Section 2

Environmental Considerations for Port

Development and Operations
The purpose of this section is to identify port development and operation
activities that may affect environmental quality. For each activity, the potential
pathways for environmental impacts are also evaluated.

2.1 Port Activities

Activities and operations vary widely among ports depending on the types and
volume of materials shipped. However, there are many common activities, such as
vehicle maintenance or bulk materials handling that occur at nearly every port,
and impacts to the environment from these activities may occur. For example, fuel
spills of varying amounts that occur during routine on- or off-loading activities
can be carried by stormwater into a water body, and can have serious effects on
water quality, waterfowl, and sediments.

However, a port can play a significant role in protecting and

Figure 2-1 enhancing the environment through careful initial planning and
Typical Development Process
implementation of appropriate measures. The degree to which a
particular activity may impact the environment is dependent on:
In v e n to r y o f
F a c ilitie s
# Proximity to sensitive natural resources
# Open pathways between the activity and these resources
Needs # Extent of the activity
Assessm ent # Controls in place to prevent or reduce impacts
# Opportunities to enhance the environment
M a s t e r P la n n in g
(S e e S e c tio n 2 .3 .1 ) This section presents a list of key port activities that have potential
to affect environmental quality, divided into two main categories:
C o n c e p tu a l D e s ig n
& P e r m ittin g # Development-related activities
(S e e S e c tio n 2 .3 .2 ) # Operations-related activities

P r e lim in a r y D e s ig n
For the purpose of this document, development-related activities
(S e e S e c tio n 2 .3 .3 ) include construction, and operations-related activities include
maintenance. The following section presents activities in each major
heading. Activities that are both development and operations-
F in a l D e s ig n related are discussed in the most appropriate section.

C o n s tru c tio n 2.1.1 Development-Related Activities

Figure 2-1 shows a typical development process, starting with an
O p e ratio n s inventory of current facilities and needs assessment, followed by
master planning, several stages of design, construction, and finally
into startup and operations. While environmental impacts are most

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likely to occur during construction and operations,

Table 2-1
environmental concerns may arise at any step of
Development Related Activities
the development process, and are best addressed
during the earliest possible stages. In particular, # Building Demolition
environmental issues and concerns are often # Building Renovation
identified during the needs assessment, and # Bulkhead Renovation & Installation
# Remediation
addressed (i.e., potential solutions are found) # Dredge Material Placement
during the master planning step. # Dredging
# Landfilling
Table 2-1 presents a list of the key construction # New Building Construction
# Pier Construction / Rehabilitation
activities that may be of greatest concern for port # Pavement Installation
development. Section 3 presents a variety of # Pavement Removal
environmental management practices (EMPs) # Site Cleaning
designed to reduce or eliminate the impacts from # Utility Construction
these activities.

2.1.2 Operation-Related Activities

Table 2-2 presents a list of operational activities that are
Table 2-2 common to most port facilities. This list was developed through
Operations Related Activities discussions with the HN&E Committee and a series of site visits
# Automobile Transport
to ports throughout the US. Section 3 also presents EMPs
# Building/Grounds Maintenance designed to reduce impacts associated with operational
# Cargo Handling activities.
# Chemical Storage and Handling
# Fueling
# Painting 2.2 Potential Environmental Impacts and
# Paint Stripping
# Public Access & Recreation Pathways
# Rail Maintenance
# Ship Liquid Discharges In general, impacts to the environment occur through four
# Ship Air Emissions
media — air, surface water, soils, and groundwater. For many
# Ship Breaking
# Vehicle & Equipment Maintenance port activities, there is more than one pathway leading to an
# Vessel Repair & Maintenance environmental impact and each should be reduced or
eliminated. For example, for dry bulk storage of coal products,
dusts may be created and carried by wind currents offsite to
nearby residences. Stormwater may fall on the product and
carry fine particles and other contaminants to nearby surface waters, or the
stormwater may dissolve contaminants and carry those contaminants into the
soils and eventually into groundwater.

Each activity performed by a port and its tenants should be evaluated to

determine the potential pathways for contaminants to reach the environment. An
understanding of both the contaminants and potential pathways provides a basis
to start or change environmental management practices to help eliminate those
pathways, which is the focus of Section 3.

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2.3 Environmental Concerns for Table 2-3

Typical Environmental
Port Development Considerations For Port
Development Projects
Each step of the typical development project —
for a port or for any other industry — requires # Underground Storage Tanks/ Above
careful consideration of numerous environmental Ground Storage Tanks (USTs/ASTs)
factors including those shown in Table 2-3. Three # Chemical Storage
critical steps in the development process shown # Spills & Leaks
# Solid Waste
in Figure 2-1 are discussed in the following # Water Resources
sections. # Wetlands
# Cultural Resources
# Air Emissions
2.3.1 Master Planning # Wastewater Discharges
# Storm Water Discharges
During the master planning stage, a port must # Construction Impacts
determine the type and extent # Fisheries
Figure 2-2 of activities that will occur at # Traffic
the new facility. It is important # Noise
Assessment of Potential Impact Pathways
# Endangered Species
From Operational Activities to understand all of the # Public Outreach/Access
processes and procedures used # Mitigation
at a facility, not only the final # Hazardous Wastes
A s s e s s A ll A c tiv itie s a t # Sediment & Erosion Control
F a c ility product or service that will be
provided. Then the port,
working with its tenants if
A s s e s s P o tential Im p a c ts to applicable, would develop a
A i r , S u r f a c e W a te r , S o ils , o r plan to protect and enhance the environment, as demonstrated
G r o u n d w a ter in Figure 2-2.

D e term i n e T y p e a n d E x tent Community and regulatory agency outreach is necessary during

o f E m is s i o n s this stage to assess community concerns, and develop a strategy
to address them. This strategy may involve project
D e t e r m i n e C o m p a t ib ility w ith modifications, such as limits on the size of the project; additions
P o r t E n v i r o n m e n ta l of new project features, such as public awareness opportunities;
P ractices or voluntary environmental management programs, including
energy efficiency initiatives. In addition, this strategy should be
A s s e s s A v a ila b le C o n t r o l developed in conjunction with other elements of the port’s
T e c h n o lo g i e s management team (e.g., marketing, engineering, financial, legal)
to ensure that any project meets the port’s mission.

E v a lu a te a n d M o n ito r
E ffectiveness or C o n trol
2.3.2 Conceptual Design & Permitting
T e c h n o lo g i e s Once the master plan is complete, conceptual design and
permitting efforts are conducted. Permitting is one of the most
critical steps in any development project with the extent and
D e v e lo p a n d I m p le m e n t number of permits dictated by the county or region involved. In
E n v ironm e n tal the US, permitting is strongly dependent on the state in which
M anagement the project occurs. For example, some states have their own
NEPA-like programs (e.g., California (CEQA) and
Massachusetts (MEPA),) wetlands programs, as well as special programs related

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Environmental Considerations for Port Development and Operations

to construction in waterways of the state. In addition, Federal air, water and waste
regulations are managed/enforced at the State level.

A typical permitting program, as shown in Figure 2-3 is an iterative process

involving extensive negotiations
with local, state, and federal
Figure 2-3 regulatory and resource
Iterative Permitting Process agencies. There are an extensive
number of factors that are
Project is weighed by the regulatory
Developed by Port
or Tenant
agencies during a review of
impacts and potential
mitigation alternatives, not the
least of which are community
Preliminary Discussions
concerns regarding the project.
Project Presented
to Regulatory
Project Presented Many ports prefer to consult
to Public
Agencies with regulatory agencies and
the public while projects are
still in the conceptual stages to
identify potential
Regulatory/Resource Impacts Public Review
Agency Review & Defined and Comment environmental concerns before
Comment costly design plans have been
completed. For example,
because the permitting process
Regulatory/Resource Mitigation Public Review
often results in conditions
Agency Review & Alternatives and Comment placed on a project’s design, the
Comment Defined Port of Everett uses a five-step
process involving:

# Step 1 - Project Definition

Mitigation
No
Acceptable to
# Step 2 - Preliminary
Port, Engineering and
Community, & Environmental Review
Regulators
# Step 3 - Permits
# Step 4 - Final Design
Yes # Step 5 - Construction.
Submit Permit
Application
In Step 2, a project is brought
No
only to the 30 % complete stage
and the Port gathers agency and
Agency public comments. In Step 3,
Approves
Permits permit applications are
submitted, and approvals that
Yes
include conditions on the design
and received before final design
Project is started in Step 4.
Proceeds

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When agency and public concerns are not well understood, community outreach
and involvement programs become essential elements of the project. Section 5
presents a guide for development of community outreach programs and a series
of case studies of successful efforts.

2.3.3 Preliminary and Final Design & Construction

Once a plan to minimize the impacts of a development project has been
developed, the port/tenant should design the most cost-effective method to
eliminate/reduce potential pathways. During the design, the port should also
develop plans to minimize the impacts of construction activities — from
demolition of existing facilities through construction of new ones. Table 2-4
presents an overview of the basic development activities of concern and potential
pathways and environmental impacts for each activity. Included in the table is a
subjective assessment of the types of
impacts — short-term or long-term — to
Table 2-4
1, 2 the four media and freshwater and marine
Potential Impacts from Development Related Activities
biota. This assessment is strongly
iota

dependent on the location of the activity

t
imen
ater

ter b
ater

and the levels of controls used to protect

ta
e Bio
ty

ty
ce W
uality

nd W

h Wa
/Sed

the environment. However, for the most

Quali

Quali

Marin
Surfa

part, construction-related impacts tend to

Air Q

Grou
Soils

Fres

be more localized, acute in nature (i.e.,

S T LT S T LT S T LT S T LT S T LT S T LT
Building they occur over a short period of time
Demolition H L H L L L L L M L M L during construction) and dissipate rapidly
Building at the completion of the project.
Renovation M L M L L L L L M L M L
Bulkhead
Installation M L H L L M L L M M M M
Contamination 2.4 Environmental
Remediation M L H L L L L L M L M L
Dredge Concerns for Port
Material
Disposal M L H M L M L L H M H M Operations
Dredging M L M L L M L L H M H M
Landfilling M L M L L L L L M L M L
New Building
Port operations and activities, by their
Construction M L M L L L L L M L M L
Pavement nature, have the potential to impact one or
Installation M L L L L L L L M L M L more environmental media. The port and
Pavement
Removal M L M L L L L L M L M L
its tenants should evaluate their
Pier operations, determine which pathways
Construction/ and media can be affected and develop
Rehabilitation M L M L L M L L M L M L
Site Clearing M L M L L L L L M L M L
plans to eliminate or minimize potential
Utility impacts. Environmental compliance audits
Construction
1.
M L M L L L L L M L M L are generally used to assess port and
The type and magnitude of impact is dependendent on the extent
to which an activity occurs, its proximity to sensitive receptors, and
the controls employed by the port or its tenants
2.
ST - Short Term; LT - Long-Term; L-Low impact;
M - Moderate impact; H -High impact

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T a b le 2-5 tenant operations and determine

1, 2
Potential Impacts from O p e rational Activities which pathways require
attention. An audit carefully

t
imen
ater

ater
examines the processes used at a

ta
ter

e Bio
ty

ty
ce W
uality

nd W

h Wa
/Sed
facility, determines the actual or

Quali

Quali

Biota

Marin
Surfa
Air Q

Grou
Soils
potential impact pathways, and

Fres
A c tivity
identifies current control
ST LT ST LT ST LT ST LT ST LT ST LT methods. From the audit, the port
Automobile
Transport or its tenants can then select
O ff-Loading H M M L L L L L M L M L appropriate methods to manage
S to r a g e M L M L L L L L M L M L the activity more effectively. The
B u i l d in g G r o u n d s
audit process is described in
M a intenance/ L L M M M M M M M M M M
Cargo Handling greater detail in Section 4.
D r y B u lk H M H L M L L L M M M M
Liquid Bulk M M M L M M M M M M M M Table 2-5 presents a summary of
General Cargo L L M L L L L L L L L L
C o n ta i n e r s L L L L L L L L L L L L major port activities and a
B r e a k B u lk M L M L L L L L M M M M subjective assessment of potential
C h e m ical Storage
a n d H a n d l in g M M M L M L M L M L M L
impacts from each operation. As
F u e ling discussed previously, this
O n - L o a d ing H M M L M L M L M M M M assessment is dependent on:
S to r a g e M M M L M M M M L L L L
O ff-Loading M M M L M L M L M M M M
P a in t i n g # Location. For example,
B u ilding H L L L L L L L L L L L application of ship paints
Anti-Fouling H L M L L L L L M M M M
Service Vehicles H L L L L L L L L L L L over land or in a drydock is
P a in t S t r i p p i n g H L M L L L L L M L M L likely to cause less impact
Public Access &
than painting over water
Recreation
Cruise Lines M M L L L L L L M L M L (assuming that materials
F ishing Piers L L M L L L L L L L L L falling in the dry dock are
Moorings/Slips L L M M L L L L M L M L
swept up and not
P u b lic R e c r e a t i o n a l discharged.)
Access M M M M L L L L M L M L # Sensitivity of Species of
Rail M a intenance L L M L M L L L M L M L
Ship Liquid
Concern. In areas where
D ischarges highly sensitive species
B a llast W ater L L H L L L L L M M M M exist, more severe, chronic,
T a n k C le a n i n g M L H L L L L L M L M L
B ilge W ater L L H L L L L L M L M L
and/or acute impacts may
Sewage L L M L L L L L M L M L occur as compared to an
Solid W aste area where less sensitive
S h ip-G e n e r a t e d L L M L L L L L M L M L
Shore-Generated L L M L L L L L M L M L species exist.
Vehicle and # Physical Features. Physical
Equipm ent
M a intenance
features such as breakwaters
H L M L M L M L M L M L
Vessel Repair and may reduce
M a intenance M M M L M L M L M L M L dilution/flushing rates and
Ship Breaking M L M L M L L L M L M L
may cause greater impact, in
S h i p A i r E m is s io n s M M L L L L L L L L L L localized areas, when
1.
T h e t y p e a n d m a g n itude of im p a c t is dependendent on the extent compared to areas with
to w h ich an activity occurs, its proxim ity to sensitive receptors, and higher flushing rates.
the controls em p loyed by the port or its tenants
2.
ST - Short Term; LT - Long-Term; L-Low impact;
M - M o d e r a te im p a c t ; H - H i g h i m p a c t

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It should be noted that the impacts described in both Tables 2-4 and 2-5 are site-
and project-specific and could vary substantially depending on the
implementation process. In addition, the likelihood of impacts is substantially
lower when appropriate environmental management techniques are implemented
and maintained properly.

2.5 Regulatory Issues

In most countries, environmental rules and regulations are becoming more
stringent and are reaching more broadly into private and public sectors. These
environmental regulations generally define the potential risks of port operations
and most related businesses. This document is intended to provide general
environmental guidance to AAPA member ports, and it would be impossible to
define the regulatory programs for each country, state, province, or region.
Appendix A provides a guide to retrieving EPA’s Section Notebook entitled
Profile of the Water Transportation Industry that contains a brief overview of the
federal regulatory programs specific to the United States. Readers should refer to
their local, regional, state, or federal guidance for the specific interpretation of
rules and regulations pertinent to each activity.

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