbestos disposal area 21º24’51.84”N 72º09’39.23”E
H Near TSDF asbestos disposal area 21º24’51.84”N 72º09’39.23”E
I Inside ship adjacent to asbestos removal activity 21º23’03.22”N 72º10’12.55”E
J Inside ship adjacent to asbestos removal activity 21º23’03.22”N 72º10’12.55”E
210
Figure 11-15 Location of asbestos sampling sites at the ship breaking yard
Note: Mobile Asbestos Decontamination Unit was parked near sites A&B.
Table 11-13 shows the results of the asbestos survey. Apart from sites E and F, the results were
compared with OSHA asbestos work environment standard for shipyard employment (1915.1001).
Results of sites E and F were compared with Japanese standard for boundary of asbestos handling
factories set under Japan’s Air Pollution Control Act.
Table 11-13 Results of asbestos survey
Results OSHA*1 Japan*2

Location
(f/cc) (f/cc) (f/cc)
A Outlet of Mobile Asbestos Decontamination Unit 0.034 0.1 －
B Outlet of Mobile Asbestos Decontamination Unit 0.050 0.1 －
C Inside ship breaking yard 0.084 0.1 －
D Inside ship breaking yard 0.000 0.1 －
E Outside ship recycling yard 0.034 － 0.01
F Outside ship recycling yard 0.050 － 0.01
G Near TSDF asbestos disposal area 0.101 0.1 －
H Near TSDF asbestos disposal area 0.017 0.1 －
I Inside ship adjacent to asbestos removal activity 0.034 0.1 －
J Inside ship adjacent to asbestos removal activity 0.050 0.1 －
f/cc: fiber per cubic centimeter of air
*1: OSHA asbestos work environment standard for shipyard employment (1915.1001)
*2: Japanese standard set under Air Pollution Control Act: applied to boundary of asbestos handling factories
Asbestos concentration at sites I and J (inside ship) and sites A-D (inside yard) were all below
the OSHA standard (0.1 f/cc), which implies that asbestos removal and handling works are
undertaken in an appropriate manner. Asbestos concentration at TSDF disposal site (site G) very
211
slightly exceeded the OSHA standard despite the fact that asbestos wastes are contained within
leak-proof bags throughout the transportation and solidification treatment processes. Following are
possible reasons why asbestos were detected at TSDF disposal site:
 Although asbestos are transported and disposed at TSDF in leak-roof bags, there might have
been some accidental leaks during the transportation and storage process for example
through tear in the leak-roof bags.
 There might have been some error during the analysis for example by miscounting with
glasswool fibers which were abundant in the vicinity of the sampling site.
Asbestos concentration at the boundary of the ship recycling yard (site E, F) exceeded the
Japanese standard (0.01 f/cc) although their concentration was below OSHA standard (0.1 f/cc).
This may be due to the proximity between the yard boundary and Mobile Asbestos
Decontamination Unit (the laboratory report is attached as Appendix xx).
(2) Water quality

1) Seawater
The EIA has conducted seawater quality survey in May 2015 at 8 locations around the Project
sites. Figure 11-16 shows the sampling sites. Table 11-14 shows the Indian seawater quality
standard. Table 11-15 shows the survey results.
Figure 11-16 Location of EIA seawater quality sampling sites
Table 11-14 Seawater quality standard of India
Parameter Indian standard: Primary Water Quality
212
Criteria for Designated Best Uses for

Coastal Waters (harbor waters)
pH 6-9
DO >3.0 mg/l or 40% saturation
Color and odour No noticeable colour or offensive odour
Oil and grease 10 mg/l
Fecal Coliform 500/100 ml (MPN)
BOD 5 mg/l
Source: Environment (Protection) Rules 1986
Table 11-15 Results of EIA seawater quality survey
213
Although BOD levels slightly exceeded Indian standard at one site (SW3), other parameters were
all under Indian standard. Hazardous substances such as heavy metals and PCBs were all below
detection limit.
2) Groundwater
The EIA has conducted groundwater quality survey in May 2015 (dry season) at 4 locations
around the Project sites. Figure 11-17 shows the sampling sites. Table 11-16 shows the survey
results. Since India has no groundwater quality standards, the results are compared with Indian
drinking water standard (IS: 10500, 2012).
214
Figure 11-17 Location of EIA groundwater sampling sites

215
Table 11-16 Results of EIA groundwater quality survey
The results show no contamination by hazardous substances such as heavy metals as they were
all below Indian drinking water standard. However, at some sites, concentration of TDS,
magnesium, nitrate and sulphate exceeded Indian drinking water standard, which may be due to
influences from farmland and sewage.
a. JICA supplementary survey
Since the EIA lacked baseline groundwater quality data around TSDF and ship recycling yard, a
supplementary survey was conducted. Groundwater samples were collected in August 2016 from
wells around TSDF (4 sites) and from inside 2 ship recycling yards (see Figures 11-18 and 11-19
for the sampling locations). In addition, leachate water of TSDF landfill site (Cell 4.1) was also
collected for analysis (GW5). Analyzed parameters are cadmium, hexavalent chromium, lead,
mercury, PCBs, PBBs, PBDEs, PCN, PAHs and TBT, which are except PAHs, hazardous
substances listed in Appendix 1 and 2 of the HKC.
216
Station Latitude Longitude

GW1: groundwater 21°24'41.61"N 72° 09'42.93"E
GW5: Leachate 21°24'51.87"N 72° 09'38.08"E
Figure 11-18 Location of groundwater/leachate sampling sites around TSDF

217
Station Latitude Longitude

GW6: groundwater 21°24'04.51"N 72°11'05.99"E
GW7: groundwater 21°25'40.53"N 72°12'51.21"E
Figure 11-19 Location of groundwater sampling sites at ship recycling yards

Tables 11-17 and 11-18 show the results of the survey for groundwater (GW1-4 and GW6-7) and
leachate (GW5) sites respectively (lab report is attached as Appendix xx). For groundwater, all
parameters except lead were below detection limit. For lead, all sites except GW2 had lead levels
exceeding Indian standard. While the cause of such lead levels are uncertain (i.e. natural or
anthropogenic origin) it should not be interpreted as a representative baseline data of the area as the
results are based on one-time survey in the wet season. Further regular groundwater monitoring will
be necessary to obtain an accurate trend of groundwater quality. For leachate, lead, mercury, PCBs
and PBBs were above detection limit and the others all below detection limit.
For further verification, GMB requested the JICA Study Team to undertake additional survey in
the dry season specifically for parameters that were above Indian standards (i.e. lead) or were
relatively high (i.e. mercury and PCBs).
218
Table 11-17 Results of groundwater quality analysis
GW1 GW2 GW3 GW4 GW6 GW7 Indian Japan

Unit DL Analysis method
(TSDF) (TSDF) (TSDF) (TSDF) (Yard) (Yard) standard*1 standard*2
pH - 8.0 7.6 7.6 7.6 8.0 7.8 6.5-8.5 - IS 3025 (Part 11)-1983 (R.2006)
Salinity ‰ - 1.9 1.01 0.78 0.86 2.72 1.77 - - 2520-B APHA 22nd Ed. 2012
Cd mg/l 0.002 BDL BDL BDL BDL BDL BDL 0.003 0.003 IS 3025 (Part 41)-1992 (R.2009)
Cr+6 mg/l 0.01 BDL BDL BDL BDL BDL BDL - 0.05 3500-Cr-B APHA 22nd Ed. 2012
Pb mg/l 0.005 0.17 BDL 0.15 0.12 0.21 0.19 0.01 0.01 IS 3025 (Part 47)-1994 (R.2009)
Hg mg/l 0.001 BDL BDL BDL BDL BDL BDL 0.001 0.0005 IS 3025 (Part 48)-1994 (R.2009)
PCBs µg/l 0.01 BDL BDL BDL BDL BDL BDL 0.5 ND Annex M of IS 13428-19988TEST
PBBs µg/l 0.01 BDL BDL BDL BDL BDL BDL - - CTL/SOP/WATER/192-2016
PBDEs µg/l 0.01 BDL BDL BDL BDL BDL BDL - - CTL/SOP/WATER/193-2016
PCN µg/l 0.01 BDL BDL BDL BDL BDL BDL - - CTL/SOP/WATER/194-2016
PAHs µg/l 0.03 BDL BDL BDL BDL BDL BDL 0.1 - APHA 22 nd Edition 6440 C
TBT µg/l 0.01 BDL BDL BDL BDL BDL BDL - - CTL/SOP/WATER/195-2016
*1：IS 10500: 2012 (Drinking water)
*2：Japanese Environmental Quality Standards for Groundwater Pollution
DL: Detection limit, BDL: Below Detection Limit, ND: Not to be detected
219
Table 11-18 Results of leachate quality analysis

Unit DL GW5 Analysis method
pH - 7.5 IS3025 (Part 11)-1983 (R.2006)
Salinity ‰ - 8.56 2520-B APHA 22nd Ed. 2012
Cd mg/l 0.002 BDL IS 3025 (Part 41)-1992 (R.2009)
Cr+6 mg/l 0.01 BDL 3500-Cr-B APHA 22nd Ed. 2012
Pb mg/l 0.005 0.99 IS 3025 (Part 47)-1994 (R.2009)
Hg mg/l 0.001 0.01 IS 3025 (Part 48)-1994 (R.2009)
PCBs µg/l 0.01 22.14 Annex M of IS 13428-1998
PBBs µg/l 0.01 3.425 CTL/SOP/WATER/192-2016
PBDEs µg/l 0.01 BDL CTL/SOP/WATER/193-2016
PCN µg/l 0.01 BDL CTL/SOP/WATER/194-2016
APHA 22nd Edition 6440 C
PAHs µg/l 0.05 BDL
CTL/SOP/WATER/102-2012
TBT µg/l 0.01 BDL CTL/SOP/WATER/195-2016
b. JICA additional survey
As per request of GMB, additional groundwater/leachate survey was implemented in February

2017 focusing on lead, mercury and PCBs. Sampling and analysis were conducted by a leading
Japanese consultancy firm (IDEA Consultants Inc.). Water samples were taken from the same wells
as the supplementary survey plus one additional site inside TSDF (GW8). Sampling was conducted
with the same protocol employed in the supplementary survey. Figure 11-20 shows the location of
the TSDF sampling sites.
Figure 11-20 Location of groundwater/leachate sampling sites around TSDF
Note: GW8 is the new sampling site (latitude: 21°24'46.63" N, longitude: 72°09'47.80 E)
Laboratory analysis was conducted by employing as far as possible a similar method to the ones
employed in the supplementary survey. For heavy metals (lead and mercury), samples were
220
analyzed through two types of instruments namely: Atomic Absorption Spectrometry (AAS) and
Inductively coupled plasma - mass spectrometry (ICP/MS). Tables 11-19 and 11-20 show the
results of the survey for groundwater (GW1-4 and GW6-8) and leachate (GW5) sites respectively.
The results of the supplementary survey are included in the tables for comparison.
221
Table 11-19 Results of groundwater quality analysis (additional survey)
GW1 GW2 GW3 GW4 GW8 GW6 GW7 Indian Japan

(TSDF) (TSDF) (TSDF) (TSDF) (TSDF) (Yard) (Yard) standard*1 standard*2
8.0 7.6 7.6 7.6 - 8.0 7.8 IS3025 (Part 11)-1983 (R.2006)
pH - - 6.5-8.5 -
7.4 7.5 7.3 7.5 7.4 7.6 7.6 EPA 1600/4-79/020 150.1
1.9 1.01 0.78 0.86 - 2.72 1.77 2520-B APHA 22nd Ed. 2012
Salinity ‰ - - -
<2 <2 <2 <2 <2 3.2 <2 EPA ESTUARI
BD - IS 3025 (Part 47)-1994 (R.2009)
0.005 0.17 0.12 0.21 0.19
L 0.15
AAS: ISO 8288: 1986
Pb mg/l BDL BDL BDL BDL BDL BDL 0.007 0.01 0.01
0.005
ICP/MS: EPA 6020A
0.001 BDL 0.001 BDL BDL 0.004 0.007
0.001
0.001 BDL BDL BDL BDL - BDL BDL IS 3025 (Part 48)-1994 (R.2009)
AAS: ISO 12846: 2012
BDL BDL BDL BDL BDL BDL BDL
Hg mg/l 0.0005 0.001 0.0005
ICP/MS: EPA 6020A
BDL BDL BDL BDL BDL BDL BDL
0.0001
0.01 BDL BDL BDL BDL - BDL BDL Annex M of IS 13428-1998
PCBs µg/l 0.5 ND
0.5 BDL BDL BDL BDL BDL BDL BDL EPA 8082A
Grey column: Results of supplementary survey
*1：IS 10500: 2012 (Drinking water)
*2：Japanese Environmental Quality Standards for Groundwater Pollution
AAS: Atomic Absorption Spectrometry, ICP/MS: Inductively Coupled Plasma Mass Spectrometry
222
Table 11-20 Results of leachate quality analysis (additional survey)
Unit DL GW5 Analysis method

7.5 IS3025 (Part 11)-1983 (R.2006)
pH - -
7.7 EPA 1600/4-79/020 150.1
8.56 2520-B APHA 22nd Ed. 2012
Salinity ‰ -
6.5 EPA ESTUARI
0.005 0.99 IS 3025 (Part 47)-1994 (R.2009)
AAS: ISO 8288: 1986
BDL
Pb mg/l 0.005
ICP/MS: EPA 6020A
0.001
0.001
0.001 0.01 IS 3025 (Part 48)-1994 (R.2009)
AAS: ISO 12846: 2012
0.0005
Hg mg/l 0.0005
ICP/MS: EPA 6020A
0.0002
0.0001
0.01 22.14 Annex M of IS 13428-1998
PCBs µg/l
0.5 BDL EPA 8082A
Grey column: Results of supplementary survey
AAS: Atomic Absorption Spectrometry, ICP/MS: Inductively Coupled Plasma Mass Spectrometry
Following are the main findings of the groundwater survey:
 The values of pH and salinity were similar to the supplementary survey.

 Lead concentration (max value 0.007 mg/l at GW7) was significantly lower than the
supplementary survey (around 0.12～0.21 mg/l) at all the sites and were also below Indian
standard. Although the sampling sites are different, the results of the additional survey were
similar to the values recorded in the EIA study (< 0.005 mg/l).
 Mercury concentration was below detection limit at all the sites and were also below Indian
standard. The results were similar to the supplementary survey.
 PCBs concentration was below detection limit (< 0.5 mg/l) at all the sites and were also below
Indian standard. The results were similar to the supplementary survey.
Following are the main findings of the leachate survey:
 The values of pH and salinity were similar to the supplementary survey.

 Lead concentration (0.001 mg/l by ICP/MS) was significantly lower than the supplementary
survey (0.99 mg/l)..
 Mercury concentration (0.0002 mg/l by ICP/MS) was significantly lower than the
supplementary survey (0.01 mg/l).
 PCBs concentration was below detection limit (< 0.5 µg/l) which was significantly lower than
the supplementary survey (22.14 µg/l).
In general, the results of the additional survey were significantly lower than the supplementary
survey, especially for groundwater lead concentration and leachate lead, mercury and PCBs
concentration. Possible reasons for these differences are discussed below:
 Although heavy metals and PCBs were analyzed in the supplementary survey as per Indian
approved methodologies, erroneous results may be obtained in case the samples were not
223
pretreated sufficiently (e.g. removal of impurities contained in the sample prior to

measurement ).
 Groundwater quality may differ with the season. Groundwater in wet season may be prone to
receive more pollutants such as through soil infiltration and rise in groundwater level.
However, regular monitoring will be required to further verify if there are such seasonal
fluctuations in the area.
(3) Noise
Noise survey was conducted through the EIA during April-May 2015 at 7 sites around Alang/Sosiya.
Table 11-21 shows the survey results.
Table 11-21 Results of EIA noise survey
Noise levels at the recycling yard area (St. AN1) satisfies both day time (75 dB) and night time (70
dB) Indian standards for industrial area. Village sites (St. AN2-7) also satisfies both day time (55 dB)
and night time (45 dB) Indian standards for residential areas.
(4) Soil quality

Although the EIA conducts soil quality survey around TSDF and in some farmland, the studied
parameters were considered inadequate as a baseline for this Project.
1) JICA supplementary survey
A supplementary soil quality survey was conducted in August 2016. Soil samples were collected
from HKC uncertified ship recycling yards and from around TSDF. Survey parameters for the ship
recycling yard are cadmium, hexavalent chromium, lead, mercury, PCBs, PBBs, PBDEs, PCN,
PAHs and TBT, which are except PAHs, hazardous substances listed in Appendix 1 and 2 of the
HKC. For the TSDF sites, dioxin was measured.
For the ship recycling yard, soil samples were collected from 10 plots as shown in Figure 11-21.
For each plot, samples were collected from 6-10 spots depending on the width of the plot. Surface
(around 0-10 cm) and subsurface (around 10-30 cm) samples were collected separately then later
mixed together at equal quantities to make one composite sample per plot. As for the TSDF sites,
soil samples (surface only) were collected from the same four locations as the groundwater survey
sites (see Figure 11-12).
224
Station Latitude Longitude Station Latitude Longitude

So1: Plot V-6 21°26'17.40"N 72°13'19.56"E So6: Plot 51 21°24'34.01"N 72°11'46.84"E
So2: Plot 136 21°25'38.92"N 72°12'52.73"E So7: Plot 42 21°24'21.94"N 72°11'35.29"E
So3: Plot 120M 21°25'25.04"N 72°12'42.81"E So8: Plot 36 21°24'15.75"N 72°11'27.14"E
So4: Plot V2 21°25'05.69"N 72°12'19.42"E So9: Plot 62 21°23'12.90"N 72°10'17.91"E
So5: Plot 89/90 21°24'50.92"N 72°12'05.26"E So10: Plot 84F 21°22'37.58"N 72°10'00.21"E
Figure 11-21 Location of soil sampling sites (ship recycling yard)

Table 11-22 shows the results of the soil quality analysis for the ship recycling yard sites (lab
report is attached as Appendix xx). For reference, the results were compared with Netherland and
Canadian soil quality standards, as there are no Indian standards yet. Apart from lead and PAHs, all
parameters were below detection limit at all the sites. Although lead and PAHs levels were
relatively high, none of the sites exceeded Netherland and Canadian soil quality standards.
225
Table 11-22 Results of soil quality analysis (ship recycling yard)
Netherlan Analysis method

Unit DL So1 So2 So3 So4 So5 So6 So7 So8 So9 So10 Canada*2
ds*1
Moisture % - 7.60 10.33 7.13 4.68 3.75 5.11 7.42 6.93 5.58 7.09 - IS 2720 (Part 2):1973 (R.2010)
TOC % - 0.21 0.22 0.35 0.31 0.44 0.30 0.29 0.26 0.21 0.37 - FAO Method (Pg. No.61) 2007
Particle size
% - 60.6 69.22 69.25 55.2 72.98 67.69 65.79 61.61 61.41 60.81 - -
(>0.5 mm)
FAO Method
Particle size
% - 39.4 30.78 30.75 44.8 27.02 32.31 34.21 38.39 38.59 39.19 - -
(<0.5 mm)
EPA 3050B–1996 (Rev-2)/EPA
Cd mg/kg 2.0 BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL 13 22
7130-1986
EPA Method - 7196A:1992
Cr+6 mg/kg 0.1 BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL 78 -
(Rev-1)
EPA 3050B–1996 (Rev-2)/EPA
Pb mg/kg 5.0 58.59 34.00 10.26 39.86 108.31 16.74 51.42 159.97 35.82 17.21 530 600
7420-1986
Hg mg/kg 0.2 BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL 36 50 EPA 7471A-2007 (Rev-2)
PCBs mg/kg 0.01 BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL 1 33 CTP/SOP/SOIL/132-2014
PBBs mg/kg 0.01 BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL - - CTP/SOP/SOIL/139-2014
PBDEs mg/kg 0.01 BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL - - CTP/SOP/SOIL/132-2014
PCN mg/kg 0.01 BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL - - CTP/SOP/SOIL/151-2014
PAHs mg/kg 0.05 0.334 0.306 BDL 0.328 0.652 2.03 0.536 0.337 0.904 0.705 40 - CTP/SOP/SOIL/147-2014
TBT mg/kg 0.01 BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL - - CTP/SOP/SOIL/158-2014
*1：Soil Remediation Circular 2013
*2：Canadian Soil Quality Guidelines for the Protection of Environmental and Human Health (Industrial use)
DL: Detection limit, BDL: Below Detection Limit
Laboratory: Chennai Testing Laboratory Private Limited (NABL certified lab)
226
Table 11-23 shows the results of soil quality analysis for TSDF sites (lab report is attached as
Appendix xx). Dioxins levels were below detection limit at all the sites.
Table 11-23 Results of soil quality analysis (TSDF)
So1 So2 So3 So4

(GW1) (GW2) (GW3) (GW3)
Moisture % - 20.41 5.87 9.79 13.81 IS 2720 (Part 2):1973 (R.2010)
TOC % - 0.35 0.47 0.44 0.21 FAO Method (Pg. No.61) 2007
Dioxins/furans ng-TEC/kg 0.06 BDL BDL BDL BDL USEPA 1613
DL: Detection Limit, BDL: Below Detection Limit
Laboratory: Vimta Lab Limited (NABL certified lab)
(5) Sediment quality

1) JICA supplementary survey
As per requirement of JICA’s Environmental guideline, supplementary sediment quality survey

was conducted. Sediment samples were collected from 10 sites: 8 sites in front of the ship recycling
yard and 2 sites outside the ship recycling yard area (see Figure 11-22). Survey parameters are
cadmium, hexavalent chromium, lead, mercury, PCBs, PBBs, PBDEs, PCN, PAHs and TBT, which
are except PAHs, hazardous substances listed in Appendix 1 and 2 of the HKC.
Station Latitude Longitude Station Latitude Longitude

S1 21°26'43.41"N 72°13'33.86"E S6 21°24'10.53"N 72°11'33.32"E
S2 21°26'14.41"N 72°13'20.91"E S7 21°23'27.39"N 72°10'35.08"E
S3 21°25'36.38"N 72°12'56.45"E S8 21°22'53.53"N 72°10'11.94"E
227
S4 21°25'03.17"N 72°12'22.09"E S9 21°22'32.98"N 72°10'05.01"E

S5 21°24'31.34"N 72°11'48.63"E S10 21°22'26.16"N 72°09'55.74"E
Figure 11-22 Location of sediment sampling sites

Table 11-24 shows the results of the sediment quality analysis (lab report is attached as Appendix
3).The table also shows the Australian and Canadian sediment quality guideline values for ad hoc
comparison, as there is no sediment quality standard in India yet. However, note that these
guideline values were used solely for reference purpose and may not be appropriate to apply for
Indian environment. The main findings of the survey are as follows:
 For heavy metals, lead and cadmium were detected at relatively high levels but others were all
below detection limit.
 For organic pollutants, PCBs levels were relatively high at 7 sites.
 While it is not possible to accurately identify the source of lead, cadmium and PCBs, it should
not be interpreted as a representative baseline data of the area as the results are based on one-
time survey in the wet season. Further regular monitoring will be necessary to obtain an
accurate trend of sediment quality.
For further verification, GMB requested the JICA Study Team to undertake additional survey in the dry
season specifically for parameters that were above the Australian and Canadian sediment quality
guideline values (cadmium, lead and PCBs).
228
Table 11-24 Results of sediment quality analysis (supplementary survey)
Unit DL S1 S2 S3 S4 S5 S6 S7 S8 S9 S10 Australia*1 Canada*2 Analysis method

Moisture % - 17.23 16.40 17.14 16.70 20.45 31.45 21.14 17.83 20.66 33.54 - - IS 2720 (Part 2):1973 (R.2010)
TOC % - 0.84 0.85 0.92 0.88 1.01 0.40 1.01 0.45 0.84 0.95 - - FAO Method (Pg. No.61) 2007
Particle size
% - 31.00 27.33 27.28 30.67 32.91 31.08 33.57 29.91 34.06 30.99 - -
(>0.18 mm)
FAO Method
Particle size
% - 69.00 72.67 72.72 69.33 67.09 68.92 66.43 70.09 65.94 69.01 - -
(<0.18 mm)
ISQGL: 1.5 ISQG: 0.7 EPA 3050B–1996 (Rev-2)/EPA
Cd mg/kg 2.0 2.84 2.68 BDL 3.21 2.86 2.61 2.42 2.92 2.78 2.85
ISQGH: 10 PEL: 4.2 7130-1986
EPA Method - 7196A:1992
Cr+6 mg/kg 0.1 BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL - -
(Rev-1)
ISQGL: 50 ISQG: 30.2 EPA 3050B–1996 (Rev-2)/EPA
Pb mg/kg 5.0 328.19 248.83 170.75 273.81 180.32 211.93 293.14 410.11 248.14 115.82
ISQGH: 220 PEL: 112.0 7420-1986
ISQGL: 0.15 ISQG: 0.13
Hg mg/kg 0.2 BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL EPA 7471A-2007 (Rev-2)
ISQGH: 1 PEL: 0.70
ISQGL: 0.023 ISQG: 0.0215
PCBs mg/kg 0.01 0.042 0.024 BDL 0.045 BDL BDL 0.041 0.096 0.032 0.040 CTP/SOP/SOIL/132-2014
ISQGH: NA PEL: 0.189
PBBs mg/kg 0.01 BDL BDL BDL 0.012 BDL BDL 0.010 0.016 BDL BDL - - CTP/SOP/SOIL/139-2014
PBDEs mg/kg 0.01 BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL - - CTP/SOP/SOIL/132-2014
PCN mg/kg 0.01 BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL - - CTP/SOP/SOIL/151-2014
ISQGL: 4
PAHs mg/kg 0.05 0.601 0.515 0.429 0.282 0.524 0.512 0.673 2.04 0.799 0.438 - CTP/SOP/SOIL/147-2014
ISQGH: 45
ISQGL: 0.005
TBT mg/kg 0.01 BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL - CTP/SOP/SOIL/158-2014
ISQGH: 0.070
Methyl
mg/kg 0.5 BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL - - CTP/SOP/SOIL/023
mercury
Note may be taken that there is no reference value for Indian conditions. However, for the purpose of adhoc comparison, Australian/New Zealand and Canadian guidelines were used as
reference standards.
*1: Australian and New Zealand Guidelines for Fresh and Marine Water Quality, ISQGL: Interim Sediment Quality Guideline-Low, ISQGH: Interim Sediment Quality Guideline-High
*2: Canadian Sediment Quality Guidelines for the Protection of Aquatic Life, ISGG: Interim sediment quality guidelines, PEL: Probable effect level
DL: Detection limit, BDL: Below Detection Limit, NA: Not available
229
2) JICA additional survey
As per request of GMB, additional sediment survey was implemented in February 2017 (dry
season) focusing on parameters that exceeded the sediment guideline values namely cadmium, lead
and PCBs in monsoon season. Sampling and analysis were conducted by a leading Japanese
consultancy firm (IDEA Consultants Inc.). Sediment samples were taken from the same 10 sites as
the supplementary survey. Sampling was done with the same protocol employed in the
supplementary survey.
Laboratory analysis was conducted by employing as far as possible a similar method to the ones
employed in the supplementary survey. For heavy metals (cadmium and lead), samples were
analyzed through two types of instrument namely: AAS and ICP/MS. Table 11-17 shows the results
of the sediment quality analysis (the results of the supplementary survey are included for
comparison). Results of the particle size analysis is attached as Appendix xx
230
Table 11-25 Results of sediment quality analysis (additional survey)
Unit DL S1 S2 S3 S4 S5 S6 S7 S8 S9 S10 Australia*1 Canada*2 Analysis method

17.23 16.40 17.14 16.70 20.45 31.45 21.14 17.83 20.66 33.54 - - IS 2720 (Part 2):1973 (R.2010)
Moisture % -
47.9 58.8 60.0 54.5 62.3 42.2 52.0 55.6 58.2 58.0 Gravimetry
0.84 0.85 0.92 0.88 1.01 0.40 1.01 0.45 0.84 0.95 - - FAO Method (Pg. No.61) 2007
TOC % -
0.46 0.68 0.71 0.63 0.70 0.62 1.00 0.96 0.84 0.74 TOC meter
Particle size
% - 31.00 27.33 27.28 30.67 32.91 31.08 33.57 29.91 34.06 30.99 - -
(>0.18 mm)
FAO Method
Particle size
% - 69.00 72.67 72.72 69.33 67.09 68.92 66.43 70.09 65.94 69.01 - -
(<0.18 mm)
EPA 3050B–1996 (Rev-2)/EPA
2.0 2.84 2.68 BDL 3.21 2.86 2.61 2.42 2.92 2.78 2.85
7130-1986
ISQGL: 1.5 ISQG: 0.7
Cd mg/kg AAS: 0.5 BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL ISO11047:1998
ISQGH: 10 PEL: 4.2
ICP/MS:
0.12 0.11 0.10 0.10 0.14 0.16 0.39 0.27 0.11 0.11 ISO16965:2013
0.01
EPA 3050B–1996 (Rev-2)/EPA
5.0 328.19 248.83 170.75 273.81 180.32 211.93 293.14 410.11 248.14 115.82
7420-1986
ISQGL: 50 ISQG: 30.2
Pb mg/kg AAS: 8 14 11 12 10 16 14 71 34 9.2 9.9 ISO11047:1998
ISQGH: 220 PEL: 112.0
ICP/MS:
16 12 13 11 15 17 81 42 11 11 ISO16965:2013
1
0.01 0.042 0.024 BDL 0.045 BDL BDL 0.041 0.096 0.032 0.040 ISQGL: 0.023 ISQG: 0.0215 CTP/SOP/SOIL/132-2014
PCBs mg/kg
0.01 0.02 0.01 0.01 0.01 0.03 0.06 0.36 0.15 BDL 0.01 ISQGH: NA PEL: 0.189 ISO13876:2013
Note may be taken that there is no reference value for Indian conditions. However, for the purpose of adhoc comparison, Australian/New Zealand and Canadian guidelines were used as
reference standards.
*1: Australian and New Zealand Guidelines for Fresh and Marine Water Quality, ISQGL: Interim Sediment Quality Guideline-Low, ISQGH: Interim Sediment Quality Guideline-High
*2: Canadian Sediment Quality Guidelines for the Protection of Aquatic Life, ISGG: Interim sediment quality guidelines, PEL: Probable effect level
Grey column: Results of JICA supplementary survey.
DL: Detection limit, BDL: Below Detection Limit, NA: Not available
231
Following are the main findings of the sediment quality survey:
 Particle size of the sediment samples were generally finer (i.e. more silty) compared to the
supplementary survey.
 Cadmium concentration was less than 0.5 mg/kg at all the sites, which are lower compared
to the supplementary survey (approx. range: 2～3 mg/kg). All sites were below the lower
threshold of the Australian and Canadian guideline values.
 Lead concentration was in the range of 10～80 mg/kg, which are lower compared to the
supplementary survey (approx. range: 100～300 mg/kg). Sites S7 and S8 are comparable
with Australian and Canadian Standards and found exceeded the lower threshold of both the
Australian or Canadian guideline value.
 While PCBs concentration was more or less similar to the supplementary survey, sites S5 to
S8 were slightly higher than the supplementary survey (approx. range: < 0.01～0.1 mg/kg).
Sites S5 and S8 exceeded the lower threshold of either the Australian or Canadian guideline
value and site S7 exceeded the upper threshold of Canadian guideline value (0.189 mg/kg).
Although PCBs values were relatively high for both surveys, these values are not at a level
that will require immediate remedial action in case for example the values are compared
with Japan’s “Provincial Sediment Removal Standards (1975)” for PCBs, which is set at 10
mg/kg. After PCB Convention came into force in 1978, hardly any vessel contain PCB
hence possibility of PCB source from recent vessels beached in last 10 years are scanty.
In the additional survey, cadmium and lead concentration were more or less an order of
magnitude lower than the supplementary survey. Possible reasons for these differences are
discussed below:
 According to yard operators, there are some seasonal variation in intertidal mud accumulation
and distribution. This may be the reason why particle size of the samples was smaller in the
additional survey.
 Although sediment samples were taken by referring to GPS data of the supplementary survey,
there may have been some slight differences in the actual sampling locations.
 Although heavy metal analysis in the supplementary survey were conducted in accordance to
EPA methodologies, erroneous results may be obtained in case the samples were not pretreated
sufficiently (e.g. removal of impurities contained in the sample prior to measurement).
(6) Waste
1) Type and quantity of wastes and treatment and disposal methods
Figure 11-23 shows the volume of wastes received at TSDF and the number of beached ships of
the past 10 years. Around 5,000-10,000 MT of wastes are received each year at TSDF.
232
Source: GEPIL
Figure 11-23 Volume of wastes received at TSDF and the number of beached ships
Table 11-26 shows the type and volume of wastes received at TSDF and treatment and disposal
methods (statistics between 2015-2016). Volume wise glasswool is highest, occupying almost half
of the total received wastes.
Table 11-26 Type and volume of wastes received at TSDF and treatment and disposal methods
Volume
Type Category Treatment/disposal method
(ton)
Asbestos containing waste Hazardous 22 Stabilization/Solidification
Bilge water Hazardous 1,600 ETP
Puff, Thermocol, Booch Hazardous 110 Incineration
Ceramic Non-hazardous 10 Landfill
Contaminated sand Hazardous 106 Controlled landfill
Garbage Non-hazardous 34 Landfill
Glass Non-hazardous 6 Landfill
Glasswool Hazardous 2,362 Controlled landfill
Incinerator ash Hazardous 8 Controlled landfill
Oily sludge Hazardous 1 Incineration
Oily rags Hazardous 42 Incineration
Oily water Hazardous 2 ETP
Paints and coatings Hazardous 25 Incineration / Controlled landfill
Plastics Hazardous 1 Incineration
Others Hazardous/Non- 667 Incineration / Controlled landfill
hazardous
Total 4,996
Source: GPCB
2) Storage and transport methods of wastes
Once collected from ships, hazardous wastes such as asbestos are packed into specialized
containers/bags and temporary stored in the yard at a designated area prior to transportation to
TSDF. Hazardous wastes are then transported to TSDF with specialized trucks of TSDF and then
are either stored at TSDF waste storage area or undergo treatment/disposal. Bilge water is
transported by specialized tank lorry to TSDF.
233
3) Waste composition survey
The JICA Study Team conducted waste composition survey to study the chemical composition of
wastes generated from ship recycling activities. The survey focused on two types of ships: bulk
carrier (built in 1994) and container ship (built in 1996). Component analysis was conducted for
PCBs, TBT, asbestos and heavy metals: Following are main findings of the survey:
 PCBs were not detected from the two ships.

 TBT was not detected from the two ships.
 Asbestos was detected from the bulk carrier (from insulation material used in the engine room
pipes)
 Heavy metals such as Pb, Cd, As, Co, Mn, Ni and Zn were detected from paints used inside and
outside of the ships. Table 11-27 shows the results of component analysis of ship paints.
Table 11-27 Results of component analysis of ship paints
Container
Unit Hull side Upper side Upper deck Deck side Side deck
Pb ppm 160 231 953 824 422
Cd ppm ND 44.8 15.8 ND ND
Hg ppm ND ND ND ND ND
As ppm ND ND ND ND ND
Co ppm ND ND ND ND ND
Mn ppm 27.3 152 15.7 26.2 86.6
Ni ppm ND ND ND ND ND
Zn ppm 28,089 53,625 217,391 476 18,458
Cr+6 ppm ND ND ND ND ND
Bulk carrier
Unit Control room Hull side Inside tank Engine room
Pb ppm 64 4,501 13.4 442
Cd ppm ND ND ND ND
Hg ppm ND ND ND ND
As ppm ND ND 16.6 ND
Co ppm 39 ND 14.5 146
Mn ppm 38.4 52.2 2,018 87.4
Ni ppm 17.7 ND 79.9 ND
Zn ppm 249 186 84 1,632
Cr+6 ppm ND ND ND ND
11.3.5. NATURAL ENVIRONMENT
(1) Protected area

The nearest protected area is Velavadar Blackbuck National Park which is approximately 75 km north
from Alang.
(2) Terrestrial flora/fauna

The EIA conducted terrestrial flora/fauna survey (walk-through survey) in 2015 along the coast near
the Project site. Twelve flora species were identified and none were classified as threatened under the
234
IUCN red list. As for fauna, 6 mammal species and 27 bird species identified and none were classified as
threatened under the IUCN red list. Tables 11-28-30 show the identified flora and fauna species.
Table 11-28 Results of EIA flora survey
Family Scientific name IUCN status

1 Tree Mimosaceae Acacia nilotica N/A
2 Prosopis juliflora N/A
3 Fabaceae Leucaena leucocephala N/A
4 Shrub Agavaceae Agave americana N/A
5 Asclepiadaceae Calotropis procera N/A
6 Grass Poaceae Cynodon dactylon N/A
7 Paspalum spp. N/A
8 Herb Commelinaceae Commelina benghalensis LC
9 Asteraceae Parthenium hysterophorus N/A
10 Chenopodiaceae Suaeda maritima N/A
11 Climber Asclepiadaceae Chamar dudheli N/A
12 Zygophyllaceae Tribulus terrestris N/A
N/A: Not assessed; LC: Least Concern
Table 11-29 Results of EIA fauna survey (mammals)
Common name Scientific name IUCN status

1 Common Mongoose Herpestres edwardsii N/A
2 Golden Jackal Canis aureus LC
3 Bengal Fox Vulpes bengalensis LC
4 House rat Rattus rattus LC
5 Nilgai Boselaphus tragocamelus LC
6 Squirrel Funambulus pennanti N/A
N/A: Not assessed; LC: Least Concern
Table 11-30 Results of EIA fauna survey (birds)
Common name Scientific name IUCN status

1 Red Wattled Lapwing Vannelus indica N/A
2 Indian Reef Egret Egretta gularis LC
3 Whimbrel Numenius phaeopus LC
4 Common Sandpiper Tringa hypoleucos LC
5 Pariah Kite Milvus migrans LC
6 Common Crow Corvus splendens LC
7 Grey Partridge Francolinus pondicerianus LC
8 Black Ibis Pseudibis papillosa LC
9 White Ibis Theskiornis aethiopica N/A
10 Painted Stork Mycteria leucocephala NT
11 Little Egret Egretta garzetta LC
12 Drongo Dicrurus adsimilis LC
13 Koel Eudynamis scolopacea N/A
235
14 House Swift Apus affinis LC

15 White Breasted Kingfisher Halcyon smyrnensis LC
16 Jungle Babbler Turdoides striatus LC
17 Large Grey Babbler Turdoides molcolmi N/A
18 Green Bee-eater Merops orientalis LC
19 Chestnut Headed Bee-eater Merops leschenaulti LC
20 Shrike Lanius spp. -
21 Common Tern Sterna hindo N/A
22 Brahminy Kite Haliastur indus LC
23 Brahminy Mynah Sturnus pagodarum LC
24 Red Vent BulBul Pycnonotus cafer LC
25 Small Indian Cormorant Phalacrocorax niger LC
26 Kentish Plover Charadius alexandrinus N/A
27 Black Winged Stilt Himantopus himantopus LC
N/A: Not assessed; LC: Least Concern; NT: Near Threatened
(3) Marine fauna

The EIA conducted marine plankton and benthos surveys along the coastal area of the Project site
(100 m-2 km area from shore). For planktons, biota and species diversity were studied. For benthos,
biota, biomass and species diversity were studied. Table 11-31 shows the location of the surveyed
transects.
Table 11-31 Location of surveyed transects
Transect Location
A Coast adjacent to Jaspara village (approx. 3.5 km from north-end of ASSRY)
B Coast adjacent to Sosiya
C Coast adjacent to Alang Fire Station
D Coast adjacent to south-end of ASSRY
E Coast approx. 2 km south from south-end of ASSRY)
Table 11-32 shows the results if the phytoplankton survey. Identified species were Naviculas spp.,
Coscinodiscus spp., Nitzschia spp., and Surirella spp. The Shannon Weaver Index was under 1 at all the
sites.
236
Table 11-32 Results of phytoplankton survey
Table 11-33 shows the results if the zooplankton survey. Identified species were foraminifera,
copepods, decapods, polychaeta and gastropods.
Table 11-33 Results of zooplankton survey
Table 11-34 shows the results if the benthos survey. Identified species were polychaeta, bivalves and
crabs.
237
Table 11-34 Results of benthos survey
In addition to the above surveys, the EIA conducted benthos survey in the more nearshore area of
each transect. Main species identified were polychaetas, gastropods, bivalves and crabs. Table 11-35
shows the results of the nearshore benthos survey.
Table 11-35 Results of nearshore benthos survey
Transect Identified species

A Polychaete (Neries sp.), Gastropods (Trochus spp., Telescopium spp*), Bivalve (Donax
spp., Sunetta spp.*), Rock Oyster*, Fiddler Crab, Hermit Crabs
B Gastropods (Trochus spp., Pseudomoris spp., Clavus spp.), Acorn barnacles (Balanus spp.),
Rock Oyster, Pistol Shrimp, Goby fish (Parachaeturichthy spp.)
C Gastropods (Cerithidae spp.*), Bivalve (Donax spp .), Polychaete colonies
D Polychaete colonies, Gastropods (Trochus sp., Clavus spp*, Cerithium spp*, Clypeomorus
spp.*), Sea Slugs (Sedadoris sp.), Crabs (Matuta lunaris, Graspus spp, Macropthalamus
spp.)
E Polychaete colonies, Gastropods (Trochus sp, Cerithium spp*), Bivalve (Donax spp.)
*: Empty shell
The EIA also analyzed the heavy metal content inside a crab species (Matuta lunaris) caught near the
Project site. Table 11-36 shows the analysis results.
Table 11-36 Analysis results of heavy metal content inside Matuta lunaris
Parameter Concentration (µg/g)

Zn 0.23
Pb 0.08
Cu 8.6
Cr 2.1x10-4
Cd 3.2x10-5
238
(4) JICA supplementary survey

The aim of the survey was to analyze the TBT concentration inside benthic species inhabiting the
intertidal area of the ship recycling yards. However, the field survey team could only collect one live
specimen namely a small crab. Nevertheless, the crab was analyzed at the laboratory but no TBT was
detected (DL: 0.01 mg/kg).
11.3.6. SOCIAL ENVIRONMENT
The JICA Study Team conducted social survey (hereafter called “JICA Social Survey”) in June 2016 to
understand the current social and economic status of Alang, Manar and Sosiya village, the neighboring
villages of Alang Sosiya Ship Recycling Yard. The survey was implemented by subcontracting Market
Insight Consultants. At each of the three villages, 30 locals were randomly interviewed covering topics
such as demography, livelihood, health and opinions on the Project. Section 11.2.2 provides an overview
of the social environment of Alang, Manar and Sosiya villages based on the JICA Social Survey and
existing information.
(1) Population
According to the Census 2011, the total population of Alang, Manar and Sosiya villages is
approximately 13,000. Female sex ratio against 1,000 male is 918 (Alang-Manar village) and 935
(Sosiya village), which is similar to the average ratio of Bhavnagar district. Percent working population
is around 40%, which is similar to Bhavnagar district. Table 11-37 shows demographic composition of
Alang, Manar and Sosiya villages.
Table 11-37 Demographic composition of Alang, Manar and Sosiya Village
Bhavnagar Alang-Manar Sosiya village

district village
Population 2,880,365 8,309 3,467
Household 538,605 1,443 576
Female ratio (against 1,000 male) 933 918 935
Working population (%) 40% 40% 37%
Source：Census of India 2011
(2) Livelihood
Figure 11-24 shows the main source of income of the villagers interviewed in JICA Social Survey (30
people from each village of Alang, Manar and Sosiya). When the three villages are combined, 40% of
the villagers were engaged in agriculture and animal husbandry, 30% in ship recycling related work and
16% in small shops. The results shows relatively high dependence on ship recycling at these villages,
and in fact for Alang village and Manar village, ship recycling work was the most prominent source of
income comprising 40% and 37% of the interviewees respectively. Some of the villagers that were
engaged in small shops, work at the restaurants and retail shops along the road behind ship recycling
yards, which mainly cater for ship recycling workers. These villagers are also indirectly dependent on
the ship recycling industry.
239
Figure 11-24 Type and ratio of income sources of interviewed Alang, Manar and Sosiya villagers
Survey subjects: 30 people in each village of Alang, Manar and Sosiya village (total of 90 people)
Table 11-38 shows the income level of villagers interviewed in the JICA Social Survey who are
engaged in agriculture and ship recycling related work. Income level of owner farmers is the same level
as experienced ship recycling workers which is in the range of INR 10,000 to 15,000 per month. Income
of employed agriculture workers and inexperienced ship recycling workers are more or less at the same
level which is around INR 5,000 to 8,000 per month.
Table 11-38 Income level of interviewed villagers engaged in agriculture and ship recycling related work
Occupation Income level (INR/month)

Agriculture (owner farmer) 10,000-15,000
Agriculture (employed worker) 5,000-8,000
Ship recycling (experienced worker) 10,000-15,000
Ship recycling (inexperienced worker) 7,000-8,000
Survey subjects: 30 samples from each village in Alang, Manar and Sosiya village (total 90 samples)
Source: JICA Survey Team
(3) Fishery
Since the nearshore area around Alang/Sosiya Ship Recycling Yard is designated as a port area, fishing
activities are prohibited inside the designated port areas. While some fish traps were observed in the
intertidal areas outside of the recycling yards, these are unlikely to be affected. None of the interviewed
villagers in the JICA Social Survey were engaged in fishery.
(4) Land Use

Figure 11-24 shows the land use map around the project site. Large portion of the hinterland of ship
recycling yard (red) are agriculture land (yellow) and horticulture land (light green).
240
Figure 11-24 Land use around the Project site
241
Source：GMB (2015), EIA of Proposed Upgradation of Existing Ship Recycling Yard at Alang Sosiya
242
(5) Social infrastructure

1) Water and sanitation
Water supply to Alang Yard is supplied through pipeline from Gujarat Water Supply Board.
Capacity of the clean water supply is 3 million litre per day whereas requirement is around 1.6 to
1.8 MLD so as such there is no issue of water supply. However, during summer for about one
month sometime there is shortage of water supply so fresh water supply through tankers are
provided to fulfill the balance requirement. The sewage system is under planning.
2) Educational institution
Educational institutions in the villages are primary school to upper primary school and the highest
class is 8 standard. There are 5 schools in Alang village, 3 schools in Manar village and 2 schools in
Sosiya village.
3) Medical facility
Main hospitals in Alang Sosiya Ship Recycling Yard are Alang Hospital and Red Cross Hospital.
Both hospitals cater for ship recycling workers and surrounding villagers. There are also small
private clinics in the villages but are only capable of first-aid treatment.
(6) Level of education

According to Census 2011, male literacy rate in Alang-Manar village and Sosiya village are above 80%
whereas female literacy rate is 55 to 60% which is lower than male. Table 11-39 shows the literacy rate
in Alang-Marnar village and Sosiya village.
Table 11-39 Literacy rate of Alang-Manar village and Sosiya village
Bhavnagar district Alang-Manar Sosiya village

village
Average (%) 75.52 72.53 70.13
Male (%) 84.39 82.44 83.73
Female (%) 66.08 61.87 55.43
Source: Census of India 2011
(7) Religion
According to Census 2011, majority of the population in Alang-Manar village are Hindu (97.28%) and
the rests consist of Muslim (2.47%), Jain (0.18%) and others.
(8) Caste
Table 11-40 shows the proportion of scheduled castes and scheduled tribes in Alang-Manar village and
Sosiya village. Scheduled castes in Alang-Marnar village is 5% of the population which is higher than
the average of Bhavnagar district. On the other hand, population of schedule tribe is 0.18% in Alang-
Manar village and non-existent in Sosiya villages which are below the average of Bhavnagar district.
Table 11-40 Ratio of scheduled caste/tribes population in Alang-Manar village and Sosiya village
Bhavnagar district Alang-Manar village Sosiya village

Scheduled castes (%) 2.99 4.12 0.43
Scheduled tribes (%) 0.50 0.18 0.00
243
Source: Census of India 2011
(9) Health
Health issues in relation to ship recycling industry were not confirmed from the interviewed villagers
during JICA Social Survey.
(10) Opinions on the Project

Followings are the opinions on the Project expressed by villagers interviewed in JICA Social Survey.
 Increasing employment opportunities from ship recycling related work

 Improving living standard by having easy access to daily necessity goods
 Concern about traffic congestion, traffic accidents and pollution due to increase in vehicle
traffic.
 Concern about noise and vibration from ship recycling yard
 Concern about possible disturbance of lifestyle and deterioration of public safety due to
increasing influx of migrant workers
According to GMB, it is revealed that the Ship Recycling Yard is in operation since in 1982 and
thereafter prosperity of village surrounding to the yard is many more time increased. Hence the above
issues are common issues like other industrialization seen in any country.
11.3.7. WORKING ENVIRONMENT OF SHIP RECYCLING INDUSTRY
In order to understand working environment of ship recycling workers, total of 60 workers were
interviewed as a part of JICA Social Survey. Based on the JICA Social Survey and existing information,
following section outlines the current working environment in Alang Sosiya Ship Recycling Yard.
(1) Legal framework on working condition

1) Occupational safety
Occupational safety is regulated by India Factories Act 1948 and Gujarat Factories Rule 1963. In
Gujarat Factory Rules 1963, industry wise safety regulations are specified and ship recycling
industry falls under “ship building, ship repairing and ship recycling industry (68-H)”.
2) Labour insurance
In accordance to Employees’ State Insurance Act 1948, it is mandatory for workers to join labour
insurance (Employees State Insurance: ESI). Under ESI, workers are entitled to receive financial
support for their medical services 10 . Also, in case of an accident, compensation will be made
towards worker’s families from the employers based on Public Liability Insurance Act 1991.
(2) Current condition of workers

1) Number of workers
The number of workers employed in ship recycling yards fluctuates depending on the ship
recycling demand. Based on the information provided from GMB and Alang Sosiya Ship Recycling
10
According to Alang Hospital, government is responsible for 60% of insurance whereas employers and employees
cover 20% respectively. Some recyclers (employers) also covers the portion of employees.
244
General Workers Association (ASSRGWA), the number of workers is usually around 20,000 of
which most are male.
2) Home state of workers
Most of the workers employed in ship recycling yards are migrant workers from outside Gujarat
state, majority of which are from impoverished states in northern India. Home states of the workers
interviewed in JICA Social Survey were Orissa (47%), Bihar (27%), Jharkhand (13%) and Uttar
Pradesh (12%). These four states constituted 99% of the total interviewed workers.
3) Age and year of experience of workers
Around 70% of the workers interviewed in the JICA Social Survey were aged between 25-40
years old. Around 70% of the workers had less than 10 years’ experience in ship recycling work,
and around 40% less than 1 year of experience. Workers with more than 10 years’ experience were
around 12%.
(3) Occupation type and wage

1) Occupation type
Based on the interview at the recycling yards, around 100 to 150 workers are required to dismantle
one ship. Each yard employs workers in different positions including managers in charge of
worker’s safety and recycling processes, crane and winch operators, gas cutters, and unskilled
workers handling non-ferrous metal, ropes and steel plates.
2) Workers’ wage
Depending on the position of workers, required skill differs and so does their wage level. Monthly
wage for supervisor level is INR 15,000, heavy equipment operator is INR 17,000, gas cutter is
INR 10,000 and unskilled worker is between INR 8,000 to 10,000. Table 11-41 shows position-
wise wage level of workers.
Table 11-41 Position-wise Salary Level of Workers
Position Required skill Wage (INR/month)

Health Safety Environment Manager Related educational background
Plot Manager Skilled worker
Safety Officer Educational background &experience 17,000-20,000
Plot supervisor (Mukadam) Skilled worker 15,000
Crane Operator Skilled worker 17,000
Winch Operator Skilled worker 15,000
Gas cutter（Battiwala） Unskilled worker 10,000
Non-ferrous metal segregation Unskilled worker 8,000-10,000
(Malpani) Unskilled worker (depends on the years
Steel plate/ rope handling (Jodiwala) Unskilled worker of experience)
Loader Unskilled worker
Helper
(4) Occupational accidents

1) Status of accidents
245
Figure 11-25 shows the probable causes of fatal accidents in Alang Sosiya Ship Recycling Yard.
Major causes of fatal accidents are fire and explosion (26.40%), falling from height (19.47%) and
struck by falling objects (17.07%).
Figure 11-25 Causes of fatal accidents in Alang Sosiya Ship Recycling Yard
Table 11-42 shows the statistics of accidents during 2011-2015 in Alang/Sosiya based on the report by
European Community Ship owners’ Associations (ECSA). There were 41 cases of fatal accidents and 19
cases of injury accidents during this 5 year period. Major causes of fatal accidents were fire and
explosion, falling from heights, struck by falling object and breakage of winch wire and entrainment.
The statistics shows that over 70% of the fatal accidents occurred onboard. Accidents caused by
fire/explosion and falling from heights commonly lead to death.
Table 11-42 Statistics of accidents during 2011-2015
Causes of accidents Location Injury Death

Fire and explosion (in pump, engine room and during gas cutting) On board 2 11
Falling from heights On board － 10
Struck from falling object including cutting block (Gas cutting) On board 5 9
Crane operation (Struck from falling object) Yard 4 6
Winch operation (wire breakage, entrainment) Yard 8 5
Total - 19 41
Source: Prepared by JICA Survey Team based on ECSA Technical Report ”ECSA Fact Finding Visit to Indian Ship
Recycling Yards Alang-Sosiya, April 2016”
2) Safety measures
Followings are the main safety measures employed at recycling yards (“well-managed”) to avoid
above mentioned accidents.
a. Measures against fire and explosion
As per Ship Breaking Code 2013, as a condition of obtaining Breaking Permission from GMB, the
ship recycler is required to obtain hot-work certificate from DISH. In addition, some yards double-
check enclosed spaces with gas meters for presence of explosive and toxic gas mixtures prior to
workers entering such areas.
246
b. Measures for working at height

Application of safety belts on workers and warning tapes at the deck edges are being practiced as a
basic safety measures while working at heights. Since the majority of the accidents occur on board,
those works are commonly assigned to workers having over 10 years of experiences.
c. Measures for winch operation
As a precautionary measure against winch line snapping, winch line and other parts are regularly
inspected for any damage. The winch is also fenced to protect the winch operators from accidental
snapping of the winch line.
d. Personal Protective Equipment (PPE)

In most yards, basic PPEs including helmet, shoes, clothes and gloves are worn by the workers
throughout the recycling process. For gas cutting works, masks and safety goggles are also used by
the workers.
e. Safety training
It is mandatory for the workers to take basic training courses at Safety Training & Labour Welfare
Institute operated by GMB before they are employed at ship recycling yards. However, since there
is limited practical training within the basic training courses, workers are further trained through
OJT by HSE officers and skilled workers in each yard.
(5) Health status of ship recycling workers

As part of the JICA Social Survey, workers were interviewed regarding their health issues. However,
no health issues or complains were raised by the interviewed workers. Therefore, in order to further
investigate workers’ health issues, results from past workers’ medical checkup at the yards and
information provided by the hospitals in Alang Sosiya Ship Recycling Yard were studied. In addition,
past studies of Indian research institution were also reviewed.
1) Result of worker’s medical checkup
India Factory Act (1948) and Gujarat Factories Rules (1963) stipulate that it is made mandatory
for the employers to conduct medical examination of their workers at pre-employment stage and
also periodically during the employment period by a medical doctor certified by Directorate of
Industrial Safety and Health (DISH). In Alang Sosiya Ship Recycling Yard, as per the regulation,
DISH certified medical doctor is conducting the medical checkup by visiting each yard at a
frequency of once every 6 months. The checkup covers simple physical and medical examination
items as per Gujarat Factories Rules (1963). According to one of the DISH certified medical doctor
who has been examining workers in Alang Sosiya Ship Recycling Yard for the past 10 years,
common symptoms among the workers are skin diseases and hypertension.
In addition to the above medical checkup, one NK certified yard voluntarily had conducted further
medical checkup of its workers for the past 12 years. According to the yard owner, some workers
have cough and skin issues but no asbestos related symptoms have been identified so far. The
owner informed that cough was noticed mainly among cigarette smokers and the main causes of
skin issues was likely to be attributed to unhygienic living conditions. With regards to skin issues,
the expert from National Institute of Occupational Health (NIOH) pointed out the possibility of
exposure to glasswool fiber as one cause of skin issue as per their study in the year 2007 but
presently no workers are exposed to glasswool fibers as workers are wearing PPEs. Table 11-43
shows further information on the above mentioned medical checkups including the examined items.
247
Table 11-43 Results of medical checkup of workers in Alang Sosiya Ship Recycling Yard
DISH certified medical doctor A NK certified ship recycler

(periodical checkup) (occupational specific items conducted
in addition to periodical checkup)
Years of medical 10 years 12 years
checkup
conducted
Medical checkup • Physical examination (height, • All workers: Complete blood count
item weight, blood pressure, ear, (CBC), urine check
eyes, skin) • Jodi (plate loader often work close to
• Medical examination winch): Auditory
(Respiratory system, nervous • Gas cutter: Pulmonary
system, circulatory system, • Waste handler and cleaner 11 :
endocrine system) Pulmonary, Sputum, Chest X-ray
Main symptoms Skin disease, hypertension, etc. Cough, Skin issues (itching and radish
spot)
2) Information of patients visited the hospitals in the Alang/Sosiya
The main hospitals located in Alang Sosiya Ship Recycling Yard are Alang hospital and Red
Cross hospital and both cater for ship recycling workers and surrounding villagers. In both
hospitals, around 10% of the visited patients were for injuries sustained during ship recycling
works. The proportion of workers and residents is unknown but other common symptoms reported
by both hospitals were skin diseases and respiratory issues.
In addition, Red Cross Hospital has conducted chest X-ray test for ship recycling workers during
2006 to 2009. Based on the information provided, around 10-20% of workers showed some kind of
abnormalities including bronchitis, pneumonitis and so on. According to the doctor in Red Cross
Hospital, there were no cases of asbestosis identified from those tests. Table 11-44 shows the
outline of patients visited and examined at Alang Hospital and Red Cross Hospital.
Table 11-44 Summary of patients visited Alang Hospital and Red Cross Hospital and
major symptoms identified
Alang Hospital Red Cross Hospital
No. of 30-45 ppl/day (2015-16) 21,801 ppl/year (2015-16)
patients
Main • Minor injury: 2-5 ppl/day (6-10%) • Injury: 1,834 ppl (8%) (Sutures, broken
symptoms • Serious injury: 3-5 ppl/month bones, burns, etc.)
• Respiratory • Skin disease: 1,500-1,600 ppl (6-7%)
• Skin disease • Respiratory: 400-500 ppl (1-2%)
• Others: high blood pressure, • Others: cold, cough, fever, joint pain,
malaria, malnutrition, heat stroke, diarrhea, swelling of legs, stomachache,
etc. etc.
11
Additional medical checkup items for waste handler and cleaner are in line with the requirement set for Asbestos
removal workers by Gujarat Factories Rule 1963.
248
Result of N/A 80-150 workers were examined during 2006-

chest X- 2009. Out of which, 10-20% showed
ray test abnormality including pneumonia, bronchitis,
minor heart enlargement, etc.
3) HIV/AIDS
According to the annual report (2015-2016) published by National AIDS Control Organization
(NACO), adult HIV prevalence rate in Gujarat state is 0.42% which is the sixth highest prevalence
rate among India. In Alang/Sosiya, India Red Cross Society (IRCS) has been conducting statistical
survey since 2012 and it is reported that the adult HIV prevalence rate in the area was 0.23% in
2015 which is the same level as the national average.
As for the ship recycling workers in Alang/Sosiya, Bhavnagar Blood Bank carried out the survey
targeting 2,155 workers in 2004. Based on the survey, HIV prevalence rate was 0.70% which is
higher rate than Gujarat state and the Indian national average.
(6) Living condition of workers

Residential facilities of ship recycling workers are clustered along the road behind the ship recycling
yard. Majority of the workers are living in dormitories provided by ship recycling yards, self-made
wooden house and rented shanty dwellings, etc. GMB is in catering sanitary facilities across the 10 km
stretch of ASSRY. At present, there are total of seven such complexes in operation.
Dormitory provided by ship Self-made wooden house Rented shanty dwellings

recycling yards
Figure 11-26 Workers’ residential facilities located behind the ship recycling yard
(7) Workers’ opinions on the Project

Followings are the opinions and concerns towards ship recycling by workers interviewed in JICA
Social Survey.
• Poor living conditions with issues of access to drinking water
• Concerns about the risk of accidents
• Compensation for injury is not paid as agreed amount or its delay in payment12
12
Compensation for injuries is within the scope of ESIC coverage, therefore medical benefits can be received by paying
the insurance premiums. However, during JICA Social Survey, some workers informed that if the workers are uninsured
by ESIC or if the treatment was performed in non ESIC registered hospitals, medical expenses shall be paid by workers
first and then refunded by the yard owner.
249
• No wage payment for sickness absence13

• Concerns about unstable employment
According to GMB, the above opinions and concerns are not true as present regulation about safety
health and environment are already covered under Ship Breaking Code 2013 enforced.
11.4. ANALYSIS OF ALTERNATIVES

11.4.1. Without Project option
While there will be no construction related impacts, the following issues are likely to arise without
this Project:
• The global ship breaking capacity will become limited if the number of HKC certified ship
recycling yards in Alang/Soisya do not increase. This may result in a global increase in old and
unsafe ships.
• The ASSRY may lose its competitiveness against other countries, which may result in the
decline of the ship recycling industry in the region. This will subsequently lead to the decline in
employment opportunities and regional economy.
• Environmental risks from ship recycling activities will remain as present.
11.4.2. Analysis of alternatives of ship breaking methods
The following four types of ship breaking methods are compared to analyze the most suitable option
for the ASSRY, taking into account environmental impacts, costs, labor safety and so on. Table 11-45
shows the results of the alternative analysis.
Option 1: Ship breaking by beaching method as done presently
Option 2: Pre-removal of hazardous material at a new dry dock and then ship breaking by beaching
method
Option 3: Pre-removal of hazardous material at a new berthing facility and then ship breaking by
beaching method
Option 4: Ships will be broken on land by constructing a new slipway at each yard
13
According to India Factory Act (1948) and Gujarat Factories Rules (1963), for those who have worked 240 days in the
previous year are entitled to receive paid holidays or sickness absence by submitting a Medical Certificate with the
information of the reason of absence and duration which is issued by registered or approved doctors. Also, ESIC will
cover 70% of wages as sickness benefit to the workers who have contributed for about 3 months in the period of 6
months.
250
Table 11-45 Results of analysis of alternatives

(2) Dry dock + beaching
(1) Beaching method (3) Berth + beaching method (4) Slipway method
method
Required  Improvement of existing yard  Construction of drydock  Construction of berthing  Construction of slipway and
construction (concrete pavement, rainwater  Capital and maintenance facility associated facilities (winch,
works / facilities collection facilities etc.) dredging  Capital and maintenance cradle etc.)
 Improvement of existing yard dredging  Capital and maintenance
(concrete pavement, rainwater  Improvement of existing yard dredging
collection facilities etc.) (concrete pavement, rainwater  Improvement of existing yard
collection facilities etc.) (concrete pavement, rainwater
collection facilities etc.)
Construction / Lowest as only yard improvement Significantly higher than Significantly higher than Significantly higher than
operation costs is required with minimum beaching method as construction beaching method as construction beaching method as construction
maintenance cost and maintenance costs of dry and maintenance costs of berthing and maintenance costs of slipway
dock are required facility are required are required
Main pollution  There is risk of pollution from  There will be no risk of  There is risk of pollution from  There is risk of pollution from
risks ship paints as pre-removal is pollution from ship paints as ship paints as pre-removal is ship paints as pre-removal is
not possible they can be pre-removed at dry not possible not possible
dock  Water pollution associated  Water pollution associated
 Water pollution associated with dredging with dredging
with dredging
Main impacts on  Possible impacts on marine  Loss of habitat due to  Possible impacts on marine  Possible impacts on marine
natural organisms through pollution of construction of dry dock organisms through pollution of organisms through pollution of
environment intertidal area  Possible impacts on adjacent intertidal area intertidal area
coastal areas (e.g. coastal  Loss of habitat due to  Loss of habitat due to
erosion) due to construction of construction of berthing construction of slipway
dry dock facility  Possible impacts on adjacent
 Water pollution from dredging  Possible impacts on adjacent coastal areas (e.g. coastal
activities may impact marine coastal areas (e.g. coastal erosion) due to construction of
organisms erosion) due to construction of slipway
berthing facility  Water pollution from dredging
 Water pollution from dredging activities may impact marine
activities may impact marine organisms
organisms
Risk of accidents No change in risks from present Same level of risk as beaching Same level of risk as beaching Level of risk less than beaching
251
(2) Dry dock + beaching

(1) Beaching method (3) Berth + beaching method (4) Slipway method
method
method as ship breaking method method as ship breaking method method as ship breaking is
does not change does not change conducted on land where safety is
easier to manage
Main health risk There are health risks associated Same as beaching method Same as beaching method Same as beaching method
to workers with exposure to asbestos and
gas-cutting fumes
252
As per the alternative analysis, beaching method is considered most appropriate for ASSRY for the
following reasons:
• Technical aspect: High level of maintenance work is required for non-beaching methods.
• Cost: Beaching method requires the least investment for construction and maintenance and
favorable in ASSRY in terms of geographical features..
• Social: High operational cost of non-beaching methods may result in loss of competitiveness of
ASSRY, which may result in the decline of the ship recycling industry in the region.
• Environment: Dry-dock method will eliminate the risk of pollution by ship paints. The merit of
dry-dock however is likely to become less in the future as ships using hazardous paints are
likely to gradually decrease through recent enforcements. Non-beaching methods will have
additional potential environmental impacts such as loss of habitats, coastal erosion and dredging
associated water pollution.
• Labor: No major difference between the four methods.
11.5. SCOPING AND TOR OF THE EIA STUDY

The potential environmental impacts of the Project were identified initially through a scoping exercise,
covering the construction and operation phases. The scoping process identifies the impacts that are likely
to be of most importance and eliminates those that are of little concern.
Scoping was conducted by referring to the current environmental status, opinions of stakeholders and
JICA’s “Guidelines for environmental and social considerations (2010)”, which provides a list of items
to be considered in the scoping process. The potential impacts of each scoping item were rated in
accordance to the following criteria:
A+/-: Significant positive/negative impact is expected.
B+/-: Positive/negative impact is expected to some extent.
C+/-: Extent of positive/negative impact is unknown.

D: No impact is expected
Table 11-46 shows the results of the scoping including the rationale behind the rating. Note that the
alleviating effects of mitigation measures were not considered in the evaluation. The table also shows
the TOR of the EIA study for items identified with potential negative impacts.
253
Table 11-46 Results of scoping
Item Phase Rating Rationale TOR of JICA EIA study

1 Air pollution C B- Dust and exhaust gas emissions from construction works  Consider impacts by identifying major air pollution
may temporary affect the local air quality. sources by referring to the construction plan.
O B+ Fugitive dust emissions from ship recycling yards are likely ―
to decrease due to new concrete pavement.
O A- The following air pollution sources may have significant TSDF:
impacts on air quality:  Consider accumulative impacts of waste incinerators by
TSDF: referring to the air dispersion simulation undertaken in
 Stack emissions from existing and new waste the EIA.
incinerators.  Consider impacts by predicting future traffic volume of
 Exhaust gas emissions from waste transport vehicles. waste transport vehicles.
Yard: Yard:
 Asbestos dispersion and leakage of refrigerants (e.g.  Consider impacts by investigating current asbestos
ODS and GHG) through ship breaking activities. handling practices and implementing asbestos survey.
 Emission of toxic fumes from gas cutting works.  Consider impacts by investigating current refrigerant
handling practices.
 Consider impacts by investigating current gas cutting
practices.
2 Water C A- The following pollution sources may have significant  Consider impacts by investigating soil quality at selected
pollution impacts on water quality: ship recycling yards.
 Uncontrolled dumping of polluted excavated soil from  Consider impacts of washwater by referring to the
ship recycling yard. construction plan.
 Uncontrolled discharge of concrete washwater.
O A- The following pollution sources may have significant TSDF:
impacts on water quality:  Consider impacts by investigating groundwater quality
TSDF: around TSDF and wastewater treatment method of
 Effluent from existing and new ETP. existing and new ETP.
Yard: Yard:
 Spills and leakage of pollutants (e.g. waste oil, bilge)  Consider impacts by investigating pollution risks of ship
through ship breaking activities in the intertidal zone. breaking activities and how the Project can reduce such
 Rainwater runoff from polluted ship recycling yards. risks.
 Discharge of treated effluent and oil spills from offshore  Consider impacts by investigating pollution risks of
tank cleaning barge. offshore tank cleaning operation.
254

3 Soil pollution C A- The following pollution sources may have significant  Consider impacts by investigating soil quality at selected
impacts on soil quality: ship recycling yards.
 Uncontrolled dumping of polluted excavated soil from  Consider risks of oil spills and leakage by referring to the
ship recycling yard. type of construction vehicles and machines.
 Spills and leakage of oil from construction vehicles and
machines.
O A- The following pollution sources may have significant TSDF:
impacts on soil quality:  Consider impacts by referring to the air dispersion
TSDF: simulation undertaken in the EIA and by investigating
 Stack emissions from TSDF waste incinerators. soil quality around TSDF.
Yard: Yard:
 Oil and paint chips remaining on dismantled ship blocks  Consider impacts by investigating pollution risks of ship
and parts. breaking activities and how the Project can reduce such
 Oil leakages from heavy vehicles and machines. risks.
4 Waste C A- Various types of non-hazardous and hazardous construction  Consider impacts by identifying the type of construction
wastes may be generated including potentially waste that will be generated.
contaminated excavated soil.
O A- The risk of pollution is high as various types of hazardous  Consider impacts by investigating current waste
wastes will be generated such as asbestos, paint chip, treatment and disposal practices and how the Project can
glasswool, oil sludge and bilge water. reduce such risks.
5 Noise and C B- Noise from construction vehicles and machines may have  Consider impacts by identifying major noise sources by
vibration some impacts. referring to the construction plan
O B- Ship breaking and associated activities may have some  Consider impacts by identifying major noise sources.
impacts.
6 Ground C, O D There are no activities that may cause ground subsidence. ―
subsidence
7 Offensive C D There are no notable odor sources. ―
odor O B- TSDF may become a source of offensive odor.  Consider impacts by identifying whether there are any
current odor issues.
8 Bottom C D There are no activities that may cause sediment pollution. ―
sediment O A- Ship breaking activities and rainwater runoff from polluted  Consider impacts by investigating pollution risks of ship
ship recycling yards may contaminate bottom sediments. breaking activities and how the Project can reduce
pollution risks. Also implement sediment quality survey.
9 Conservation C、O D There are no conservation areas around the project area. ―
area
255

10 Ecosystem, C D Impacts on ecosystem are unlikely as construction works ―
flora/fauna will be inside existing yards and TSDF.
O A- Pollution from ship breaking activities may have significant  Consider impacts by studying the situation of marine life
impacts on marine ecosystem. and how the Project can reduce impacts by reducing
pollution risks.
11 Hydrology C D Impacts are unlikely as construction works will be inside ―
existing yards and TSDF.
O D No impacts are expected. ―
12 Topography C D Impacts are unlikely as construction works does not ―
involve any major civil works.
O B- Coastal erosion/accretion may occur through construction  Consider impacts by studying the coastal erosion and
of jetty. accretion dynamics of the coastal area.
13 Involuntary C, O D There will be no involuntary resettlement ―
resettlement
14 Vulnerable C, O D There are no vulnerable social groups around the project ―
social groups area.
15 Livelihood, C B+ Construction works will provide employment opportunities ―
living to the local people.
environment C B- Job opportunities for ship breaking workers may reduce as  Consider impacts by referring to construction plan.
ship breaking activities may be halted during construction
works.
O B+ Job opportunities for ship breaking workers are likely to ―
increase due to expected increase in demand of ship
recycling.
16 Land use C, O D There will be no significant change to current land use. ―
17 Local C, O D All required resources (e.g. construction materials) will be ―
resource procured from licensed suppliers and there will be no need
for new local development for resource.
18 Water use C D Impacts are unlikely as construction works will be inside ―
existing yards and TSDF.
O B- . Consider impacts by studying water use of potentially
 Discharge of treated effluent from TSDF may affect affected areas.
downstream water use.
 Operation of offshore tank cleaning barge may affect
water use in the offshore sea area.
256

19 Social C D Impacts are unlikely as construction works will be inside ―
infrastructure existing yards and TSDF.
s and services O B+ Living environment of workers will improve through the ―
renovation of the worker’s housing complex.
20 Social C, O D There are no activities that may have adverse impacts on ―
institutions social institutions.
21 Misdistributi C, O D There are no activities that may cause misdistribution of ―
on of benefit benefit and losses.
and losses
22 Local C, O D There are no activities that may cause local conflicts of ―
conflicts of interest.
interest
23 Cultural C, O D There are no cultural heritages around the project area. ―
heritage
24 Landscape C, O D There will be no significant changes to current landscape. ―
25 Gender C, O D There are no activities that may trigger gender issues. ―
26 Children’s C, O D There are no activities that may violate children’s rights. ―
rights
27 Infectious C B- There is risk of infectious diseases spreading through influx  Consider risks by studying current situation of infectious
diseases of construction workers. diseases and by referring to construction plan.
(HIV/AIDS O B- The risk of infectious diseases spreading is relatively high  Consider risks by studying current situation of infectious
etc.) as most workers will be from other regions. diseases.
28 Occupational C B- There is a moderate risk of occupational accidents as  Consider risks by referring to construction plan.
safety construction works may proceed together with ship
breaking works.
O A- The risks of occupational accidents and health impacts are  Consider risks by identifying high risk works.
high as ship breaking involves various dangerous works  Consider risks by studying status of workers health.
and exposure to pollutants.
29 Accidents C B- Traffic accidents may occur due to construction vehicles.  Consider accident risks by referring to construction plan.
O B- The risks of traffic accidents may increase with increase in  Consider accident risks by predicting future traffic
heavy vehicles. volume.
C: Construction phase, PC: Post-construction phase
257
258
11.6. IMPACT ASSESSMENT AND MITIGATION MEASURES

11.6.1. IMPACT ASSESSMENT
This Section assesses the impacts for items that were rated with potential negative impacts in the
scoping exercise. Note that mitigation measures are not considered in the assessment.
Table 11-47 summarizes the results of the impact assessment.
259
Table 11-47 Results of impact assessment
Rating after impact

Rating of scoping
assessment
Item Rationale
Constru Operati Constru Operati
ction on ction on
1 Air pollution B- A- B- B- [Construction]
Rated from “B-” to “B-”as there is to some extent potential for air pollution through for example
construction vehicle traffic, heavy civil works and concrete plant operation.
[Operation]
Rated from “A-” to “B-” as air pollution from TSDF incinerators are predicted in the EIA air
pollution model to be negligible. However, there is still to some extent potential of air pollution such
as through gas-cutting fumes, leakage of refrigerants and asbestos handling.
2 Water A- A- B- B- [Construction]
pollution Rated from “A-” to “B-” as the JICA soil quality survey did not show any significant contamination
of yard soil, which means the risk of water pollution from soil disposal is minimal. However, there is
still to some extent potential for water pollution such as through uncontrolled discharge of concrete
washwater.
[Operation]
Rated from “A-” to “B-” as risk of water pollution will reduce through the Project (e.g. yard
improvement, use of MDS and large crane). However, there is still to some extent potential for water
pollution such as through discharge of treated effluent from tank cleaning barge and new ETP of
TSDF.
260
Rating after impact

Rating of scoping
assessment
Item Rationale
ction on ction on
3 Soil A- A- B- B- [Construction]
pollution Rated from “A-” to “B-” as the JICA soil quality survey did not show any significant contamination
of yard soil, which means the risk of soil pollution from soil disposal is minimal. However, there is
still to some extent potential of soil pollution such as through oil spill/leakages from construction
vehicles and machines.
[Operation]
Rated from “A-” to “B-” as air pollution from TSDF incinerators are predicted in the EIA air
pollution model to be negligible, hence risk of soil pollution low. However, there is still to some
extent potential for soil pollution in the yard areas such as from gas-cutting fumes.
4 Waste A- A- B- B- [Construction]
Rated from “A-” to “B-” as the JICA soil quality survey did not show any significant contamination
of yard soil, which was a potential hazardous waste. However, there is still to some extent potential
impacts as various other construction wastes will be generated.
[Operation]
Rated from “A-” to “B-” as the new TSDF facilities will contribute in reduction of waste volume,
stabilization of hazardous wastes and so on. However, there is still to some extent potential impacts
as by-product wastes will be generated from the new TSDF facilities (e.g. sludge, fly ash).
5 Noise B- B- B- B- [Construction]
Rated from “B-” to “B-” as there is to some extent potential of noise pollution from construction
activities such as through frequent passing of construction vehicles.
[Operation]
Rated from “B-” to “B-” as there is to some extent potential of noise pollution from yard operation.
6 Odor D B- D D [Operation]
Rated from “B-“ to “D“ as no odor issues have been raised in the past and the Project will have no
added significant odor source.
261
Rating after impact

Rating of scoping
assessment
Item Rationale
ction on ction on
7 Sediment D A- D B- [Operation]
Rated from “A-” to “B-” as less pollutants will enter the sea through the yard improvements works,
deployment of MDS/large crane and so on. However, there is still to some extent risk of sediment
pollution from ship paints.
8 Ecosystem, D A- D B- [Operation]
flora/fauna Rated from “A-” to “B-” as conditions for marine organisms are expected to gradually improve.
9 Topography D B- D D [Operation]
Rated from “B-“ to “D“ as the new jetty for the tank cleaning barge is expected to have minimal
impacts on the littoral drift due to its limited length (around 50 m) and sufficient spacing between
the piers (5 m spacing).
10 Livelihood, B- B+ D B+ [Construction]
living Rated from “B-” to “D” as yard construction works will be planned in manner to prevent any
environment stoppage of ship breaking operation.
11 Infectious B- B- B- B- [Construction]
diseases Rated from “B-” to “B-” as there will usually be around 100 construction workers, which could
(HIV/AIDS potentially spread infectious disease.
etc.) [Operation]
Rated from “B-” to “B-” as there will be constant influx of yard workers from other regions, which
could potentially spread infectious disease.
12 Occupational B- A- B- B- [Construction]
safety Rated from “B-” to “B-” as there will be risk of occupational accidents mainly as construction works
will proceed side-by-side with ship breaking works.
[Operation]
Rated from “A-” to “B-” as risk of occupational accidents is expected to reduce through
strengthening of the current GMB safety training programs.
13 Accidents B- B- B- D [Construction]
Rated from “B-” to “B-” as there is to some extent risk of accidents such as by frequent movement
of construction vehicles.
[Operation]
Rated from “B-” to “D” as risk of accidents are not expected to increase through this Project.
262

263
11.6.2. MITIGATION MEASURES (CONSTRUCTION STAGE)
This Section describes the planned mitigation measures for items that are assessed to have potential
negative impacts in the construction stage.
(1) Air pollution

1) Fugitive dust and exhaust gas emissions from construction vehicles
There will be frequent movement of construction vehicles to and from the construction site to
transport construction materials. While it will be temporary, fugitive dust and exhaust gas emissions
from these construction vehicles may deteriorate the surrounding air quality. Hence, the following
measures will be implemented to minimize such impacts:
 Only use construction vehicles in compliance with vehicle emission standards set under
Central Motor Vehicles Rules, 1989.
 Only use construction vehicles with “Pollution under Control Certificate”.
 Conduct regular maintenance of construction vehicles.
 Covering of truck loading bed when transporting loose materials such as rock and soil.
 Avoid to the extent possible passing through sensitive areas (e.g. residential area, schools).
If unavoidable, minimize dust dispersion through slow driving.
2) Dispersion of fugitive dust from yard improvement works
Yard improvement works will involve some heavy construction activities such as excavation and
ground-levelling works, which may deteriorate the surrounding air quality through dispersion of
fugitive dust. Hence, the following measures will be implemented to minimize such impacts:
 Regular water spraying of exposed surfaces.
 Covering of unused stockpiles such as excavated soil.
3) Dispersion of fugitive dust from concrete batching plant
A temporary concrete batching plant will be established in an area near the Project site. Concrete
batching plant may deteriorate the surrounding air quality as there are various fugitive dust sources.
Hence, the following measures will be implemented to minimize such impacts:
 Concrete batching plant to be established at least 200 m14 away from sensitive areas (e.g.
residential area).
 Concrete batching plant to be equipped with standard dust suppression measures (e.g.
enclosed conveyor and hopper).
 Cement to be stored in sealed and dust-tight storage silos.
 Regular water spraying of exposed surfaces.
 Height of aggregate stockpile to be minimized to reduce wind erosion.
 Aggregate stockpile to be covered when not actively being used.
(2) Water pollution

1) Pollution by uncontrolled disposal of excavated soil
Construction works at the ship recycling yards will generate excavated soil. While the JICA soil
quality survey did not show any significant contamination, pollutants such as lead and PAHs were
detected. Since uncontrolled disposal of such soil may cause water pollution, the excavated soil will
be reused inside the yard as material for raising the yard ground level (e.g. road section). The raised
14
Recommended setback distance for concrete batching plant as per South Australia EPA, Guidelines for separation
distances (2007).
264
areas (i.e. exposed excavated soil) will then be covered by geomembrane and clean soil layer to
prevent exposure to rainwater and hence minimize risk of groundwater and seawater contamination.
Figure 11-27shows the how the excavated soil will be reused and covered.
Figure 11-27 Process of excavated soil reuse

2) Pollution by uncontrolled discharge of concrete washwater
Concrete washwater generated from the construction sites and concrete batching plant (e.g.
agitator washout areas) will be highly alkaline (typically around pH 12), which could cause water
pollution if discharged in an uncontrolled manner. Hence, the following measures will be
implemented to avoid such impacts:
 All concrete washwater generated from construction sites and concrete batching plant to be
collected and treated through an impermeable settling pond installed inside the premises of
the concrete batching plant.
 Recovered washwater to be reused inside the plant as much as possible to avoid or minimize
discharge to the environment.
 Discharge of recovered water to be allowed only if pH levels are within effluent discharge
standard set under Environment (protection) Rules, 1986, Schedule VI (pH 5.5-9.0).
 Settled solids in the settling pond to be removed regularly and reused or recycled to the
extent possible. Disposal only to be allowed at GPCB authorized disposal facility.
 In addition to the above, all conditions stipulated in GPCB consent to establish will need to
be complied.
(3) Soil pollution

1) Pollution by uncontrolled disposal of excavated soil
Soil pollution by excavated soil will be avoided by reusing inside the yard as material for raising
the yard ground level (see Section 11.7.2 for details).
265
2) Pollution by oil leakages from construction vehicles and equipment
Various construction vehicles and equipment will be used during construction works, which if
not well maintained may cause soil contamination through oil/fuel leakage. Hence, the following
measures will be implemented to avoid such impacts:
 Regular inspection for oil and fuel leaks. Leaking vehicles and equipment to be removed
until repaired.
 Repair and maintenance works to be undertaken at dedicated workshops. If not available,
appropriate spill prevention measures (e.g. use of oil tray) to be used and oil spill response
kit (e.g. absorbents) be readily available.
 Fuel storage and handling areas to be bounded with an impermeable base.
(4) Waste
Major construction wastes will be concrete debris, metal scraps, wood scraps and domestic wastes.
These wastes will be handled as per Construction and Demolition Waste Management Rules 2016 and
will be reused/recycled as much as possible to reduce waste volume. Hazardous wastes if any, will be
handled as per Hazardous Waste (Management, Handling & Transboundary Movement) Rules 2008 and
treated/disposed at GPCB authorized facilities after obtaining authorization from GPCB. Excavated soil
from the ship recycling yard will be reused inside the yard as raising material, which as result will
prevent generating large volume of waste.
Prior to the commencement of construction works, the Construction Contractor will be required to
prepare a Waste Management Plan (WMP) and report to GMB and other waste authorities for approval.
The WMP shall include among other the following information:
 Type and quantity of construction wastes and planned storage, treatment and disposal methods.
 Reuse and recycling plan.
 Hazardous waste management plan (if any).
(5) Noise
There will be frequent movement of construction vehicles to and from the construction site to
transport construction materials, which may become a nuisance to local residents. Hence, the following
measures will be implemented to minimize such impacts:
 Only use construction vehicles in compliance with vehicle noise standards set under
Environment (protection) Rules, 1986: Part E Schedule VI.
 Regular maintenance of construction vehicles and machines.
 Avoid to the extent possible passing through sensitive areas (e.g. residential area, schools).
(6) Infectious diseases

There will usually be around 100 construction workers, and such influx of construction workers may
raise the risk of infectious disease (e.g. HIV) spreading. To minimize such risks, the Construction
Contractor will be required to prepare HIV/AIDS Prevention Plan and obtain approval from GMB and
other relevant organizations. The plan shall among others include the following:
 Planned awareness programs for construction workers
 Code of Conduct to be complied by the construction workers
 Other measures
(7) Occupational safety

There is a moderate risk of occupational accidents mainly as construction works will proceed side-by-
side with ship breaking works. The Construction Contractor will therefore be required to prepare an
Occupational Health and Safety Plan in accordance to Indian laws and regulations and JICA’s “The
Guidance for the Management of Safety for Construction Works in Japanese ODA Projects” and obtain
approval from GMB and other relevant organizations if necessary. The plan shall among others include
the following:
 Risk assessment and planned safety measures
266
 Training plan for construction workers

 Organizational structure
 Emergency response plan
(8) Accidents
There is a risk of traffic accidents as there will be frequent movement of construction vehicles such as
for transporting construction materials. Hence, the following measures will be implemented to minimize
such risks:
 Strict compliance to speed limits.
 Avoid to the extent possible using roads with high risk of accidents.
 Vehicle motion alarm to be installed on all construction vehicles.
 Placement of warning signs and traffic control officers at high risk areas.
11.6.3. MITIGATION MEASURES (OPERATION STAGE)
This Section describes the planned mitigation measures for items that are assessed to have potential
negative impacts in the construction stage.
(1) Air pollution

1) Impacts of stack emissions from TSDF incinerators
The air quality around the Project area may worsen through the combined operation of the
existing and new TSDF incinerators. The EIA predicts the future ground level air quality (PM10,
SO2, NOx) around the Project area by considering the added emissions from the new incinerator.
USEPA AERMOD air quality simulation model was used and the simulation was conducted under
the following scenario:
• Emission rates from the new incinerator was computed based on the stack emission monitoring
results of the existing incinerator.
• For NOx concentration, expected emissions from the 15 new recycling plots16 and associated
vehicles were incorporated into the simulation.
• For meteorological input, three-month observation data in the summer of 2015 was used.
Table 11-48 shows the predicted 24-hour average ground level concentration at the EIA air
quality monitoring stations. Figure 11-29 shows the location of the EIA air quality monitoring
stations.
Table 11-48 Predicted 24-hour average ground level concentration at EIA air quality monitoring stations
(µg/m3)
PM10 SO2 NOx
Station Monitored Predicted Total*3 Monitored Predicted Total*3 Monitored Predicted Total*3
*1 *2 *1 *2 *1 *2
Alang Fire Stn. 79.8 0.30 80.10 7.3 0.45 7.75 31.7 0.43 32.13
Alang village 77.2 0.14 77.34 7.0 0.21 7.21 22.8 0.99 23.79
Sosiya village 73.7 0.07 73.77 6.1 0.10 6.20 20.5 0.24 20.74
Mathavda 67.0 0.17 67.17 6.3 0.26 6.56 21.4 0.24 21.64
Kathava 72.8 1.02 73.82 5.5 1.53 7.03 21.2 0.84 22.04
*1: Mean concentration recorded during EIA air quality baseline study (March-May 2015).
*2: Predicted contribution of the new incinerator (and others in case of NOx) to ground level air quality concentration.
16
The plan of constructing 15 new recycling plots is no longer included in this Project.
267
*3: Predicted future ground level air quality concentration (sum of Monitored and Predicted values).
Figure 11-28 Location of EIA air quality monitoring stations

The EIA prediction shows that the new incinerator will have negligible impacts on the local air
quality. For example, PM10, SO2 and NOx levels will only increase at maximum by about 1 µg/m3,
1.5 µg/m3 and 1 µg/m3 respectively. The predicted sum concentrations are also below the 24-hour
national ambient air quality standard (PM10: 100 µg/m3, SO2: 80 µg/m3, NOx: 80 µg/m3) at all the
stations.
Impacts of incinerating PCB containing materials are considered negligible as the new
incinerator is designed to destruct PCBs into constituent elements through the high-temperature
incineration process (minimum of > 1,100 °C with over 2 seconds retention time). Other measures
to prevent or minimize impacts are as follows:
 The incinerator will be designed so that formation of hazardous incineration byproducts such
as dioxins are minimized by rapid cooling of flue gas.
 Flue gas will be treated through a dust collector system so that stack emission gas complies
with Indian emission standards (Emission standards for common hazardous waste incinerator
set under Environmental Protection (Fifth Amendment Rules) 2008).
 An online monitoring system will be installed as per requirement of EC (Specific conditions
xviii) for continuous monitoring of stack emission gas concentration and operation will
immediately cease if exceedance of set standards is detected.
 Implementation of regular maintenance works.
 Treatment performance will be checked regularly by sampling and analysis of stack emission
gas concentration when under critical operating conditions.
2) Impacts of yard operation

a. Impacts of asbestos handling
Currently asbestos are removed and handled in accordance to Ship Breaking Code 2013 which
are conducted by qualified yard workers or by GPCB authorized operators. Some of the main
measures employed are as follows:
268
 Asbestos handling in the yard area are undertaken only in dedicated facility equipped with
negative pressure chamber and HEPA filter exhaust outlet.
 Wetting of asbestos parts during removal and handling works.
 Removed asbestos are contained in specialized leak proof bags and stored in dedicated storage
facility until transport to TSDF.
 At TSDF, asbestos wastes are solidified with cement at a dedicated disposal site.
Providing these measures are implemented appropriately, the risk of asbestos pollution should be
low. However, since relatively high levels of asbestos was detected at TSDF, TSDF operators
should take extra precaution when handling asbestos so to prevent any tears in the leak proof bags,
especially when temporary storing them at the TSDF storage area. Also asbestos handling facility in
the yard should be placed as far as possible from the yard boundary so to minimize dispersion
outside the yard premises. The asbestos handling facility should also be inspected regularly and
recorded for the following to ensure asbestos dispersion is prevented / minimized:
 Negative pressure ventilation

 HEPA filter
b. Impacts of refrigerants handling
Refrigerants may contain ozone depleting substances (ODS) and green-house gases (e.g. HFC,
HCFC), which if handled inappropriately may have significant impacts. Refrigerants are currently
removed from ships by authorized persons and then sent to customs. This procedure may change as
customs are expected to no longer accept refrigerants in the future. Hence instead of sending to
customs, as per requirement of EC (Specific Conditions xx), yard operators will be required to send
recovered refrigerants to authorized recycler/reclaimer, and if recycling/reclaiming are not possible
refrigerants will need to be sent to authorized destruction facilities. Yard operators must also ensure
that refrigerants are recovered without leaking and stored safely.
c. Impacts of gas-cutting works
According to the JICA waste composition study, various heavy metals were detected in some
paints used on the surveyed ships. Gas cutting of ship parts may therefore release toxic fumes into
the atmosphere. According to the prediction of Deshpande PC et al., (2012)17, gas-cutting works
can potentially elevate yard area lead concentration up to levels of 8-30 µg/m3, which significantly
exceeds the Indian national ambient air quality standard for lead (industrial area 24 hours-average:
1.0 µg/m3).
To prevent such release of toxic fumes it is recommended by GPCB to remove paints prior to gas
cutting at least up to a distance of 10 cm from the cutting line. However, according to some yard
operators such practice is too time consuming and impractical, unless some efficient paint removal
methods are developed. For the time being, regular air quality monitoring will be conducted in the
yard and surrounding areas to check the pollution status.
d. Impacts of waste transportation
There will be a slight increase in the waste transport vehicle traffic due to the transport of oily
wastewater from the MDS and offshore tank cleaning barge to TSDF. However, the estimated
increase in traffic volume will only be around 15 vehicles/day, which will have negligible impact
on air quality. Nevertheless, to minimize impacts, it will be necessary to only use vehicles in
17
Deshpande PC, Tilwanker AK, Asolekar SR. A novel approach to estimating potential maximum heavy metal exposure
to ship recycling yard workers in Alang, India. Science of the Total Environment 438 (2012) 304-311.
269
compliance with vehicle emission standards set under Central Motor Vehicles Rules, 1989 and
vehicles with a valid “Pollution under Control Certificate”.
(2) Water pollution

1) Impacts of ship breaking activity in the intertidal zone
The risk of water pollution in the intertidal zone during ship breaking activity is expected to
decrease significantly through the employment of MDS and large mobile crane. Main reasons are as
follows:
 MDS will be capable of removing oil residues from places inside ships that were previously
difficult to completely remove before ship breaking such as inside fuel tanks and pipes. Figure
11-29 shows an image of fuel tank cleaned by MDS.
Figure 11-29 Image of fuel tank before and after cleaning by MDS
(left: before cleaning, right: after cleaning)
 By employing large mobile crane it will be possible to avoid cutting off ship stern during the
ship recycling process which is a common practice employed now especially for large ships.
This will enable to prevent oil spills/leakage into intertidal zone from engine compartment.
The risk of water pollution from yard operation is expected to decrease significantly through the
concrete pavement of the cutting area and storage area of dismantled parts. However, to be
effective, it will be important that the rainwater runoff drains and collection tanks are regularly
checked and cleaned to avoid any overflow.
3) Impacts of tank cleaning vessel
There is a risk of accidental oil spill during the operation of offshore tank cleaning barge as it
will be conducted in rough offshore waters. The following oil spill response measures are planned
so that water pollution can be minimized in case of such oil spill incidents:
 Installation of oil boom during tank cleaning works.

 Stand-by of oil spill response vessel during tank cleaning works.
To reduce the volume of oily water treatment at TSDF, low-oil content oily water generated
through the tank cleaning process is planned to be discharged to sea after treatment by onboard ETP
as per Environment (Protection) Amendment Rules 2015: effluent standards for common effluent
treatment plants (into sea). Treated effluent will be monitored continuously through online
monitoring system and the water quality of the receiving sea area will also be monitored throughout
the operation. In case of any detection of water pollution or exceedance of discharge standards,
270
operation will be ceased immediately. Providing that effluents are discharged under set standards, it
is expected that the effluent will quickly dilute to negligible levels through biological
decomposition and current/wave actions. However, since the operation area is still undecided, there
could be some impacts in case there are any sensitive ecosystem or fishing grounds nearby. A
detailed impact assessment should therefore be implemented in the D/D stage taking into account
for example the locations of sensitive ecosystem and fishing grounds and operation area shifted
accordingly. The applicability of Environment (Protection) Amendment Rules 2015: Effluent
standards for common effluent treatment plants (into sea) should also be considered. Stakeholders
should also be consulted through the process especially GPCB in case the operation area lies inside
territorial water which is under their jurisdiction.
4) Impacts of TSDF effluent treatment plant
The new ETP (120 m3/day) will treat wastewater generated from MDS, offshore tank cleaning
barge, sludge treatment plant, oil/water separation system and so on. Under full operational
condition, the total effluent generated from the existing and new ETPs will add up to 150 m3/day,
which if not treated/discharged appropriately may contaminate the surrounding environment. To
minimize such pollution risks, the following measures will be implemented:
 Wastewater will be treated to levels below the effluent standard set under Environment
(Protection) Rules, 1986 (Schedule VI).
 Treated effluent will be reused as far possible within the TSDF facility so to minimize
discharge outside TSDF.
 Continuous monitoring of treated effluent concentration through automatic/online monitoring
system as per requirement of EC.
 Pre- and post-effluent concentration will be monitored regularly to check the effectiveness of
the ETP.
Further studies will be required to estimate how much treated effluent can be reused inside TSDF.
Currently to avoid groundwater contamination, non-reusable effluent is planned to be discharged
into the rainwater drainage outside TSDF. However, the appropriateness of such discharge route
should be studied in the D/D stage together with an impact assessment on downstream water use.
(3) Soil pollution
1) Impacts of TSDF incinerators
Uncontrolled stack emissions from the TSDF incinerators may contaminate soils of the
surrounding area for example by PCBs and dioxins. However, the risks of such contamination is
low as the existing and new incinerators are designed to prevent/minimize emissions of such
pollutants. The EIA air quality simulation also predicts that emission gas from the TSDF
incinerators will have negligible impact on ambient air quality, which also can be implied that
potential for soil pollution from the incinerators will be minimal. Nevertheless, regular soil quality
monitoring will be implemented around TSDF to check the soil pollution status.
The risk of soil pollution from yard operation is expected to reduce significantly through the yard
improvement works as pollutants will be contained within the concrete flooring areas. The yard
area will also be cleaned daily to remove any debris such as paint chips. Each yard will need to be
equipped with an oil spill response kit in response to accidental spills.
Toxic fumes from the gas-cutting works may pollute the soil. While such pollution can be
minimized by removing toxic paints prior to cutting, such practice is currently too time consuming
271
and impractical. Therefore, for the time being, regular soil quality monitoring will be conducted in
the yard area to check the pollution status.
(4) Wastes
The Project will have the following positive impacts regarding waste:
 The lifespan of the TSDF landfill will be extended significantly as waste volume can be reduced
by the baler and high-temp incinerator.
 Oily sludge can be disposed at the TSDF landfill in a more stable state as most of the oily content
will be removed through the new oil sludge treatment plant.
 Hazardous wastes with persistent organic pollutants (e.g. PCB containing wastes) can be
disposed at the TSDF landfill in a safer state through thermal treatment by the high-temp
incinerator.
The new TSDF facilities will on the other hand create new wastes such as sludge from ETP and
bottom/fly ash from high-temp incinerator. These wastes will be disposed through the following method
to avoid/minimize any impacts:
 Sludge from ETP will be disposed at the TSDF landfill after drying.
 Bottom ash will be reused/recycled and fly ash will be disposed at TSDF landfill after
containment inside specialized container.
(5) Noise
Noise levels from recycling activities are expected to be of similar level as present, as there will be no
significant additional noise sources generated through this Project. Impacts if any will also be limited to
daytime as no works are done in nighttime.
(6) Odor
TSDF could be a source of odor but no issues have been raised by the residents and GEPIL. Therefore,
odor impacts are unlikely to occur as there will be no additional odor sources generated through this
Project.
(7) Sediment
The risk of sediment pollution is expected to reduce significantly as less pollutants will enter the sea
through the yard improvements works and introduction of MDS, large crane and so on. Paint chips
however may still fall into the sea during ship breaking works, but this is somewhat impossible to fully
prevent unless all paints are removed before ship breaking works. Meanwhile, regular sediment quality
monitoring will be conducted in the sea area to check the pollution status.
(8) Ecosystem
According to the EIA study, marine life along the ship recycling yard area is relatively low in
biodiversity and abundance, which may partly be attributed to ship breaking activities. However, this
situation may change as risk of marine pollution is expected to reduce significantly through this Project.
The abundance and diversity of marine life will be monitored regularly to see how marine life will
change over time.
One other concern is impact of paint chips on benthic marine life, as there will still be risk of pollution
by falling paint chips. Hence benthos TBT concentration will be regularly monitored to check the
impacts of paint chips on benthos.
(9) Topography
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The new jetty for the tank cleaning vessel may cause coastal erosion or accretion by interrupting the
longshore littoral drift. However, the risk of such impacts is likely to be minimal due to its limited length
(around 50 m) and sufficient spacing between the piers (5 m spacing)
(10) Infectious disease

According to existing information, HIV infection is not uncommon among the yard workers. To
minimize spreading of HIV, HIV/AIDS awareness program will be implemented as part of the GMB
training program.
(11) Occupational safety

1) Occupational accidents
The main causes of fatal accidents occurring in the ship recycling yards previously were due to
fire/explosion, falling from height, hit by falling object, snapping of winching lines and so on.
These types of accidents are preventable providing that standard safety practices are implemented
as in certified yards. Training of yard workers and managers on occupational safety are also
important and necessary approach to prevent accidents. In this respect, the Project will strengthen
and improve the current GMB safety training programs.
2) Health impacts
a. Impacts of asbestos handling

Currently asbestos are handled by qualified yard workers or by GPCB authorized contractors
wearing appropriate PPE. The results of the JICA asbestos survey imply that asbestos removal
works are undertaken in a safe manner as asbestos concentration in work environment was
below OSHA standard. Therefore, the health risk of asbestos handling will likely be low
providing that current asbestos handling protocol is appropriately implemented. The GMB
training program will also be strengthened through this Project, which will further enhance
worker’s awareness on asbestos risk.
Regular health checks are being done and also will be implemented for workers involved in
asbestos handling for more than 30 days/year, which is a requirement under the EC (Specific
conditions xiv) of this Project. Furthermore, as per Gujarat Factories Rule (Schedule XVII), in
case symptoms of asbestos related disease is detected, those workers will be removed from such
works and provided alternative work until certified as fit to work by a specialized doctor.
Considering the long latency period of asbestos symptoms, asbestos workers should also be
eligible for regular health checks even after leaving his job.
b. Impacts of gas-cutting works

Fumes emitted from gas-cutting works are potentially hazardous to worker’s health as paints
coated on ship plates may contain hazardous substances such as heavy metals as found in the
JICA waste composition study. Although, gas cutters currently wear PPE and avoid fumes by
positioning themselves on the downwind side of the fume, some gas cutters still do not wear
appropriate PPE. Yard workers and operators will be trained though GMB’s training program so
to raise their awareness on the health risks and importance of employing appropriate safety
measures.
Furthermore, each yard will implement regular health checks of gas cutters focusing on
pulmonary function test and blood lead concentration. The OSHA occupational health standard
(1910.1025) sets blood lead level concentration of 50 µg/dL, and workers exceeding this level
are required to be removed from such works until blood lead levels return to below 40 µg/dL.
Such rules will be established as a precautionary measure in all the yards. Ventilation equipment
should also be used when gas cutting in areas with poor ventilation.
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11.7. ENVIRONMENTAL MANAGEMENT PLAN

Based on the environmental impact assessment, an Environmental Management Plan (EMP) was
prepared to ensure that construction and operation works are implemented with minimal environmental
impacts. The EMP summarizes the planned mitigation measures against the anticipated environmental
impacts, the responsibility for its implementation and supervision, and estimated cost. If necessary, the
EMP should be revised in the detailed design phase in line with the progress of the Project plan and
design. Tables 11-49 and 11-50 show the EMP for the construction and operation stages respectively.
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Table 11-49 Environmental Management Plan (Construction stage)
Implementation Supervision
Item Potential impact Mitigation measures Approx. cost
responsibility responsibility
Air pollution Fugitive dust and exhaust gas  Only use construction vehicles in compliance with vehicle emission Construction Supervising Included in
emissions from construction standards set under Central Motor Vehicles Rules, 1989. contractor consultant construction base
vehicles  Only use construction vehicles with “Pollution under Control GMB cost
Certificate”.
 Regular maintenance of construction vehicles.
 Covering of truck loading bed when transporting loose materials
such as rock, sand and mud.
 Avoid to the extent possible passing through sensitive areas (e.g.
residential area, schools). If unavoidable, minimize fugitive dust
through slow driving.
 GMB to impose penalty in case of continuous non-compliance.
Fugitive dust dispersion from  Regular water spraying of exposed surfaces. Construction Supervising Included in
yard improvement works  Covering of unused stockpiles such as excavated soil. contractor consultant construction base
GMB cost
Fugitive dust dispersion from  Concrete batching plant to be established at a sufficient distance Construction Supervising Included in
concrete batching plant away from sensitive areas (e.g. residential area). contractor consultant construction base
 Concrete batching plant to be equipped with standard dust GMB cost
suppression measures (e.g. enclosed conveyor and hopper). GPCB
 Cement to be stored in sealed and dust-tight storage silos.
 Regular water spraying of exposed surfaces.
 Height of aggregate stockpile to be minimized to reduce wind
erosion.
 Aggregate stockpile to be covered when not actively being used.
 In addition to the above, all conditions stipulated in GPCB consent
to establish will need to be complied with.
Water Uncontrolled disposal of  All excavated soil to be reused as material for raising the yard Construction Supervising Under
pollution excavated soil ground level. contractor consultant consideration
 Raised areas to be covered by geomembrane and clean soil. GMB
Uncontrolled discharge of  All concrete washwater generated from construction sites and Construction Supervising Included in
concrete washwater concrete batching plant to be collected and treated through an contractor consultant construction base
impermeable settling pond installed inside the premises of the GMB cost
concrete batching plant.
 Recovered washwater to be reused inside the plant as much as
275
possible to avoid or minimize discharge to the environment.
 Discharge of recovered water to be allowed only if pH levels are
within national effluent discharge standard (Environment
(protection) Rules,1986, Schedule VI).
 Settled solids in the settling pond to be removed regularly and
reused or recycled to the extent possible. Disposal only to be
allowed at TSDF.
 In addition to the above, all conditions stipulated in GPCB consent
to establish will need to be complied with.
Soil pollution Uncontrolled disposal of  All excavated soil to be reused as material for raising the yard Construction Supervising Included in
excavated soil ground level. contractor consultant construction base
 Raised areas to be covered by geomembrane and clean soil. GMB cost
Oil leakages from  Regular inspection for oil and fuel leaks. Leaking vehicles and Construction Supervising Included in
construction vehicles and equipment to be removed until repaired. contractor consultant construction base
equipment  Repair and maintenance works to be undertaken at dedicated GMB cost
workshops. If not available, appropriate spill prevention measures
(e.g. use of oil tray) to be used and oil spill response kit (e.g.
absorbents) be readily available.
 Fuel storage and handling areas to be bunded with an impermeable
base.
Waste Generation of construction  All excavated soil to be reused as material for raising the yard Construction Supervising Included in
waste ground level. contractor consultant construction base
 Construction contractor will be required to prepare Construction GMB cost
Waste Management Plan (CWMP) as per Indian laws/regulations
(Construction and Demolition Waste Management Rules 2016) and
obtain approval from GMB and other relevant organizations when
necessary. The CWMP shall among others include the following:
 Type and quantity of construction wastes and planned storage,
treatment and disposal methods.
 Reuse and recycling plan.
 Hazardous waste management plan (if any).
Noise Noise from construction  Only use construction vehicles in compliance with vehicle noise Construction Supervising Included in
vehicles standards set under Environment (protection) Rules, 1986: Part E contractor consultant construction base
Schedule VI. GMB cost
 Regular maintenance of construction vehicles and machines.
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 Avoid to the extent possible passing through sensitive areas (e.g.
residential area, schools).
Infectious Proliferation of infectious  Construction contractor will be required to prepare HIV/AIDS Construction Supervising Included in
diseases diseases due to influx of Prevention Plan and obtain approval from GMB and other relevant contractor consultant construction base
construction workers organizations when necessary. The plan shall among others include GMB cost
the following: DISH
 Periodical health check twice a year
 Planned awareness programs for construction workers (twice a
year)
 Code of Conduct to be complied by the construction workers
 Other measures
Occupational Risk of occupational  Construction contractor will be required to prepare an Occupational Construction Supervising Included in
safety accidents Health and Safety Plan in accordance to Indian laws and regulations contractor consultant construction base
and JICA’s “The Guidance for the Management of Safety for GMB cost
Construction Works in Japanese ODA Projects”. The plan shall
among others include the following:
 Risk assessment and planned safety measures
 Training plan for construction workers
 Organizational structure
 Emergency response plan
Accidents Risk of traffic accidents  Strict compliance to speed limits. Construction Supervising Included in
 Avoid to the extent possible using roads with high risk of accidents. contractor consultant construction base
 Vehicle motion alarm to be installed on all construction vehicles GMB cost
 Placement of warning signs and traffic control officers at high risk
areas.
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Table 11-50 Environmental Management Plan (Operation stage)
Air pollution Stack emission from TSDF  Stack emission gas concentration to be kept within emission TSDF operator GPCB Included in
incinerators standards for common hazardous waste incinerator set under GMB operation base
Environmental Protection (Fifth Amendment Rules) 2008. cost
 PCB containing materials to be destructed through high-
temperature incineration process (minimum of > 1,100 °C with
over 2 seconds retention time).
 Formation of hazardous incineration byproducts such as dioxins to
be minimized by rapid cooling of flue gas.
 Installation of automatic/online monitoring system for continuous
monitoring of stack emission gas concentration. Operation to cease
immediately in case of exceedance of emission standards.
 Implementation regular maintenance works.
 Confirmation of treatment performance though regular sampling
and analysis of stack emission gas concentration.
Dispersion of asbestos  Asbestos handling to be undertaken only by GPCB authorized Yard operator GPCB Included in
operators or qualified yard workers. TSDF operator GMB operation base
 Asbestos handling in the yard area to be undertaken only in cost
dedicated facility equipped with negative pressure chamber and
HEPA filter exhaust outlet.
 Wetting of asbestos parts during asbestos handling works.
 Removed asbestos to be contained in specialized leak proof bags
and stored in dedicated storage facility until transport to TSDF.
 Asbestos when temporary stored at TSDF should be stored in a
manner that will not cause tears in the leak proof bags.
 Asbestos waste to be solidified with cement at TSDF’s dedicated
disposal site.
 Placing of asbestos handling facility as far as possible from the yard
boundary.
 Regular inspection of asbestos handling facility especially for
negative chamber ventilation and HEPA filter.

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Leakage of refrigerants  Ozone depleting or greenhouse gas refrigerants (e.g. CFC-12, Yard operator GMB Included in
HCFC-22, HFC) to be recovered without leaking into atmosphere operation base
and stored safely. cost
 Recovered refrigerant to be sent to authorized recycler/reclaimer. If
recycling /reclaiming are not possible, then recovered refrigerant to
be sent to authorized destruction facilities.
Dispersion of toxic fumes  To minimize release of toxic fumes, toxic paints or coatings to be Yard operator GMB Included in
through gas-cutting works removed to the extent possible, up to a distance of 10 cm from the operation base
cutting line of the plate. cost
Fugitive dust dispersion from  Water spraying of exposed yard area and roads. Yard operator GMB Included in
yard and access roads  Regular maintenance of access roads. GMB (road operation base
 Establishment of green belt along the access roads wherever space maintenance and cost
is available. green belt
establishment)
Exhaust emissions from  Only use vehicles in compliance with vehicle emission standards TSDF operator GMB Included in
waste transport vehicles set under Central Motor Vehicles Rules, 1989. operation base
 Only use vehicles with “Pollution under Control Certificate” and cost
renew in accordance Central Motor Vehicles Rules, 1989.
Water Ship breaking works in  Oil spills/leakage into intertidal zone to be prevented/minimized by Yard operator GMB Purchase cost of
pollution intertidal zone removing oil residues inside ships with MDS before breaking mobile
works. decontamination
 Oil spills/leakage into intertidal zone to be minimized by avoiding system and
cutting off ship stern through use of large mobile crane (only mobile crane
applicable to bulk carriers and container ships). included in
 Use of oil booms when breaking oil tankers. Project budget
Ship breaking works in yard  Cutting works and equipment maintenance works to be undertaken Yard operator GMB Included in
area only inside dedicated concrete-floor cutting area. operation base
 Oily parts to be stored inside dedicated concrete-floor storage area. cost
 Rainwater collection ditch and tanks to be regularly checked and
cleaned.
279
Offshore tank cleaning works  Installation of oil booms during tank cleaning works. Operator of offshore GMB Purchase cost of
 Stand-by of oil spill response vessel during tank cleaning works. tank cleaning barge offshore tank
 Onboard treated effluent to be discharged in compliance with GMB: Stand-by of cleaning barge
effluent standard set under Environment (Protection) Amendment oil spill response included in
Rules 2015: Effluent standards for common effluent treatment vessel and water Project budget
plants (into sea). quality monitoring
 Continuous monitoring of effluent concentration through
automatic/online monitoring system.
 Immediately cease operation in case of exceedance of effluent
standards or when water pollution is detected through water quality
monitoring.
Effluent from TSDF effluent  Treated effluent to be reused as far possible within the TSDF TSDF operator GPCB Included in
treatment facility facility. GMB operation base
 Treated effluent to be discharged in compliance with effluent cost
standard set under Environment (Protection) Amendment Rules
2015.
 Continuous monitoring of treated effluent concentration through
automatic/online monitoring system.
 Regular sampling and analysis of pre- and post-treated effluent
concentration.
Soil pollution Stack emission from TSDF  Ensure that stack emission gas concentration are kept within TSDF operator GPCB Included in
incinerators emission standards for common hazardous waste incinerator set GMB operation base
under Environmental Protection (Fifth Amendment Rules) 2008, cost
through regular maintenance works and confirmation of treatment
performance though regular sampling and analysis of stack
emission gas concentration.
Ship breaking works in yard  Oil spill response kit to be equipped at each yard in response to Yard operator GMB Included in
area accidental spills. operation base
 Yard areas to be cleaned daily to remove any debris such as paint cost
chips.
Waste Wastes from new treatment  Sludge generated from the new treatment facilities to be disposed at TSDF operator GPCB
facilities TSDF controlled landfill after drying. GMB
 Bottom ash to be reused/recycled and fly ash to be disposed at
TSDF controlled landfill after sealing inside specialized container.
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Bottom Ship breaking works in  Implementation of water pollution control measures such as by use Yard operator GMB Purchase cost of
sediment intertidal zone of MDS and large mobile crane. GMB (monitoring) MDS and mobile
 Regular monitoring of sediment quality. crane included in
Project budget
Ecosystem Deterioration of marine  Implementation of water pollution control measures such as by use Yard operator GMB Purchase cost of
habitat through ship breaking of MDS and large mobile crane. GMB (monitoring) MDS and mobile
works  Regular monitoring of marine life status. crane included in
Project budget
Infectious Proliferation of infectious  Implementation of AIDS awareness program as part of GMB GMB DISH Included in
diseases diseases training course. training base cost
Occupational Occupational accidents  Implementation of occupational health and safety training. GMB DISH Included in
safety Yard operator training base cost
Health impacts due to  Use of appropriate PPEs (respirator, protective clothing, gloves) Yard operator DISH Included in
asbestos handling  Wetting of asbestos parts during asbestos handling works. GMB (training) operation base
 Removed asbestos to be contained in specialized leak proof bags cost
and stored in dedicated storage facility until transport to TSDF.
 Implementation of occupational health and safety training.
Health impacts due to gas  Gas cutters to be positioned in downwind direction. Yard operator DISH Included in
cutting works  Use of appropriate PPEs (e.g. mask, goggles, protective clothing, GMB (training) operation base
gloves). SRIA (health check) cost
 As far as possible, toxic paints or coatings to be removed up to a
distance of 10 cm from the cutting line of the plate.
 Use of ventilation equipment when working inside areas with poor
ventilation.
 Implementation of occupational health and safety training.
 Regular health check of gas cutters.
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11.8. ENVIRONMENTAL MONITORING PLAN

An Environmental Monitoring Plan (EMoP) was prepared to check the effectiveness of the proposed
mitigation measures, status of the surrounding environment and worker’s health. The plan describes the
monitoring objective, methodology, implementation responsibility, approximate cost and justification
(for operation EMoP). The operation EMoP was developed based on approved EIA, conditions of EC,
CPCB guidelines, draft monitoring plan of GMB and JICA Study Team’s technical judgement. Tables
11-51 and 11-52 show the EMoP for the construction and operation stages respectively. Monitoring form
to be used for reporting to JICA is attached as Appendix xx.
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Table 11-51 Environmental Monitoring Plan (Construction stage)

Implementation
Item Objective Method Frequency Approx. cost
responsibility
Air quality To check whether excessive exhaust  Inspection of whether construction vehicles have a Daily Supervising Included in
gases are not emitted from valid Pollution under Control Certificate. consultant supervision base
construction vehicles and machines  Visual inspection of exhaust gases emitted from cost
construction vehicles and machines.
To check whether excessive dust is  Visual inspection of dust emission from yard Daily Supervising Included in
not emitted from the yard construction sites and concrete batching plant. consultant supervision base
construction sites and concrete cost
batching plant
Water To check whether the water pollution  Visual inspection of concrete washwater treatment 1/month Supervising Included in
quality control measures at concrete batching facility (e.g. settling pond). consultant supervision base
plant are appropriately implemented cost
To check the water quality of treated  Parameter: pH Prior to Construction pH meter: US$ 600
concrete washwater (in case of  Assessment criteria: 6.0-9.0 (Effluent quality discharge contractor
discharge outside of the premises) standards for common effluent treatment plant set
under Environment (Protection) Amendment Rules
2015)
Soil quality To check oil leaks from construction  Visual inspection of oil leaks from construction Daily Supervising Included in
vehicles and machines vehicles and machines consultant supervision base
cost
Noise To check noise impacts of  Parameter: LAeq 1/month Construction Noise meter:
construction vehicles  Location: Residential area adjacent to construction contractor US$ 1,600
access road (5 sites)
 Assessment criteria: Noise Pollution (Regulation and
Control) Rules 2000
Waste To check whether wastes are stored  Visual inspection of waste storage areas. Daily Supervising Included in
and handled in accordance to the  Checking of waste disposal records. consultant supervision base
contractor’s Waste Management Plan cost
Infectious To check implementation status of  Confirmation of implementation date of health checks 2/year Supervising Included in
diseases HIV/AIDS prevention plan and awareness programs including number of consultant supervision base
participants. cost
Occupational To check whether safety measures are  Visual inspection of compliance to labor safety Daily Supervising Included in
safety implemented in accordance to the measures consultant supervision base
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Implementation
Item Objective Method Frequency Approx. cost
responsibility
contractor’s OHS plan  Confirmation of accident records cost
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Table 11-52 Environmental Monitoring Plan (Operation stage)
Implementation
Item Objective Method Approx. cost Justification
responsibility
Air quality Confirmation of stack Method: Sampling and analysis of stack emission gas TSDF operator Analysis cost: All parameters except PCBs are
emission gas Parameter: PM, HCL, SO2, CO, TOC, HF, NOx, US$8,500/year required under Indian regulation.
concentration from Dioxins/furans, Cd+Td, Hg,
TSDF incinerators Sb+As+Pb+Co+Cr+Cu+Mn+Ni+V, PCBs (PCBs for Frequency is based on CPCB
new incinerator only) guideline*
Frequency: 4/year
Assessment criteria: Emission standards for common PCBs proposed by JICA Study
hazardous waste incinerator set under Environmental Team as the new incinerator will
Protection (Fifth Amendment Rules) 2008. treat PCB containing waste.
PCBs: Interim emission standard for PCBs incineration Technical capacity of PCB
set by Ministry of Environment Japan. analysis may be an issue.
Method: Continuous monitoring of stack emission gas TSDF operator Included in Continuous monitoring
Parameter: PM10, NOx, SO2, CO, HCL operation base cost requirement under EC of EIA.
Frequency: Continuously during incineration
Assessment criteria: Emission standards for common Parameters based on CPCB
hazardous waste incinerator set under Environmental guideline* and EC of EIA.
Protection (Fifth Amendment Rules) 2008.
Confirmation of ambient Parameter: TSDF operator Analysis cost: Monitoring of NAAQS
air quality around TSDF  NAAQS parameters: PM10, PM2.5, SO2, NO2, O3, US$40,000/year parameters, VOCs and PAHs
CO, Pb, As, Ni, Benzene, Benzo(a)Pyrene (including location and
 Others: Asbestos, VOCs and PAHs frequency) based on CPCB
Location: guideline*.
 NAAQS parameters, VOC and PAHs: 3 sites around
TSDF Asbestos proposed by JICA
 Asbestos: 3 sites at boundary of TSDF Study Team as it was detected
Frequency: during supplementary survey.
 PM10, PM2.5, SO2, NO2: 104/year
 Other parameters: 2/year Technical capacity of PAHs and
Assessment criteria: asbestos analysis may be an
 National Ambient Air Quality Standards 2009 issue.
 VOC: Baseline data that will be acquired prior to
operation.
285
Implementation
responsibility
 Asbestos: 0.01 f/cc (Japanese standard set under Air
Pollution Control Act: applied to boundary of
asbestos handling factories)
Confirmation of ambient Parameter: GMB Analysis cost: Monitoring proposed in EIA.
air quality around ship  NAAQS parameters: PM10, PM2.5, SO2, NO2, O3, US$12,000/year
breaking yards and CO, Pb, As, Ni, Benzene, Benzo(a)Pyrene Parameters, location and
access road  Others: Asbestos frequency based on GMB
Location: 6 sites monitoring plan.
Frequency: 4/year
Assessment criteria: Technical capacity of asbestos
 National Ambient Air Quality Standards 2009 analysis may be an issue.
Asbestos: Baseline data that will be acquired prior to
operation.
Confirmation of air Parameter: PM10, PM2.5, SO2, NO2, Pb GMB Analysis cost: Monitoring proposed in EIA.
quality inside ship Location: 1 site per yard US$2,000/year/yard Frequency based on EIA.
breaking yards Frequency: 1/month
Assessment criteria: National Ambient Air Quality Parameters except lead based on
Standards 2009 (Industrial) Consent to Operate of existing
yard.
Lead proposed by JICA Study

Team as gas fumes may contain
lead.
Confirmation of asbestos Parameter: Asbestos GMB Analysis cost: Based on requirement of EC of
concentration inside ship Location: Adjacent to asbestos handling facility and US$30/measurement EIA.
breaking yards yard boundary
Frequency: During asbestos handling Technical capacity of asbestos
Assessment criteria: analysis may be an issue.
 Work zone: 0.1 f/cc (OSHA standard: 1915.100)
 Yard boundary: 0.01 f/cc (Japanese standard set
under Air Pollution Control Act)
Noise Confirmation of noise Parameter: Equivalent sound level (LAeq) GMB Cost of noise meter: Monitoring proposed in EIA.
around ship breaking Location: 6 sites around ship breaking yards and US$1,600 Frequency based on EIA.
286
Implementation
responsibility
yards and access road access road
Frequency: 4/year
Assessment criteria: Noise Pollution (Regulation and
Control) Rules, 2000
Water Confirmation of seawater Parameter: GMB Analysis cost: Based on requirement of EC of
quality quality around the ship  pH, DO, color/odor, oil, Fecal Coliform, BOD US$58,000/year EIA.
breaking yards  Others: Temperature, turbidity, SS, salinity, T-N, T-
P, Chlorophyll-a, heavy metals (Al, As, Cd, Co, Cr, Parameters, location and
Cu, Hg, Mn, Ni, Pb, Zn) frequency based on EC and
Location: 6 sites (ship breaking yard) + 2 sites GMB monitoring plan.
(Background), Surface and bottom layers
Frequency: 4/year
Assessment criteria:
 Environment (Protection) Rules 1986: Primary Water
Quality Criteria (Harbour waters)
 Others: Baseline data that will be acquired prior to
operation.
Confirmation of Parameter: TSDF operator Analysis cost: Parameters and frequency based
groundwater quality  CPCB guideline: pH, colour, EC, Turbidity, SS, US$24,000/year on CPCB guideline* except
around TSDF TDS, TOC, COD, heavy metals (Pb, Cd, Cu, Zn, Cr, PCBs, PBBs, PAHs and, TBT.
Hg, Ni, Fe, Cn, F, As, Mn), Cl, NO3, SO4, T-N, Total PCBs, PBBs, PAHs and, TBT
Alkalinity, Total hardness, Total pesticides proposed by JICA Study Team.
 Others: PCBs, PBBs, PAHs, TBT
Location: 4 sites Technical capacity of PCBs,
Frequency: 4/year PBBs, PAHs and, TBT analysis
Assessment criteria: IS:10500 (2012) and baseline may be an issue.
data
 IS:10500 (2012)
 Parameters not listed in IS:10500 (2012): Baseline
data that will be acquired prior to operation.
Confirmation of Parameter: GMB Analysis cost: Monitoring proposed by JICA
groundwater quality  CPCB guideline: pH, colour, EC, Turbidity, SS, US$12,000/year Study Team as groundwater is
around ship breaking TDS, TOC, COD, Pb, Cd, Cu, Zn, Cr, Hg, Ni, Fe, used by locals.
yards CN, F, As, Mn, Cl, NO3, SO4, TKN, Total
287
Implementation
responsibility
Alkalinity, Total hardness, Total pesticides Parameters based on CPCB
 Others: PCBs, PBBs, PAHs, TBT guideline*. PCBs, PBBs, PAHs,
Location: 4 sites TBT proposed by JICA Study
Frequency: 2/year Team.
Assessment criteria:
 IS:10500 (2012) Technical capacity of PCBs,
 Parameters not listed in IS:10500 (2012): Baseline PBBs, PAHs and, TBT analysis
data that will be acquired prior to operation. may be an issue.
Confirmation of effluent Method: Sampling and analysis of effluent TSDF operator Analysis cost: Parameters based on Consent to
concentration from ETPs Parameter: US$10,000/year Establish of existing TSDF
of TSDF  pH, temp., colour, SS, Oil and grease, NH3-N, BOD,
COD, Cl, SO42-, TDS, Phenolic compound, CN, F, PCBs proposed by JICA Study
As, Cr, Cr+6, Cu, Pb, Hg, Ni, Zn, Team as high levels were
Insecticide/pesticides recorded in leachate in
 PCBs supplementary survey.
Frequency: 4/year
Assessment criteria: Technical capacity of PCBs,
 Effluent quality standards for common effluent analysis may be an issue.
treatment plant set under Environment (Protection)
Amendment Rules 2015 (into inland surface water)
 PCBs: Uniform National Effluent Standards of Japan
Method: Continuous monitoring of effluent TSDF operator Included in Continuous monitoring
Parameter: Temp., pH, oil, SS operation base cost requirement of EC of EIA.
Frequency: Continuously during ETP operation
Assessment criteria: Effluent quality standards for Parameters proposed by JICA
common effluent treatment plant set under Study Team.
Environment (Protection) Amendment Rules 2015
(into inland surface water)
Confirmation of effluent Method: Continuous monitoring of effluent Operator of Included in Proposed by JICA Study Team
concentration from ETP Parameter: Temp, pH, oil, SS offshore tank operation base cost
of offshore tank cleaning Frequency: Continuously during ETP operation cleaning barge
barge Assessment criteria: Environment (Protection)
Amendment Rules 2015: Effluent standards for
common effluent treatment plants (into sea)
288
Implementation
responsibility
Confirmation of water Method: Visual observation, in situ measurement, lab GMB Analysis cost: Proposed by JICA Study Team
quality around offshore analysis US$690/operation
tank cleaning barge Parameter:
operation area Visual observation: Oil slick, color/odor, floating
matter
in situ measurement: Temp. pH, DO, turbidity
Lab analysis: SS, oil, heavy metals (Hg, Pb, Cd)
Frequency:
Visual observation and in situ measurement: Daily
during operation
Lab analysis: 3 times (pre-, mid-, post-operation)
Assessment criteria: Primary Water Quality Criteria
for Class SW-I and II Waters
Sediment Confirmation of Parameter: Particle size, TOC, heavy metals (Al, As, GMB Analysis cost: Monitoring proposed in EIA.
quality sediment quality around Cd, Co, Cr, Cu, Hg, Mn, Ni, Pb, Zn), PAHs, PCBs, US$36,000/year Frequency proposed in EIA.
the ship breaking yards TBT
Location: 8 sites (ship breaking yard) + 2 sites Parameters based on GMB
(background) monitoring plan.
Frequency: 4/year
Assessment criteria: Baseline data that will be Technical capacity of PAHs,
acquired prior to operation. PCBs and TBT analysis may be
an issue.
Soil quality Confirmation of soil Parameter: Particle size, TOC, heavy metals (Cd, GMB Analysis cost: Based on GMB monitoring plan
quality inside the ship Cr+6, Hg, Pb), PAHs, PCBs, TBT US$580/year/yard
breaking yards Location: 1 site per yard (composite sample of surface Parameters proposed by JICA
layer) Study Team.
Frequency: 1/year
Assessment criteria: Baseline data that will be Technical capacity of PAHs,
acquired prior to operation. PCBs and TBT analysis may be
an issue.
Confirmation of soil Parameter: Particle size, TOC, heavy metals (Al, As, TSDF operator Analysis cost: Based on CPCB guideline*
quality around TSDF Cd, Co, Cr, Cu, Hg, Mn, Ni, Pb, Zn), Dioxins/furans, US$3,600/year
PCBs Parameters proposed by JICA
Location: 4 sites (surface layer) Study Team.
289
Implementation
responsibility
Frequency: 1/year
Assessment criteria: Baseline data that will be Technical capacity of PCBs and
acquired prior to operation. dioxins/furans analysis may be
an issue.
Ecosystem Confirmation of TBT Parameter: TBT GMB Analysis cost: Proposed by JICA Study Team
concentration in benthos Location: 5 samples from intertidal area US$500/year
Frequency: 1/year Finding appropriate samples may
Assessment criteria: Baseline data be an issue.
Technical capacity of TBT

analysis may be an issue.
Confirmation of status of Parameter: Abundance and diversity of phytoplankton GMB Analysis cost: Based on GMB monitoring plan
planktons and zooplankton US$4,000/year
Location: 6 sites (ship breaking yard) + 2 sites
(Background)
Frequency: 1/year
Assessment criteria: Baseline data
Confirmation of status of Parameter: Abundance and diversity of benthos GMB Analysis cost: Based on GMB monitoring plan
benthos Location: 6 sites (ship breaking yard) + 2 sites US$4,000/year
(Background)
Frequency: 1/year
Assessment criteria: Baseline data
Occupational Confirmation of health Parameter: Pulmonary function test, sputum test, SRIA Test cost: Based on requirement of EC of
safety status of yard workers chest X-ray, chest HRCT test (if necessary) US$6/worker EIA.
handling asbestos Target: Workers handling asbestos more than 30
days/year
Frequency: 1/year
Confirmation of health Parameter: Pulmonary function test, lead blood SRIA Test cost: Proposed by JICA Study Team
status of gas cutters concentration US$10/worker
Frequency: 1/year
Assessment criteria: Lead blood concentration of 50
µg/dL (OSHA standard: 1910.1025)
Confirmation of Method: GMB Included in Responsibility of GMB
290
Implementation
responsibility
occupational safety and  Inspection of occupational safety measures operation base cost
accidents implemented at yards and TSDF.
 Record keeping of occupational accidents and cause
investigation.
Frequency: Daily
291
11.9. IMPLEMENTATION STRUCTURE

Various organizations will be responsible for implementation and supervision of the EMP/EMoP. The
GMB’s Environmental Cell will be responsible for the overall management and supervision of the
recycling yards and TSDF and implementation of ambient environmental monitoring. Environmental
monitoring and lab analysis are planned to be assigned to a research institution. The GMB Alang office
will be responsible for inspection of recycling yards and implementation of GMB’s training programs
for the yard workers.
Yard operators will be responsible for implementing HSE measures and environmental monitoring
inside the yard area. SRIA will implement regular health checks under the supervision of DISH. GPCB
will also conduct regular inspection at each yard.
TSDF operator will be responsible for implementing HSE measures and monitoring of TSDF facilities
(e.g. effluent from ETP and emission from incinerator) and surrounding environment. GPCB will also
conduct regular inspection at TSDF. Table 11-53 shows the main responsibilities of each organizations
that will be involved in the implementation of EMP/EMoP. Figures 11-31 and 11-32 show the
implementation and reporting/feedback structure of EMoP for the construction and operation stages
respectively.
Table 11-53 Main organizational responsibilities for implementation of EMP/EMoP
Organization Main responsibilities

GMB  Supervision and inspection of recycling yards and TSDF
 Implementation of ambient environmental monitoring
 Review of monitoring results and feedback
 Implementation of EHS training programs
 Reporting of monitoring results to MoEFCC and JICA
GPCB  Inspection of facilities that require consent from GPCB
TSDF operator  Implementation of environmental management and safety measurers
 Monitoring of facility performances and surrounding environment
 Reporting of monitoring results to GMB/GPCB
Yard operator  Implementation of environmental management and safety measurers
 Monitoring of work environment
 Reporting of monitoring results to GPCB/GMB
SRIA  Monitoring of worker’s health
DISH  Supervision of labour safety and health
292
JICA MoEFCC
 Review/feedback of monitoring  Review/feedback of monitoring
results from GMB results from GMB
GMB
 Review/feedback of monitoring results
from Supervision consultant
Supervision consultant
 Inspection/monitoring of construction
sites and works
 Review/feedback of monitoring results
from Construction Contractor
 Assist GMB for review/reporting works
GPCB
 Review/feedback of
monitoring results from
Construction Construction contractor
Contractor (applicable  Monitoring of construction sites and
to concrete batching works
plant)
Feedback Reporting
Figure 11-30 Implementation and reporting/feedback structure of EMoP (construction stage)

293
JICA MoEFCC
 Review/feedback of monitoring  Review/feedback of monitoring
results from GMB results from GMB
GMB
Supervision consultant  Monitoring of ambient environment
 Assist GMB for monitoring  Review/feedback of monitoring results
review and reporting works from yard/TSDF operators and SRIA
Yard operator
GPCB  Monitoring of work
 Review/feedback of environment
monitoring results
from yard/TSDF TSDF operator
operators  Monitoring of facility
performances and surrounding
environment
DISH
 Review/feedback of SRIA
monitoring results  Monitoring of worker’s health
from SRIA
Feedback Reporting
Figure 11-31 Implementation and reporting/feedback structure of EMoP (operation stage)

11.10. STAKEHOLDER MEETING

Two stakeholder meetings were held during the course of the study. The first meeting was held on
July 2016 to introduce the Project and for scoping purposes. The second meeting was held on November
2016 to explain about the study results. Both meetings were held at the GMB meeting hall in Alang. The
meetings were attended by representatives from SRIA, GPCB, ship recyclers, ASSRGWA, cash buyers
and so on. Tables 11-54 and 11-55 show the main questions and opinions raised by the participants and
responses from GMB/JICA Study Team during the 1st and 2nd meetings respectively. Minutes of both
meetings are attached as Appendix 3.
Table 11-54 Main questions and opinions raised during the 1st meeting and responses from GMB/JICA
Study Team
Organization Comments/questions Responses from GMB/JICA Study Team

SRIA SRIA: The JICA Study Team should provide The JICA Study Team will provide technical
technical criteria for yard improvement as criteria at the DFR stage.
294
some recyclers are planning to improve their

yards in advance by themselves.
Cash buyer Cash buyer: Request the JICA Study Team The JICA Study Team will consider
to consider methods for collecting ship waste methods to collect waste oil offshore.
oil offshore, since construction of drydock is
not in the plan.
ASSRGWA ASSRGWA: The new labor colony with The JICA Study Team will consider
dormitory rooms are not appropriate for the appropriate design for the labor colony.
labors, as they come from different regions
and social background and may become a
source of conflict.
Table 11-55 Main questions and opinions raised during the 2nd meeting and responses from GMB/JICA
Study Team
Organization Comments/questions Responses from GMB/JICA Study Team

GPCB Customs may no longer collect Ozone TSDF will not be able to treat ODS. It is the
Depleting Substances (ODS) from ships. Can first time we heard such news. If it becomes
the improved TSDF treat ODS? official, we will need to find another way to
treat/dispose ODS.
The new oil sludge treatment plant is a good Noted.
plan. Hopefully, this will help to reduce illegal
disposal of oily sludge.
Concrete batching plant will require Consent Noted.
to Establish and Operate from GPCB.
Will new plant treat electric cable contained TSDF will not treat insulation of the electric
PCB? cable but as PCB contained, it can be
incinerated.
Is the plan for the labor colony included in the The plan is within the scope of EIA.
EIA?
Result of the sediment investigation need to Noted.
be justified with other data.
There are no Indian standard for discharging We are planning to apply MARPOL standard
oily water in offshore waters as planned with but will consider further what is most
the offshore tank cleaning barge. This may be appropriate.
an issue if discharge is undertaken within
territorial water (i.e. 12 nm).
SRIA Will recyclers need to take all waste oil to No. Sellable waste oil can be sold to other
TSDF? authorized facilities as practiced now.
If health check for asbestos workers and gas This issue must be discussed among all
cutters becomes compulsory it should be the stakeholders and find the appropriate way
responsibility of the government to implement forward.
and not recyclers.
How will recyclers be charged after It will be based on use and pay system.
introduction of the new facilities?
Are 5 large mobile cranes sufficient for Since using the large mobile crane is a new
handling all the ships? approach to ship breaking, we think it is better
to limit are purchase to 5 units. And if proved
successful we can purchase more later.
Considering the recent accident in Pakistan, Noted and we expect that this will contribute in
we now fully support the introduction of attracting oil tankers to Alang.
offshore tank cleaning which will contribute
in safer dismantling of oil tankers.
Will there be any additional financial burden There shall not be any additional burden on the
295
on the Ship Recyclers on their current tariff current Ship Recyclers tariff. However, the
(to be paid to GMB) once the JICA loan is financial mechanism is still being finalized and
sanctioned and the Project commences? will require further discussion with GMB,
SRIA and other stakeholders.
11.11. Conclusion and recommendations
 One of the critical aspect for a successful environmental monitoring program is to have the
capacity to produce accurate and reliable results. This is of particular importance to this Project
as the EMoP covers a wide range of monitoring parameters in various fields which some may not
have not been commonly monitored and analyzed locally in the past. Furthermore, some target
parameters such as TBT are not included in any of the India’s environmental standards and hence
there are no nationally approved analysis methodology. In this respect, the JICA Study Team
strongly recommends GMB to establish a standard sampling and analysis protocol for the EMoP
and at the same time strengthen the capacity of the organizations/personal that will be involved
in the monitoring activities. A baseline survey should also be implemented prior to operation in
accordance to the established standard sampling and analysis protocol, especially for monitoring
parameters that will be compared with baseline data for the assessment. Table 11-56 shows the
proposed specification of the baseline survey.
Table 11-56 Proposed specification of the baseline survey
Item Parameter Frequency

Ambient air quality (TSDF) VOC, PAHs 2/year
Ambient air quality (yard) Asbestos 2/year
Seawater quality Temperature, turbidity, SS, salinity, T-N, T-P, 2/year
Chlorophyll-a, heavy metals (Al, As, Cd, Co, Cr, Cu, Hg,
Mn, Ni, Pb, Zn)
Groundwater quality (TSDF EC, SS, TOC, COD, T-N, Total pesticides, PBBs, TBT 2/year
and yard)
Sediment quality Particle size, TOC, heavy metals (Al, As, Cd, Co, Cr, Cu, 2/year
Hg, Mn, Ni, Pb, Zn), PAHs, PCBs, TBT
Soil quality (yard) Particle size, TOC, heavy metals (Cd, Cr+6, Hg, Pb), 1/year
PAHs, PCBs, TBT
Soil quality (TSDF) Particle size, TOC, heavy metals (Al, As, Cd, Co, Cr, Cu, 1/year
Hg, Mn, Ni, Pb, Zn), Dioxins/furans, PCBs
TBT benthos TBT 1/year
Plankton Abundance and diversity 2/year
Benthos Abundance and diversity 2/year
 Currently to avoid groundwater contamination, non-reusable effluent from the TSDF ETP is
planned to be discharged into the rainwater drainage outside TSDF. However, the
appropriateness of such discharge route should be studied in the D/D stage together with an
impact assessment on downstream water use.
 Low-oil content effluent from the offshore tank cleaning barge is planned to be discharged into
sea area after onboard treatment . Effluent standards of Environment (Protection) Amendment
Rules 2015 are planned to be applied as there are no other applicable national or international
standards. A detailed impact assessment should be undertaken in the D/D stage taking into
account for example the locations of sensitive ecosystem and fishing grounds, and the EMP and
EMoP should be updated accordingly. The applicability of Environment (Protection)
Amendment Rules 2015: Effluent standards for common effluent treatment plants (into sea)
296
should also be considered. Stakeholders should also be consulted through the process especially
GPCB in case the operation area lies inside territorial water which is under their jurisdiction.
 Regular health checks will be implemented for asbestos workers. However, considering the long
latency period of asbestos symptoms, retired workers should also be eligible for regular free
health checks. Since there is no such scheme now, GMB should initiate to establish such scheme.
 Due to certain changes in the Project plan and design, new potential impacts are generated which
are not assessed in the approved EIA. Table 11-57 shows the new potential impacts. GMB
should therefore submit to MoEFCC an amended EIA with an impact assessment and obtain
approval together with CRZ clearance.
Table 11-57 Main changes of the Project from the approved EIA and additional potential impacts
Item Approved EIA Changes and additional potential impacts

New ETP of TSDF Treatment capacity is 30t/day [Changes]
and treated effluent planned to Treatment capacity increased to 120t/day
be reused inside TSDF. and non-reusable treated effluent planned to
be discharged outside TSDF.
[Additional potential impacts]
Discharged effluent may affect downstream
environment.
New incinerator of TSDF Treatment capacity is 25t/day [Changes]
with similar design as existing Although treatment capacity is reduced to
incinerator 5t/day, the new incinerator is planned to
treat PCB containing material and the
design has changed accordingly.
GMB consider seeking opportunity to
incinerate Ozone Depleting Substances
(ODS) in the new incinerator during the
detailed design stage. This option may be
included the specification of new
incinerator.
[Additional potential impacts]
New impacts may arise through handling
PCB.
Offshore Tank cleaning Not mentioned [Additional potential impacts]
barge and associated Low-oil content effluent from the offshore
jetty/access road tank cleaning barge is planned to be
discharged after onboard treatment into
offshore sea area, which may have impacts
on surrounding environment.
297

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Gujarat Maritime Board

JAPAN INTERNATIONAL COOPERATION AGENCY

JAPAN MARINE SCIENCE INC.

1. BACKGROUND AND HISTORY OF THE PROJECT .......................................... 2

2. PRESENT CONDITION AND ISSUES OF THE INDUSTRY............................... 9

3. PRELIMINARY DESIGN OF THE PROJECT ..................................................... 42

4. PROCUREMENT METHOD ............................................................................... 117

4.2.2. CONSIDERATION ON PROCUREMENT ........................................................................... 121

5. CONSULTING SERVICES.................................................................................. 126

6. PROJECT COSTS AND FINANCIAL PLAN ..................................................... 133

7. FINANCIAL AND ECONOMIC ANALYSIS ..................................................... 145

8. PROJECT IMPLEMENTATION SCHEDULE.................................................... 159

9. PROJECT IMPLEMENTING ORGANIZATION AND MAINTENANCE

9.1.2. EVALUATION OF FINANCIAL CAPABILITY OF IMPLEMENTING AGENCY AND

10. CAPACITY DEVELOPMENT PLAN ................................................................. 176

11. ENVIRONMENT AND SOCIAL CONSIDERATION ....................................... 188

11.11. Conclusion and recommendations ...................................................................................... 296

Table 7-2 Annual O&M Costs ................................................................................................................ 146

Figure 1-1 .................................................................................................................................................... 4

Abbreviations and Acronyms

GMS Global Marketing System

NOx Nitrogen Oxide

1. BACKGROUND AND HISTORY OF THE PROJECT

1.1.2. SHIP RECYCLING CONVENTION

Applied to ：Ships (commercial ship more than 500GT)

：Ship Recycling facilities (place of ships to be recycled)

(1) Requirements to Ships

・ Restrict to use Asbestos, Polychlorinated Biphenyl: (PCBs ） , Ozone Depleting

(2) Requirements to Ship Recycling Facilities

・ Sound operation and management to mitigate environmental pollution and industrial

(3) Requirements to Ship Recycling Process

Figure 1-1Ship Recycling Process in accordance with the Convention

(4) Entry into force the Convention

1.1.3. INTERNATIONAL SHIP RECYCLING SITUATION AND ITS ISSUES

entry into conditions within a few years from now..

1.2. SHIP RECYCLING INDUSTRY IN INDIA

Ship Recycling Volume (Uniti: 10,000 GT)

Average share by country 2006-2015

1.3. NATIONAL DEVELOPMENT PLAN RELATED TO THE PROJECT

1.4. BACKGROUND AND HISTORY OF THE RQUEST OF THE PROJECT

1.5. COOPERATION BY OTHER DONERS AND/OR INTERNATIONAL

(1) Contents of the Cooperation

Duration : 3 years , Total cost 5 Million Japanese Yen

(2) Target of Training and its Implementation

2. PRESENT CONDITION AND ISSUES OF THE INDUSTRY

2.1.1. PRESENT CONDITIONS OF THE SHIP-RECYCLING PROCESS IN ALANG

(1) Current Ship Recycling Process

2 Beaching 1)Procedure to obtain beaching permit

4 Recovery of un-used materials or 1) Marking on the cylinder by the Safety officer.

5 Collection of bilge water and other 1) Inspection of the bilge tanks.

(2) Fundamental Requirements of the Ship Recycling Convention

Table 2-2 Main Requirements of the Ship Recycling Convention

(3) Evaluation and tasks for requirements of Ship Recycling Convention

1) Issues of the recycling process

Ship Recycle Convention Status of India Conformity

2.1.2. CURRENT STATUS AND ISSUES OF SHIP RECYCLING FACILITIES IN ALANG /

(1) Condition of Improvement of Ship Recycling Yards

Table 2-4 Result of the 36 Yards

HKC Compliant Yards information Total Plot 131