The sponsor has presented plans to address these impacts to ensure that the proposed project will, upon implementation of the specific agreed measures, comply with the environmental and social requirements - host country laws and regulations and the World Bank/IFC environment and social policies and environmental, health and safety guidelines. The information about how these potential impacts will be addressed by TRP is summarized in the paragraphs that follow:
>> Health, Safety and Environmental (“HS&E”) organization and management
Consistent with P&O Ports’ corporate HS&E policy, TRP has established a certified environmental management system (“EMS”) under ISO 14001, the international EMS standard. To monitor compliance with P&O Ports’ policies and to ensure they are implemented consistently, TRP’s EMS was independently certified in year 2000 and again in 2003. TRP is also ISO 9001:2000 certified for quality. In 2006, recertification of the management system is planned as well as its migration to Terminal 3, with the goal that during 2007, the entire operation will be fully certified.
Specific environmental issues that have been identified include reduction of the consumption of resources (water, gas, motive power and liquid fuel); decrease in generated waste; and improvements in infrastructure and training, in order to minimize the occurrence of spills and other emergency situations.
IFC will rely upon TRP’s regular internal auditing and annual reporting programs to support compliance with World Bank/IFC requirements.
>> Compliance with the International Ship and Port Safety Code (ISPS)
The International Ship and Port Safety Code (“ISPS Code”), which came into effect on July 1, 2004, is a comprehensive security regime that aims to establish an international framework of co-operation between governments, government agencies and the shipping and port industries in order to detect and take preventive measures against security incidents affecting ships or port facilities used in international trade. Within the port, each terminal operator is obliged to conduct facility security assessments. Security assessments have three essential components. First, they must identify and evaluate important assets and infrastructures that are critical to the port facility as well as those areas or structures that, if damaged, could cause significant loss of life or damage to the port facility's economy or environment. Then, the assessment must identify the actual threats to those critical assets and infrastructure in order to prioritize security measures. Finally, the assessment must address the vulnerability of the port facility by identifying its weaknesses in physical security, structural integrity, protection systems, procedural policies, communications systems, transportation infrastructure, utilities, and other areas within a port facility that may be a likely target. Once this assessment has been completed, the risks can be accurately evaluated by the Port Authority.
TRP is fully compliant with the ISPS Code. Risk evaluations have been completed by the Port Authority with no adverse findings. TRP’s plan of protection of port premises has been submitted and certified by the local Port Security Authority (Prefectura Naval Argentina). This plan complies with protection measures recommended by the ISPS Code. It also includes the operative procedures, such as on-going inspections and corrective measures that are part of the physical protection being implemented by TRP.
>> Liquid effluent and storm water management
Container and equipment wash water and certain other effluents generated at the terminal complex are pre-treated in a dedicated wastewater treatment unit prior to discharge to the local municipal sewerage system. Waste oils and sludges removed from this unit are disposed via licensed contractors. Employee sanitary wastewaters are also discharged directly to the local municipal sewerage system.
Drainage networks throughout the yard areas collect storm water runoff for discharge to the river. At discharge points serving Terminal 1 & 2 areas, control valves prevent release of oils or any hazardous material that might be accidentally spilled in the yard area. In this way, run-off that might become contaminated can be isolated, collected, and removed for appropriate treatment and disposal. Terminal 3 will have a storm water management and contaminated runoff containment system similar to Terminals 1 and 2 once the civil infrastructure work connected with the demolition of the old warehouses and the related paving of the yard is completed.
>> Oil/hazardous materials storage and handling
Hazardous materials are only an incidental part of TRP’s operations. Small amounts of paints, solvents and petroleum lubricants are used for maintenance and repair activities; and lead acid batteries are used in motorized equipment. TRP has established dedicated storage areas within the oil storage and maintenance workshop with containment and spill control features. Use of products that contain polychlorinated biphenyls, asbestos, furans, chlorinated solvents and other potentially hazardous substances which could raise toxicity levels and cause contamination in the sea is prohibited at TRP.
The activities of TRP and its principal contractors are audited on a periodic basis (both internally and by the certifying body) to ensure compliance with Argentine environmental and occupational health regulations.
>> Waste disposal
Wastes managed at TRP consist primarily of general solid waste, waste oils and workshop wastes (such as waste solvents, paints, spill clean-up residues, etc.), container repair wastes and metal scrap, and spent batteries. Each waste type is stored in separately labeled containers (or, in the case of used oil, an underground tank) in designated accumulation areas. Licensed commercial contractors then periodically collect and dispose of these waste materials.
>> Ship support operations
TRP does not manage any ship-generated wastes, such as sanitary sewage, common solid wastes, oily wastes and bilge waters, or chemical wastes and tank washings. These ship-generated wastes are left to the ships to be managed through direct relationships with contractors. Discharging of ballast water to the sea while in the berth and channel areas is prohibited by the port. Bunkering (fueling) of vessels is arranged independently by the shipping agencies, and is carried out in accordance with TRP’s environmental procedures and Argentine regulations.
>> Handling and storage of dangerous cargoes
About 2% to 3% of the containerized cargo to be handled at TRP’s three terminals is considered to be hazardous under the International Maritime Organization (“IMO”) Dangerous Goods Code, and, as such, requires special handling. This material includes flammable gases, poisons, flammable liquids, corrosives, reactive and spontaneously combustible substances, oxidizing substances, etc. Containerized hazardous cargo is continuously controlled and monitored within the container storage yard using segregation software that is designed to evaluate product incompatibilities and so reduce the potential for high risk incidents. TRP has equipment and procedures in place for the containment of hazardous spills that occur within containers.
All containers that contain explosives, chemical, or radioactive material are kept physically separate from other containers, and TRP complies with the necessary distance requirements (depending on the material). Explosives are stored in a separate area and are not kept in the terminal for more than 24 hours. In addition, inventories of dangerous cargo are passed on a weekly basis to the Port Authority and the Argentine Coastguard.
For handling general cargo, TRP has specific segregated restricted access areas, adequately marked, and located away from the container handling area. Specifically trained personnel are exclusively assigned to these areas.
>> Maintenance dredging and dredge spoil disposal
Under the terms of TRP’s concession agreement, responsibility for dredging of the approach channels and the berthing areas rests with the Port Authority (Administración General de Puertos). Dredging operations are coordinated between the dredge master, and TRP’s Engineering and Operations Departments in order to minimize impacts on the facility’s regular operations.
>> Emergency response planning and preparedness
TRP has developed and put in place emergency plans, procedures and equipment for preventing and combating oil and chemical spills, fires, explosions, and major accidents (and related contamination remediation) during operation of all three terminals. This includes appropriate notification of potentially-affected neighbors and coordination with outside emergency response authorities. No significant environmental incidents, or incidents with serious consequences, have been registered in the past three years. Minor spills that have occurred typically relate to hydraulic fluids, oils and/or lubricants for machinery or equipment; in such cases, reporting of incidents is incorporated in the EMS (“Procedure for control of minor spills”).
Any major incident, whether related to persons or affecting the environment, is evaluated and sent to P&O Ports’ risk management team, using a “Critical Incident Report” form (“CIR”), where the events, immediate causes, original causes, organization failures, and corrective measures taken to avoid repetition, are analyzed.
>> Employee health and safety (including training)
TRP has an excellent safety record and is continually seeking to improve procedures and employee training to reduce the number of incidents and accidents. P&O Ports has embarked on a major drive to introduce a zero incident culture at all the terminals it operates, including TRP. Its global target is for zero fatalities and a reduction of 80% in the number of Lost Time Incidents by 2009.
It is doing this by focusing on devoting management time to active participation in safety improvement; eliminating fatalities by managing pedestrians, mobile equipment, load handling, working at heights, and contractors; preventing injuries through safe behavior, and strengthened professional support resources.
Occupational Health at TRP is in charge of a contracted company, and a physician attends from Monday through Friday, and there are registered nursing personnel round the clock every day of the week. The facility has an ambulance station to respond to medical emergencies.