Environment, health and safety are at the core of TRP’s management philosophy. Key environmental, social, health and safety (ESHS) issues identified for this project include: debris and soils disposal; blasting related to demolition; sediment disturbance; liquid effluent and storm water management; oil/hazardous materials storage and handling; waste disposal; handling and storage of dangerous cargoes; emergency response planning and preparedness; and labor and working conditions. The information about how these issues will be addressed by TRP is summarized in the paragraphs below.
PS1: Social and Environmental Assessment and Management Systems
Consistent with DPW’s corporate ESHS policy, TRP has in place an Integrated Management System (IMS) that has been certified ISO 9001 (for quality), ISO 14001 (for environment) and ISO 28001 (for supply chain security), and is aligned with OHSAS 18001 (for occupational health and safety). TRP is also certified as compliant with the International Ship and Port Facility Security (ISPS) Code. TRP’s IMS aims at ensuring the implementation of good industry practices for its operations and follow DPW corporate procedures and standards. The latest external audit of TRP’s ISO 14,001 certification was conducted on April 2009 and it was found to be satisfactory. TRP produces regular internal ESHS performance reports of its operations which are submitted to management for review as per ISO 14001. IFC has monitored TRP’s ESHS performance and the effectiveness of its IMS over the past 4 years as part of an existing investment. TRP will incorporate IFC’s Performance Standards (PSs) as part of the legal and other requirements of the IMS.
The ESHS issues related to the Project will be managed in accordance with TRP’s IMS, local regulations and IFC’s PSs. The design of the modification of the layout of Pier 3 and the refurbishment of the cruise passenger terminal has been conducted based on international construction and quality standards, and it has taken into consideration hydrological and environmental conditions in order to allow for the natural flow of water and minimize sedimentation. The passenger terminal has been designed to ensure that it constitutes a safe and obstacle-free environment and that it has adequate accessibility and safety features for disabled people.
In 2009, TRP, through qualified consultants, conducted an Environmental Impact Assessment (EIA) of the Project to identify potential risks and impacts and outline mitigation measures required to ensure compliance with Argentinean regulations. The Engineering, Procurement and Construction Contractor (EPC Contractor) will develop and implement detailed ESHS Management Plans and procedures in accordance to the EIA recommendations, IFC’s PSs and applicable IFC’s EHS Guidelines dated April 2007. These ESHS management plans and procedures will address, among others, the following issues: management of construction waste and disposal; occupational health and safety procedures and training; use of Personal Protective Equipment (PPE); management of liquid waste; oils, and fuels; management of explosives; management and disposal of debris and soils; and noise and dust control measures. The EPC Contractor will be continuously supervised by TRP’s ESHS Department.
TRP’s ESHS Department consists of a senior ESHS manager supported by 3 full time professionals. TRP engages specialized local consultants on per needed basis. The EPC Contractor will be required to have an on-site ESHS coordinator and supervisors. PS2: Labor and Working Conditions
As of April 2010, TRP employs 532 people (of whom 80% are unionized). Project-related construction activities are expected to generate approximately 100 short-term jobs. TRP’s Human Resources Policy is consistent with Argentinean law and IFC’s PS2 requirements. The Policy, and related induction material for employees, clearly defines rights and obligations and information about working conditions, including: compensation and benefits; ESHS training; non-discrimination policy; protection against harassment; grievance redress procedure for employees; education and career development; and annual, maternity and sick leave policy, among others. As mentioned before, an important number of employees are unionized and there are collective agreements in place with 5 different workers unions. These collective agreements define working hours, benefits, compensation rates, among other issues, and are based on country and sector-wide agreements. TRP do not employ minors and do not engage in forced labor. TRP requires all its contractors, subcontractors and service providers to comply with local labor laws.
As noted under PS1, TRP has in place a robust health and safety management system aligned with OHSAS 18001and Argentinean laws. TRP is continually seeking to improve procedures and employee training to reduce the number of incidents and accidents, and DPW actively promotes a zero incident culture at all the terminals it operates, including TRP. TRP’s health and safety procedures include: use of PPE, traffic safety, emergency response and preparedness plans, fire safety, and specific procedures for reporting and investigating incidents and identifying corrective actions, among others. All employees, including contractors, subcontractors and service providers, must be covered by an occupational risk insurance issued by a recognized Occupational Risk Agency (Administradora de Riesgo de Trabajo –ART-) and are required to abide by TRP’s ESHS procedures. Compliance is constantly monitored by TRP’s ESHS Department. As mentioned before, the EPC Contractor will develop and implement project-specific ESHS Management Plan and procedures that will include measures to address any health and safety risks related to their activities. TRP has installed fire safety systems and equipment (including networks of hydrants, foam generator and wet pipes and sprinklers for selected areas) and has trained fire brigades. Fire and emergency response drills are conducted four times a year.
PS3: Pollution Prevention and Abatement
Given the nature of container handling and storage TRP does not generate significant amounts of gaseous emissions or effluents. Power consumption is moderate and is supplied from the national grid. Greenhouse gas emissions associated with this project will be negligible. The water required for the administrative buildings and limited operational activities will be sourced from the municipal water system.
Liquid Waste and Effluents: 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 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 and 2, 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 has in place mobile equipment to contain any spills and allow for their adequate management and disposal.
Waste Management: 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. Hazardous Materials and Cargo: 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. About 2% to 3% of the containerized cargo to be handled at TRP is considered to be hazardous under the International Maritime Organization (“IMO”) Dangerous Goods Code, and is handled accordingly. 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. 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. 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 Authority. 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. 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 - AGP). 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.
Sediment Control During Construction: The Project requires the reshaping of a Pier 3 and construction of a new section of 3,800 mts2 to be supported by hollow metallic piles. Even though no dredging will be required, some sediment removal will take place during the demolition and piling process. The ESHS Management Plan will include provisions to ensure sediment control, including surrounding the work site with a silt curtain to minimize and contain any re-suspension of solids in the water column. Additionally, before, during and after operations, the water column inside and outside the silt curtain will be monitored for quality, turbidity, suspended solids, pH, concentrations of heavy metals, and benthic communities.
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 operations. This includes appropriate notification of potentially-affected neighbors and coordination with outside emergency response authorities. Any major incident, whether related to persons or affecting the environment, is evaluated and sent to DPW’s 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.
Air Quality Control: As mentioned above, gaseous emissions during operations will be minimal. However, during demolition and construction activities some emissions of particulates (dust) are expected and the ESHS MP will include specific procedures to address this issue, including covers for trucks transporting materials and debris, and water suppression.
Debris management - demolition: The reshaping of Pier 3 is expected to require the removal of 113,000 m3 of soils and debris that will be disposed in a Government-approved site. Given that Pier 3 has not been used for handling or storing hydrocarbons or other hazardous materials, it is unlikely that the soils to be removed are contaminated. However, the Company will conduct soil testing to ensure that the selected disposal method correspond to actual soil conditions. In order to manage, handle and dispose of the materials and soils that will result from the reshaping of Pier 3 the ESHS Management Plan will include procedures for managing debris, verification of the environmental management and licenses of final disposal sites, and specific measure to avoid any debris from falling into river.
Use of Explosives and Blasting: The demolition of a section of Pier 3 will require the use of explosives and controlled blasting. The EPC Contractor will follow local explosive safety regulations and these activities will be conducted by certified experts. Blast mats will be used to minimize fly rock and adequate warning devices and procedures will be implemented to alert any workers and third parties in the surrounding areas. The ESHS Management Plan will include a detailed procedure for use, handling and transportation of explosives based on local regulations and international best practices.
Vehicular Traffic: Traffic within the Terminal follows strict safety conditions. Traffic increase directly related to project activities and operation will be marginal. However, current heavy truck traffic and presence of trucks standing idle in front on the Port of Buenos Aires has been associated with negative impacts on traffic safety, congestion, and air quality. Even though TRP’s activities are not the main cause of such traffic, the Company is implementing measures to help address this issue, including the following: i) implementation of a scheduling system to allot specific time frames for trucks to pick-up cargo in order to minimize waiting times; ii) development, in conjunction with a neighboring Terminal, of a pre-gate truck staging area of approximately 13 has located in Pier 6; iii) regular meetings with the municipal transit authority to explore ways to re-route heavy traffic; and iv) development of Inland Storage Depots outside the urban area for storage of full or empty containers.
