The sponsor has developed a Health, Safety and Environmental (HSE) Action Plan to address the issues raised by the audit and to ensure that the proposed project will, upon implementation of the specific measures identified, comply with applicable Brazilian laws and regulations, the terms of the concession contract, and World Bank/IFC requirements. The information about how these potential impacts will be addressed by the sponsor/project is summarized in the paragraphs that follow.
Contamination from past uses. Tecon Salvador was built at the end of the 1960’s, on a site previously used as a dock for small vessels unloading goods from nearby islands and other parts of the coastal region of Bahia State. The construction technique adopted at the time was that of a gravity wall made of concrete (reinforced concrete pontoon) filled with locally derived dredged material. There is no evidence of any pre-exisiting environmental contamination on the site.
Dredging. The port area of Salvador is a natural port with an average depth of 10 meters in the docking area. Maintenance dredging is sparse, and was last performed during the 1970''s. CODEBA dredged the immediate Tecon pier area in 1999 (approximately 130,000 cu. m.), in order to deepen the channel to 12 meters. The material was disposed in an authorized area (approved by the Navy) near the entrance to Todos os Santos Bay at a depth of 50 meters. Although this work was undertaken without complying with all of the the necessary environmental licensing procedures, the environmental effects of the dredging and related disposal activity are believed to be neglible and reversible and without environmental consequence. CODEBA was fined by IBAMA (the Federal Environmental Agency) for not complying with the licensing requirements.
Sewage and stormwater management. Sanitary wastewaters generated at the Terminal are collected and treated in a system that operates in compliance with applicable discharge requirements. Non-contaminated stormwaters are collected in a drainage network and discharged directly to the Bay. Tecon Salvador will appropriately expand and modify these systems as the Terminal improvements are implemented.
Oil/hazardous materials storage and handling. Diesel oil is stored onsite in an above ground tank not currently provided with adequate secondary containment. Tecon Salvador will implement the necessary containment and spill control features for this activity so as to prevent any leaks and spills from contaminating soil and waters. Incidental small amounts of paints, solvents, and petroleum lubricants used for maintenance and repair are adequately stored inside Terminal buildings.
Handling and storage of dangerous cargoes. A small amount of the containerized cargo handled at the Terminal may be considered to be hazardous under the International Maritime Code (IMC). This material includes flammable gases, poisons, flammable liquids, corrosives, reactive and spontaneously combustible substances, oxidizing substances, etc. Containerized hazardous cargo will be stored by material class in segregated areas within the container storage yard, and Tecon Salvador will ensure good access to containment resources and emergency response equipment. The majority of containers with dangerous cargoes will be handled as full containers, and the inventory will be monitored continuously.
Ship support operations. Tecon Salvador will not manage any ship generated wastes (sewage, bilge waste, used oil, etc.), nor will ships serviced by the Terminal be allowed to discharge their wastes while berthed. These wastes are to be handled by CODEBA, and are not the responsibility of Tecon Salvador. Going forward, Tecon Salvador will notify its shipping customers of this arrangement, as well as coordinate with CODEBA to ensure that the Port Authority provides these services, either directly or by a separate concession contract. In addition, CODEBA will also be encouraged to provide adequate emergency spill response equipment for shipboard activities.
Solid and hazardous waste management. Wastes managed at the Terminal consist primarily of equipment washwaters, waste oils, and domestic solid waste. The existing equipment washwater oil separator serving the temporary maintenance shop is currently inoperative. As part of Tecon Salvador''s Terminal improvement program, a new maintenance shop will be built, which will include a properly operating and functioning oil/water separation system for equipment washwaters. The Terminal currently collects all other liquid (i.e., waste oils) and solid wastes (i.e., garbage) generated during operations and ensures that they are disposed, without segregation, at the local municipal landfill. Tecon Salvador will develop and implement a waste management plan, which will address ways to better segregate, minimize, and/or recycle its wastes.
Emergency response planning and preparedness. Tecon Salvador will develop procedures, train personnel, and provide equipment for responding to emergencies, including fire, chemical spills and mishaps, accidental release of petroleum products, and medical emergencies. Activities will need to be coordinated with the local Fire Department, CODEBA and other appropriate agencies and authorities. As a first step, a Terminal Emergency Action Plan will be developed which provides:
· Procedures for plan review and periodic training of employees and schedules for drills;
· Spill recordkeeping requirements;
· Description of the emergency response organization;
· Description of hazardous material cargo segregation program;
· Documentation and reporting requirements (including notification requirements and contacts, incident reports and post incident reviews);
· Emergency equipment inventory;
· Resource and agency directory ; and
· Internal and external communications plan.
Employee health and safety. Most of the employee health and safety activities are currently managed by OGMOSA under an agreement with Tecon Salvador and CODEBA. In light of OGMOSA''s limited resources and capabilities, Tecon Salvador will reassess the Terminal''s occupational health and safety needs, and develop their own program to ensure the health and safety of all Terminal employees going forward. An individual will be assigned responsibility for these matters, and procedures will be developed and regularly communicated to employees through training programs. Training will include basic equipment safety and security, first aid and CPR, fire fighting, and emergency response.
EHS organization and management. The Terminal''s current problems in complying with Brazilian environmental licensing and permitting process requirements points to a need to improve its organization, structure and overall EHS management systems. Moreover, since the concession was awarded, there has been some confusion among CODEBA, OGMOSA and the Bahia state regulatory agency (CRA) as to responsibilities for various EHS actions at the Terminal. As a result, Tecon Salvador will identify an individual with overall responsibility for Terminal EHS performance. This individual, in turn, will oversee the development of necessary policies and procedures to ensure operations comply with all applicable Brazilian requirements and World Bank policies and guidelines while ensuring coordination with all appropriate stakeholders.
