TTS has presented plans to address these impacts to ensure that the proposed project will comply with applicable environmental, health and safety (EHS) requirements, including: international navigation standards under the International Safety Management (ISM) Code of the IMO, the Danube Commission recommendations, Romanian shipping-related rules and EHS laws, and World Bank Group environmental and social policies and guidelines. The information about how these potential impacts are being addressed by TTS is summarized below.
- Environmental, Health and Safety Management Systems.
TTS has a written corporate policy indicating management’s commitment to navigation safety and the protection of the environment in the conduct of their shipping activities. Objectives include compliance with relevant safety and environmental protection rules governing river transport and related activities in Romania and on the Danube River. The Group has defined and established an organizational structure with the appropriate responsibility and authority to manage EHS matters. Employees are trained at several levels to ensure they have the knowledge and skills to perform their work consistent with TTS safety and environmental policy and objectives. There are written operating procedures covering navigation safety, environmental protection and employee health and safety, and performance is monitored through a system of periodic inspections and internal audits. Non-conformities and accidents are investigated and corrected, as necessary. Senior management reviews performance results annually and ensures that appropriate adjustments to procedures are made.
- Vessel Safety and Pollution Control.
TTS ships are designed and operated to meet Romanian safety and pollution control requirements, as well as the international marine safety standards of the IMO. Vessels are all equipped with tanks and containers for storing ship-generated wastes and effluents – domestic wastes, maintenance waste and oils, bilge waters, sanitary wastewaters, recyclable plastics, metals and glass. When accumulated, segregated wastes are separately delivered to authorized port collection centers or specialized ships for treatment and disposal. In between carrying certain cargoes, barges are cleaned by licensed contractors, and the wastes generated during cleaning are properly disposed by these parties.
TTS has all necessary certificates to permit operation of its ships and barges with regard to safety and environmental protection. The ships are periodically inspected by Romanian government authorities for compliance with safety and environmental requirements in accordance with approved schedules.
- Oil/Hazardous Cargo Spill Prevention and Control.
All TTS ships requiring fuel are equipped with secondary containment around the fueling connection area, and associated spill collection tanks. In addition, all vessels have the requisite oil spill clean-up equipment and absorbent material on board to contain spills.
With the exception of oil and diesel fuel, the principal cargoes TTS transports are not considered hazardous or dangerous. In accordance with IMO, the Danube Commission recommendations, and Romanian requirements, vessels engaged in the transport of oil have plans and procedures in place for handling and storage of the material, as well as responding to emergencies, such as collisions, grounding, fire, and spills. In addition, these ships are suitably equipped with fire/spill prevention and emergency response equipment and supplies on board in the event of any accident. Crews are trained in fire fighting and hazardous cargo handling and emergency response, and provided with appropriate personal protective equipment. Training includes both classroom training and emergency drills. As appropriate and depending on the size and location of a spill, TTS coordinates with, and often relies upon, the spill response resources of the ports in which it operates. As required by law, these ports have sufficient oil/chemical emergency response plans, procedures, and equipment. TTS has not experienced any oil spills or emergencies involving hazardous cargoes within the last three years.
- Maintenance/Repair Yard Pollution Control and Hazardous Materials and Waste Management.
TTS operates a ship repair and maintenance yard at the Galati port that services the technical and maintenance needs of their river vessels. Activities include: dry-docking repairs of ship hulls, pipelines and propulsion and steering systems; cleaning (i.e., sandblasting) and painting of hulls and superstructures; and mechanical equipment maintenance (repairs of deck machinery and engine room equipment).
Ship repair necessarily involves the storage and handling of hazardous materials, like paints, solvents, and oils. Repair activities also generate effluents, emissions, and wastes –waste particles from shot blasting, metal scrap, paint wastes, spent solvents, waste oils, discarded containers, other paint contaminated materials, waste scrap, and sludges. Wastes and hazardous materials are managed properly to avoid contaminating the environment and potentially harming the health of workers and local residents. Wastes are collected, temporarily stored, and delivered to specialized, licensed waste management contractors serving the entire port area. There is no evidence that historical operating practices at the repair yard contributed to subsurface contamination of the properties or sediments of the adjacent water bodies.
- Employee Health and Safety.
TTS has an active occupational health and safety program designed to comply with Romanian workplace regulations and ensure the safety of their crews and workers. The program includes a set of specific safety and health procedures for ship and shore-based activities. Workplaces are designed with appropriate health and safety protection equipment and systems in place. Personnel are provided with appropriate personal protective equipment, and participate in extensive health and safety training programs covering fire fighting, hazardous work activities, life saving, and medical first aid. Sailors and shore staff undergo periodic medical examinations. TTS and the Romanian regulatory authorities both conduct regular inspections of the ships and the repair yard to ensure all health and safety requirements and procedures are being properly followed. Job-related accidents and incidents are investigated to prevent reoccurrence.
