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WP 5 - Act 5.2Feasibility Studies for Port Operators

FEASIBILITY STUDY FOR THE PORT OF BURGASEdited by: Transconsult MP Ltd.

Port Operator: BMF Port Burgas EAD

Supported by: Bulgarian Ports Infrastructure Company (BPI Co)

South East Europe Transnational Cooperation Programme PRIORITY AXIS 2: Protection and Improvement of the Environment AREA OF INTERVENTION 2.2: Improve prevention of environmental risks Project “Transnational ENhancement of ECOPORT8 network” TEN ECOPORT project – Code SEE/D/0189/2.2/X

Feasibility Studies for Port Operators Port of BURGAS

Port Operator: BMF Port Burgas EAD CONTENTS

1 Summary .............................................................................................................. 1

2 Description of the port .......................................................................................... 2

3 Chosen EPO (External Port Operator) description ................................................. 6

3.1 Port terminal Burgas East 2 ................................................................................ 6

3.2 Port terminal Burgas West .................................................................................. 7

3.3 Organisational structure of BMF Port Burgas PLC ................................................... 8

4 EPO risk assessment ............................................................................................. 9

4.1 Identification of all aspects of the environment related to the reviewed activities and/or services........................................................................................................... 9

4.2 Determining the environmental impact on every aspect ....................................... 10

4.3 Determine the significance of the environmental impact of every aspect ................ 10 4.3.1 Determine the environmental impact ......................................................... 10 4.3.2 Environmental risk assessment ................................................................. 11

5 EPO (the greatest) risk reduction/elimination action ......................................... 24

6 Human resources, equipment and costs.............................................................. 26

7 Worthiness of the EPO proposed environmental action....................................... 28

[Feasibility study for the Port of Burgas] [December 2014] page 1

1 Summary The aim of this study is to analyse the risk based on the impact of the activity of the external port operator (EPO) “BMF Port of Burgas” (MPB) PLC, the elements of the environment identifying possible economically feasible measures to reduce the negative impact.

Analysing the current organizational, managerial and technological practices in “BMF Port of Burgas” PLC, in the context of a public transport port of national importance, an analysis of the risk to the elements of the environment, as identified significant ones, applying methodologically combined with quality and quantitative criteria for assessing the environmental aspects is made.

To identify the main risks and significant aspects are proposed measures to minimize the risk and the negative environmental impact of two main types:

• soft measures (training and consulting); • investment measures (repair, rehabilitation and construction of new infrastructure and

superstructure, and the purchase of equipment)

Finally, a general analysis of the benefits of the proposed measures, as well as possibilities for their replication in other port operators.


2 Description of the port Port for public transport of national importance Burgas

According to Art. 92а of the Law on Sea Spaces, Inland Waterways and Ports in the Republic of Bulgaria (LSSIWPRB), the port of Burgas is exclusive state property. The territory and infrastructure of the port is owned by the state.

According to Art. 93 of LSSIWPRB Burgas port is a port for public transport and Art. 103a of the same Law defines it as a port for public transport of national importance.

Port of Burgas is divided to the following terminals:

Port Terminal Burgas East 1 – operated by port operator “Port of Burgas” PLC.

Total area of the terminal is 338 880 sq.m.

Total length of berths is 2 147 m.

Carrying capacity of port terminal Burgas East 1, under

current technical and technological conditions is to 2 154 405 tons of cargo annually.

Port terminal Burgas - East 1 has 15 births with numbers from 0 to 14. Berth № 0 is for yachts and boats; births № № 1 and 2 function as passengers; berths № № 3, 4, 5, 7, 8, 9 and 10 are used for mooring of tugs of the port fleet, for small caters and official ships is not functioning. Cargo is handled at 4 berths. These are berths №№ 6, 11, 12 and 13.

Terminal quay equipment consists of 22 power cranes – portal, beam cranes with loading capacity from 6 tons to 20 tons: “Abus“ – 6, “Kirkiovets“ – 7, “Fod“ – 2, “Albatros“ – 1, “Kalmar“ – 5, “Sokol“ – 1.

Logistics equipment consists mainly of:

• Power cranes in warehouses – 4: gantry cranes with capacity 20 tons – 4. • Wheel and crawler cranes – total 9: – 1 crane with loading capacity 50 tons, 1 crane with

loading capacity 40 tons, 2 with loading capacity 25 tons, one crane with loading capacity 20 tons, 2 бр. с loading capacity 16 tons, 2 бр. с loading capacity 12.5 tons.

• Other specialized machines (total 104) basket loaders (1), Tractors (21), forklifts and trucks (40), trailers (42).

The terminal has a storage capacity as follows:

• Indoor warehouses - 26 000 sq.m. • Open warehouses - 35 000 sq.m. • Warehouses for specialized cargoes: cement (concrete silos with capacity 10 000 tons), for

tobacco (store № 6), for liquid cargo (1 бр. х 1 000 cub.m. tanker for oils) - not used.


Port terminal Burgas East - 2 – given on concession to “BMF Port Burgas” PLC for 35 years according to Concession Contract, concluded on 08.09.2011, enforced as of 01.01.2012. See p.3. Chosen EPO (External Port Operator) description in the present report. See it.3.

Port terminal Burgas - West - given on concession to “BMF Port Burgas” PLC for 35 years according to Concession Contract, concluded on 08.03.2013 г., effected as of 03.05.2013. See it. 3. Chosen EPO (External Port Operator) description in the present report.

Port terminal Rosenets – given on concession to “BMF Port Burgas” PLC for 35 years according to Concession Contract, concluded on 12.05.2011, enforced as of 07.2011.

Port terminal “Rosenets” is designed and build with the aim to serve the manufacturing process of Oil Refinery Plant “Neftochim” – Burgas. It is started in operation in 1963. It is designated to handle liquid


cargo – crude oil, petrol products and chemicals.


The carrying capacity of the port terminal Rosenets, under the current technical and technological conditions is to 16 500 000 tons annually.

The port terminal does not have storage area. Storage of the handled cargo is done in the neighbouring warehouse of “Lukoil” АД.

Port terminal Nessebar – given on concession to “BMF Port Burgas” PLC for 35 years according to Concession Contract 09.07.2014, enforced as of 08.09.2014.

Port terminal Nessebar, inherently represents specialized passenger terminal, consisting of hydro installation, jetties, breakwaters and sea station.

The terminal covers an area with boundaries port facilities – breakwater and quay walls, and parking of Nessabar Municipality.


Terminal capacity is up to 17 400 passengers/per year.

Port terminal Nessebar has 3 berths and breakwater.

On Port terminal Nessebnar is not performed any handling and/or storage activity. No detached indoor and open warehouses.

Throughput of the public transport port of national importance Burgas for 2013. Ro-Ro and cabotage is excluded.

OPERATOR TYPE OF CARGO TOTAL TONS

Port Burgas - West Farm animals 721 311

Port Burgas - West Food and feed 13 019

Port Burgas - West Ore and metal scrap 16 340

Port Burgas - West Products of ferrous metals 508 500

Port Burgas - West Construction materials and products 36 195

Port Burgas - West Chemical substances and products 224

Port Burgas - West Machines and other goods and products 642 195

Port Burgas - East 1 Agriculture products live stock 64 510

Port Burgas - East 1 Food products and feed 50 958

Port Burgas - East 1 Solid mineral fuels 5 818

Port Burgas - East 1 Ore and metal scrap 175 718

Port Burgas - East 1 Products of ferrous metals 112 827

Port Burgas - East 1 Construction materials and products 46 176

Port Burgas - East 1 Fertilizers 55 620


OPERATOR TYPE OF CARGO TOTAL TONS

Port Burgas - East 1 Machines and other goods and products 1 714

Port Burgas-East 2 Agriculture products live stock 311 713

Port Burgas-East 2 Food products and feed 16 905

Port Burgas-East 2 Solid mineral fuels 52 613

Port Burgas-East 2 Petrol and petrol products 193 464

Port Burgas-East 2 Ore and metal scrap 1 086 138

Port Burgas-East 2 Products of ferrous metals 154 282

Port Burgas-East 2 Construction materials and products 75 626

Port Burgas-East 2 Chemical substances and products 7 044

Port Burgas-East 2 Machines and other goods and products 5 041

Port Rosenets Petrol and petrol products 10 533 082

Port Rosenets Chemical substances and products 25 573

TOTAL: 14 912 606


3 Chosen EPO (External Port Operator) description Subject of the present feasibility study under project TEN ECOPORT – Transnational enhancement of ECOPORT8 is BMF Port of Burgas PLC. The Company is concessionaire of port terminals Burgas East 2 and Burgas West.

3.1 Port terminal Burgas East 2

Port terminal “Burgas East 2” is with total area of 419 468 sq.m. and locates 9 berths 1 piers. Total length of quay front is 1 592 m, and maximum admissible draft is 14.60 m, which allows berthing of heavy-tons ships type “Panamax”.

Port terminal is protected by a breakwater with length of 1 260 m, which allows performing of port services even in bad meteorological conditions.

Terminal “Burgas East 2” has 163 000 sq. m. Open storage area and 6 000 sq.m. indoor warehouses.

Loading capacity of the port terminal Burgas East - 2 at the above described facilities is 9 350 000 tons annually.

Fig. 1 Port terminal Burgas East 2


3.2 Port terminal Burgas West

Port terminal Burgas West is with open area of 641 499 sq. m. and locates 6 berths. Total length of the quay front is 958 m, and maximum admissible draft is 11.00 m.

Port terminal Burgas West has 442 410 m2 open storage area and 31 350 m2 indoor warehouses.

At the territory of terminal Burgas West is handled general cargo, bulk cargo, grain and containers. Berth no. 24 has a conveyor system with adjacent warehouses, for loading bulk (grain) cargo. The system is with capacity of 8 000 / 11 000 tons of cargo for 24 hours depending on the specific gravity of the cargo.

On the territory of terminal West is located Refrigerated warehouse with an area of 7 000 sq. m. There can be stored different foods that do not require special temperature regime. The warehouse is certified under NVS. The warehouse “Lozovo” has 71 000 m2 open storage area and 20 250 m2 indoor warehouses.

Fig. 2 Port terminal Burgas West


There is a well-developed road and rail network.

The available equipment is the following: • 10 gantry cranes • 1 mobile cranes • 8 bridge cranes • 11 reach stackers • 11 terminal tractors • 17 trailers

Total cargo handling capacity for the cargo berths in port terminal Burgas West is 2 046 153 t./per year.

3.3 Organisational structure of BMF Port Burgas PLC

The personnel of BMF Port Burgas PLC are continuously growing given the new contracts and activities of the Company. At the time of study there are 850 employees.

The technological processes on handling of the different types of cargo are specified by technological cards, developed under the requirement of Art. 15 of Regulation 9/ 29.07.2005 on operational suitability and coordinated by the EA “Maritime Administration”.

Fig. 3 Organisational structure of BMF Port Burgas PLC

ITC Ecologis

OHS

Admin

FINANCIAL

Accounti

HR

BOARD OF DIRECTORS

EXECUTIVE DIRECTOR

PROCURATOR

Legal Advisor / MR

CHIEF DIRECTOR

Container terminal

Terminal Burgas

Inventory Dry Bulk

Liquid

LPG cargo

Director Operations Security Supply and

Support

Technical Director

Repair shop

Technical Dep. Burgas

Technical

Dep. Burgas

Energy Dep.

Terminal Burgas

Coordination and

statistics


4 EPO risk assessment In BMF Port Burgas PLC is developed and implemented an environmental management system (EMS). The Company’s management is committed to:

• Carry out periodic environmental review and develop all activities, processes and services in a manner that ensures a continuous decrease of negative consequences for the environment, including pollution reduction and separation of waste in nature and reducing unnecessary energy consumption, materials and paper;

• Comply with the laws and regulations, rules and internal regulations relating to environmental protection, adopted for mandatory in BMF Port Burgas PLC;

• Continually improve performance in terms of environmental protection, maintenance and development of the systems of environmental management in accordance with the requirements of ISO 14001:2004;

• Systematically to monitor environmental performance; • Through training and information to motivate their employees, customers and suppliers to

think about the protection of the environment in which we live.

These commitments are formed in a policy which is regularly reviewed for suitability, adequacy and implementation. The policy is communicated to all staff so that they consciously and actively contribute to its implementation. The guide provides the necessarily financial and human resources to implement and continuously improve the system of environmental management, in accordance with the requirements of ISO 14001:2004.

In BMF Port Burgas PLC are identified environmental aspects, taking into account the scope of management system and geographic boundaries of the port, as well as situations in which they may arise:

• planned activities; • minimum activities; • normal working conditions; • non-normal/emergency conditions.

The aspects are distinguished also on those on which BMF Port Burgas can influence:

• “directly” (they are connected with the direct activities of the organization, on which control is performed);

• “indirectly” (they are connected with the activities of clients, suppliers, companies operating in the territory of the port, neighbouring organisations).

Aspects identification undergoes the following steps:

STEP 1 – Identification of all environmental aspects related to the activity in question and/or services.

STEP 2 – Determination of the environmental impact of every aspect.

STEP 3 – Determine the significance of the environmental impact on every aspect.

4.1 Identification of all aspects of the environment related to the reviewed activities and/or services

a. Determine of activity, product or service within the framework of the defined scope of application of EMS: Port services – handling of general, bulk, liquid, Ro-Ro, container


cargo and liquefied natural gas. Stacking, towing, Strengthening and repacking of goods; Mooring/unmooring; Training in centre for professional qualification.

b. Determining the spatial parameters within the defined scope of application of EMS (see Fig.1 and Fig. 2 – cards of Port terminal Burgas East 2 and Port terminal Burgas West).

c. Determining environmental aspects

In order to systematically determine the aspects and related effects, they are grouped as follows:

• Emissions to air • Emissions to water • Emissions in soil • Waste generation • Use of water • Energy consumption • Use of raw materials • Use if hazardous materials • Generation of noise

4.2 Determining the environmental impact on every aspect

In order to connect the environmental impact it is to be taken in consideration the nature of receptors impact: flora, fauna, people and means of transmission (air, water, soil), which constitute the environment and “paths” for potential polluting effects. One aspect of the environment can have several environmental impacts.

The impacts on the environment can be:

• negative • positive • short-, medium- and long-term • permanent • reversible • increasing • local, regional and global

4.3 Determine the significance of the environmental impact of every aspect

4.3.1 Determine the environmental impact

Qualitative criteria:

• legal requirements – in cases where on one question exists legislation / regulations/ requirement in the concession contract, then the aspect is significant;

• international requirements – even when those requirements are not subject to the legislation aspect to be considered significant;

• requirements of stakeholders (legislative, regulatory and governmental organizations, emergency services, customers, residents associations and individuals, insurance and financial organizations interested in environmental groups, etc.), determining the


significance of this criterion in each case after discussion of leadership. Following the requirements in the concession contract, the aspect is defined as significant;

• local issues – impact on port neighbouring sites: - people – houses, schools, hospitals, entertaining places, recreation areas, museums and etc.; - business – industrial, offices, stores, farms; - historical – ancient monuments, earth formations, buildings; - nature – protected territories, dump areas, reserves

determining the importance of this criterion in each case after discussion by the management • lack of information about danger – is defined as significant.

Quantitative criteria:

• severity of impact (expert assessment); • frequency of impact (probability of occurrence)

4.3.2 Environmental risk assessment

Environmental risk assessment is connected with aspect based on two-dimensional model and should be assessed from 1 to 5 according to the probability of impact and severity of the impact, which can cause.

Risk = Frequency of impact Х Severity of impact

The evaluation of frequency of impact is performed in the following manner: 1 = Improbable

2 = Probable in normal conditions (loss of power, incapable operator, malicious damage, one usually controlled condition, which is out of control or emergency conditions – fire, flood, spill and etc.)

3 = Random probability

4 = Probable

5 = Nearly sure, it happens under normal conditions

Freq

uen

cy o

f im

pac

t

5 5 10 15 20 25

4 4 8 12 16 20

3 3 6 9 12 15

2 2 4 6 8 10

1 1 2 3 4 5

1 2 3 4 5 Severity of

Impact


The assessment of the severity of the impact is performed in the following manner: 1 = Immeasurable impact on the environment

2 = minimal and immediately correctable impact on the environment, a minor violation of the law, the minimum economic losses

3 = Limited and/ or short term recoverable impacts, accidental violation of law or policy, moderate economic losses

4 = Immediate and/ or long term, serious impacts on the environment, greater violation of law or policy

5 = Irreversible or permanent impacts on the environment or risk of danger to the health or safety of persons, a serious violation of law or policy, catastrophic economic losses.

At values above 12 risk is high and the aspect is significant. Filter of significance

All significant aspects are managed following the regulations of EMS with one of the following methods:

• Operational control • Concrete targets and programmes • Investigation in the cases with lack of information

Normative requirements

International requirements

Requirements of stakeholders/ Concession contracts/ /Management Decision/ Approved by the Executive

Local issues /Management Decision/

Lack of information for the danger

Environmental risk

З н

а ч

и м

а

с п

е к

т

START YES

YES

YES

YES

YES

YES

NO

NO

NO

NO

NO

Insignificant aspect

≤ 12

>12


Table 1 General EPO risk assessment

In the Table are reviewed some aspects of the main activity of BMF Port Burgas, assessment of significance, audit observations relating to the administration of this aspect.

Environmental issues

Activities, products &

services

Aspects that effect the environment

Impacts on the

environment Observations

Air

Handling activities

for bulk cargo (coal

and coal dust

copper concentrate)

Significant aspect:

international requirements (see

IMDG Code and EmS for concrete UN

Nr.)

Risk assessment: 16=4Х4

Emissions in the air: coal and coal

dust and dust particles of copper

concentrate

Pollution of air

with coal and dust

particles of

copper

concentrate,

Control of the activity is performed. Technological cards are prescribed

and work instructions with rules on health and safety, fire and rescue and

environment preservation.

In the loading-unloading process of coal and coal dust is used irrigation

water installation at the reception baskets of taps. When loading wagons

with coal are started dust suction and cleaning systems (filters and

cyclones) in bunkers and cargo weight and protective flaps, lowered to

the floor of the wagon.

When loading wagons with copper concentrate, after inspection and

clearance of their weight, they are sprinkled with lime.

Recommendations: To reduce the emissions in the air, especially in

adverse weather conditions (wind) could be invested in the modernization

of existing system for loading.

Storage of bulk

cargo in open

warehouses (coal

and coal dust

copper concentrate)

Significant aspect:

international requirements (see


Nr.)


Emissions in the air: coal and coal

dust and dust particles of copper

Pollution of air

with dust and

dust particles of

copper

concentrate,




When increasing the temperature of stored coal above 800 C due to self-

heating with risk of ignition as well as in dry and windy weather, stiffing,

storage areas and roads are irrigated against dust formation and fire.

It is practiced sprinkling of stows, cover with flaps, wetting, treatment

with grout. Instructions for sprinkling the copper concentrate are to be




services


Impacts on the


concentrate consented with the client. Irrigation is performed on under crane routes

and tracks, paths, passages and areas covered with copper concentrate.

Given that copper concentrate is expense raw material, it is subject to

special measures to prevent the dispersal of its residues in cargo handling

operations. After expedition of goods from stows, the empty warehouses

have to be swept thoroughly, to asphalt. Collected copper concentrate is

loaded on the wagons.

Recommendation: Given the regular processing of copper concentrate and

large stocks of the same on the territory of port terminal Burgas East 2

would be better to build an indoor warehouse storage for keeping copper

concentrate, in order to reduce air emissions in bad weather conditions

(wind).

Loading-unloading

of hazardous liquid

cargo gas oil, fuel

oil, alcohol,

chemicals,

maintaining penol

drenching

installation

Significant aspect:

normative requirements

(Regulation I-з-2377/2011 on the

rules and standards for fire safety in

the operation of the objects)

Fire

Air pollution by

sulphur gases,

carbon dioxide,

nitrogen oxides

Based on the assessment and analysis of potential risks and forecast

consequences, to the regulatory requirements for port activities and

experience gained, are identified the rules for emergency situations as

described in the plan for carrying out rescues and emergency restoration

works in disasters, accidents and catastrophes in port terminals operated

by BMF Port Burgas and the appropriate instructions for action.

Recommendations: To be organized periodic training and testing

(training) of the emergency plans, and to initiate their change in

establishing such a need (in testing, in an incident occurrence, in changes

in the organization and technology activities and others.).

Transport activity

by carriers in

transportation of

cargoes - trucking



Emissions in the air: exhaust gases

Air pollution:

formation of acid

rains

This aspect has not been assessed as significant. It can be managed

directly by BMF Port Burgas. Responsibility of haulers and customers of

the port.




services


Impacts on the


from internal combustion engines -

aerosols (GMS), sulphure dioxide

(SO2), nitrogen oxides (NOx),

carbon monoxide (CO), carbon

dioxide (CO2), volatile organic

compounds (VOCs)

Water Loading-unloading

of bulk cargo (coal

and coal dust

copper concentrate

and others.)

Significant aspect:

international requirements ((see


Nr)


Emissions in the water: coal and coal

dust copper concentrate and others.

Water pollution Control of the activity is performed. Technological cards are prescribed



When loading and unloading of bulk cargo in working position is put a wall

between the board and the portal crane, preventing the fall of the bulk in

the sea. It is forbidden to clean the pier area and workers to pull down

load at sea. It is forbidden to drop into the sea and dipping washing

grabs, buckets and other facilities and equipment of bulk loads is set to

position working wall.

Recommendation: Emissions reduction in the water, especially in adverse

weather conditions (wind and rain) could be invested in the modernization

of existing systems for unloading and upgrading the drainage system for

rainwater.

Loading-unloading

of hazardous liquid

cargo gas oil, fuel

oil, alcohol,

chemicals,

maintaining penol

drenching

Significant aspect:

Normative requirements (see

Regulation 16/2006 for treatment

and haulage of hazardous goods)

Water emissions: release of

hazardous liquid cargoes in the

Water pollution

directly and

through

underground

waters

(see IMDG Code

and EmS for




Responsible operator via a licensed company puts boom to limit spill after

berthing of a tanker carrying petroleum products with ignition

temperature above 610C. It is forbidden to clean the piers and the region

to tear down load from the pier into the sea, and washing hoses, buckets,




services


Impacts on the


installation water concrete UN Nr.) containers, tools and equipment at sea

Recommendations: : To prevent spills, leading to water pollution it may

be provided investments for modernization of technological equipment in

the complex processing of goods (pumps, pipes and etc. To be organized

periodic training on preventive and emergency actions.

Loading-unloading

of bulk grain cargo



Falling grain in the water

Decay processes,

oxygen depletion

and adverse

impact on flora

and fauna




To prevent any spillage of grain cargo on the working site or falling into

the sea are placed between the board and the pier tarpaulins (lights)

before the holds under treatment. Tarpaulins are tensioned and direct

load to the pier.

Soil and underground water

Loading-unloading

of hazardous liquid

cargo gas oil, fuel

oil, alcohol,

chemicals,

maintaining penol

drenching

installation

Significant aspect:

normative requirements (see

Regulation 16/2006 for treatment

and haulage of hazardous goods)

Emissions in soil: release of

hazardous liquid cargo on the soil at

hosing,

Contamination of

soil and

groundwater




Periodically and, if necessary, it is carried out preventive cleaning of

drainage ditches, tank oiled waters, oil spills, etc. The collected oil

polluted materials and water (rain, snow, spill) disposed faeces drive

machine to the local treatment plant for bilge water.

Recommendation: To prevent spills, leading to pollution of soil and

groundwater can be provided investments for modernization of

technological equipment in the complex processing of bulk goods (pumps,

pipes, etc.)

Activities carried out

within the station:

Significant aspect:


Contamination of

soil and

Perform control of fuel consumption.




services


Impacts on the


loading of vehicles,

storage of diesel,

loading of tankers in

SML, storage of oils

– stock SML

Regulation 3/1989 on norms of fuel

consumption and lubricants,

Regulation on the procedure and

manner of storage of hazardous

chemical substances and mixtures.)

International requirements (see

Regulation EC 1907/2006 regarding

REACH)

Emissions in soil: diesel, fuel venting

filling of tanks, accidental spills of

fuel in the integrity braking of the

seals connections, spills at

emergency situation

groundwater

Depletion of non-

renewable natural

resources: oil

Maintenance of the facilities, prevention is made

Separated are places for each type of oil labelled drums, containers for

clean and oil absorbents.

Recommendation: 5training of employees for the implementation of the

procedures for preventive actions and implementation of emergency

plans.

Perform repair of

grabs and

containers, KTM,

tugs, auto-cranes,

vulcanizer,

carpentry

workshop, turnerys,

electrical workshop,

motor service

Significant aspect:


Regulation for requirements for

treatment and transportation of

manufacturing and hazardous waste)

Emissions in soil: oil and liquid fuel.

Waste generation:

- absorbents, contaminated oily

substances.

- Packing of dangerous

chemicals,

- Mixture of metals.

Soil

contamination

Repairs are performed at concrete sites, incidental spills are collected with

absorbent, which are collected and sent for treatment. Temporary

separate storage of generated waste in specially designated premises.

Contracts concluded with licensed companies for activities on the relevant

waste.

Recommendation: training of employees for the implementation of

procedures for waste collection.




services


Impacts on the


- Lead batteries

Noise Berths – loading-

unloading with

containers, Berth 23

– containerization

and de-

containerisation

Significant aspect:


Regulation №6/2006 for noise

indicators in the environment)

Generating of noise

Increasing the

aural

The residential buildings are located about 950 metres from the port

terminals.

RIEW Burgas perform checks of noise indicators in the environment,

taking into account the degree of discomfort in different parts of the day.

Conducted are own measurements of noise levels requirements under

Regulation №54/2010 for the activity of the national system for

monitoring of noise in the environment. The results are border-lined there

is room for improvement agreed in respect of noise pollution in urban

areas.

Recommendation: Purchase of specialized transport equipment for

containers to reduce noise during loading-unloading operations.

Transport activity b

by the haulers in

transportation of

cargo – railway

haulage

Significant aspect:

Normative requirements (see

Regulation №6 on noise indicators in

the environment)

Generating noise

Increasing the

aural

The residential buildings are located about 950 metres from the port

terminals.

RIEW Burgas perform checks of noise indicators in the environment,

taking into account the degree of discomfort in different parts of the day.


Table 2 Matrix of EPO risk

Relation

/ Risk caused by

Ship

I

Cargo

II

Cargo handling

equipment

III

Transportation

Devices

IV

Employees (on port workers)

V

Ship to shore

Ship-buffer zone

X X X X

Ship-truck X X X X X

Ship-wagon X X X X X

Ship-buffer-warehouse

X X X X X

Shore-to-Shore

Warehouse - warehouse

X X X X

Warehouse – truck and reverse

X X X X

Warehouse – wagon and reverse

X X X X

Shore to ship

Wagon - ship X X X X X

Truck - ship X X X X X

Warehouse-buffer zone-ship

X X X X X

Could be grouped the following risks for the port operator with respect to the environment:

• In view of the content of the Tables 1 and 2 above, as well as the specific activities, the main risks regarding the environment (significant aspects), arise from loading-unloading, warehousing and transport operations with the cargoes passing through the port, as connecting link between sea and land transport modes;

• There are risks (evaluated as significant aspects), connected with the maintenance activities of the port operator, as maintenance and repair of the equipment and machinery, loading and storage of fuel and oil (see Table 1).

• Other risks, stemming from normative changes, with potential environmental impacts


New Annex V of MARPOL 73/78 - HME

Following the entry into force of 01/01/2013 of the new version of Annex V of MARPOL 73/78, the washing waters of the cargo premises are classified as cargo residues. These cargo residues containing substances that are classified as “hazardous” to the marine environment” (HME), should not be disposed of at the sea, as required by Ruled 4.1.3 and 6.1.2 of the new Annex V, and therefore mandatory should be submitted to PPS. Since significant amounts of cargo handled by the port operator BMF Port Burgas PLC, is dry bulk cargo, the needs of PPP needs to adopt such washing water will rise. The amount of such waste can be very large (up to several hundred m3 per ship).

In the texts of rules 4.1.3 and 6.1.2.1 of the revised Annex V of MARPOL 73/78 is referred to the Guide for implementation of MARPOL Annex V, 2012 – introduced by Resolution MEPC.219(63) of the Committee for protection and marine environment protection of IMO.

One of the main goals of this Guide is to assist the operators of ports and terminals, in assessing needs and providing adequate PPP for solid waste – the result of ship.

Considering the volume of solid bulk cargo that is handled by BMF Port Burgas PLC, it is essential that consideration of section 3 Management of residues of solid bulk cargo by Guide (MEPC.219(63), defining the procedures for classification of these residues representing Hazardous to Marine Environment - HME).

In the classification of the dry bulk cargo, the shippers have to apply the criteria of the United Nations Globally Harmonized System for Classification and Labelling of Chemicals - UN GHS), regarding the following 7 parameters:

• Acute Aquatic Toxicity Category 1; and/or • Chronic Aquatic Toxicity Category 1 or 2; and/or • Carcinogenicity Category 1A or 1B combined with not being rapidly degradable and

having high bioaccumulation; and/or • Mutagenicity Category 1A or 1B combined with not being rapidly degradable and having

high bioaccumulation; and/or • Reproductive Toxicity Category 1A or 1B combined with not being rapidly degradable

and having high bioaccumulation; and/or • Specific Target Organ Toxicity Repeated Exposure Category 1 combined with not being

rapidly degradable and having high bioaccumulation; and/or • Solid bulk cargoes containing or consisting of synthetic polymers, rubber, plastics, or

plastic feedstock pellets (this includes materials that are shredded, milled, chopped or macerated or similar materials).

Should be considered the requirements of the International Maritime Solid Bulk Cargoes Code - IMSBC), as regards the inclusion of a statement by the consignor for the categorized as hazardous to the marine environment (HME) ship cargo, to the information required under Chapter 4 of the Code.

In many cases, ships calling at the terminal currently used for the carriage of only one type of cargo, which does not require special cleaning of cargo spaces.

Cargo residues, which are hazardous to the marine environment, may require special handling that is normally offered by existing port reception facilities. Therefore, management for the implementation of MARPOL Annex V requires ports and terminals receiving such goods to have


adequate reception facilities for all related cargo residues, including those contained in the washing waters.

Real risk may occur when ships stand to load dry bulk cargo at a terminal of BMF Port Burgas PLC, whereas during the passage has done washing and preparation of cargo holds of previous cargo unloaded at another port and classified as HME (which may not be traditionally transported through the port of Burgas). In this case, the ship will have to step down the cargo residues (in dry form and/ or washing waters) at appropriate PPS, and its lack or insufficiency may result in delays or in the worst case– overboard.

Entry into force of BWMC, 2004

Considering the problems and potential risks arising from bio invasion of organisms trans-bordered with ship ballast water, the Member states of the International Maritime Organisation have considered it necessary and appropriate to introduce the international convention for the Control and Management of Ships’ Ballast Water and Sediments (BWMC), 2004. At present the status of the convention is the following: parties are 43 countries (with a minimum threshold for entry into force from 30 countries), whose vessels constitute total 32,54% of the world merchant gross tonnage (with minimum threshold for entry into force by 35%). Given the expected recent ratification by other countries, it is quite possible optimistic forecasts to cover requirements for entry into force of BWMC to be implemented until the beginning of 2015, and a year later, the Convention to be in force.

At European level is prepared a regulation for bio invasion that has to be approved by the European Parliament and the Council in 2016 - see. http://ec.europa.eu/environment/nature/invasivealien/.

Beyond the general requirements to Bulgaria (after the ratification of the Convention) to ensure its implementation by changing the local legislation, there is a risk for the port operator, in the case of a ship which stands for loading and whose management system of ballast water is damaged and cannot function according to the specifications under which is certified to achieve the requirements of Rule D-2.

In the above case, Article 9 of the Convention should be applied:

2

Where a ship does not carry a valid Certificate or there are clear grounds for believing that:

(a) the condition of the ship or its equipment does not correspond substantially with the particulars of the Certificate; or

(b) the master or the crew are not familiar with essential shipboard procedures relating to Ballast Water Management, or have not implemented such procedures;

a detailed inspection may be carried out.

3 In the circumstances given in paragraph 2 of this Article, the Party carrying out the inspection shall take such steps as will ensure that the ship shall not discharge Ballast Water until it can do so without presenting a threat of harm to the environment, human health, property or resources.

Furthermore, Article 10.3 reads: ”If the sampling described in Article 9.1(c) leads to a result, or supports information received from another port or offshore terminal, indicating that the ship poses a threat to the environment, human health, property or resources, the Party in whose waters the ship is operating shall prohibit such ship from discharging Ballast Water until the threat is removed.”


In these cases, there are two practical solutions applicable in order not to be cancelled the vessel handling in BMF Port Burgas PLC:

• to be carried out repair and subsequent certification of the management system of ballast water (which in practice would significantly delay the ship / cargo operations);

• to be discharged the ballast water in suitable reception facility, as provided in paragraph 6 of Rule B-3 of the:

6 “The requirements of this regulation do not apply to ships that discharge Ballast Water to a reception facility designed taking into account the Guidelines developed by the Organization for such facilities”. Currently, port of Burgas missing reception facilities for receiving ballast water, which create a risk for the operator BMF Port Burgas PLC.

New version of ISO 14001:2015 entry into force

Since the port operator BMF Port Burgas PLC has implemented the integrated management system, certified under the standards ISO 9001:2008, ISO 14001:2004 and BS OHSAS 18001:2007, the expected publishing of the new versions of these standards in 2015-2016 creates a risk for sustaining of the certificate, if not taken the appropriate steps to update the management system.

The main aspects, in which the management system —in particular the management system of the environment (EMS) of BMF Port Burgas PLC— should be updated after the publication of the new versions, are the following:

• complete restructuring of the specification for EMS: based on the high level structure of Annex SL of the International Standardization Organisation (ISO);

• Context of the Organisation (BMF Port Burgas PLC): include new requirements for understanding the organization and its context (external and internal issues that may affect EMS), understanding the needs and expectations of stakeholders that are relevant to EMS, determining the scope of EMS. Points 1 – 3 of this study may be of particular benefit to cover these requirements;

• The new requirements for the leadership and commitment of senior management, strategic management and environmental policy: it is necessary reconciliation of the policy objectives and environmental activities with the business targets and processes of BMF Burgas PLC. In this sense, specific processes and performance of the EMS should be maximum integrated in the port, and in the process of decision- making;

• Protection of environment: New goal of EMS and requirements to the policy is to be undertaken commitment for protection of the environment (unlike the current requirement to prevent pollution). This can be done by implementing measures to reduce energy consumption, use of renewable resources, protection of biodiversity, impact on life-cycle and managing of the supply chain and others.

• Environmental performance: Greatly increased focus on performance and its continuous improvement is reflected in a number of clauses of the standard, specifying different aspect of EMS (clauses 4.1, 5.2.е), 5.3.b), 6.2.2, 7.3, 9.1.1, 9.3.d). This requires the introduction of a clear system of performance indicators, and in the context of the integrated management system of BMF Port Burgas PLC, should be harmonized the process for to define them, their monitoring and updating, balancing for sustainable development of the Organisation (e.g. implementing the model ISO 9004:2009);


• Thinking within the life cycle: although it is not required assessment of product life cycle, the new version requires taking into account the entire life cycle when identifying and assessment of the aspect of the environment. This may require an update of the methodology applied in the EMS of BMF Port Burgas PLC.


5 EPO (the greatest) risk reduction/elimination action What is (are) the greatest risk(s) considered EPO at your port?

Risks, resulting from the handling, storage and transport operations with cargoes; Risks, connected with the maintenance activities of the port operator; Risks, resulting from changes in the regulatory framework

Detailed description of these risks is given in it.4 above.

What can be done to reduce or eliminate it (them)?

To reduce the risks, connected with the handling, storage, transport operations and cargoes, analyzing the findings and the recommendations described in the last column of Table 1 can be formulated the following three groups of measures to reduce the risks:

• Purchase of new and/ or updating of handling and inter-transport equipment; • Repair and rehabilitation of port infrastructure, construction of covered storage areas; • Training of personnel related to the protection of the environment and environmental

management system (EMS)

To reduce the risks related to maintenance activities of the port operator should be conducted staff training, related to preservation of the environment and environmental management system (EMS)

Measure to minimize the risks arising from changes in the legal framework:

• Measure to minimize the risks from cargo residues, dangerous for the marine environment: - Port operator should consider the application of handling technology to minimize

cargo residues after unloading; - Ship operators must use ships, appropriate to the particular type of goods and the

adequate handling technologies; - Maximum effective discharge of cargo, using appropriate precautions to prevent

injures, damage to the ship and equipment, and to avoid or minimize cargo residues;

- Minimize spillage of cargo in handling operations in the supply chain from the ship – to the exit of the port. This measure requires effective communication between the ship and port operator personnel during handling operations, and if possible use of specialized equipment, such as conveyors. As far as the spillage takes place within the terminal, it should be cleaned immediately after the handling operations and be treated as part of the cargo

- As the amount of cargo residues, hazardous to the marine environment can be very large (washing waters to several hundred m3), a possible solution would be to install facilities for the temporary storage of sufficient capacity, located on the terminal for bulk cargo, so that the treatment and final disposal, including integration with similar waste from coastal sources, can be organized subsequently, by delivery trucks or barges for a longer period of time (without danger of undue delay of the departing vessel).

• Measures to minimize the risk of non-compliance with the requirements of BWMC after its entry into force:


- In connection with the need to ensure reception facilities for ballast waters, it is necessary to explore the possibilities of the existing operators of port facilities under MARPOL 73/78 in port of Burgas;

- Purchasing (concluding framework contract with operator) of barge, allowing the adoption of ballast water and treatment with an appropriate system for ballast water management for cases of malfunctioning shipping system for ballast water management.

• Measure to minimize the risk of the expected publishing of the new versions of standards ISO 9001, ISO 14001 and ISO 45001, in the period 2015-2016. - Restructuring of documented information (policy, manual, procedures, etc.),

concerning the EMS of BMF Port Burgas PLC, to achieve compliance with the new requirements of the standard ISO 14001 and timely implementation of changes allowing re-certification in the new versions during the allowed transitional period 1-2 years. For this purpose it is appropriate to use external consulting services;

- On job training of the personnel of the operator, according to the importance in the management of processes related to the environment. This requires the use of external training services on management committed to implementation of EMS, including internal auditors.

- Establishing a system of performance indicators in relation to the environment, with the relevant target levels in the context of the integrated management system of BMF Port Burgas PLC. It is necessary to harmonize and integrate the process of their definition, monitoring and periodic updating, to achieve effectiveness and continuous improvement, balanced with other areas of management of the organisation (business development, quality of service, financial status, health and safety at work, etc.).

- Updating the assessment of the aspects on the environment from the activities of BMF Port Burgas PLC, and on this basis – updating of the Environmental Programme, with eventual measures for energy efficiency, use of renewable resources, protection of biodiversity and others. These changes should lead to protection of the environment, taking into account the life cycle and management on the supply chain.


6 Human resources, equipment and costs Based on the analysis of the greatest risks and the potential measures for their minimization to be made the following investments in training and development of the human resources related to the environment:

Type of training Who will be trained?

Obligations of trainees

What are the expected costs?

Protection of environment. Environmental Awareness Training

20% of the personnel (managers – medium and high level) – 160 people

Commitment to protection form pollution and protection of environment

Training on the spot – 8 trainings 4 hours

80 – Man-days Salary

8 – Lecturing man-days

Total:

8000 Euro – costs salaries

4000 Euro – costs lecturers payment

Training in emergency plans

Managers and responsible personnel – 100 people

Training and implementation of emergency plans. Update emergency plans

5 trainings 4 hours

Total: 10000 Euro

Training on separate collection and management of waste

All staff Separate collection of waste

Training during briefings on OHS and OS.

Total: 2000 Euro – for visual aids and training instructing

Complete training for implementation of EMS of the port operator

60 people – key personnel for implementing of EMS

Implementing of EMS

4 trainings of 1 working day

Working time – 6000 Euro

Lecturers – 2000 Euro Training for managers and internal auditors of the EMS

10 people Conducting internal audits

1 training of two days

Salary – 1000 Euro

Lecture – 1000 Euro

Consulting on restructuring processes and documented information concerning EMS (revaluation of Aspect, objectives, policies, programmes, system performance indicators)

10 people Restructuring of EMS for compliance of the new version of ISO 14001:2015

Salary – 5000 Euro

Consultants – 10000 Euro

Certification of EMS on the new version of the standard ISO 14001:2015

Certification organisation

10000 Euro- Certification for 3-year period


Based on the analysis of the greatest risks ant the possible measures for the minimization are provided the following investments in the equipment, repair and rehabilitation activities.

Description of the investment Value in Euro

Construction of new covered rear warehouses 24 Х 150 m for concentrates 30 к.м.

11 000 000

Repair of rainwater drainage system 80 000

Modernization of the existing system for unloading bulk cargo from ships

4 000 000

New system for handling of concentrates when imported 2 500 000

New system for loading railway wagons 1 500 000

Technological equipment in the complex for liquid cargo handling (pumps, pipes and etc.)

2 000 000

Reach stackers – 2 700 000

Spreader for loading and unloading of containers – 3 360 000


7 Worthiness of the EPO proposed environmental action

By taking into the consideration both environmental risks and the costs, is the action worthwhile of realizing in economic and environmental term?

Regarding the environment:

• Reducing the negative impact of the defined significant aspects in the air, water and noise, as elements of the environment;

• Improving the waste management by separate collection and prevent improper disposal or mixing;

• Improving and restructuring environmental management system (EMS) of BMF Port Burgas PLC, as integrated part of the complete business management in line with the new standards ISO (9001, 14001, 45001);

• Improving awareness and competency of the personnel of BMF Port Burgas PLC related to the environment aspects, Environmental management system, readiness for action in emergency situations and etc.

Regarding the economic effect

• Improved environmental management will have direct economic effect for the port operator by reducing the cost of repairing the consequences of pollution, reduced costs for energy and other non-recoverable natural resources, improved performance and capacity due to the introduction of new equipment;

• Reduce the cost to society, municipality, port authorities and other stakeholders to recover from pollution of environment, negative impact of the health, etc.

• Improving and restructuring environmental management system

It should be noted that it is generally very difficult to calculate quantitative benefits to environment, thus here is made only general assessment of the benefits of making those described in item 6 costs.

How will it affect the strategy of the whole port authorities EMS (short term, up to one year, and long-term)?

Implementation of the above measures is fully consistent with the strategic objectives of the port authority and port operator, and in particular:

• Comply and support the achievement of programme objectives and environmental management system, forming part of the integrated management system of BMF Port Burgas PLC;

• Comply with and support the implementation of the investment programme to the concession contract of BMF Port Burgas PLC with MTITC;

• Correspond and support the achievement of the objective defined in the document Strategy for development of the transport system of the Republic of Bulgaria 2020 “Development of sustainable transport sector by reducing the negative impact of the transport on the environment and the climate”;

• Investing in the personnel training have short and long-tern positive effect; • Investment in new equipment have double positive effect in achieving the goals of the

development of the activity of the port of Burgas – improving performance in terms of environment and increasing the efficiency and capacity of port logistics process.


Is there a possibility to transfer the new-generated knowledge throughout conducted EMS action to another EPOs within your port, or to another ports?

Overall, this study can be used as a model to evaluate the situation regarding the environment and possible improvement measures applicable to all port operators in Bulgaria.

In particular, the measures proposed to ensure compliance with recent or forthcoming in the near future changes in the instruments of the International maritime Organisation can be applied to all port operators in ports of Varna and Burgas.

As regards the measures proposed to ensure compliance of the EMS of the port operator BMF Port Burgas PLC with the upcoming publishing of the new version of ISO 14001:2015, the same can be applied to all port operators in sea and river port of Republic of Bulgaria.

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