Arkas has presented plans to address these issues and to demonstrate that the proposed project will, upon implementation of the specific measures described below, comply with applicable Turkish laws and regulations, international maritime standards, and World Bank Group safeguard policies. Detail on how these potential issues are addressed by Arkas follows.
- EHS Management Systems
Arkas is developing and implementing a Company-wide EHS Management System (EMS) to ensure its port and shipping businesses are conducted in a manner that protects the environment and the health and safety of its employees. Consisting of seven objectives, Arkas’ EHS policy commits: to compliance with applicable laws and regulations; to take the necessary precautions to protect the environment; and to efficiently use natural resources and energy. Arkas aims to develop and implement its EMS for all of its businesses in accordance with ISO 9001 and 14001 and OHSAS 18001, the international quality, environmental and health and safety management system standards, respectively.
Arkas’ recently established corporate EHS department has overall responsibility for ensuring all operations meet the Company’s EHS policies and objectives. Relying on support from site-based environmental and safety staff, as well as outside experts from universities, the EHS director ensures that the environmental impacts of new business areas are assessed; mitigation measures are identified, implemented, and monitored; and emergency response plans are prepared to minimize damages from accidents. The Company maintains a comprehensive listing of the various legal and other EHS-related requirements that apply to their activities, including Turkish laws and regulations, international maritime standards under SOLAS, MARPOL, the ISM code, and the IMO Dangerous Goods code. Written operational procedures are in place to minimize environmental impacts and provide safe working conditions, and to ensure compliance with these requirements and environmental permits and licenses. To monitor compliance, Arkas’ EMS also includes regular EHS inspection and auditing processes. Where areas of concern or non-compliance are identified as a result of these audits, corrective action plans with specific mitigation and performance improvement measures are developed and implemented.
Arkas will adopt IFC environmental and social safeguard policies as part of the EMS requirements it is implementing for each of its port and shipping operations. In addition, the Company will incorporate formal procedures for environmental and social screening of investment opportunities and new projects into its business strategy, commercial planning, and project bidding processes.
Where Arkas has (or will) develop new port terminals adequate environmental assessment is conducted consistent with Turkish Environmental Impact Assessment requirements. Examples include the Marport container terminal at the Ambarli port and the new Zeyport car terminal where EIA approvals were issued in 1999 and 2004 by the Ministry of Environment. For existing terminals for which Arkas assumes operational control under agreements with the government, such as the prospective container terminal at Iskenderun, the Company will conduct an environmental audit of the facilities in order to identify mitigation measures and programs to bring them into compliance with their corporate environmental policy and objectives.
- Port and Terminal Pollution Prevention and Abatement
At terminals Arkas develops and operates, the Company implements a range of measures identified during environmental assessment and in relevant licenses to protect the environment during both construction and operation. To date, Arkas has not had to dredge sediment deposits to develop or operate any of its terminals given the nature of the local topography. Should the Company’s new business activities involve dredging going forward, appropriate dredging programs will be developed to minimize the impacts on environmental resources consistent with IFC environmental guidelines.
Construction controls are in place to minimize increases in water quality turbidity during filling activities, dust formation, and noise. Wastes and wastewaters generated during construction are managed appropriately.
Because of the day-to-day equipment maintenance activities conducted at terminal operations, only incidental amounts of hazardous materials – paints, solvents, and petroleum lubricants, fuels – are stored and handled. Storage areas are constructed to contain and prevent any leaks from being released to the environment. Oily wastewaters generated from the equipment maintenance and washing in the maintenance workshops are treated in oil/water separators. Stormwaters are collected in drainage networks equipped with bar grills and sand filters. Sanitary sewage generated by employees is collected and treated prior to discharge to the sea. The small amounts of waste oils and other solid and hazardous wastes generated along with any oils recovered by oil/water separators are stored in tanks and/or containers, and periodically collected by licensed contractors and appropriately recycled as fuel, or disposed at approved, government-operated facilities. Bilge and other ship-generated wastewaters and wastes are collected and managed at facilities licensed and operated by other parties consistent with Turkish regulations.
- Port and Terminal Emergency Preparedness and Response
At some port facilities where Arkas is one of several terminal operators (i.e., the Marport terminals at the Ambarli port), a third party port services organization is responsible forcoordinating the planning and response to hazardous materials accidents and emergencies. Known as Altas, the port services operator at Ambarli has put in place port-wide emergency action plans consistent with international maritime conventions (MARPOL 73/78). As such, Altas is responsible for responding to general shipboard emergency response needs and related marine spill response activities. With regard to the Marport terminal operations for which they are responsible, Arkas has established procedures, trained personnel, and equipment in place for responding to emergencies, including fire, chemical spills and mishaps, accidental release of petroleum products, and medical emergencies.
Some of the containerized cargo handled at Arkas terminals is considered to be hazardous under the International Maritime Organization’s (IMO) Dangerous Goods Code. This material includes flammable gases, poisons, flammable liquids, corrosives, reactive and spontaneously combustible substances, oxidizing substances, etc. Containerized hazardous cargo is stored by material class in segregated areas within the container storage yard with good access to containment resources and emergency response equipment; no radioactive materials or explosives are handled. The majority of containers with dangerous cargoes are handled as full containers, and the inventory is monitored continuously.
- Vessel Safety and Pollution Control
Arkas’ container shipping vessels are designed and operated to meet appropriate and relevant international and Turkish safety and pollution control requirements. All ships are certified in accordance with the ISM code and applicable national and international (SOLAS) maritime rules. Used to manage all safety aspects of its shipping activities, the Company’s safety management system (SMS) is also internationally certified and annually audited.
Containers with dangerous cargoes are carried in full accordance with the IMO Dangerous Goods Code, including labeling, manifest documents, and special on-board storage measures.
Vessels are all equipped with tanks and containers for storing ship-generated wastes and effluents – domestic wastes, maintenance waste and oils, oily wastewaters, sanitary wastewaters, recyclable plastics, metals and glass. When accumulated, segregated wastes are delivered to MARPOL-authorized on-shore port facilities for treatment and disposal. All vessels meet current MARPOL pollution control standards, and new ships will be designed to meet new standards coming into force.
In accordance with MARPOL, vessels have plans and procedures in place for responding to emergencies, such as collisions, grounding, fire, and oil and chemical 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 oil spill emergency response, and provided with appropriate personal protective equipment. Training includes both classroom training and emergency drills.
Arkas has not experienced any oil spills or emergencies involving hazardous cargoes within the last three years.
- Employee Health and Safety
Arkas has implemented robust programs to ensure the health and safety of its shore-based employees and ship-based crews. In the case of Marport, the program is guided by a recently conducted occupational health risk assessments of all workplaces and activities. Pre-employment and periodic medical evaluations are conducted for all employees. Personnel are issued appropriate Personal Protective Equipment (PPE), briefed on its mandatory use, and regularly monitored to ensure it is used properly. Detailed procedures and manuals have been established and are regularly communicated to employees and crews through regular health and safety meetings and comprehensive training programs. All new employees receive a basic safety and security presentation, and regular training is conducted for first aid and CPR, fire fighting, and emergency response. Incidents are thoroughly investigated and appropriate preventive or corrective actions are implemented to prevent reoccurrence.
