FEASIBILITY STUDY FOR THE PORT OF CONSTANTA · FEASIBILITY STUDY FOR THE PORT OF CONSTANTA Edited...

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WP 5 - Act 5.2 Feasibility Studies for Port Operators FEASIBILITY STUDY FOR THE PORT OF CONSTANTA Edited by: Irina-Mihaela Togan, Environmental Expert National R&D Institute for Marine Geology & Geoecology (GeoEcoMar) Port Operator: ARSVOM

Transcript of FEASIBILITY STUDY FOR THE PORT OF CONSTANTA · FEASIBILITY STUDY FOR THE PORT OF CONSTANTA Edited...

WP 5 - Act 5.2Feasibility Studies for Port Operators

FEASIBILITY STUDY FOR THE PORT OF CONSTANTAEdited by:

Irina-Mihaela Togan, Environmental ExpertNational R&D Institute

for Marine Geology & Geoecology (GeoEcoMar)

Port Operator: ARSVOM

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

CONTENT

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

2 Description of Constanta port ............................................................................... 2

2.1 Constanta port organizational structure ................................................................ 2

2.2 Superstructure and infrastructure ........................................................................ 2

2.3 Romanian Naval Authority (RNA) ......................................................................... 4

3 Chosen EPO (External Port Operator) description ................................................. 7

3.1 ARSVOM organizational scheme ........................................................................ 10

3.2 Technical capacity ........................................................................................... 11

3.3 Legal and operational framework to carry out the activities of search, rescue and pollution response..................................................................................................... 16

3.4 Assessment of pollution sources generated by ARSVOM ....................................... 18

3.5 Collecting and recording of ARSVOM ship generated waste, according to the Waste Management Plan ..................................................................................................... 19

3.6 Accounting of the ARSVOM ship generated waste ................................................ 21

4 EPO risk assessment (RA) ................................................................................... 23

5 EPO (the greatest) risk reduction/elimination action ......................................... 26

6 Human resources, equipment and costs .............................................................. 29

6.1 Human resources and costs .............................................................................. 29

6.2 New equipment and costs................................................................................. 29

7 Worthiness of the EPO proposed environmental action ....................................... 33

8 Acknowledgement .............................................................................................. 38

Annex 1 Mentoring activities for EPO questionnaire - ARSVOM ................................ 39

[Feasibility Study for the Port of Constanta] [August 2014] page 1

Summary 1This study aims to provide to ARSVOM port operator, recommendations and scientific

information regarding the environmental aspects, either directly or indirectly influenced by the

operator specific activities, in order to comply with environmental standards. It is designed to

analyze the technical/technological, and socio – economical capability of ARSVOM to further

proceed on the way of environmental certification according to ISO 14001. The study

comprises also a risk assessment based on the chain analysis of the activities and processes

involved and evaluates the alternatives and solutions for overcoming the gaps identified at the

organizational, managerial and technological level in order to decrease the environmental

impact generated by the carried out activities.

[Feasibility Study for the Port of Constanta] [August 2014] page 2

Description of Constanta port 2

The Port of Constanta (Fig. 1) is located on the Western coast of the Black Sea, at 179 NM

from the Bosphorus Strait and 85 NM from the Sulina Branch, through which the Danube flows

into the sea. The present length of the North breakwater is 8.344 m and the South breakwater

is 5.560 m. Constanta Port has a handling capacity of over 100 million tons per year and 156

berths, of which 140 berths are operational. The total quay length is 29.83 km, and the depths

range between 8 and 19 meters.

It is located at the crossroads of the trade routes linking the markets of the landlocked

countries from Central and Eastern Europe with the Transcaucasus, Central Asia and the Far

East. The favourable geographical position and the importance of the Port of Constanta is

emphasized by the connection with two Pan-European Transport Corridors: Corridor VII –

Danube (inland waterway) and Corridor IV (rail-road). The two satellite ports Midia and

Mangalia that are located not far from Constanta Port are part of the Romanian maritime port

system under the Maritime Ports Administration SA Constanta coordination.

2.1 Constanta port organizational structure

The Administration plays the role of Port Authority within the ports of which infrastructure has

been granted by the Ministry of Transports and Infrastructure, the commercial maritime ports

Constanta, Midia, Mangalia and Tomis, respectively.

2.2 Superstructure and infrastructure

The Port of Constanta is one of the main distribution centers for the Central and Eastern

Europe. The main characteristics are:

• Total area: 3,926 ha out of which 1,313 ha is land and the rest of 2,613 ha is water

• Total quay length: 29.83 km

• Depths range: 8 - 19 meters

• Handling capacity: > 100 million tons per year

• 156 berths, out of which 140 berths are operational

• 7 terminals (Liquid bulk, Dry bulk, Containers, Break bulk, Ro-Ro/Ferry, Passengers,

barges and river tugs, LPG Terminal)

• Accommodate tankers with capacity of 165,000 dwt and bulk carriers of 220,000

dwt.

[Feasibility Study for the Port of Constanta] [August 2014] page 3

Fig. 1 The Port of Constanta layout

The protection of the environment represents a permanent concern developed both in

defining and achieving of clear objectives/strategies regarding environment aspects and in

lining up with EU practices and standards in the field. Quality parameters of inland port waters

are permanently monitored by several authorities (Port Administration, National Institute

Grigore Antipa, National Company Romanian Waters Dobrogea Litoral in respect with national

and international laws and norms.

Port Administration insures the installations and logistic for intervention in case of

pollution. Works in the Romanian seaport basins, dredging works included, can be performed

under the legal provisions in force, only after their previous authorization by the Port

Administration, that shall be given according to Romanian maritime ports’ development and

maintenance plans.

Following the provisions of the Strategic Plan for Waste Management, Maritime Ports

Administration S.A. Constanta launched in 2001 the project named: “Environment and

Infrastructure in Constanta Port”.

The cooperation with the Dutch company Royal Haskoning consisted in a pilot project,

dedicated to the treatment of the oily waste collected from the ships calling the Port of

Constanta. The treatment plant is in function from 2001 and represents a good example of

technology and equipment needed for oily waste treatment.

[Feasibility Study for the Port of Constanta] [August 2014] page 4

The Administration also put in function the following objectives:

• an ecological landfill for solid waste and garbage

• an incinerator for sanitary waste and contaminated ship residues

• multipurpose vessel used for marine pollution fighting

Residuals and mixed hydrocarbons from the ships are temporary stocked in non-

propelled barge SN 101 where they are gravitational separated through successive transfer

between barge’s compartments. A treating station is projected for the depuration of waters

with hydrocarbons residuals through physical, chemical and biological treatments, having a

capacity of 814,000 mc/year. At the end of treatment process, the effluent is discarded into

the port area. The quality of the effluent is periodically verified in respect of legally ranged

limits through laboratory analyses, performed by specialized laboratories. After neutralizing

and filtration through press-filter, the sludge is evacuated to the dumping site. The delivery of

bilge waters and of the oil residuals from the ships is insured in the maritime ports by the port

administration – Technical Ships Port Branch.

Residuals and hydrocarbons mixture collected from the ships are temporarily stocked into

a compartmented tank with a total capacity of 970 mc. Domestic waste and garbage removal

from the economic port agents is made by specialized economic entities (S.C. Consal Trade

SRL – Port Branch) for carrying on this activity in the Romanian maritime ports, which

concluded a contract with the port administration for such services performance.

Each vessel arrived in port, is compelled to collect the domestic waste in containers or

plastic bags, according to the provision of the MARPOL Convention, ANNEX 5. Works in the

Romanian seaport basins, dredging works included, can be performed under the legal

provisions in force, only after their previous authorization by the Port Administration, that shall

be given according to Romanian maritime ports’ development and maintenance plans. In

Romanian seaports the Port Administration organizes and performs the entire hydrographical

survey activity necessary to the use of the port basin by the vessels.

2.3 Romanian Naval Authority (RNA)

Romanian Naval Authority is the specialized technical body subordinated to the Ministry of

Transports through which the latter exerts its function as a state authority in the field of

safety of navigation.

Romanian Naval Authority is a self-financed executive agency, with legal personality,

having its headquarters in Constanta Port, established by merging the Civil Navigation

Inspectorate and the Romanian Register of Shipping. As a result of the merger, RNA took over

the rights and obligations of both corporate bodies, which consequently were dissolved.

[Feasibility Study for the Port of Constanta] [August 2014] page 5

Main tasks of the Romanian Naval Authority have been defined as follows:

• inspection, control and surveillance of navigation in Romanian maritime waters and

inland waterways;

• fulfilment of the obligations assumed from the international agreements and

conventions to which Romania is part of;

• implementation of international rules, regulations and conventions into the Romanian

legislation;

• Port State Control and Flag State Control;

• coordination of search and rescue activities in the Romanian navigable waters and of

the actions to be taken in case of navigation accidents and casualties;

• protection of navigable waters against pollution by vessels and coordination of the

pollution response;

• sanctioning of the contraventions and investigation of the navigation accidents and

casualties;

• ships’ registration;

• registration, endorsing and certification of the Romanian seafarers;

• technical surveillance and certification of maritime and inland water ships, offshore

drilling units flying the Romanian flag and of naval equipment, as per RNA

regulations;

• supervising the compliance of the Romanian naval transports with the provisions of

the ISM and ISPS Codes.

Romanian Naval Authority exerts its tasks through its own central unit, through the

harbours master’s offices and technical inspectorates - its operative subsidiaries without legal

personality. The jurisdiction areas of the operative subsidiaries has been settled by the

General Director and approved by RNA’s Managing Board.

The management of Romanian Naval Authority is ensured by the Managing Board,

consisting of 7 members leaded by a President, being also the RNA’s General Director.

SAR – POLLUTION DEPARTMENT

To meet and apply the requirements set in the International Conventions SOLAS/1974,

SAR/1979, MARPOL 1973/1978, CLC ’92, BUNKERS 2001 and OPRC 1990, and set in the EU

relevant legislation for marine environment protection, Romanian Naval Authority has been

legally appointed as the responsible authority to perform the management and mission co-

ordination for SAR and Oil Pollution Response activities within the area under Romanian

responsibility, though SAR - Pollution Department, 24 h/day.

SAR-Pollution Department has been designated as national operational contact point

(NOCP), according to the National Contingency Plan for Oil and HNS Pollutions.

[Feasibility Study for the Port of Constanta] [August 2014] page 6

As an obligation of EU coastal member states, Romania through RNA - SAR-Pollution

Department, performs the application of the CleanSeaNet service, which is a satellite based

monitoring system for marine oil spill detection, tracing and surveillance by checking on scene

the satellite images.

SAR - Pollution Department is connected also at SafeSeaNet (SSN) System for port and

alert notifications. SSN consists essentially of setting up an electronic network between the

maritime administrations of the member states in order to facilitate the implementation of EU

maritime safety aspects.

In addition, SAR - Pollution Department is connected to the GISIS database, which is a

Global Integrated Shipping Information System of the International Maritime Organization, for

introducing all information regarding port reception facilities, SAR and pollution incidents and

others.

RNA, through SAR-Pollution Department, fulfils Romanian obligations within the

Consultative Technical Group for Marine Pollution Preparedness and Response within the

European Maritime Safety Agency (EMSA), also within the Advisory Group on Environmental

Safety Aspects of Shipping belonging to The Black Sea Commission, established to ensure

regional coordination to oil pollution emergency response, at regional level.

The responsible personnel for coordinating SAR activities and response to marine

pollution, is specialized personnel having necessary knowledge about the equipment and

means of intervention using them, including locations and is able to coordinate in close

collaboration with the other appropriate national and international organizations from the

Black Sea region.

The training and the exercises are carried out at regular periods, in order to improve the

efficiency of personnel and for maintaining a high level of the response coordination to SAR

and pollution incidents.

[Feasibility Study for the Port of Constanta] [August 2014] page 7

Chosen EPO (External Port Operator) description 3

A meeting, organized within TEN ECOPORT project, with the scope of “counseling the port

operators in regard of the implementation of an Environmental Management System”, took

place on 21.05.2014 at Romanian Naval Authority (RNA) premises. A number of port operators

involved in the ship generated waste reception activities were invited to attend the meeting:

CONSAL TRADE SRL, OIL TERMINAL), CN APMC SA, ARSVOM, GeoEcoMar. Oil Terminal was

the only one not attending the meeting.

Two of the invited companies, OIL TERMINAL and ARSVOM, do not have in place EMS

certification. RNA presented its reasons for considering ARSVOM as optimal candidate for the

drafting of the feasibility study in view of implementing an EMS, in accordance with activity

5.1. of TEN ECOPORT project.

Mr. Iulian Cretu, operational manager of ARSVOM, expressed the management

acceptance for cooperation in view of drafting the feasibility study, which was considered very

useful as there is the intention of near future certification, taking into account the fact that the

operational area of ARSVOM ships will be extended as a result of starting the Black Sea

operations.

He also confirmed that ARSVOM will cooperate with GEOECOMAR to fulfil this objective,

by nominating a person in charge of providing the necessary data, presenting the ships, their

equipment and production processes.

ARSVOM representatives then filled in the questionnaire “Mentoring activities for EPO

questionnaire” and submitted it to GEOECOMAR representatives, a close relation going to be

maintained between ARSVOM, GEOECOMAR and RNA for drafting this feasibility study

preceding the Environmental Management System certification.

The Romanian Agency for Rescue of Human Life at Sea - ARSVOM, is a public institution

with legal personality stated through the G.O. no. 33/2004, approved by the Law no.

337/2004 with modifications and completions.

ARSVOM is the technical specialized body subordinated to the Romanian Ministry of

Transports, by which the latter exerts the activity of search and rescue of human life at sea

and pollution response.

General Data:

Name of company, address, phone, fax.

ARSVOM, Constanta Port, Berth 78;

Phone/Fax: +40 241 616111; +40 241 488226; +40 241 488227

E-mail: [email protected]; Web: www.arsvom.ro

[Feasibility Study for the Port of Constanta] [August 2014] page 8

Location of the Agency within Constanta Port and its surroundings are presented in Fig. 2

and 3.

ARSVOM is located in the vicinity of the oil tanker terminal, Oil Terminal, consisting of 7

operative berths, this fact increasing the need of taking higher prevention measures against

the risks of oil/noxious substances spills or fire (Fig. 3).

Fig. 2 ARSVOM location

[Feasibility Study for the Port of Constanta] [August 2014] page 9

Fig. 3 ARSVOM location and neighbors within the Northern Part of Constanta Port

(source: Google Earth, elevation 2.73 km)

ARSVOM main responsibilities:

a) Carries out the obligations assumed from the international agreements and

conventions to which Romania is a party, in respect of search and rescue of human

life at sea;

b) Fulfils the tasks foreseen in the National Plan of Preparedness, Response and

Cooperation in case of marine pollution;

c) Intervenes in case of pollution events;

d) Performs, on contractual basis, according to Law no. 337/2004, the following

services:

• Search, assistance and rescue activities;

• Refloating of ships and wrecks removal;

• Diving services;

• Internal towage in accordance with specific activities;

• Firefighting;

• Ice breaking within the harbour and on navigable waterways.

[Feasibility Study for the Port of Constanta] [August 2014] page 10

3.1 ARSVOM organizational scheme

ARSVOM has 3 main departments (Fig. 4):

• The Operational Department: comprising the dispatcher, the ships group, the divers

group, the decontamination area and the technical branch

• The Juridical Department

• The Internal Public Audit Office and Technical Department

• Financial - Economical Department

Number of posts: 133

Managerial posts: 5

Fig. 4 ARSVOM organizational scheme

[Feasibility Study for the Port of Constanta] [August 2014] page 11

3.2 Technical capacity

a) Vessels for operations

Table 1 Vessels for operations

Type and

ship name Capacity

Year of

building/

Shipyard

Max.

Length

(m)

Max.

Width

(m)

Max.

Sea

gauge

(m)

GRT Main

engine

Engine

type

MULTI – FUNCTIONAL TUG

HERCULES 50 tf at

hook

1988

Braila

Romania

68.5 16.5 6.5 388 2x3300 HP 6L40/

54A

ASSISTANCE CRAFTS

SORANA 1 13 persons 1990/Ribinsk

URSS 12.56 3.06 0.83 1x150 HP

3D6SP

15/18

SORANA 2 13 persons 1990/Ribinsk

URSS 12.56 3.06 0.83 1x150 HP

3D6SP

15/18

SORANA 3 13 persons 1990/Ribinsk

URSS 12.56 3.06 0.83 1x150 HP

3D6SP

15/18

SATURN 13 persons 1981/Ribinsk

URSS 12.61 2.86 0.62 1x150 HP 3D6 C

JUPITER 13 persons 1981/Ribinsk

URSS 12.61 2.86 0.62 1x150 HP

3D6SP

15/18

SEARCH AND RESCUE CRAFTS

OPAL 25 persons

2002/Tyove

ne OY

Finlanda

15.3 4.20 0.65 2x410 HP SCANIA 9

DSI 55M

TOPAZ 25 persons

2003/Tyove

ne OY

Finlanda

15.3 4.20 0.65 2x410 HP SCANIA 9

DSI 55M

ALBATROS 24 persons

2001

Mangalia,

Romania

17.63 5.11 1.6 6 2x420 HP

CATERPIL

LAR 3126

DITA

INTERVENTION CRAFTS

CRISTAL 14 persons

2002

Mangalia,

Romania

18.7 4.95 1.5 4

6 2x430 HP

VOLVO

TAMD74C

-B 2071

SAFIR 14 persons

2002

Mangalia

Romania

18.7 4.95 1.5 4

6 2x430 HP

VOLVO

TAMD74C

-B 2071

RUBIN 14 persons

2002

Mangalia

Romania

18.7 4.95 1.5 4

6 2x430 HP

VOLVO

TAMD74C

-B 2071

[Feasibility Study for the Port of Constanta] [August 2014] page 12

b) Pollution response equipment

During 2001 ARSVOM was the beneficiary of the RO-0107.12 project – Improvement of

maritime and inland navigable channels safety financed within the PHARE 2001 National

Programme. According to the European Union recommendations, the following pollution

response equipment has been purchased:

• Pollution response booms curtain type (1700 m for the sea and 1000 m for the port)

and floating type (3300 m for the sea and 2000 m for the port);

• 7 pumps for hydrocarbons recovery (5 pieces of 20 cm/h and 2 pieces of 130 cm/h

capacity);

• 10 portable tanks for temporary storage of recovered hydrocarbons of 25 cm each.

• Facilities for deposit and decontamination of equipment used and the level of

compliance with environmental regulations.

c) Area of decontamination

According to the International Convention on Oil Pollution Preparedness, Response and

Co-operation (OPRC), 1990, any pollution response operation is considered fulfilled only after

performing the equipment decontamination procedures. Therefore, ARSVOM has organized a

decontamination area for the pollution response equipment.

The decontamination area comprises the following:

1. Washing hall for contaminated equipment

The building is disposed on one level floor.

The building is split in:

- decontamination hall;

- cloakroom;

- Toilet and shower.

2. Storage platform for contaminated equipment from sea

It has a built surface of 270 sqm, and the platform floor is coated with sea water proof

material, mainly in respect of sulphate actions.

The platform has a metal structure with supporting pillars. The metal structure is

protected from sea water corrosive action by painting with primer and paint protective.

The platform for removing contaminated equipment from the sea is composed of several

parts:

• Contaminated equipment removal area;

• Temporary storage of contaminated equipment from sea, until their placement into

the washing hall

• Collector drain for the contaminated waters resulted from the washing process.

The whole metallic structure is fire proof, coated with multi layers special paint.

[Feasibility Study for the Port of Constanta] [August 2014] page 13

3. Segregation area for oil residues resulted from the contaminated washing

water

It has a built area of 150.00 sqm and has at the facility limit a concrete upstanding of

200 mm, to prevent the sewage collected from the device surface to migrate and contaminate

the adjacent areas with oil residues.

The segregation system consists of a three compartment tank and an AWAS (Q=30l/s)

type segregator which guarantees the conformity of the treated water that can be recycled

(returned to the washing circuit) or directly discharged in the domestic drainage, with the

NTPA 001/2005 limits.

Apart from the AWAS segregator the following are in place: sampling tank and manhole

with valves for directing the treated water to the recirculation tank or the sump.

Technological Flux

First of all we have the platform for removing contaminated equipment from the sea. The

equipment removal is done using monorail beams with electric chain hoists. The equipment is

removed transversally to the position of the hall and its related washing area.

After sea removal, the equipment is placed at the entry zone of the washing and oil

residues removal hall. From the hall entry zone, the equipment used for pollution response are

taken and placed on a metallic structure with adjustable wheels, to ease the handling of

equipment during wash. The hall is 30 m long, which is enough to accommodate a large part of

segments of each type of depolluting equipment that ARSVOM owns. Placing the contaminated

equipment inside the hall adjacent to the platform used for their removal from sea is done

using electric chain hoists. If the contaminated equipment from the washing area are kept

longer under washing operations due to high contamination, the sea removal operations can

continue as the platform for removal of contaminated equipment has a storage area, where

these can be safely stored until placing them into the washing hall.

The washing area inside the hall, where the pollution response contaminated equipment

are taken, is 3.00 m wide, this making possible for introducing any type of equipment on two

rows, on the entire length of the washing area.

Therefore, four segments of port booms curtain type or open sea booms curtain type can

be simultaneously introduced, totalising 60 m, quantity that can be washed in the same time.

The port and open sea booms curtain type are handled inside the hall, alongside the metallic

structure with wheels, using electric winches of 0.5 tf, with metal wires.

The washing of inflatable port barriers, RO-CLEAN type, is done using hydraulic drums.

The skimmer pumps are cleaned of oil, after their removal and placement inside the platform

for the removal of depollution equipment, through pressure washing equipment using hot

water to clean them in the shortest time possible. Sea removal of barriers, pumps and portable

[Feasibility Study for the Port of Constanta] [August 2014] page 14

tanks for oil storage is done using monorail beams with electric chain hoists, for better

handling operations.

The oil contaminated equipment washing hall is composed, besides the washing area, of an

area where the washing technological equipment is stored (under pressure systems, hot water

tanks, distribution switchboard and an administrative area, with an office, a shower and toilet).

After removing the equipment from the washing area inside the hall, it is stored in the

area for decontaminated equipment, from where they are transported into the storage area or

part of them released back into the sea.

The contaminated equipment washing hall is provided on the seaward side, with a

collector drain for the contaminated waters resulted from the washing process.

This drain is connected to the drain in the area of the platform for removal of

contaminated equipment from sea, and is continued up to the area of segregation of oil

residues from the water used in the washing process. The washing of the contaminated

equipment is done using biodegradable detergent, posing no harm to the environment and

having the approval of European Union specialised institutions.

The oil contaminated water will be directed, by drainage segments and collecting drains,

towards a segregation system in compliance with NTPA 001/2005, namely under 5mg/l oil

residue in the treated water.

The segregation system consists of a three compartment tank and an AWAS (Q=30l/s)

type segregator which guarantees the conformity of the treated water that can be recycled

(returned to the washing circuit) or directly discharged in the domestic drainage, with the

NTPA 001/2005 limits. Apart from the AWAS segregator the following are in place: sampling

tank and manhole with valves for directing the treated water to the recirculation tank or the

domestic existing drainage.

The segregation of oil from the water used in the washing of contaminated equipment is

located at one end of the actual decontamination area and is at about 1.00m lower field level

than the rest of the installation. This offers the possibility of installing equipment in the

separation zone at ground level while ensuring a slope for the drain pipes and collectors for

sewage reception. The equipment used in the segregation process of oil from oil contaminated

waters, collected from the washing process are advanced equipment used worldwide for

processes of this type, and waters resulted from the separation process can be discharged into

the domestic drainage system without posing any danger to the environment.

Washing water will be provided through an ø3 „joint (HDPE-PN 6) of the existing pipe,

equipped with manhole with closing valve before entering the decontamination area of

contaminated equipment. Connection to existing water pipe is done in the area of ARSVOM office.

The drainage systems provide separate collection of domestic sewage flows, polluted

sewage, potentially polluted rainwater and clean conventional water (Fig. 5).

[Feasibility Study for the Port of Constanta] [August 2014] page 15

Fig. 5 Technological flux – decontamination area

[Feasibility Study for the Port of Constanta] [August 2014] page 16

3.3 Legal and operational framework to carry out the activities of search, rescue and pollution response

The National Plan for Preparedness, Response and Cooperation in case of Marine Oil

Pollution and other harmful noxious substances (The Contingency Plan) is the

operational document which states the activities performed by RNA and ARSVOM.

It stipulates the mandatory necessary steps agreed also at the regional level for:

a) Planning the intervention, which includes assessment of: • Possible sources of oil products pollution, vulnerable resources and priorities for

protection;

• Resources allocated for intervention in case of accidental pollutions, available at

national scale;

• Rules regarding the use of dispersant agents;

• National regulations regarding the elimination of oil residues;

• Logistic support available.

b) Strategy of intervention

The main strategy of intervention foreseen by the Contingency Plan applied by the

operational authorities during interventions related to accidental pollution of marine

environment consists of:

Evaluation of accident severity, at least the following factors being taken into

consideration:

• The area where the accident occurred;

• The type of pollutant/pollution;

• The amount of spilled pollutant or the potential spillage;

• The possibility to transport the pollutant;

• The risk level for the human life and/or the risk for the health;

• Risk of fire/explosion;

• Toxicity of spilled pollutant;

• Potential impact on natural resources;

• Potential impact on building and other valuable assets;

• Activation of the Contingency Plan and notification of contracting parties;

• Selection of adequate methods of intervention;

• Evaluation of available resources for intervention;

• Activation of plan and request of assistance;

• Implementation of methods of intervention;

• Re-evaluation of the situation and adjustment of the Contingency Plan;

• Deactivation of the Plan after concluding the intervention.

[Feasibility Study for the Port of Constanta] [August 2014] page 17

Waste Management Plan applied to the ships belonging to ARSVOM

The Plan elaborated in 2013 is pending approval from RNA and the Agency of

Environmental Protection.

It comprises the legislative, technical and practical information regarding ARSVOM

obligations assumed by Romania in the field of safety of navigation and protection against

pollution.

Thus, the Plan aims to establish the framework which regulates the management of ship

generated waste and waste resulted from ARSVOM main field of activity.

The Plan was conceived in accordance with the obligations provided by the European

Directive 2000/59/EC transposed into the Romanian legislation through Government Ordinance

no. 20/2012 regarding port reception facilities for ship-generated waste and cargo residues.

The legislative framework covering ARSVOM’s obligation to implement a

Management Plan for ships generated waste is:

Laws for environmental and waters protection

• Emergency Government Ordinance no.195/2005, on environmental protection, in its

updated consolidated version from 03.12.2008.

• Waters law no.107/1996, in its updated consolidated version from 19.02.2010.

Laws regarding waste management

• Government Ordinance no. 20/23/08/2012, on port reception facilities for ship

generated waste and cargo residues;

• Law no. 211/2011, regarding the waste management regime;

• Government Decision no. 856/2002, regarding waste management and for the

approval of list comprising waste, including dangerous waste;

• Government Decision no. 349/2005, regarding the waste deposit, in its updated

consolidated version from 22.12.2010;

• Government Decision no. 235/2007, regarding the management of used oils;

• Government Decision no. 1037/2010, regarding the electric and electronic equipment

waste;

• Law no. 132/2010 regarding the selective collection of waste in public institutions. Laws regarding the authorization of naval transport activities

• Ministry of Transport, Housing and Public Works Order no. 287/2003 regarding the

authorization of naval transport activities, with subsequent modifications and

completions. Local regulations

• Regulation concerning Romanian Maritime Ports Operations (approved by the

Ministry of Transport, Housing and Public Works Ministry Order no. 956/23.06.2003)

[Feasibility Study for the Port of Constanta] [August 2014] page 18

Authorizations

• Environmental Authorization released by Environmental Protection Agency Constanta

no. 392/28.09.2009, valid 28.09.2014.

3.4 Assessment of pollution sources generated by ARSVOM

Types of ship generated waste in possession and operated by ARSVOM

• hydrocarbons (oil, mixed and oily residuals)

• bilge water

• sludge/used oil

• oily residuals from tanks washing

• cargo residues from oil tankers

• oil contaminated ballast water

Ships sewage

• sewage from toilets

• sewage from kitchens, washing room, medical rooms

Ship generated waste

• food waste

• domestic waste

Waste from ships exploitation (operational):

• Cargo associated waste – the materials used for binding, packing, wrapping or

protecting the goods (cardboard or wood pack, ropes, girths, wires, cables) on board

which were removed;

• Maintenance waste - the materials used for ship’s maintenance/functioning by the

deck and machines department, including electric and electronic waste;

• Cargo residues – represents residues from the warehouses and tanks eliminated at

the end of unloading and cleaning operations, including surplus and outflows

appeared during loading/unloading operations;

• Contaminated water resulted during the decontamination of floating response

pollution booms.

The regime of wastes mentioned above are included in the general category of

”WASTE”, and identified in the Waste Record Book according to subcategories of waste

stipulated in the MARPOL Annexes (Annex V).

A. Plastics

B. Food waste

C. Domestic waste (paper products, rags, glass, metal, dishes, etc.)

[Feasibility Study for the Port of Constanta] [August 2014] page 19

D. Fried oil

E. Incinerator ashes

F. Operational waste

G. Loading waste

H. Animals carcasses

I. Fishing gears

3.5 Collecting and recording of ARSVOM ship generated waste, according to the Waste Management Plan

Collecting the ship generated waste and cargo residues can be done directly by the port

administration or by different economical agents, according to the national legislation in force

and under the port administration supervision.

The port authority ensures the legal working framework for the port waste operators, by

issuing adequate working licenses. Moreover, the waste operators should be authorized for

the waste collecting activities by the local environment authority – The Environmental

Protection Agency.

ARSVOM has the obligation to draw up and implement a plan for reception and

collecting of waste and residues generated by their own ships. Therefore, the

Romanian Naval Authority recommended to ARSVOM to review the actual Plan, otherwise

this cannot be considered valid and in line with regulations stipulated by legislation on waste

management.

The schemes of actual system of collecting and hand over of waste generated

by ships are presented below: 1. Domestic waste:

Each ship is required to selectively collect domestic waste in containers and plastic bags,

according to regulations in force and international conventions regarding this activity, to which

Romania is a party.

Domestic waste generated by ARSVOM vessels/crafts: Crystal, Sapphire, Ruby, Topaz,

Opal, Albatros, Saturn, Jupiter, Sorana1, Sorana2, and Sorana3 are delivered to Hercules ship

under a reception bill. The waste quantities are recorded in the logbook of each vessel.

The waste delivering from the Hercules ship to S.C. IRIDEX GROUP IMP EXP BUCHAREST

SRL - COSTINESTI BRANCH is done once a week.

After the delivering operation, a confirmation voucher waste collection it’s being released,

to the person designated by ARSVOM.

If the ship leaves the port, is required to deliver the entire quantity of waste on board, to

the port facilities and to prove this operation.

Recording/registering

[Feasibility Study for the Port of Constanta] [August 2014] page 20

After the delivering operation, a reception residues and waste collection bill is being

released (Fig. 6) to the person designated by ARSVOM.

Bills and invoices are monthly centralized in the Management, Strategy and Environment

Department.

Fig. 6 Administrative headquarters and ship generated waste delivering process

2. Oil residues, sewage and liquid cargo residues:

Reception of oil, sewage and liquid cargo residues from ARSVOM ships is performed by

the Technical Port Ship Department within port administration.

Recording/registering of oil residues

The quantity of oil residues generated by ARSVOM ships is evidenced in the Reception Bill

issued by the representatives of the Port Administration - Technical Port Ships Department.

The information is centralized according to the standard model stipulated in the Government

Decision no. 856/2002, regarding the waste administration and approval of the waste list,

including the dangerous ones (Fig. 7).

Delivering procedures for domestic wastes resulted from offices

and motorboats

Collecting ship Constanta Port Administration

Residues reception bill

Firm order Management, environment and strategy Department

Order confirmation

Constanta Port Administration

Order confirmation

ARSVOM ships

Oil residues delivery request

Shifting

[Feasibility Study for the Port of Constanta] [August 2014] page 21

Fig. 7 Oil residues, sewage and liquid cargo residues delivery scheme

3.6 Accounting of the ARSVOM ship generated waste

Analysing the evidence of waste generated by ARSVOM ships in the last three years (Table 2),

there has been a decrease of almost 4 times the amount of municipal waste generated in 2014

compared to 2012 (Fig. 8). Regarding bilge oils, there has been a significant decrease in the

quantities generated and thus handed over for recovery, compared to 2013. According to the

Environmental Protection Agency reports, all kinds of waste generated are delivered to the

specialized companies in recycling / recovery materials / recyclable materials, action outlined

in the ARSVOM management in the codes that describe each type of recovery action, provided

by the Government Decision no. 856/2002.

Delivering procedures for domestic wastes resulted from offices

and motorboats

Collecting ship Constanta Port Administration

Residues reception bill

Firm order Management, environment and strategy Department

Order confirmation

Constanta Port Administration

Order confirmation

ARSVOM ships

Oil residues delivery request

Shifting

[Feasibility Study for the Port of Constanta] [August 2014] page 22

Table 2 Waste accounting 2012-2014

Crt. No. Waste

2012 2013 2014

Generated quantity

Recovered quantity

Generated quantity

Recovered quantity

Generated quantity

Recovered quantity

1. Bilge oils 15.600 15.600 65.100 65.100 14.400 14.400

2. Used oil 0.393 0.393 0.215 0.215 0.866 0.866

3. Lead batteries 0.200 0.200 0.300 0.300 0.061 0.061

4. Discarded tires 0.000 0.000 0.000 0.000 0.000 0.000

5. Paper and cardboard 0.600 0.600 0.280 0.280 0.120 0.120

6. Plastics 0.060 0.060 0.060 0.060 0.004 0.004

7. Iron and steel 0.181 0.008 0.254 0.000 0.000 0.000

8. Copper, bronze brass 0.009 0.009 0.000 0.000 0.000 0.000

9. Public common mixed waste 154.960 154.960 93.680 93.680 34.020 34.020

Fig. 8 Dynamics of ARSVOM generated and handed over waste in 2012-2014

Authorized institutions to which ARSVOM delivers the generated waste:

National Company “Constanta Port Administration” - Technical Port Ship Department

- Oil waste, including cargo residues collecting services.

- Sewage collecting services S.C. IRIDEX GROUP IMP EXP BUCHAREST SRL - COSTINESTI BRANCH

- Collection, transport and storage of wastes generated from trade, industry and

companies, debris and other constructions generated waste.

5 25 45 65 85 105 125 145 165 185

Generated quantity

Recovered quantity

Generated quantity

Recovered quantity

Generated quantity

Recovered quantity

2012

2013

2014

Bilge oils Used oil Lead batteriesPaper and cardboard Plastics Iron and steelCopper, bronze brass Public common mixed waste

[Feasibility Study for the Port of Constanta] [August 2014] page 23

EPO risk assessment (RA) 4

Risk is defined as the possibility of occurrence of an event that affects negatively the

organization's objectives. Environmental Risk Assessment (ERA) represents an estimate of the

likelihood or probability of an adverse impact on the environment resulting from human

activities. At the heart of RA is an assessment of the interactions between management

regimes and environmental values. The assessment and reporting of risk to environmental

values can then be used to identify risk reduction strategies. Subsequent revisions to

management plans and actions will then —hopefully— be undertaken to reduce risk.

To assess the potential environmental risk associated with major activities and processes

performed within ARSVOM, we analyzed the most probable causes that may lead to negative

effects on key environmental issues (Table 3). These were then evaluated based on the

severity of the effects they may have on the environment, the community and the socio –

economic activities (Table 4). To get a more complete picture of potential risks from ARSVOM,

the information from the questionnaire filled in on 05.21.2014 at the Romanian Naval

Authority (RNA) premises was analyzed (Annex no. 1 "Feasibility Study for the Port of

Constanta"), and also the information out of the interview conducted on 07/08/2014, with one

ARSVOM managers, Mr. Cretu Julian - Operations Director).

In Table 5, the resulting matrix is given by crossing the environmental aspects with

possible effects caused by polluting sources within ARSVOM, the colors of each box

representing the cumulative risk level generated by their impact on the three components

(human, environmental, socio - economic). It also presented the risk associated with these

activities in emergency situations, such as serious accidents or natural hazards. It is obvious

that the potential risks exist in nearly all activities performed by ARSVOM, therefore it is recommended that specific procedures have to be drafted for each activity, in which to highlight environmental issues potentially affected and operational control and monitoring methods.

[Feasibility Study for the Port of Constanta] [August 2014] page 24

Table 3 Environmental Aspects

Aspects, According to Annex A, ISO 14001:2004

Activity/ Process

Specific environmental aspects for Activity/Process Impacts on the environment Observations

Air Ships operation Air pollution caused by burning of diesel oil and operation of diesel

generator in port

Greenhouse effects (CO2, CO, SOx, NOx)

Fuels and electrical power high consumption due to old age of ships and speed crafts

Soil

Equipment Decontamination

Soil pollution caused by accidental leakage of water contaminated with

hydrocarbons Degradation of soil quality

In cases of improper operation of equipment or

soil protection Storage of wastes contaminated with

dangerous substances

Soil pollution due to storage of hazardous substances (PPE, rags, waste from booms/barriers etc.)

Degradation of soil quality In cases of improper handling and storage of waste

Water

Ships operation

Pollution during reception of bilge oils, cargo residues, sewage

Physical -chemical and biological pollution Accidental pollution leaking due to improper operation

Ships operation (Bilge, sewage system)

Sea water contamination with bilge water Biological contamination of water Segregation rate under 15ppm,

inadequate to MARPOL rules (for bilge system) Bunkering

Water pollution caused by leakage

of fuel Generating sea water toxic/harmful

components Accidental pollution leaking due to improper

operation Transport of

contaminated materials Oil mixtures Water pollution with oil mixtures, dispersion of spill

Accidental pollution leaking due to improper operation

Equipment Decontamination Oil spills from washing operations Sea and drainage system infiltration In cases of improper operation of equipment

and segregator operation failure

Use of raw materials,

electric energy, natural resources

Ships operation

Consumption of fuel and lubricants for operating equipment on board

ship. Electrical power consumption

Raw materials consumption

Poor technical condition of ships (e.g. Hercules) and speed crafts.

Development and compliance of the equipment maintenance / upgrading.

Setting the consumption rates

Decontamination area Fresh water, electrical power consumption Natural resources consumption Setting the consumption rates.

Losses and water quality monitoring Emergency

situations (for e.g. fire, ship’s

collision/sinking)

Ships operation / Bunkering/ Equipment

Decontamination Water, air, soil pollution Water, air, soil contamination

Implementation and compliance with accidental pollution prevention plans

[Feasibility Study for the Port of Constanta] [August 2014] page 25

Table 4 Interpretation of the level of risk by the potential effect on the environment, the community and the socio – economic activities

No. Risk Level Effects

1. Minor For people: Insignificant injury Economical: Insignificant Ecosystem: Some minor adverse effects on some species of flora or fauna or habitats, on short-term and reversible Socio-political: Insignificant social effects without concern for authorities / community.

2. Moderate For people: Medical treatment is required Economical: Temporary decrease of operational activities Ecosystem: Temporary and reversible damage, air quality affected by compounds with potential health risk for long term potential, possible harm to aquatic life, pollution requiring physical treatment, limited contamination of soil and water which can be quickly remedied. Socio-political: Social effects of moderate concern for authorities / community.

3. Major For people: Significant injury/death Economical: Stop of operational activities Ecosystem: Destruction of species of flora, fauna, and long-range permanent contamination of soil, water and air. Socio-political: Social effects of great concern for authorities / community.

Table 5 Risks matrix

Environmental issues/ activities

Bunkering Ships exploitation

Unloading, cleaning of tanks

and warehous

es

Decontamination of

booms

Fuel leakage

Discharge of residual oil and sewage and bilge

water and oil into the water

Sewage leakage/ discharge

Discharge of Food & domestic waste

Cargo residues

Storage/ improper disposal of wastes from maintenance activities

Gas emission exceeding the acceptable limits

Vibrations generating

Fuel consumption exceeding the agreed rates

Cargo residues

Discharge of residual water

Air Soil

Water Energy/water consumption

Emergency situations (ex. fire, earthquake collision/ sinking of ship)

[Feasibility Study for the Port of Constanta] [August 2014] page 26

EPO (the greatest) risk reduction/elimination action 5

In order to increase the efficiency and safety of activities performed and to minimize the

environmental risks and impact it is necessary to:

• Improve the efficiency of the used equipment, especially the ships performance in

order to increase the operability and decrease the intervention time;

• Create special procedures for the strict monitoring of waste fluxes from their

generation until elimination;

• The operational control procedures implementation for significant environmental

aspects (Table 6).

• The review and revision of the Waste Management Plan for ARSVOM ships so that

each ship to deliver the generated waste, according to the current

regulations, as RNA clearly recommended after evaluation of the Plan.

• Currently, the Waste Management Plan must be updated according to the revised

requirements of MARPOL Annex V.

• Reviewing the Garbage Management Plans for vessels over 100 GRT and which are

certified to carry 15 persons on board (e.g. Opal, Albatros) under Rule 10 of the

revised MARPOL Annex V).

• Implementation of environmental monitoring measures according to the

Environmental Permit.

• Renewal of the Environmental Authorization released by the Environmental

Protection Agency Constanta no. 392/28.09.2009, valid 28/09/2014.

[Feasibility Study for the Port of Constanta] [August 2014] page 27

Table 6 Operational control of activities and services, monitoring and measuring of compliance

Environmental issues Activities & services Aspects that effect

the environment Operational control

(including necessary equipment, facilities) Monitoring and measuring

Air Ships operation

Air pollution caused by burning of diesel oil and operation of diesel generator and auxiliary machinery

- Upgrading and refurbishment of marine engines and electrical system; - Planning, revisions and regular technical inspections; - Regular checks of the fuel combustion system and the flue system;

- Compliance with the revisions and technical inspections planning - Compliance with national (Ministerial Order no. 462/1993) and international regulations regarding the gas emissions and the sulfur content of liquid fuels (H.G. 470/2007)

Soil

Equipment Decontamination

Soil pollution caused by accidental

leakage of water contaminated with

hydrocarbons

- Activities development according to the working procedures; - Planning of revisions and regular technical inspections; - Soil protection against infiltrations;

- Compliance with the revisions and technical inspections planning

Storage of wastes contaminated with

dangerous substances

Soil pollution due to storage of hazardous

substances (PPE, rags, waste from

booms/barriers etc.)

- Storage in special places; - The storage area should be accessible ; - The compliance with the storage rules regarding the types of waste stored; - Regular inspections regarding the waste storage; - training of personnel regarding the waste storage; - Waste recording according to G.D 856/2002;

- Waste management recording - Compliance with the Environmental Authorization and Waste Management Plan - Reports towards Authorities

Water

Ships operation

Pollution during

reception of bilge oils, cargo residues,

sewage

- Activity development according to the working procedures; - Waste delivery to the authorized societies;

- Waste management recording - Compliance with the Environmental Authorization and Waste Management Plan - Reports towards Authorities

Ships operation (Bilge, sewage

system)

Sea water contamination with bilge water below

quality norms

- Facilities modernization and refurbishment; - Planning of revisions and regular technical inspections; - Training of personnel regarding the technical maintenance of facilities;

- Water Quality monitoring - Compliance with MARPOL requirements

Bunkering

Water pollution caused by leakage of

fuel

- Performance of activities according to the working procedures; - Deployment of anti – pollution barriers;

- Water Quality monitoring - Compliance with MARPOL requirements

Transport of contaminated materials and

equipment

Leakage of oil - Activity development according to the working procedures; - The compliance with the safety rules regarding the transport of dangerous goods;

- Water Quality monitoring - Waste management recording - Compliance with the Waste Management Plan

[Feasibility Study for the Port of Constanta] [August 2014] page 28

Environmental issues Activities & services Aspects that effect

the environment Operational control

(including necessary equipment, facilities) Monitoring and measuring

Equipment Decontamination

Oil spills from washing operations

- Activity development according to the working procedures; - Protection against oil dispersion and infiltration

- Compliance with the Environmental Authorization - Water Quality monitoring

Use of raw materials,

electric energy, natural resources

Ships operation

Consumption of fuel and lubricants for

operating equipment on board ship.

Electrical power consumption

- Modernization and refurbishment of marine engines and electrical system; - Development and compliance with the equipment maintenance / refurbishment programs. - Planning and revisions and regular technical inspections; - Regular verifications of fuel combustion system, and of the flue system;

-Fuel and electrical power monitoring, checking compliance with consumption rates

Decontamination area Fresh water,

electrical power consumption

- Development and compliance with the maintenance programmes - Water loss and water quality monitoring; - Establishment of standardized consumption.

- Water monitoring, checking compliance with consumption rates - Compliance with the Environmental Authorization

Emergency situations (for e.g. fire, ship’s

collision/sinking)

Ships operation / Bunkering/ Equipment

Decontamination

Water, air, soil pollution

- Implementation of plans for the prevention and response to accidental pollution and compliance;

- Periodical testing of emergency plans; - performance report;

[Feasibility Study for the Port of Constanta] [August 2014] page 29

Human resources, equipment and costs 6

6.1 Human resources and costs

Within ARSVOM, there is settled the Management, Strategy and Environmental Department,

which is responsible for record keeping of generated waste within its activities. In case of EMS

implementation, it is recommended that this Department staff will participate in training

courses in the field of environmental management, for regulatory compliance and

implementation of specific system maintenance actions.

Table 7 Training courses and costs

Training documents Cost [Euro], plus VAT, if applicable

Environmental responsible – waste management course, according to Law no. 211/2011, art. 22, paragraph.3 250

Environmental responsible – environmental responsible training course 250 EMS training (policy, objectives, environmental aspects, management programs, legislation) min. 5 persons =1 500

Total (Euro) 2 000

6.2 New equipment and costs

In order to modernize and increase the ARSVOM activities performance, the Ministry of

Transportation and Infrastructure, through the Technical-Economic Council, has approved

(Notice no. 95/104 / 27.09.2012) as „favorable ", modernizing and upgrading the „Hercules "-

6,600 hp maritime multifunctional tug ice class, upgrades consisting of:

1. Design modernization works

2. class transfer documentation and class transfer

3. Ship docking and specific related works

4. Removal of equipment and systems that require replacement

5. Repairs and structural changes

6. Upgrading works to the unchanged installations

7. New equipment acquisition

8. Mounting of new equipment and installations/modernization

9. Dock and sea trials

The estimated value of “Hercules” tug modernization is about 7.936.000 Euro.

According to the Explanatory Memorandum regarding the necessity and opportunity of

modernization and refurbishment of "Hercules" tug and to the Advising Document, one of the

[Feasibility Study for the Port of Constanta] [August 2014] page 30

advantages conferred by this strategy is that of implied costs which would represent less than

50% of the price of a new vessel, of equivalent class, functions and capabilities.

When drafting the study on refurbishment / upgrading HERCULES ship, maintain all the

current capabilities of the ship and eventually improving them in order to obtain the

accreditation of IACS members’ classification societies, was taken into account.

The study recommends a scenario as high as possible in relation to the available funds, in

the context of oil and gas operation constant development in the Black Sea.

Based on the documentation made available by ARSVOM, including the incomes and

expenditures (Budget of public institutions partly financed from own revenues for the years

2013 to 2017), it seems that the necessary resources have been allocated for the upgrading

and refurbishing of the "Hercules" maritime multifunctional class ice tug - 6,600 hp.

The upgrading / refurbishment carried out will lead to improved environmental indicators

in relation to the current situation, in which many environmental issues observed are related

with the very poor technical performance of the "Hercules" tug.

Thus, the modernization in view of environmental protection provides, inter alia:

• Replacing of the ship engines, which now have a consumption rate of 170-190 g / hp

/ h, compared to latest technology engines consumption that is between 140-160 g /

hp / h, while enhancing environmental indicators: "flue gas releases", "vibration and

noise emitted" (by changing the generating system which also works with high

vibrations);

• it is proposed the use of marine diesel oil instead of heavy oil (HFO);

• redesign of the bilge installation (the replacement of bilge separator), which must

comply with the new limits regarding the purity of the water discharged overboard;

• the replacement of the feces disintegrator and sewage collection facilities;

• the ship’s equipment with an anti-collision radar and AIS tracking and radio

identification system, according to SOLAS;

• installation of a sewage collection tank (non - existent at the moment);

• increasing the number of pollution response equipment (dam, skimmer, buoyant

tank).

"Hercules" tug carries out search and rescue of human life at sea, rescue and towing

ships in distress and depollution operations, being requested over time to perform icebreaking

operations. This is one of the 2 ships built in Romania in 1989.

The ship cannot be used for domestic or international towage and was not required to be

rented due to low reliability, high consumption of fuel and oil, unfit for safety navigation, fairly

large crew.

[Feasibility Study for the Port of Constanta] [August 2014] page 31

Modernization opportunity

By the time the ship will be modernized, ensuring high reliability and navigation safety it

will be able to perform search and rescue activities of human life at sea, rescue ships in

distress, icebreaking, and other necessary activities for maritime safety faster and with

reduced costs.

Upon completion of modernization works, better operating parameters will be obtained

such as:

• facilities high reliability;

• enhanced safety navigation;

• a decrease in consumption of fuels and lubricants;

• a decrease of emissions, noise and vibration;

• a maximum reduction of the accidental pollution possibilities;

• increasing of ship’s competitiveness through increasing the ship’s operation safety,

reducing consumption;

• lower overall costs

Currently, ARSVOM aims at:

• bringing the ship in accordance with the latest applicable rules and regulations;

• transfer of the ship from the RNA supervision under the supervision of IACS member

classification societies with branches in Romania.

Based on the current situation and considering the ship’s desired functionality, relevant

class notations are proposed in accordance with class symbol under BUREAU VERITAS - RULES

FOR THE SHIPS-2011 CLASIFFICATION OH SHIPS – 2011.

The class symbol describes the ship’s functions and equipment.

There are described three upgrading / refurbishment scenarios (Table 7):

• minimal scenario, absolutely necessary for giving the required capabilities for the

reinstatement in the minimum requirements of the current rules and regulations;

• recommended scenario, where the ship is brought to a normal level of performance in relation with similar existing vessels;

• full upgrade scenario, where the ship is brought into the equivalent position with the latest achievements in the field.

Table 7 Upgrading / refurbishment Scenarios of “Hercules”

Scenario Description Total value EURO, plus VAT, if applicable

Mandatory Reintroduction in rules and regulations, keeping the present functions

6.400.000

Recommended Superior level, with a positive outlook 8.130.000 High Strategic capabilities ship 9.180.000

[Feasibility Study for the Port of Constanta] [August 2014] page 32

Other investments needed to increase the efficiency of pollution response and rescue lives on sea (Table 8):

Table 8 Equipment to be purchased

Equipment Technical specifications No. of pieces

Model AP - 2401 Air - Max Inflatable Boom

Fabric: 28 oz. Urethane Coated Polyester Fabric, Orange; Inflation: single point inflation, section by section; inflation: 15:1; waves: 1.0 m; current: 3 knots; wind: 20 knots; towing speed: 12 knots

3

Model AP - 4201 Air - Max Inflatable Boom

Fabric: 28 oz. Urethane Coated Polyester Fabric, Orange; Reserve Buoyancy: closed cell foam Planks in each air chamber; Buoyancy ratio: 15:1; waves: 1.0 m; current: 3 knots; wind: 20 knots; towing speed: 12 knots

3

Model AP - 8.0 X 6.5 Boom Reel

Frame: Steel Tubing; Finish: Epoxy Prime & Paint, International Safety Orange: Capacity: 250 meters of AP-4201 Air-Max or 350 AP-2401 Ai -Max Boom

3

Model AP-l0 Diesel Hydraulic Power pack

Controls: On/Off Valve, Flow Control Valve, Engine: 10 h.p. Yanmar Type Diesel Hydraulic Tank: 12 gallons with return filter Wheels: 16" pneumatic with solid steel rims Frame: 1 " Stainless Steel Gauges: 2-0 to 3,000 p.s.i. liquid filled hydraulic pressure gauges

3

Model 36 Multi-Skimmer with Electric Hydraulic power pack.

Skimmer Heads: Drum Skimmer head, and Brush Skimmer Head Drum Skimmer Head:110 GPM./ 25m3lltr with 95.6% oil to water ratio Brush Skimmer Head:180 GPM./ 40m3lhr witkr95.60/o oil to water ratio Viscosity of Oil: 1 -200,000 CST at 15"C Type: Drum type, Hydraulic driven from power pack, oil eolphilic & Hydrophobic Disc Speed:0 - 100 rpm, adjustable

3

Model 60 Multi - skimmer with diesel power pack

Recovery Rate: Type: Drum Skimmer Head: 50m3/.hr. Brush Skimmer Head: 100 m3/hr. Drum and Brush Skimmer Heads, Hydraulic interchangeable Driven, can be interchanged in 1 minute without tools

2

[Feasibility Study for the Port of Constanta] [August 2014] page 33

Worthiness of the EPO proposed environmental action 7

Which are the advantages of adopting an EMS?

reducing negative environmental impacts;

reducing production costs by monitoring the daily / monthly consumption of

utilities and the compliance with consumption rates;

efficient waste management (selective collection, storage, transportation of waste

according to applicable legislation, recovery);

compliance with legal requirements (national and international)

reducing the risks of environmental accidents.

What represents the EMS certification by an independent body?

The Environmental Management System certification by an internationally recognized

independent certification body serves to build trust that the environmental management

system is functional and effective.

An environmental management system can be certified by the international recognized

standard ISO 14001: 2004.

Certification is subject to a certification audit.

The purposes of the certification audit are:

to neutrally and objective verify that all elements of an EMS are effective;

to determine that the written documentation is valid and reflects the situation on

site;

to evaluate the effectiveness and efficiency of the EMS.

Which are the steps to certification?

I. Starting the certification process – Filling in the Certification questionnaire;

II. Acceptance of the offer and signing the certification contract;

III. EMS certification audit (Stage 1 –Initial Audit + Stage 2 – Certification Audit);

IV. EMS supervision audits.

The certification is granted for a 3 years period.

Which are the steps ARSVOM has to follow to implement an EMS?

To document and implement an EMS, the organization must follow these steps:

Identification of environmental impacts associated with the activities and

processes of the organization:

Establish the associated environmental issues;

Establish the criteria for assessing environmental aspects;

Classification of the environmental issues;

[Feasibility Study for the Port of Constanta] [August 2014] page 34

Drafting the environmental policy by top management based on:

significant environmental aspects identified

environmental legal requirements

strategy and development plans of the organization

Creating the environmental programs:

Setting the environmental objectives of the environmental policy;

Establishing targets, actions, responsibilities and deadlines for each objective;

Allocation of resources needed to achieve objectives;

Cross - checking the correspondence between the significant environmental

aspects identified / environmental objectives of the environmental policy/ targets and

actions in the environmental program/programs;

Establishing the organizational structure and documentation:

Appointment of Management Representative for EMS;

Establish responsibilities and authorities for EMS;

Develop documentation required for the operation of the Environmental

Management System (manual, procedures, instructions, forms, etc.);

Implementation:

Staff awareness of the importance and benefits of an EMS;

Training related to implementation of the EMS specific procedures and

instructions;

Monitoring of environmental performance;

Internal Audit;

Management analysis and proposed actions to continually improve

environmental performance.

ARSVOM initial evaluation, regarding its capacity to implement ISO 14001:2004

Initial assessment of ARSVOM interest to implement the EMS, was based on the

questionnaire "Mentoring activities for EPO questionnaire" (Annex 1). Based on the responses

recorded in the first conclusions were drawn in respect of knowledge of the environmental

issues and of the impacts resulting from their own activities, but also in terms of the

weaknesses of the organization on the enforcement of protection regulations in certain

activities.

To have a complete picture on ARSVOM institutional/organizational capacity for EMS

implementation, their evaluation was done following the achievement / implementation status

of the main requirements of ISO 14001: 2004 (Table 9).

The costs estimated for consulting and EMS certification are presented in the Table 10.

[Feasibility Study for the Port of Constanta] [August 2014] page 35

Table 9 Status and necessary measures to fulfill EMS requirements

Requirements ISO 14001:2004

ARSVOM Status Measures proposed

Environmental policy

Not defined

Standard 4.2.– ISO 14001:2004

Identification of environmental compliance requirements

Yes, the company acts in accordance with the environmental national and international legislation, excepting the limits of emissions (gas emissions, sewage discharged due to technical deficiencies identified at ships)

Standard 4.5.2.1 – ISO 14001:2004

Identification of environmental aspects, impacts and significant environmental impacts

Yes, but the criteria have to be defined (legislation, severity, occurrence, control, defect etc.), limits, significant aspects)

Standard 4.3.1 – ISO 14001:2004

The development of objectives and targets, and their environmental management programs;

Not defined At organizational level, the overall investment objectives to improve technical operating conditions and also to improve environmental performance (e.g. Reducing of air emissions) are established. Setting measurable targets

Standard 4.3.3 – ISO 14001:2004

Defined resources, roles, responsibilities and authorities for environmental management;

YES (equipment and human resources). Standard 4.4.1 – ISO 14001:2004 RM nominated, trained, responsibilities set by job description file and the organizational chart revised

The development of competence, training and awareness procedures;

Yes, periodically training courses

Standard 4.4.2 – ISO 14001:2004 Training programs established, internal and external trainings performed (Waste management trining course – according to Law 211/2011 art. 22, para.3., Internal auditor/ environmental responsible training courses, as appropriate).

A communication process of the EMS to all stakeholders and interested parties;

Not yet the case 4.2.f) si g)– ISO 14001:2004 4.4.3– ISO 14001:2004

The development of EMS documentation as required by the standard;

no 4.4.2– ISO 14001:2004

The development of document control procedures;

no 4.4.2– ISO 14001:2004

The development of operational control procedures;

no 4.4.6– ISO 14001:2004

The development of emergency preparedness and response procedures

no 4.4.7- ISO 14001:2004

The development of procedures to monitor

Yes. It is a clear evidence of all categories and amount of wastes resulted from the

4.5.1- ISO 14001:2004

[Feasibility Study for the Port of Constanta] [August 2014] page 36

Requirements ISO 14001:2004

ARSVOM Status Measures proposed

and measure operations that can have significant impact to the environment;

company’s activities Environmental Authorization released by Environmental Protection Agency Constanta no. 392/28.09.2009, valid 28.09.2014.

A program for completing internal EMS audits and corrective actions;

no 4.5.5- ISO 14001:2004

An evaluation of compliance procedure;

not yet the case Post implementation evaluation

Procedures developed for the management of non-conformance, corrective and preventative actions;

no Post implementation evaluation

The development of a records management procedure

no Post implementation evaluation

The development of procedures for management review by senior management.

no Post implementation evaluation

Table 10 Costs associated with consulting and EMS certification

No. Activity Estimated Cost [Euro], (plus VAT)

1 EMS Consulting 4 500 2 EMS Certification

1. Certification audit 2. Surveillance audit 12 months 3. Surveillance audit 24 months

5 000 2 000 2 000

Total (Euro) 13 500

[Feasibility Study for the Port of Constanta] [August 2014] page 37

Conclusions:

After analyzing the documents and information that were made available during the feasibility

study, we recommend EMS certification procedure for the shore based decontamination

activity, as it is conducted according to the legislation in force, and the equipment is upgraded

in accordance with the European requirements, subject to organization renewal of the

Environmental Authorization.

EMS certification by an internationally recognized body will confirm compliance with

environmental requirements and will give confidence to ASRVOM clients on compliance with

these requirements and the organization's approach toward environmental protection.

For sea intervention (e.g. conducting search and rescue operations at sea, assistance

and rescue and so on) they have to upgrade/refurbish their ship HERCULES as to meet the

environmental standards.

[Feasibility Study for the Port of Constanta] [August 2014] page 38

Acknowledgement 8

During the drafting of this study, significant contribution has been provided by:

(a) Mr. Iulian Cretu, ARSVOM Operational Manager

(b) Mrs. Nicoleta Juguleanu, ARSVOM Expert

(c) Mrs. Mihaela Muresan, responsible TEN ECOPORT from National Institute of Development and Research of Marine Geology and Geoecology - GeoEcoMar, Bucharest

(d) Mr. Adrian Teaca, technical responsible TEN ECOPORT from National Institute of Development and Research of Marine Geology and Geoecology - GeoEcoMar, Bucharest

(e) Mr. Dumitru Bucuresteanu, Head of SAR– Pollution Department and responsible TEN ECOPORT from RNA Constanta,

(f) Mrs. Irina Casiade, technical responsible TEN ECOPORT from RNA Constanta

therefore we would like to express to them our highest gratitude.

[Feasibility Study for the Port of Constanta] [August 2014] page 39

Annex 1 Mentoring activities for EPO questionnaire - ARSVOM

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ffivIrIEsFoREPoQUESTIONNAIRE

l.Inyouropinion,whatwouldbethemainreasonforyouintroducinganenvironmental management sYstem ?

introduced an EMS?

3, In your opinion, which would be the advantages to implement an

environmental management sYstem?

It mav improve oIt may reduce the-? cability of some regu!a!!sns

iutatorsince@

Itmayallowfo@

j.o!ntl13 gn eee;routos

: :::ri ili.1. ir1: ' i:i_;-

, j] ::' ', ;j i::]:. ;:

;@cs %'n nfl*lJt\"'! LI

:.+

It mav im ve our facilitv's profilIt mav imorove information about our faciliW's operations

create cost savines in terms of use of inputsOther facilities like ours are adoptinq similarOther reasons (please specify)

4. According to you, what are the possible actions or procedures that shouldbe standardized within your organization in order to collaborate betterwith the Action Plan?

Identify the operations and activities with significantenvironmental aspects

V-

Identified environmental responsibilitiesOrganization of services that involve environmentalcomDonentsManasement of notential environmental emerqenciesMonitoring and supervisory the activities and operations thatcan have a siqnificant impact on the environment

\-/

Environmental information and communication activities /Other (please specify)

@C(} b-nfirFIJ\II La

Questionnaire to add to the public procedure.Please note that:- for each answer the score will be O,5 or 1 considering that the last two answerare alternatives;- in the selection procedure of the beneficiary it would be preferable to choosethe largest polluter;- it is preferable that the beneficiary has initiated procedures for ceftification ofqualiW

jcinilq on 6co'roul@s

jolnilV of eco-1er:te1

, t,,. : ..:_ t: :_j;::_l

:... .: :: ::it r; .. ', 1'.: .,- :t :- -

it':'

@eO."-w,a ftrrE*TJ[..'g Lt-

joinih; cn eeo-routes

tr Yes

If No, please specify why.."-..... ,- "-''b;;'-*).-r ./ur owunJ L/ fi+k Th4- ^*ouu€2r/.tnt

o/oe{ y'y'r- rivt- co,u1o /i'cr'n/-e"/ €ye/<.zz}.7.What is your knowledge about the Environmental management system?

Lack of knowledqeIn-depth knowledoeFairly qood knowledqe

8. Have you ever considered to implement an environmental management system in yourfaciliW/activity?

Xvesn No, please specify why..,.....

9. If "No", has your facility implemented any of the fallowing other management practices?(Please tick one bax for each row)

YES NOOualiW manaqement system (e.s, ISO 9000)Health and safetv manaoement svstemFull-cost or activiW-based accountincManaqement accountino svstemProcess or iob control systemInventory or materials requirement planninqOther (please specifu)