Fourth Semiannual Report- Operational Phase …...(EMP) and in the resolutions for the approval of the Environmental Impact Assessments (EIA) for the Third Set of Locks. Environmental

FINAL REPORT

Panama Canal Authority

Verification of the Implementation and Effectiveness of the Mitigation Measures for the Panama Canal Expansion

Program – Third Set of Locks Project:

Fourth Semiannual Report- Operational Phase

January - June 2018

August 2018

ERM Project: 0452664

Environmental Resources Management

Century Tower, 17th Floor, Suite 1716

Ricardo J. Alfaro Ave., Panama City, Rep. de Panamá

TABLE OF CONTENTS

ENVIRONMENTAL RESOURCES MANAGEMENT PANAMA CANAL AUTHORITY– AUGUST 2018

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DEFINITION OF FREQUENTLY USED ABBREVIATIONS AND ACRONYMS IV

EXECUTIVE SUMMARY 5

1 PROMOTER’S INFORMATION 8

2 INTRODUCTION 9

3 PURPOSE, SCOPE OF WORK, AND METHODOLOGY 10

3.1 PURPOSE 10

3.2 SCOPE OF WORK 10

3.3 METHODOLOGY 12

4 TECHNICAL ASPECTS OF THE THIRD SET OF LOCKS’ OPERATIONAL PHASE 14

4.1 ACP ORGANIZATIONAL CHART 14

4.2 BRIEF DESCRIPTION OF THIRD SET OF LOCKS’ OPERATIONS 15

4.3 LOCKS OPERATION AND MAINTENANCE ACTIVITIES 16

4.3.1 LOCKS OPERATIONS 16

4.3.2 LOCKS MAINTENANCE 18

4.4 EQUIPMENT USED IN THE THIRD SET OF LOCKS 18

4.5 PERSONNEL 19

5 VERIFICATION OF THE THIRD SET OF LOCKS’ ENVIRONMENTAL AND SOCIAL REQUIREMENTS 21

5.1 EQUATOR PRINCIPLES 21

5.1.1 OCCUPATIONAL HEALTH AND SAFETY PROGRAM 27

5.2 ENVIRONMENTAL AND SOCIAL MANAGEMENT IN THE

OPERATIONAL PHASE 28

5.2.1 AIR QUALITY, NOISE, AND VIBRATION CONTROL

PROGRAM 28

5.2.2 SOIL PROTECTION PROGRAM 31

TABLE OF CONTENTS


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5.2.3 WATER RESOURCES PROTECTION PROGRAM 34

5.2.4 FLORA AND WILDLIFE PROTECTION PROGRAM 35

5.2.5 SOLID, LIQUID, AND HAZARDOUS WASTE MANAGEMENT

PROGRAM 38

5.2.6 MATERIAL HANDLING PROGRAM 39

5.2.7 SOCIOECONOMIC AND CULTURAL PROGRAM 39

5.2.8 CONTINGENCY PLAN 45

5.2.9 ENVIRONMENTAL MONITORING PLANS 47

5.2.9.1 AIR QUALITY MONITORING 47

5.2.9.2 MONITORING OF CHLORIDES AND OTHER PARAMETERS

RELATED TO THE GATÚN LAKE 49

5.2.9.3 WASTEWATER DISCHARGE MONITORING 50

5.2.9.4 LANDSLIDE MONITORING 52

5.3 REVIEW OF THE DIEORA IA-632-2007 ANAM RESOLUTION

REQUIREMENTS 53

5.3.1 SEMIANNUAL REPORT 54

5.3.2 MODIFICATIONS TO THE EXPANSION PROGRAM 55

5.3.3 REFORESTATION PLAN 55

6 CONCLUSIONS 61

7 TABLES 65

8 APPENDICES 90

LIST OF TABLES TABLE 1. INSPECTION SCHEDULE 11

TABLE 2. EQUIPMENT USED BY GUPCSA FOR MAINTENANCE OF THE AGUA CLARA AND COCOLÍ LOCKS 19

TABLE 3. WILDLIFE CAPTURE AND RELOCATION AT COCOLÍ 36

TABLE 4. SUMMARY OF AVERAGE AIR QUALITY MONITORING RESULTS 48

TABLE 5. REFORESTATION PROJECTS SUMMARY 56

TABLE 6. VISITED LOCATION’S COORDINATES – UTM (WGS 84) 57

TABLE 7. VISITED LOCATIONS’ COORDINATES – UTM (WGS 84) 60

TABLE OF CONTENTS


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LIST OF FIGURES FIGURE 1. ACP ORGANIZATIONAL CHART 14

FIGURE 2. THIRD SET OF LOCKS COMPONENTS – PACIFIC SITE AND ATLANTIC SITE 17

LIST OF APPENDIXES Appendix A: Photographic Record Appendix B: List of Documents Reviewed Appendix C: List of Meetings Held Appendix D: Land and Water Vehicle Maintenance Log Appendix E: Dam and Landslide Control Log Appendix F: Wildlife and Flora Rescue and Vector Control Report Appendix G: Solid, Liquid, and Hazardous Waste Management Log Appendix H: Air Quality Monitoring Reports Appendix I: ACP WWTP Reports Appendix J: ACP Water Quality Reports Appendix K: Third Semiannual MiAmbiente Report Submission Note Appendix M: Socioeconomic and Cultural Program Activity Log


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FREQUENTLY USED ABBREVIATIONS AND ACRONYMS

ACP Panama Canal Authority (PAC)

ADP ACP Project Administrator

ANAM National Environmental Authority

(currently Ministry of Environment)

CHCP Panama Canal Watershed (PCW)

CIFO Center for Forestry Research – ANAM

(currently Ministry of Environment)

CO Carbon Monoxide

CO2 Carbon Dioxide

CO Contracting Officer

COPANIT Panamanian Commission of Industrial

Standards and Techniques – General

Bureau of Industrial Standards and

Technology (DGNTI) of the Ministry of

Commerce and Industry

CFU Colony Forming Units

CUSA Constructora Urbana, S.A.

(Construction Company)

dBA A-weighted Decibels

DGNTI General Bureau of Industrial Standards

and Technology

DI Dredging International de Panamá, S.A.

DIEORA Environmental Evaluation and

Organization Bureau

EA Vice-President of Environment,

Water and Energy

EACE Environmental Assessment and

Monitoring Division

EIA Environmental Impact Assessments

E.O. Executive Order

EMP Environmental Management Plan

ENO Elevation Operation Level (Spanish)

ERM Environmental Resources

Management Panamá, S.A.

FCC Fomento de Construcciones y Contratas

S.A. (construction company)

GUPCSA Grupo Unidos por el Canal, S.A.

ha Hectares

ICA Ingenieros Civiles Asociados S.A. de C.V.

(construction company)

IFC International Finance Corporation

JDN Jan De Nul NV

MECO Constructora Meco, S.A. (construction

company)

MiAmbiente Ministry of Environment

MSDS Material Safety Data Sheets

Mm3 Million cubic meters

m3 cubic meters

NMP Most Probable Number

NO2 Nitrogen Dioxide

OP Vice-President of Operation

PM Particulate Matter

PM10 Particulate Matter less than 10 microns

PNAC Altos de Campana National Park

PNCH Chagres National Park

PNCC Camino de Cruces National Park

PNOT Omar Torrijos National Park

PNS Soberanía National Park

PNVB Volcán Barú National Park

PS Performance Standard

PWM Panamá Waste Management

RFM El Montuoso Forest Reserve

ROC- Contract Officer Representative

SO2 Sulfur Dioxide

TRANEM Transportes El Emigrante S.A.

TSS Total Suspended Solids

ENVIRONMENTAL RESOURCES MANAGEMENT PANAMA CANAL AUTHORITY – AUGUST 2018

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EXECUTIVE SUMMARY

This report describes the degree of compliance in the implementation and effectiveness of mitigation measures applied in the operational phase of the Panama Canal Expansion Program - Third Set of Locks, during the period from January to June 2018. These mitigation measures were established as part of the Environmental Management Plan (EMP) and in the resolutions for the approval of the Environmental Impact Assessments (EIA) for the Third Set of Locks.

Environmental Resources Management Panamá, S.A. (ERM), under contract with the Panama Canal Authority (ACP, for its Spanish acronym), carried out the compliance verification of the aforementioned measures, which included the review of documentation, field verification visits conducted between July 17 and 19 of 2018, as well as interviews with ACP representatives, contractors, and subcontractors.

The following facilities were visited during this reporting period: (1) The Agua Clara Locks, in the Atlantic side; (2) the Cocolí Locks in the Pacific; and (3) the areas covered by the Reforestation Plan.

This report offers detailed information on each of the areas visited and the evidence verified. The Appendices include the remarks and observations gathered during the visits conducted to the different Third Set of Locks facilities and operational areas from January to June 2018, as well as excerpts from the monitoring data submitted by ACP contractors during the project’s operational phase.

Grupo Unidos por el Canal, S.A. (GUPCSA) provides system maintenance service for the operation of the new locks facilities. They also provide maintenance to the facilities that are under their management. They have established administrative offices, workshops, and equipment and supplies warehouses to support lock maintenance activities at both the Atlantic and the Pacific sites. The ACP is in charge of maintaining the new locks facilities, such as the control tower, access and security posts, green spaces, and inner roads among others.

Based on the documentation reviewed, the field visits, and the interviews with the Expansion Program – Third Set of Locks’ personnel at both sites (Pacific and Atlantic), ERM has been able to verify that during the verification period spanning from January to June 2018, prevention and/or control measures have been implemented during the operational phase in order to prevent pollution to the soil, air and water; control soil erosion; manage hazardous products and waste responsibly; and protect the local flora and wildlife.


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The ACP continues to implement actions aimed at complying with the commitments acquired with the Financial Institutions regarding the Equator Principles and the IFC Performance Standards. To this end, the main aspects regarding labor conditions and safety are met, including the upgrading of line handler’s facilities with the construction of waiting cabins during vessel traffic; communication and disclosure to the communities, pollution prevention and abatement programs, measures to protect biodiversity through the different environmental programs for environmental education, environmental economic incentives, cadaster programs and natural capital management in the watershed basin program, are met. Also, the ACP executes the Reforestation Plan within the framework of the ecological compensation commitments, under which the reported reforestation of 1244 hectares (ha) has been completed in 20 sites nationwide. Seven (7) of these sites are in their maintenance phase, while thirteen (13) sites have been transferred to MiAmbiente for their management.

Regarding compliance with the Environmental Management Plan (EMP), ERM conducted a field verification of the effective application air and noise control quality measures. Both by the ACP and the contractor. It could be noted that hygiene and safety conditions are maintained at both locks’ operating facilities; there is compliance with solid and hazardous waste management measures according to regulations; and there is an adequate management of non-hazardous and hazardous materials. Furthermore, the ACP has implemented measures to prevent and control erosion and landslides, and to maintain all locks premises. The ACP has ongoing environmental monitoring programs for water quality monitoring, effluent quality monitoring and air quality monitoring, in compliance with the corresponding environmental regulation.

In addition, the ACP, through its Environmental Division and other operational units, oversaw compliance of the institutional regulations and the corresponding application of the Environmental Management Plans in the implementation of ancillary projects to improve the efficiency of locks operations, such as the construction of a dock for tugboats.

Among the measures for compliance with the Equator Principles and the IFC Performance Standards, the ACP also implemented a Contingency Plan and has established spill care and prevention facilities and early warning protocols. In the subject of landslide prevention, the agency has established protocols and an instrumentation and monitoring system through the LIDAR system.

In general, ERM could note that, as the promoter for the Third Set of Locks’ operational phase, the ACP is responsible for implementing the measures included in the PMA. Also, with the support of GUPCSA as contractor; they are both focused on identifying and seizing opportunities to continually improve compliance with the mitigation measures.


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As a result of the verification activities performed towards the development of this report, in all, ERM has confirmed that the mitigation measures and environmental monitoring plans have been properly implemented in all visited areas during the operation of the Third Set of Locks in the Pacific and the Atlantic. Therefore, the activities performed as part of the operational phase of the Third Set of Locks are in compliance with the applicable environmental and social requirements established in the EMP and in the ANAM Approval Resolution (currently MiAmbiente), as well as compliance with the Equator Principles.


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1 PROMOTER’S INFORMATION

The promoter for the Panama Canal Expansion Program – Third Set of Locks, is the Panama Canal Authority (ACP for its Spanish acronym), an autonomous agency of the Panamanian Government, established by way of the Political Constitution of the Republic of Panama and organized under Act No. 19 of June 11, 1997. The ACP is the entity in charge of promoting the execution of the mitigation measures described in the Environmental Management Plan (EMP) included in the Category III Environmental Impact Assessment (EIA) approved through Resolution DIEORA-IA-632-2007 of November 9, 2007. General information on the ACP is shown below:

Promoter: Panama Canal Authority (ACP) Location: ACP Administration Building,

Altos de Balboa, Ancon, Panamá

Legal Representative: Jorge L. Quijano, Engineer

Personal Identity Card: 8-310-490

Web Page: www.pancanal.com

Contact Person: Ángel Ureña Manager, Environmental Management Section

Ymelda O. Smith

Environmental Protection Specialist

Technical/Administrative Contracting Officer

Representative (ROC)

Phone Number: 276-2858

Email: [email protected]

[email protected]

http://www.pancanal.com/

mailto:[email protected]


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2 INTRODUCTION

Environmental Resources Management Panamá, S.A. (ERM), under contract with the Panama Canal Authority (ACP, for its Spanish acronym), verified the level of compliance in the application and effectiveness of the mitigation measures implemented during the operational phase of the Third Set of Locks. This report presents the results of the inspections and interviews conducted by ERM, as well as the review of documentation related to the implementation and effectiveness of environmental and social impact mitigation measures for the Third Set of Locks applied by the ACP, through its contractors, from January to June 2018.

The environmental and social requirements for the operational phase of the Third Set of Locks were established in the following documents:

1. EMP of the Category III EIA of the Expansion Program, prepared by the ACP and approved by the National Environmental Authority -ANAM (currently MiAmbiente);

2. DIEORA Resolution IA-632-2007 enacted by the National Environmental Authority -ANAM (currently MiAmbiente), which approves the Environmental Impact Assessment for the execution of the Expansion Program;

3. Compliance of the requirements of Financial Institutions which are Equator Principles signatories.

ERM performed the following verification duties: (1) review of monthly and/or semi-annual environmental mitigation measures reports issued by contractor GUPCSA, and by the ACP for the operational phase of the Third Set of Locks, (2) review of GUPCSA contractor’s management records, (3) review of communications between the ACP, its contactors, and the communities, (4) review of environmental and social monitoring and follow up plans, (5) field verification visits conducted by ERM from July 17-19July 17-19, 2018, (6) interviews conducted by ERM with ACP representatives, the contractor, and Locks personnel, and (7) review of supplementary documentation provided by the ACP´s Environmental Assessment and Monitoring Division (EACE).

In this report, the Expansion Program’s main components are divided into groups by sections. The description for each component also includes a compliance matrix.


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3 PURPOSE, SCOPE OF WORK, AND METHODOLOGY

This section describes the general purpose of the report, the scope of the work performed, the schedule of field visits conducted, and the general methodology used to evaluate compliance with the relevant standards.

3.1 PURPOSE

The purpose of this report is to describe the degree of compliance regarding the implementation and effectiveness of the environmental and social mitigation measures in the operational phase of the Expansion Program -Third Set of Locks, during the period covering from January to June 2018. These measures include those contained in the EMP, as well as the ones included in the Category III EIA approval resolution for the “Expansion of the Panama Canal – Third Set of Locks.” All the mitigation measures implemented so far are related to the operational phase of the Third Set of Locks.

3.2 SCOPE OF WORK

The verification of the Expansion Program’s social and environmental mitigation measures was based on a series of office activities and field visits to the sites where the Panama Canal operations take place. These activities were performed by a team of ERM independent professionals under contract with the ACP.

In brief, the scope of the work performed by ERM toward the preparation of this report included:

1. Analysis and review of relevant documents and reports (see list in Appendix B). ERM’s technical team thoroughly reviewed the monthly reports submitted by the contractor and their environmental experts, as well as the reports submitted by the ACP regarding equipment maintenance, pest control, waste management, water and air quality reports, job creation reports, and Reforestation Program reports, among others. To the extent possible, and depending on their issuance date, efforts were made to examine these reports prior to conducting the field visits.

2. Meetings between ERM, the EACE’s Specialized Environmental Protection team, and Ms. Ymelda Smith, the OC in charge of preparing the compliance reports, prior to conducting field visits, in order to coordinate the logistics of the field visits to the Expansion Program – Third Set of Locks’ impact areas, define the scope and methodology of work, and discuss the contents of the report.

3. Field visits aimed at inspecting the facilities and complementary activities (waste water treatment plants) of the Cocolí and Agua Clara locks, corroborating the degree of compliance and the effectiveness in the implementation of the mitigation measures,


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and interviews with project contractors and ACP staff in charge of implementing the EMP, including the plans and programs contained therein. Appendix C contains the attendance list of the meetings held during the field inspection and work meetings.

The field visits were conducted from July 17-19, 2018. The ERM technical team who participated in the verification visits was composed of Dr. Hector René Ledesma, Project Director; Emlen Myers, PhD, Socioeconomic and Cultural Aspects Specialist; Oliver Obregon, PhD., Water Quality Specialist; Jessica Arango, Environmental Specialist, and Carlos Pérez, support staff member for the Reforestation Program, who visited the reforestation projects. ERM employees were accompanied by EACE environmental specialists and RHSH security staff at all times.

A photographic log of all field visits is included in Appendix A.

Field visits were conducted according to the schedule shown in Table 1 below:

Table 1. Inspection Schedule

Date AGENDA

Tuesday,

July 17, 2018

Opening Meeting (ACP):

Introduction of auditing team, agenda, scope of Audit. ACP Meeting Hall, Building 624, Corozal.

Cocolí Locks Meeting – Pacific Site

Presentation of operational progress for the Third Set of Locks, by Eng. Rafael Alvarado, from the Cocolí Maintenance Unit, with the participation of Eduardo Vargas, Jorge Urriola, Edwin Muñoz, and Ymelda Smith.

Tour of the operational areas of the Cocolí Locks, inspection of WWTPs and maintenance areas that fall under the responsibility of GUPCSA: Maintenance Building, Warehouse Building, storage yard, and outdoor workshops.

Interview with ACP Personnel

Interview with Magnolia Calderón and Noel Trejos, from the Environmental Division, Basin Management Section, and Eng. Orlando Acosta, from the Environmental Monitoring Section.

Interview with Eng. Yesenia Cerrud, from the Geotechnical Engineering Section.

Tour of the following reforestation projects: Agua Clara Project (Soberanía National Park, Camping Resort Project), Waucuco No. 1 Project

(Madungandi Region)

Wednesday,

July 18, 2018

Agua Clara Locks- Atlantic:

Meeting with ACP and Locks personnel.

Presentation of Project Progress by Eng. Ramón Porcell from the Agua Clara Locks maintenance employees at the ACP Control Tower, Gatún. With the participation of Michele Reece from Hygiene and Safety, as well as Adrián


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Date AGENDA

Duarte, Pastor Moreno, Arístides Gómez, Manuel Tejada, Ymelda Smith, and Ramón Porcell.

Tour and inspection of the Agua Clara Locks and WWTPs operational areas.

Interview with ACP personnel

Interviews with Ymelda Smith and Jorge Urriola from the Environmental Assessment Section, Maria Eugenia Ayala- WWTPs Monitoring, and Iván Domínguez from the Water Quality Division.

Reforestation Project:

Alto Playón Project (Emberá Wounaan Region).

Thursday, July 19, 2018.

Final Meeting (ACP):

Closing meeting and presentation of main findings and remarks by ERM personnel. Attendees included EACE, EACM, Water Division, and Locks and Facilities Maintenance personnel who participated in the different audits, as well as employees from the Construction Projects and Contracts Administration Section.

Reforestation Project:

Tour of the Madungandi, Wuacuco No.1. and Alto Playón regions.

3.3 METHODOLOGY

In order to evaluate compliance with the EMP, a methodology was used based on matrices that describe the mitigation measures implemented for the operational phase of the Expansion Program’s Third Set of Locks, the activities performed to comply with said measures, the observations made by ERM, and an a note indicating whether a given requirement complies, does not comply or is not applicable for each specific measure. This methodology offers a high level of accuracy in terms of compliance verification and effectiveness of a specific measure.

Measures considered as non-applicable are those which are still pending implementation because the conditions for their application have not been met, as has been the case with the measure regarding the elevation of the Gatún Lake’s operational level.

On the other hand, the compliance matrix includes only mitigation measures which, depending on the nature of the component being assessed, are applicable during the current evaluation period or may be applicable to any future phase of a project component.

Finally, to ease the reading and evaluation of the implemented mitigation measures, the following section of the report shows each of the environmental programs and plans evaluated during the reporting period. The Third Set of Locks has its corresponding


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compliance matrix of the mitigation measures, which are grouped under Section Error! Reference source not found. hereof.


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4 TECHNICAL ASPECTS OF THE THIRD SET OF LOCKS’ OPERATIONAL PHASE

This section provides technical information related to the Expansion Program – Third Set of Locks during the period covered by this report. The information used in this section has been drawn from the latest data published in the monitoring report for the period from January to June 2017, which are still in force, as well as information contained in the ACP’s website regarding the Expansion Program and recent news posted on the same webpage in 2018.

4.1 ACP ORGANIZATIONAL CHART

Figure 1. ACP Organizational Chart

Source: Information obtained from the Panama Canal Authority’s official website,

March 2018. https://micanaldepanama.com/nosotros/sobre-la-acp/organigrama/

Office of the Administrator

EXECUTIVE VICE PRESIDENT

Department of Environment, Water,

and Energy (EWA)

Department of Finance and

Administration (FA)

Department of Planning and Commercial

Development (PCD)

Human Resources Department (HR)

Corporate Management Department

Corporate Communications Department (CC)

Legal Consulting Department (LC)




VICE PRESIDENT

VICE PRESIDENT

VICE PRESIDENT


Operations Department (OP)

Information Technology

Department (IT)

Program Engineering and Management Department (EA)



SUB-ADMINISTRATOR

ADMINISTRATOR


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4.2 BRIEF DESCRIPTION OF THIRD SET OF LOCKS’ OPERATIONS

The “Expansion of the Panama Canal – Third Set of Locks,” located within the

operational and administrative areas of the ACP, consists of a new maritime traffic

lane along the Panama Canal and includes two new sets of locks, one on the Atlantic

site, known as the Agua Clara Locks, and the other one on the Pacific, known as the

Cocolí Locks. These locks provide an expanded transit system for Neopanamax

vessels, which allows for the doubling of the cargo volume and the traffic flow

through the Canal.

The operational phase of the project officially began on Sunday, June 26, 2016, when

the Panama Canal Authority directed the first transit of the Andronikos ship, a

container ship owned by Cosco Shipping Panamá which is 48.25 meters in beam and

299.98 in length, and has a maximum container carrying capacity of 9,472 TEUs.

The construction of the Third Set of Locks opens the market to global connectivity,

by allowing the passage of Neopamanax ships, whose manufacturing features

(length, width, and draught) and larger size allow for an increase in container

volume and openness to global trade, with the transit of other types of vessels, which

was not possible before due to the dimensional restrictions of the locks built in 1914.

The activities related to the locks’ operational phase are delimited by the navigation

channel that includes the Pacific and Atlantic accesses, as well as the new Cocolí and

Agua Clara Neopanamax locks (See Figure 2, Location of the Cocolí and Agua Clara

Locks Components), with their respective approach channels, the navigation

channel, the dredged material disposal sites, which are still in use for maintenance

activities and the entire water mirror of the Gatún reservoir and its banks.

In its second year of operation, the Expanded Canal has set records and has

surpassed expectations, redefining world commerce routes with a positive impact at

a global level.

As of the date of this report, the ACP has reported the transit of 3,745 Neopanamax

vessels that have used the expanded Canal since it was opened on June 2016. More

than 53% of these vessels are container ships, followed by 28% liquefied petroleum

gas (LPG) carriers, and 10% of vessels transporting liquefied natural gas (LNG),

which is one new segment for the interoceanic route. Other types of vessels, such as


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bulk carriers, tankers, car carriers, and passenger ships, have also transited through

the new locks.

Other notable transits so far include the MSC Anzu, which became the 1,000th transit

on March 19, 2017, and the COSCO Yantian, which was recorded as the 2,000th

transit, on September 26, 2017. The Norwegian Bliss is the biggest cruise ship to cross

the Canal. To date, the Theodore Roosevelt is the only container ship that has

transited the Canal, with a total of 14,863 TEUs. Another important milestone is the

transit of three LNG carriers on the same day in April 2018, and the first shipment

of LNG from Dominio Cove Point in Maryland to Japan on April 28, 2018. A total of

358 LNG carrier transits have been reported from June 26, 2016, and a 50% growth

is expected in this segment, as compared to fiscal year 2018. The Panama Canal is

now ready to handle these transits as part of their current operations.

At the environmental level, the Expanded Canal helped reduce 17 million tons of

CO2 during its first year of operation, thanks to reduced travel distances and to the

greater cargo capacity offered to its clients. Furthermore, the ”Green Connection”

Environmental Program was launched in recognition of clients who care for the

environment and who encourage other competitors to implement technologies and

standards to reduce pollutant emissions. The program includes the “Environmental

Premium Ranking” and the “Green Connection Award”.

4.3 LOCKS OPERATION AND MAINTENANCE ACTIVITIES

This section describes the activities or programs implemented by the ACP during the period from January to June 2018 in order to meet the environmental and social commitments undertaken in the approval resolution. The activities described below refer to the components audited by the ERM team.

4.3.1 LOCKS OPERATIONS

This section relates to the operation of the Third Set of Locks in the Pacific and the Atlantic sites. See Figure No. 2, Third Set of Locks Components Visited.

Some of the subjects that require more emphasis during the Third Set of Lock’s operational phase at the environmental level are those related to the treatment of waste water from the new locks workers’ buildings, the impact of the Canal’s maintenance and routine work activities on air quality, water quality monitoring at Gatún Lake, and the replanting of slopes in the areas where the Third Set of


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Lock’s administrative and maintenance buildings are located, in addition to the navigational channels at the ocean inlet, as an erosion, sedimentation, and stabilization measure to avoid the accumulation of sediment that could affect draft on the navigational channel.

Figure 2. Third Set of Locks Components – Pacific Site and Atlantic Site

Source: http://micanaldepanama.com/ampliacion/fotos/


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4.3.2 LOCKS MAINTENANCE

The Grupo Unidos por el Canal, S.A. (GUPCSA) consortium, made up by the

Spanish company Sacyr, the Italian company Impregilo, the Belgian company Jan

De Nul, and Constructora Urbana, S.A. (CUSA) from Panamá, will provide

maintenance to the new locks during a three (3)-year period under contract with the

Panama Canal Authority (ACP). For this reason, the consortium has established the

following facilities at each lock site: Maintenance Building and Warehouse Building,

storage yard, and outdoor workshop.

The automotive equipment maintenance is conducted in the workshop building.

These activities produce hazardous waste, such as used vehicle oil filters, used oil;

hydrocarbon, grease, or oil-stained rags, and lubricants, among others. Also,

different types of chemical products are stored in the spare parts warehouse,

including thinner, lubricant tanks, etc.

In addition, at the Maintenance Building, GUPCSA performs maintenance of valves,

cylinders, and other hydraulic system parts involved in the operation of the gates.

Maintenance for the Third Set of Locks’ operation includes the Filling and Emptying

systems, Locks Systems, Locks Gate System, Lighting Systems, Foam/Water

Firefighting Systems, Bridgeways, lock gate recess closures, Communication

System, and other aspects of the work assigned under the Technical Support

Maintenance Period, G00/UPCWPR0040-Appendix 3-The Maintenance Service

Equipment List.

All maintenance tasks related to the monitoring and correction of potential

landslides, slope failures, and/or morphodynamic, geodynamic, and erosive

processes are conducted by the Geotechnical Section of the Panama Canal

Authority’s Engineering Division.

Maintenance of the dredging of access and navigational channels (at the expanded

waterways and at the cut) is performed by the Dredging Division.

4.4 EQUIPMENT USED IN THE THIRD SET OF LOCKS

As stated above, Grupo Unidos por el Canal, S.A., is under contract with the ACP to

provide maintenance services to both locks (Pacific and Atlantic) for three (3) years,


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of which 24 months had already passed by the end of this audit period. Therefore,

they have the required equipment, machinery, and vehicle fleet to perform these

duties in the areas for which they are responsible.

Table 2, below, shows a list of equipment used by GUPCSA for the Third Set of

Locks’ maintenance activities:

Table 2. Equipment Used by GUPCSA for Maintenance of the Agua Clara and Cocolí Locks

Source: ACP 2017-2018

Other equipment used for maintenance and operation of the Third Set of Locks come

from the ACP’s Locks and Facilities Maintenance Division and the Dredging

Division (OPE and OPD).

4.5 PERSONNEL

The operation of the Third Set of Locks is carried out by specialized human capital,

organized under the ACP’s managerial organizational structure. See Figure 1,

Panama Canal Authority Organizational Chart.

Equipment Name in

English

Equipment Name in

Spanish

Telehandler Cat Tl 1255 Manipulador telescópico

Cat Tl 1255

Forklift Montacarga

Truck mounted crane Grúa sobre camión

Excavator Excavadora

(2) Mobile crane 90 T Grúa móvil de 90 T

Mobile crane 40 T Grúa móvil de 40 T


Manlift Elevador


Bob Cat Minicargador (marca Bob) Cat)


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During the operational phase, the ACP continues to implement the mitigation

measures established in the Environmental Impact Assessment under the

supervision of the Environment, Water, and Energy Department’s (EA)

Environmental Division.

The Locks Division of the Panama Canal Authority’s Operations Department is in

charge of managing and operating the new expanded canal facilities. Specifically, as

of June 2018, a total of 210 employees (108 at the Cocolí Locks (OPEC) and 102 for

the Agua Clara Locks (OPEL)) had been assigned by the ACP to the new locks

operations (Cocolí and Agua Clara).

GUPCSA has permanent workers at the locks facilities in Agua Clara and Cocolí,

who are responsible for performing maintenance on both locks. According to

information provided by the Safety and Environment Official, Angélica Pujol, a total

of 75 employees and 72 employees held different technical and administrative

positions at the Cocolí and the Agua Clara lock, respectively, as of the closing of June

2018.


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5 VERIFICATION OF THE THIRD SET OF LOCKS’ ENVIRONMENTAL AND SOCIAL REQUIREMENTS

This section describes the compliance status of the mitigation measures and the EMP monitoring plans during the period comprised between January and June 2018. The compliance matrix corresponding to each Environmental Program composing the EMP with the measures laid down for the Expansion Program-Third Set of Locks is presented in Section 7 of this report. Below is a description of the degree of compliance for each environmental aspect evaluated for the Expansion Program’s Third Set of Locks operations.

5.1 EQUATOR PRINCIPLES

During the July 17-19th visit, interviews were conducted with locks

operations personnel at the Atlantic and Pacific sites, as well as with

employees from the Environmental Division’s Environmental Assessment

Section and Watershed Management Section. Based on these interviews and

on the review of compliance documents for the activities for the operational

phase EMP, the ERM Team concluded that, in its operational phase, the Third

Set of Locks continues to be aligned with the requirements of the Equator

Principles Financial Institutions (EPFIs).

The Equator Principles and their applicability to the program are as follows:

1) Review and Categorization

The program was classified as Category III under national legislation,

which is equivalent to the Equator Principles Category A. This

requirement was met.

2) Environmental and Social Assessment

The Project is in compliance with Principle 2. The Category III

Environmental Impact Assessment was approved by the national

environmental authority.

3) Applicable Environmental and Social Standards

According to the inspection performed by ERM from July 17-19 2018, as

well as the documents, logs, and reports reviewed, it is confirmed that the


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subject mitigation measures and related programs are being properly

overseen and implemented by the ACP environmental team and its

contractors. These include qualified specialists and skilled professionals

who implement and review the mitigation measures and who verify the

environmental conditions through programmatic visits, sampling, and

analysis of sampling results. The ACP team regularly reviews the

operational conditions and the environmental aspects identified in the

EMP and assuring their compliance with all applicable environmental

legislation requirements.

Below are the main IFC Performance Standards (PS) that apply to the

operational phase regarding the verification of the Third Set of Locks’

environmental management.

PS1. Environmental and Social Management System Assessment. ERM

was briefed by representatives of the Environmental Division’s Basin

Management Section, which during the present reporting period had over

25 employees working in the communities on the implementation of the

various environmental programs, which include participatory activities,

environmental education, implementation of the Environmental

Economic Incentives Program to enhance environmental performance and

the implementation of the Cadastral Program to regularize land tenancy.

In addition, the ACP, through its Environmental Division, issues periodic

reports to the communities of the basin on the management of the

Expansion Program – Third Set of Locks and the different actions carried

out by the ACP for the protection of water resources. Furthermore,

through participatory platforms throughout the Canal’s watershed, the

ACP has created six Environmental Monitoring Commissions aimed at

addressing and channeling to the competent authorities any complaints or

claims in connection to activities that may affect the social-environmental

status of the Panama Canal Watershed. The system aligns with the

Equator Principles and the IFC Performance Standards (specifically PS 1,

Paragraphs 17-19, regarding its organizational capacity and competence).

ERM noted during the July 2018 site visit that these programs are under

constant review and improvement by ACP staff.


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PS2-Labor and Working Conditions. According to the review of the

recruitment process, the employees who work in the Pacific and Atlantic

Locks totaled 210 at the end of June 2018. ERM reviewed evidence of

ACP employment programs that address the staffing needs of the Third

Set of Locks, including:

Recruitment events which led to the hiring of 100 new employees

as line handlers (pasacables).

Enrollment of candidates in advanced skill training programs such

as those required for welders and lathe operators, which placed 23

candidates in training programs.

Maintenance of a publicly accessible employment portal on the

ACP website.

Also, ERM was informed of the improvements to the working conditions

of line handlers, with the installation of rest areas (sheds) in addition to

the line handler buildings contemplated for each lock during the

construction phase, which makes a positive contribution to the working

conditions of these employees.

Based on this evidence, ERM believes that the operational phase of the

Third Set of Locks will continue to create jobs for this operational phase as

new needs and challenges related to vessel transit arise, in accordance

with the measures established in the EMP, and in a manner aligned with

the Equator Principles and the IFC Performance Standards.

PS3- Pollution Prevention and Abatement

ERM conducted field verifications and reviewed supporting documents

and reports from contractors indicating the active implementation of the

measures contained in the EMP to mitigate and prevent contamination of

the environmental aspects that make up the Locks. Preventive actions

have been taken, such as spill control systems installed at both Locks;

emergency systems, WWTPs, slope stabilization measures, hydro-

seeding, early warning systems and landslide prevention control

measures, and vehicle fleet and equipment maintenance. At the


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Community level, environmental programs are in place, aimed at the

protection and conservation of natural and water resources.

In addition, the environmental monitoring of air quality, water resources, and

effluents is conducted, as well as the prevention of erosion in the main

navigation channels. ERM considers that the Third Set of Locks is controlling

the impacts identified in the EIA Report for the operational phase in

compliance with the EMP and the Equator Principles and IFC Performance

Standards.

Among other initiatives for the reduction of pollution caused by the transit of

ships, the “Green Connection Environmental Recognition Program,” which

includes the “Environmental Premium Ranking” and the “Green Connection

Award,” have been implemented.

The continuity and effectiveness of these programs was confirmed by ERM

through field visits and the review of documents, as part of monitoring visit of

July 2018.

The “Green Route” environmental recognition program, which began in July

2015, promotes the reduction of greenhouse gas emissions, by recognizing

vessels that meet the highest environmental performance standards. This

Program rewards clients who show an excellent environmental management

and encourage others to implement technologies and standards to help reduce

greenhouse gas emissions. It is estimated that the shorter travel distance and

higher cargo capacity offered by the Expanded Canal will allow for a reduction

of approximately 160 million tons of carbon dioxide (CO2) emissions in the next

10 years. 1

PS4. Community Health and Safety

According to a communication provided by the ACP, ERM confirmed that the

ACP has established a security system for the transit of small vessels and ships

1 Reference from the Green Route program, www.micanaldepanama.com, and document provided by the

ACP.

http://www.micanaldepanama.com/


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through the access channels of the Agua Clara and Cocolí locks. ERM believes

that the Third Set of Locks is offsetting impacts in compliance with the EMP,

the Equator Principles, and IFC Performance Standards. ERM observed that

this system continues in operation as of the July 2018 visit.

PS5 - Acquisition of Land and Involuntary Resettlement: ERM reviewed

documents that show that there are legal control mechanisms to prevent

settlements, migratory flows, and affectation to structures in ACP heritage

lands. In addition, during this period, the lake was not brought to the highest

operational level (Project for the Elevation of the Operational Level (ENO));

and no involvement of existing structures is reported. In addition, through the

ENO project, it was verified that the structures on the banks of the Lake will be

out of the flood-prone area, others were adapted to the projected level, and

other structures were relocated. During the site visit and/or the review of

documents, ERM found no evidence of new or potential impacts to structures

that would require compensation. Consequently, ERM believes the

operational phase of the Third Set of Locks is aligned with the EMP and the

Ecuador Principles and IFC Performance Standards on this regard.

PS6 - Conservation of Biodiversity and Sustainable Management of Natural

Resources. ERM reviewed documents and interviewed the staff of the

Environmental Division, on the various environmental programs that are

being implemented in the Panama Canal Watershed. According to these

reports, these actions have a positive impact on the environmental practices

and culture of the communities. They have also led to improvements in

productive activities, improvements in the quality of life, and the conservation

of natural and water resources . There is constant communication with the

communities and the ACP is working together with other institutions through

a participatory platform of basin and sub-basin Councils, which has enabled

the success and expansion of programs throughout the Panama Canal

Watershed.

PS8 - Cultural Heritage

While EMP measures to mitigate impact on cultural heritage are not applicable

to the operational phase per se, the ACP continues to implement public

education programs such as publications and museum exhibitions to share

archaeological, historical, and paleontological resources that were discovered


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and protected during construction-phase activities. This also includes living

heritage sites such as the Gatun Cemetery, which the ACP continues to

maintain and improve, and which hosts visitors who keep coming to pay their

respects to deceased ancestors and friends who first came to the areas in the

nineteenth century to work on the construction of the Transisthmian Railroad

and in early Canal construction efforts.

4) Management System and Action Plan

The Environmental Division of the Panama Canal Authority has a

management system in place that allows it to keep records of all the

Expansion Program’s social and environmental aspects, including the

monitoring of activities reported in the contractors’ reports and audits, as

well as the field monitoring of compliance with the contracts. All records

are kept in printed and electronic format.

5) Consultation and Disclosure

It was verified that compliance with this Principle continued during this

period. The ACP Environmental Division’s Watershed Management

Section develops programs, in a participatory and inclusive manner,

which are part of the Comprehensive Watershed Management Plan and

provide support to the communities in order to achieve a local leadership

that will empower the population and contribute to the advancement of

the Plan’s strategic principles. As recommended in ERM’s previous

monitoring report, disclosure of successful experiences with this program

had substantially increased, as witnessed during ERM’s July 2018

monitoring visit.

6) Grievance Mechanisms

The ACP has established a procedure to receive, analyze, and solve

complaints in accordance with the institution’s environmental and social

policy, and in line with this Equator Principle. During the reporting period

covering from January 2018 to July 2018, one complaint was reported

through the Escobal Local Lake Committee regarding the brackish taste of

the water used at area homes, which is supplied by the aqueduct under

the management of IDAAN. Samples were taken, and a water analysis was

performed in different parts of the Escobal area by ACP water quality

technicians, a social specialist from the Environmental Division, and


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delegates of the Lake Committee. The complaint was successfully closed

once it was determined that the taste of the water was due to the use of

aluminum sulfate during the water treatment process, as explained by the

IDAAN. This information was conveyed to the Escobal Local Lake

Committee in a note dated Thursday, July 26, 2018, therefore ruling out

the connection between the complaint and the operation of the Third Set

of Locks.

7) Independent Review

The Panama Canal Authority hired an auditing company, Environmental

Resources Management (ERM PANAMA S.A.), to prepare the Fourth

Compliance report on the implementation of the mitigation measures

(operational phase), covering the period from January to June 2018. The

program is aligned with this Equator Principle.

8) Covenants

The ACP continues to implement the aforementioned measures in each of

the Programs included in the Environmental Management Plan (EMP)

contained in the Environmental Impact Assessments approved by

MiAmbiente. The program is aligned with this Equator Principle.

9) Independent Monitoring and Reporting

During this period (January-June 2018), the fourth compliance audit of the

Environmental Management and Monitoring Plans for the Third Set of

Locks’ operational phase was conducted by ERM PANAMA S.A., an

environmental auditing company registered with the Ministry of

Environment under registry number DIPROCA-EAA-003-2013 /Act.2016.

5.1.1 OCCUPATIONAL HEALTH AND SAFETY PROGRAM

The operations of the Agua Clara locks in the Atlantic and the Cocolí locks in the Pacific

are conducted under the supervision of ACP representatives who are responsible for

monitoring and verifying the Contractor’s implementation and compliance of the health

and safety program. The ACP’s oversight and monitoring role in the protection of the

environment and the occupational health and safety of the work performed by the

contractor is played by the ACP’s Environmental Division and the Industrial Safety and

Hygiene Unit, respectively.


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ERM evaluated occupational health and safety aspects based on the review of the

contractors’ reports, visits to the operation areas, and interviews with ACP and GUPCSA

occupational health and safety representatives. ERM was able to confirm the

implementation of occupational health and safety measures, as well as the application of

the procedures established in the Occupational Health and Safety Manual and the Locks

Division Safety Manual. In reviewing the contractor’s reports, ERM observed that two

accidents were reported by maintenance personnel. An accident took place in the Atlantic

in April and a minor accident was recorded in the Pacific in May 2018. Both incidents

were addressed in a timely manner and employees returned to work. It was also informed

that the aforementioned Contractor’s control document, G00/UPCHSM0002 Health and

Safety Manual Maintenance, is applied. In a tour of the facilities at both locations during

the July 17-19 visit, ERM made a field verification of the hygiene and safety conditions at

the facilities.

5.2 ENVIRONMENTAL AND SOCIAL MANAGEMENT IN THE OPERATIONAL PHASE

This section details the relevant aspects of the different programs and environmental plans established under the Environmental Management Plan which are aimed specifically at the operational phase. The results of the evaluation of compliance of the mitigation and compensation measures are outlined in Section 7 herein.

5.2.1 AIR QUALITY, NOISE, AND VIBRATION CONTROL PROGRAM

Air Quality Control Program

The air quality mitigation measures implemented in the Pacific and Atlantic Locks areas included: (1) preventive maintenance of heavy equipment and vehicle fleet, (2) restrictions to solid waste incineration in the working area, (3) equipment and vehicle speed control, (4) periodic fumigation of the premises, and (1) preventive maintenance of the tugboat fleet.

During ERM’s visit to GUPCSA facilities at the Cocolí (July 17, 2018) and Agua Clara (July 18, 2018) locks, interviews were conducted with workshop and Safety employees, who explained the maintenance routine for heavy equipment/machinery and vehicle fleet. These activities are recorded in their environmental monthly reports from January to June 2018. According to these logs, the contractor has followed the preventive maintenance plan required for their equipment and machinery, thus complying with air the quality control program. For example, by performing oil level checks and replacing fuel, air, and engine oil filters. They also have a record of the condition of vehicles during the months of January to June 2018. This list indicates the maintenance condition (good, average,


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poor, or critical) and whether maintenance services have been provided, are pending, or are delayed, as well as the schedule of the next maintenance service. An equipment maintenance log is also kept under the GOO/UPCQMM0002” Maintenance Period Quality Manual.

Periodic maintenance is performed on ACP vehicles used for the operation of the Agua Clara and the Cocolí locks for the January-June 2018 period. The maintenance log of vehicles provided by the ACP was reviewed, which indicates the work order number, the description of the maintenance performed, the asset number, the location, the condition, the notice date, and the plant.

The monitoring of stationary and vehicle sources is conducted annually. The next monitoring will be performed in mid-August 2018. During the previous period, this monitoring was conducted by Corporación Quality Services. The measurement of vehicle emissions was performed from June 12 to July 5, 2017. Measurements were conducted on approximately 300 vehicles owned by the ACP, which were distributed among the areas of Corozal, Miraflores, Gamboa, Balboa, Pedro Miguel, Monte Esperanza, and Gatún.

According to the results obtained comparing the permissible limits of E.O. 38 of June 3, 2009, it was found that idle gasoline-fueled vehicles, 800-100 rpm 199, met the regulatory maximum and minimum limits. At idling speed 2500 ±300 rpm, 181 vehicles met the regulatory maximum permissible limits.

One hundred percent of the diesel-fueled vehicles were in compliance with the maximum permissible opacity limits. (Appendix D Land and Water Vehicle Maintenance Log).

Furthermore, the ACP conducts additional air quality control activities, such as the tugboat fleet maintenance program for the Pacific and Atlantic locks. Maintenance is performed by MARINSA PANAMA S.A. every 28,000 hours. Below is a sample of the maintenance performed on part of the tugboat fleet during this period:

Maintenance of the Cerro Picacho tugboat in Colón, on June 19, 2018.

Maintenance to the Cerro Punta tugboat, Miraflores, on June 29, 2018.

Maintenance report of the Pequení tugboat in Miraflores (April 6 to May 15, 2018). Appendix D includes the Tugboat Maintenance Log as of June 30, 2018.

Another Program


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The ACP has also developed the Green Route Strategy, aimed at channeling environmental management efforts and operational energy efficiency, as well as at the sustainable development of the Panama Canal Watershed and its areas of responsibility.

ACP’s contribution includes the implementation of a CO2 emission calculation module for the maritime industry, which enables CO2 emissions to be calculated and identified for maritime trade routes, particularly for vessels opting to use Panamá’s all-water route.

It is estimated that the expanded Canal’s Green Route will reduce CO2 emissions by more than 160 million tons in the first 10 years of operation. The initial calculation was 9.6 million tons; however, this module allowed them to calculate that CO2 were cut by 17 million tons, as compared to alternative routes, thus contributing to a general CO2 emission reduction of over 35 million tons, considering all transits through the Panama Canal.

The Panama Canal has established a performance recognition program for customers and vessels that meet and exceed the environmental limits imposed by the International Maritime Organization (IMO) and/or for outstanding compliance of globally-recognized environmental parameters. Five environmental parameters have been selected, which are described below:

1. Energy Efficiency Design Index (EEDI);

2. Environmental Ship Index (ESI), (the international standard used by the biggest ports of the world);

3. NOx (nitrogen oxide) emissions, due to the performance of its TIER2 motor;

4. LNG-powered vessels; and

5. Reduction of tons of CO2 due to the use of the Panama route, as compared to alternate routes.

The “Green Connection” recognition uses vessel motor design and efficiency, fuel efficiency measures, and emission reduction due to the use of the Panama Canal Route. The calculation of these emissions will aid in the selection of routes, not only based on cost variables, but on other environmental factors. This “Green Connection” environmental program recognizes customers who show they care for the environment and who encourage other competitors to implement technologies and standards to reduce emissions. The program includes the Environmental Premium Ranking and the Green Connection Award.


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This program has two classification levels to award the prizes for emission reduction: Level 1 and Level 2.

Through the implementation of the green strategy, the Panama Canal not only benefits the country, but it also benefits global initiatives that fight against climate change. In this sense, the Panama Canal recognized the good environmental practices of its clients and their commitment to reducing emissions of 100 vessels that accepted the Green Connection Award. The ACP received 400 applications for the Environmental Premium Ranking from the different segments of vessels transiting along the Panama Canal, including the CMA CGM T ROOSEVELT and the CMA CGM J. ADAMS, each with a total TEU Allowance (TTA) of 14,863 which, upon passing through the Third Set of Locks, contributed to a reduction of up to 30,000 tons of CO2, as compared to alternate routes.

Noise Control Program

GUPCSA’s environmental monitoring reports show that, during the past period, it was verified that machinery was in adequate condition and that preventive maintenance was provided to said machinery.

5.2.2 SOIL PROTECTION PROGRAM

According to GUPCSA’s monthly reports and the Environmental Management System Manual, the mitigation measures employed for soil protection included the following: (1) landslide control measures, (2) erosion and sedimentation control measures, (3) slope stabilization methods, (4) soil compaction measures, and (5) soil pollution control measures.

As part of the steps taken for soil protection, soil preparation measures were applied with dredged material from the disposal site in Camacho. This material was used as backfill in grass planting areas at the Cocolí Locks in the Pacific sector. In the Atlantic, slope maintenance and hydroseeding was performed at the Agua Clara Lock. The implementation of sediment retention measures was observed at both locations, such as placing sandbags around the storm drains in the open areas along the chambers (upper, middle, and lower chambers, on the continental and island sides) of the Cocolí Lock. (Appendix A, Photographic Record).

Trébol Services, INC. was hired, under Contract No. CDO364591OPEM, to conduct erosion and sedimentation control tasks. The scope of their work includes maintenance of premises, sediment, and green spaces in the operational areas of the Pacific and Atlantic sites.

Maintenance of works


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During this period, a blockage was identified at the French drain network that was built at the T-6 disposal site during the Expansion Project, which caused flooding in the area adjacent to Vía Centenario. The location of the main blockage was identified, and a drain was designed with drainage pipes (T-6 drain). Personnel from the Locks and Facilities Maintenance Division (OPEM) worked in the construction of this drain. These works began in late April 2018, but workers were temporarily withdrawn from the project on May 25, 2018. Although they are currently working on the installation of pipes under the Borinquen road, workers will be subsequently mobilized along with the equipment to complete the construction of the T-6 drain.

Environmental remediation work was performed in the area near Via Centenario. An exploratory excavation was conducted on Tuesday, March 20, to look for the water level in the French drains watercourse. It was found that sediment material from the last disposal vat created for the Mindi dredge. An estimated 6,000 cubic meters (m3) were excavated.

Below are the actions performed during this period regarding the accumulation of water forming a “lake” along Via Cincuentenario:

1. The drainage plans of the drainage system built in this area prior to the use of dredge disposal sites during the construction phase were reviewed.

2. The “lake” site was inspected, which shows a stream that surrounds the disposal sites.

3. An inspection of Via Centenario was conducted. There are no signs of damage, fissures, or cracks that could cause defects due to the accumulation of water indicated in the report.

4. Land surveying and geodetic imaging were requested to design the discharge of accumulated water at a point identified as the site of the potential blockage of the drainage system. Support was requested from internal workers, who will implement the proposed solution (the construction of a discharge drainage system measuring approximately 72 meters in length). It is estimated that it will take a month to complete the construction of the drainage system to dry the lake along Via Centenario.

A second impoundment was identified in a loaned area on the Pacific Site, which requires no maintenance or adjustments due to blockages. The impoundment is located in the area known as Cerro Sucre, from which Basalt material was extracted to be used as backfill for the new Set of Locks.


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When the material was extracted, a pit was formed that created the Sucre reservoir. This site is used by OPEM personnel to extract irrigation water for landscape maintenance at the Cocolí Locks (Landscape irrigation system). The reservoir is also used to test new erosion control technologies.

The site is the current supplier of irrigation water and dust control maintenance in times of drought.

Landslide Control

The Geotechnical Section of the ACP’s Engineering Division drafted a report that includes the Landslide Control Program for the monitoring period from January to June 2018. This report states the following:

No significant landslides were reported along the banks of the Culebra Cut during the period from January to June 2018.

Due to the heavy rains affecting the area during the month of June 2018, some landslides were reported in the Paraíso sector without causing any major incidents. The heavy rains were caused by tropical waves (Tropical Wave #8), with a total rainfall of 100 millimeters (mm) being recorded by the Pedro Miguel rain gauge station within a one-hour period. This amount of rainfall corresponded to a 60-yar period.

Two (2) projects were completed during the audited period. The first one involved the stabilization of the landslide at the East Whitehouse slide, and the second one consisted in the rehabilitation of the Summit channels.

Progress continues to be made in the acquisition of landslide monitoring equipment. During this period, the ACP acquired two (2) new piezometers. A total of one hundred eleven (111) underground instruments are currently in operation. The report in Figure 10 shows a map indicating the location of underground instruments, as well as the areas were landslides have been recorded.

According to the reports submitted by the Geotechnical Engineering Section of the ACP’s Engineering Division, dams 1E, 2E, 1W. and 2W are in good condition and performed well during the period from January to June 2018. It is recommended that vegetation areas be cleaned, as well as monitoring the piezometers of dam 2E more frequently, using the automated system. (Appendix E. Landslide Control Program. Culebra Cut. Status Report. January-June 2018.)


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No landslide alert areas were reported from January to June 2018. The areas with the greatest number of landslides were Ceniza and Summit, which accumulated between 100 and 250 mm in the last year. (Appendix E. Dam and Landslide Control Log.)

5.2.3 WATER RESOURCES PROTECTION PROGRAM

The Water Resources Protection Program that is part of the Environmental Management Plan (EMP) was designed to allow the Third Set of Locks to operate under adequate environmental and social impact prevention and mitigation measures. The purpose of this program is to execute and implement the necessary measures to prevent and minimize significant negative impacts on water resources during the Third Set of Locks’ construction and operational phase.

Based on the field visits conducted from July 17-19, 2018, and the documentation provided by the ACP, ERM noted that the measures to reduce the deterioration of water quality due to water level fluctuations in Gatún Lake are still in place, as well as measures to reduce the deterioration of water quality due to the operation of the third set of locks. The main documents reviewed by ERM include:

Gatún Lake Water Quality Report for the period from January to June 2018, dated June 2018 and prepared by the Environment, Water, and Energy Department’s Environmental Division. This report includes four appendices (Appendix 1- Figures; Appendix 2 – Total Dissolved Solids, Sulfates, and Chlorides Data; Appendix 3 – Vertical Profiles Data; y Appendix 4 – Continuous Monitoring Data).

Excel list with the total number of water extraction concessions and their location in Gatún Lake. Estimated annual water consumption between 2007 and 2017.

Email dated August 1, 2018, sent by the ACP Water Division, describing the salinity prevention and control measures implemented at Gatún Lake.

Contract between the ACP and BA-QUIMICOS S.A. to provide maintenance to Wastewater Treatment Plants (WWTP).

Liquid Effluent Report. Cocolí and Agua Clara Locks, prepared by the Environment, Water, and Energy Department’s Environmental Division for the January-June 2018 period.

Wastewater monthly reports from January to June 2018, prepared by INSPECTORATE PANAMA (January and February) and PFR Environmental S.A. (March to June), ACP’s contractor companies in charge of the monitoring of WWTP’s effluents.

Canal Port Captain Log Book, which records failures identified in the vessels’ wastewater containment and treatment systems, as well as the corrective measures


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implemented during the inspection as instructed by the ACP, prior to entering the canal’s waters.

Culebra Cut Landslide Control Program. January-June 2018 Report. Prepared by the ACP on June 2018.

Breakwater Erosion Control and Maintenance Program. Fiscal Year 2017 Report. Prepared by the ACP’s Engineering Division, Geotechnical Engineering Section, dated January 2018.

Presentation on the 2018 Sediment Control Program. Suspended Sediment Program Report regarding major rivers that flow into the Gatún Reservoir. Period from January to June 2018.

It should be noted that the ACP continues to implement water conservation measures for transit operations of the Third Set of Locks due to the decrease in rainfall at the Panama Canal’s watershed during the dry season. The proper implementation of measures for the prevention and control of saline intrusion caused by the operation of the third set of locks has also continued in Gatún Lake. These measures include flushing the locks when chloride concentrations in the areas around the locks show warning values, as well as a reduction in the amount of time that the gates remain open. These measures enable the ACP to guarantee an adequate water quality in the Gatún Lake.

ERM verified that the ACP continues to adequately implement measures for the protection of water resources, such as: (1) the installation and use of secondary containment in the flammable materials and hazardous waste storage areas, (2) the use of physical barriers for sediment containment near surface water bodies, (3) the adequate storm water and wastewater management; (4) monitoring of effluent from Wastewater Treatment Plants (WWTPs), monitoring of dredging activities, and monitoring of chlorides and other Gatún Lake-related parameters; and (5) implementation of the landslide monitoring and response protocol, including record keeping of the water concession contract currently in force within the Gatún Lake.

5.2.4 FLORA AND WILDLIFE PROTECTION PROGRAM

The Third Set of Locks is currently in its operational phase in the Atlantic and the Pacific. Based on GUPCSA’s environmental monitoring reports, ACP reports, and the field visits conducted from July 17-19, 2018, ERM noted that the flora and wildlife protection measures continue to be effectively implemented.

Flora

The flora protection program has been primarily based on the implementation of replanting measures and the prohibition of wild plant collection or use, protecting vegetation near work areas and roads, and implementing the Reforestation Plan.


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During the July 17-19, 2018 field visit, ERM observed that replanting activities have practically been completed at the Atlantic locks, where maintenance is underway.

Areas covered under the Reforestation Plan were visited at Alto Playón, Province of Darién, Parque Soberanía (Agua Clara and Camping Resort) and Wuacuco No.1. Comarca Madungandí. According to the report submitted by the ACP, seven sites are currently in their maintenance phase.

Sod maintenance activities (Zoysia toro) are being conducted at the Cocolí locks, as well as the preparation of areas for grass planting and the installation of (temporary) dead barriers during the cutting and filling stages. This, within a distance of approximately 200 lineal meters, around drains and other sediment retention areas. For this audit period (January to June 2018), the ACP’s OPEM team continued to identify the areas that need replanting at both locks (Cocolí and Agua Clara), while the resources and planning to perform this hydroseeding work were procured. The hydroseeding is carried out using the Zoysia toro and Bermuda grass species at the Cocolí lock. The fertilization of the Brachiaria has reached a 30% progress.

The green areas surrounding the Cocolí Locks are included in landscaping maintenance contract CD0364591OPEM.

Wildlife

Upon reviewing the rescue reports, ERM confirmed that a total of 23 animals were rescued and relocated in the Cocolí and Agua Clara areas during the period from January to June 2018. (Appendix F, Wildlife and Flora Rescue and Vector Control Report).

The table below describes the wildlife rescued. Table 3. Wildlife Capture and Relocation at Cocolí and Agua Clara

Wildlife Capture and Relocation

N° COMMON NAME QUANTITY SITUATION REMARKS

JANUARY

1 Black vulture 1 Capture and relocation The subject had no injuries; therefore, it was relocated.

2 Spectacled caimans 1 Capture and relocation The subject had no injuries; therefore, it was relocated.

3 Sloths 1 Capture and relocation The subject had no injuries; therefore, it was relocated.

FEBRUARY


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Wildlife Capture and Relocation

4 Sparrow hawk 2 Rescue Squabs were handed to the Ministry of Environment

5 Snake 1 Capture and relocation The subject had no injuries; therefore, it was relocated.

6 Deer 2 Capture and relocation The subject had no injuries; therefore, it was relocated.

MARCH

7 Deer 1 Capture and relocation The subject had no injuries; therefore, it was relocated.

8 Crocodile 1 Capture and relocation The subject had no injuries; therefore, it was relocated.

9 Sloth 1 Capture and relocation The subject had no injuries; therefore, it was relocated.

APRIL

10 Sloth 1 Capture and relocation The subject had no injuries; therefore, it was relocated.

11 American Kestrel 3 Rescue Squabs were handed to the Ministry of Environment

MAY

12 Dog 2 Capture and relocation The subject had no injuries; therefore, it was relocated.


JUNIO

14 Racoon 1 Capture and relocation The subject had no injuries; therefore, it was relocated.

15 Dog 1 Capture and relocation The subject had no injuries; therefore, it was relocated.

16 Crocodile 1 Capture and relocation The subject had no injuries; therefore, it was relocated.


TOTAL 23

Source: ACP, 2018.

Cocolí and Agua Clara Locks Vector Management Log for the Period from January to June 2018

Vector control inspections were performed at the Cocolí and Agua Clara locks as established in the work schedule. Three (3) weekly inspections were conducted to cover the entire lock area. A total of 78 vector control inspections were performed, during which no breeding grounds were found to be positive for Aedes aegypti or Aedes albopictus.


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Ultra-low volume aerial insecticide spraying was conducted on a daily basis for mosquito control in general. Sprayings were performed from Monday to Friday. A total of 31 applications were carried out.

The services of Panamá Pest Management were engaged to perform spraying at both the Atlantic and the Pacific sites for the control of other species, such as rodents, flying insects, and crawling insects, among others. (Appendix F, Wildlife and Flora Rescue and Vector Control Report).

During its field visits, ERM saw signs indicating the crossing of wildlife and informing on the proper care to be taken. In accordance with the information provided, ERM corroborated that wildlife rescue and relocation activities in Third Set of Locks’ operational area have been successful.

5.2.5 SOLID, LIQUID, AND HAZARDOUS WASTE MANAGEMENT PROGRAM

Solid, liquid, and hazardous waste management has been performed in accordance with ACP guidelines and national and international requirements. During the visits conducted from July 17-19, 2018, ERM noted different containers for solid waste disposal in the office areas. At the locks operation facilities on both sites (Pacific and Atlantic), ERM found color-coded 55-gallon drums and/or 1 m3 containers for the collection and classification of different types of waste, including black for waste tainted with hydrocarbons, gray for organic waste, and blue for dry solid waste.

GUPCSA has hired different companies to collect liquid and solid waste, including Alumna System for the management of liquid waste (sewage from portable toilets), which operates in Cocolí and Agua Clara locks. AguAseo is hired for the management of solid waste in the Agua Clara Locks, in the Atlantic site. The final disposal of solid waste in the Atlantic is done at the Monte Esperanza sanitary landfill. At the Cocolí Locks, in the Pacific, solid waste from GUPCSA activities is managed by the Panama Waste Management Company (PWM), while waste from the ACP’s operational areas is managed by Autoridad de Aseo (AA). All waste is taken to the Cerro Patacón sanitary landfill for final disposal.

The types of industrial and hazardous waste generated in the operational areas of the Third Set of Locks are essentially linked to equipment maintenance, such as used oil, used filters, engine coolant, hydrocarbon-stained rags, lubricating oil containers and spent batteries. Servicios Tecnológicos de Incineración (STI) is the company in charge of hazardous waste management at the Cocolí lock in the Pacific, whilst Transporte el Emigrante S.A. (TRANEM) is responsible for the management of used oil at the Agua Clara lock in the Atlantic. During the July 17-19, 2018 field visits, ERM found that these types of waste were managed in accordance with the contractual requirements and


39

pursuant to ACP and international standards. (Appendix G, Solid, Liquid, and Hazardous Waste Management Log).

5.2.6 MATERIAL HANDLING PROGRAM

GUPCSA´s Material Handling Program includes the handling of lubricants, additives, antifreeze, flammable liquids and fuels, compressed gas cylinders and dry materials.

According to the logs included in the monthly reports, GUPCSA keeps an inventory of all materials used in the projects, including hazardous materials, with their respective material safety data sheets (MSDS). Likewise, training sessions were held (induction and safety talks) on this subject.

ERM noted the presence of spill control and fire response equipment, such as fire extinguishers, explosion-resistant lights, tools, and absorbent materials, as well as proper signage regarding the potential hazards associated with the handling of these materials.

In their inspection of the storage areas, ERM verified that an adequate materials and supplies record is kept at both sites. An inventory is kept by using the EAMS/SAA system.

5.2.7 SOCIOECONOMIC AND CULTURAL PROGRAM

Section 8.3.8 (Socioeconomic and Cultural Program) of the Third Set of Locks’ Environmental Management Plan (EMP) lists mitigation measures and plans under 21 subheadings, seven of which are listed as applicable during operations. Each of these seven subheadings and related items are addressed in the subsections below.

Job Creation

According to information provided by the ACP Human Resources team’s office attached to the Locks and Maintenance Facilities Division, as of June 2018 the Cocolí and Agua Clara Locks had 108 and 102 direct ACP employees, respectively. The number of employees at each lock had seen minor fluctuations between 99 and 108 during the current reporting period (i.e., January to June 2018).

Efforts to recruit and hire new staff in a variety of labor categories continues during the present reporting period as confirmed by documents reviewed for this report. Also, for this report, ERM visited and explored the Employment Portal (Portal de Empleo) on the ACP’s official website. The site offers an array of information about employment by the ACP, including current job openings, general information on employment, frequently asked questions, and instructions on how to apply for any of the positions on-line.


40

In addition, ERM was provided with and reviewed a document identifying activities carried out under the Project’s “Panama Maritime Growth” (Panamá Crece Marítimo) program, which involves recent training and graduation of potential ACP workers. The summary documented recruitment and training events that took place between January and June 2018, including the following:

Nine recruitment events that engaged a total of 282 candidates for line handling (pasacables) positions, of which 109 have enrolled in and completed a qualifying course, with 100 candidates now employed by the ACP (100 were still in the preparatory course at the time of this report);

A recruitment program that brought in 23 candidates for extended training program specialized in a series of highly skilled professions now needed at the ACP due to the expansion program. These included such jobs as welder; lathe operator; crane operator, and other highly skilled labor positions.

ERM’s site visit and document review indicate that the operational phase of the Third Set of Locks continues to generate employment in compliance with the EMP and using approaches that are in alignment with the Equator Principles and IFC Performance Standards (specifically PS 2).

Mitigation of Possible Increases in Population and Migratory Flows

Upon reviewing documents and conducting observations during their July field visit, ERM found no evidence that the operational phase of the Third Set of Locks is currently contributing to or is at risk of increasing population and migratory flows. ERM’s site visit and document review indicate that the Third Set of Locks continues to mitigate potential increases in population and migratory flows in compliance with the PMA and in alignment with the Equator Principles and IFC Performance Standards (specifically PS 2).

Minimization of Changes in Land Use

During the previous reporting periods, ERM was provided with and reviewed documentation on the Project’s “Management and Conservation of Water Resources in the Panama Canal Watershed” (Manejo y Conservación de los Recursos Hídricos en al Cuenca Hidrográfica del Canal de Panamá). Most of the programs described in this document address potential changes in land use. More than just an effort to avoid environmentally and socially negative land use changes, the programs are aimed at making land use in the watershed more efficient, productive, and sustainable—i.e. changing land use, but for the better. The presentation described five “major programs.” The first addresses Community Consultation and Participation and Institutional Coordination (Consulta y


41

Participación Comunitaria y Coordinación Institucional). The purpose of this program is to allow for a co-management of the Canal watershed between the ACP and its communities, in order to preserve the water resource. This community socio-environmental management involves the main stakeholders in the basin in the informed decision-making process for the various initiatives that may impact their communities and their quality of life. The ACP, through the Watershed Management Section, consults with 29 Local Committees (Comités Locales), each representing several communicates, grouped into six Advisory Councils (Consejos Consultivos). The program has produced various instruments, including a Water Resources Management Plan (Plan de Gestión de Recurso Hídrico) and Sub-Watershed Management Plans (Plan de Manejo de las Sub Cuencas). The program has several sub-programs, including one that addresses Strengthening and Monitoring of Local Committees and Advisory Councils in the Panama Canal Watershed (Fortalecimiento y Seguimiento de los Comités Locales y Consejos Consultivos en la Cuenca del Canal de Panamá). This sub-program benefits 90 delegates, actors, and institutions. It includes quarterly meetings of the Advisory Councils and supports environmental clean-up days, awareness activities, and training. Another sub-program is the Environmental Conservation and Training for Work Program (Programa de Conservación Ambiental y Formación para el Trabajo). The purpose of this sub-program is to provide training in job skills and competencies under a perspective of socio-economic and environmental sustainability. A third sub-program addresses Environmental and Social Safeguards (Salvaguardas Ambientales y Sociales). This sub-program supports institutional and community workshops on procedures to address grievances (denuncias, reclamos y quejas), gender issues, conflict management, and monitoring committees.

The second major program described in the presentation addresses Environmental Awareness (Concienciación y Sensibilización Ambiental). This program includes a Solid Waste Management Program (Programa de Manejo de Residuos Sólidos), the Our Canal and its Watershed Program (Programa Nuestro Canal y su Cuenca), and an Environmental Events Program (Programa Eventos Ambientales). It also supports watershed guardians, environmental missions and projects, and environmental education.

The third major program described in the presentation addresses Land Cadaster and Titling (Catastro y Titulación de Tierras). The objective of this program is to support small, medium, and large producers to obtain title to the land which they are working and/or living on. According to the presentation, the ACP has helped obtain 6,175 titles to 8,503 properties totaling 51,156 hectares. The titled properties are located in the districts of Capira and La Chorrera, as well as in Colón.

The fourth major program described in the presentation addresses Environmental Economic Incentives Program (Programa de Incentivos Económicos Ambientales). The objective of this program is to protect water resources in the agricultural and forestry regions of the Basin, through the establishment of protective vegetation covering and the


42

establishment of sustainable agroforestry models. Specific objectives include reforestation following several models: conservation reforestation, commercial reforestation, agroforestry programs (e.g., coffee and cacao), and silvopastoral programs (e.g., cattle ranches).

The fifth and final major program addresses the Monitoring of Water Resources and Plant Cover (Monitoreo y Vigilancia del Recurso Hídrico y la Cobertura Vegetal). Additional detailed information was provided to ERM during the July 2018 visit regarding this program, which seeks to enhance sustainable practice as a voluntary environmental self-monitoring program where environmental observations or grievances made by community members are tracked, investigated, and resolved through localized Monitoring and Compliance Commissions (Comisiones de Moitoreo y Seguimiento) consisting of representatives of different sectors such as local government, agricultural and agribusiness. Council members who manage the grievance process go through a day-long group induction process. ERM reviewed various documents related to this monitoring program including, training summaries, grievance lists, and workshop summaries.

The July 2018 site visit confirmed that all of the abovementioned programs are still in place and, indeed, appear to be strengthening. The team placed special focus on the environmental monitoring program. The overall effort is also reinforced by a number of supporting publications sponsored by the ACP. In addition to the above, these publications include the Watershed Update (La Cuenca al Día) program, My Watershed (Mi Cuenca) magazine, information on the monitoring of water quantity and quality, the Water Health Project (Proyecto Agua Salud), and sustainability models for the basin.

Responding to suggestions from the ERM’s July-December 2017 monitoring report, the ACP has undertaken a series of new efforts to give greater publicity to the scope of the activities undertaken to encourage sustainable land use in the Canal’s watershed. Activities included forums, fairs, local community council meetings, TV programming on Canal TV and in the Mi Cuenca publication.

ERM visited the areas and reviewed the documents mentioned in all the Watershed programs during the construction phase. This program has continued to be implemented in the operational phase and has effectively managed, and in fact improved, land use patterns in the Panama Canal Watershed. It is ERM’s opinion that the operational phase of the Third Set of Locks is safeguarding the uses of land in compliance with the PMA and in alignment with the Equator Principles and IFC Performance Standards (specifically PS 6).

Mitigation of the Impact of the Increase in Demand for Transportation on Vehicle

Traffic


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ERM was provided with and reviewed a document that addresses the implementation of the EMP’s measures for the operational phase of the Third Set of Locks to mitigate impacts on vehicle traffic. The document provides information on the days and times when the public can cross the Agua Clara and Gatún Locks, as well as the days and times that the public can cross the canal via ferries provided by the ACP. This document also describes a mechanism for disclosing these schedules. Special hours have recently been established for crossing the Agua Clara and Gatún Locks during national holidays. These mitigation measures continue to be implemented for special days and events, as confirmed by the July 2018 monitoring visit.

Compensation for Impacts to Structures

ERM received and reviewed documents that show that there are legal control mechanisms to prevent settlements, migratory flows, and damage to structures in ACP heritage lands. During this period, the lake was not brought to its maximum operational level (there should be no involvement of existing structures). In addition, through the project to raise the operating level of the lake (ENO, for its Spanish acronym), it was verified that the existing structures in the shores of the lake were outside the floodplain, while others were adjusted to the projected level and other structures were relocated. During its site visit and documentary review, ERM found no evidence of impacts to structures that could require compensation. It is ERM’s opinion that the operational phase of the Third Set of Locks is compensating impacts to structures in compliance with the EMP and in alignment with the Equator Principles and the IFC Performance Standards (specifically PS 5).

Mitigation of Public Services Overload

During its site visit and document review, ERM found no evidence that the operational phase of the Third Set of Locks has contributed to an overloading of public services during the current reporting period. These findings were reconfirmed for this reporting period with site visits and an interview conducted in July 2018. The Project continues to implement the mitigation measures required under the PMA.

Mitigation of Landscape Impacts

ERM found no evidence during its site visit and document review that the Project has negatively impacted the landscape during the current reporting period. It is ERM’s opinion that the operational phase of the Third Set of Locks is mitigating landscape impacts in compliance with the PMA and in alignment with the Equator Principles and the IFC Performance Standards (specifically PS 6). ERM reviewed documentary evidence and noted the results of these efforts during their July 2018 monitoring visit. Additional


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information on measures to mitigate landscape impact is described in the subsection titled “Minimization of Changes in Land Use.”

Other Issues

Organizational Capacity and Competency: During the site visit, ERM was informed that the operational phase of the Third Set of Locks has maintained its staffing level during this reporting period, and that they are working with affected communities2. The activities being conducted by these employees include public consultation, environmental education, agricultural programs, and cadaster improvement. It is ERM’s opinion that the number and qualifications of the social specialists for the Third Set of Locks’ operational phase are very adequate to implement its social programs in alignment with the Equator Principles and IFC Performance Standards (specifically PS 1, Paragraphs 17-19).

Ongoing Reporting to Affected Communities: ERM was previously informed of a wide variety of public information programs on matters important for the Canal and its nearby communities. Materials included environmental videos, three audio recordings of radio broadcasts spots, and nine “Ecotip” fliers. It also includes updated copies of the Mi Cuenca magazine, the monthly El Faro magazine, and a bi-weekly magazine titled Tu Canal. These magazines are targeted at a variety of audiences and include issues such as history, environment, land use, and other public interest topics, but always in connection with the canal, especially those related to environmental issues. During the July 2018, visit ERM reviewed recent issues of these publications and also reviewed a number of presentations and special purpose brochures and publications targeted at local communities, which highlighted sustainable land use and water conservation issues.

These reports also include brochures for four different regions of the Panama Canal Watershed program. It is ERM’s opinion that the Third Set of Locks is reporting to communities within the canal’s watershed alignment with the Equator Principles and IFC Performance Standards (specifically PS 1, Paragraph 36).

Cultural Heritage: The measures in the EMP to mitigate impact to cultural heritage are not applicable to the operational phase per se. The following observations, however, refer to the continuation of cultural heritage activities that further enhance or socialize cultural heritage sites, objects or information discovered and/or protected during the construction phase. ERM reviewed a summary of information shared with the public regarding the ACP’s cultural heritage, including material discovered by the ACP and its

2 The total ranges from 25 to 30 employees.


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contractors, and which are kept by and in custody of the ACP. This includes a number of items directly related to the Expansion’s cultural heritage management efforts. These included the restoration of pre-Hispanic pottery, history of Canal lighthouses, Canal bridges as a part of the history of engineering technology, and colonial transportation in the isthmian area during pre-Canal times, among others. In addition, the ACP informed ERM of on-going plans for an archaeological exhibition at the Museum of the Canal in the historic Casco Viejo area of Panama City. The exhibition will include pre-Hispanic, Colonial and later artifacts from the area of the Canal including materials from the Canal’s initial construction phases, prior to the expansion. This is another example of the ACP’s public education effort to spread the history of the Canal and the exhibition of artifacts discovered and preserved by the Expansion Program.

ERM conducted a walkover at the old Gatún Cemetery during its tour of the Agua Clara Locks last April 2018. During the July 2018 monitoring visit, the same team visually confirmed the conditions of the cemetery as a part of a more detailed tour of the adjacent Agua Clara Locks complex. Based on this visual inspection, ERM confirmed that the ACP continues to implement its regular maintenance program on the cemetery’s facilities and also maintains public access to the area. Furthermore, the team observed that ACP contractor GUPCSA was in the process of building a paved path that will facilitate access to cemetery. This area constitutes an important heritage resource, and is visited by local Afro-Panamanians and, occasionally, by international visitors whose ancestors lived in the zone and supported the construction and operation of the Transisthmian Railway and the Panama Canal in the XIX century. The ACP has developed local awareness and knowledge regarding the funerary resources associated with the Canal’s history through the conservation of the Gatún cemetery and publications on cultural heritage.

5.2.8 CONTINGENCY PLAN

The Agua Clara Locks in the Atlantic and the Cocolí Locks in the Pacific have their own

Contingency Plan User’s Manual, which is located in the Microsoft SharePoint platform

and may be accessed from direct links or from the Operations Department INFORED site.

A telephone hotline, 272-7777, is also available on this site.

Different exercises are conducted as part of the aspects covered under this plan, to

maintain the level of preparedness and alertness. One of these exercises is the ALEPS, an

evacuation exercise for the locks and some of the Canal’s industrial areas that is carried

out once a year.


46

For the January-June 2018 period, the ACP updated the evacuation plans and evacuation

drills were conducted at the Cocolí and Agua Clara Locks. Regarding hydrocarbon spill

control, storage areas have been built which include spill control equipment.

In the subject of preparedness to handle situations involving natural gas carriers, new fire

suppression and extinguishing equipment was acquired, such as dry chemicals tugboats

and high-expansion foam application systems. Also, first responders such as firefighters,

tugboat captains, and locks personnel receive continuous training in subjects that include

natural gas emergency risk and response. The annual drills and seminars conducted since

2016 have focused on preparedness to respond to emergencies in activities involving the

use of natural gas in the expanded canal area, considering that this is a new segment in

the dangerous cargo category.

The ACP is in the process of entering into a contract to update the Canal’s sensitive areas

map. Recruitment efforts are also underway to perform a risk analysis of the Panama

Canal and to update hydrocarbon recovery strategies.3

During the field visit from July 17-19, 2018, ERM was able to verify the firefighting

emergency system and its facilities, and that both locks (Cocolí and Agua Clara) have

Spill Emergency and Response Unit, as well as a Spill Control building for each lock,

equipped with the required supplies according to ACP regulations. In addition, ERM,

witnessed the tests performed on the fire control system at the Cocolí Locks.

The Spill Operations and Response Unite continues to implement the spill control

program, wastewater and stormwater treatment, and its adaptation to the new types of

vessels and locks. No spills have been reported in the Third Set of Locks between January

and June of this year. Work continues to adapt the equipment storage areas at both lock

sites, specifically with the installation of shelves designed for this type of buildings.

Likewise, although the removal of oily waters or used oil has not been required from the

Pollution Response and Control Unit (OPPD-C) in Agua Clara, two used oil tanks were

collected in Cocolí.

3 Source: OPPD, ACP July 2018


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Additionally, ERM reviewed the information on the ACP’s internal use records for the

Early Alert and Protection management of the Cocolí locks in the Pacific and the Agua

Clara locks in the Atlantic.

5.2.9 ENVIRONMENTAL MONITORING PLANS

In the context of the operational phase of the Panama Canal’s Third Set of Locks, the Environmental Monitoring Plan considers the prevention, mitigation, and compensation actions described in the Environmental Management Plan. This section describes the environmental aspects monitored during the operational phase of the locks.

5.2.9.1 AIR QUALITY MONITORING

For the operational phase of the Agua Clara and Cocolí locks in the Atlantic and the Pacific sites, at the time of ERM’s visit on July 17-19, 2018, it was noted that the activities that have an impact on the quality of air are related to the use of motor vehicles and the passing of ships through the canal. It should be noted that the monitoring of stationary and mobile sources is performed once a year; therefore, the results will be presented in the next reporting period (July-December 2018).

Air quality monitoring entails the establishment of monitoring stations, some of them on a continuous basis and others mobile, at the following sites: Miraflores, Paraíso-Pedro Miguel, South of the T6 Disposal Site, and the Water Reutilization Basins of the Agua Clara Locks.

For the period from January to June 2018, air quality monitoring was conducted within the Panama Canal Expansion Program. The results produced by this monitoring activities are included in the report completed by the Environmental Division’s Environmental Assessment Section.

This air quality monitoring program is operated by the ACP through the Paraíso and Pedro Miguel Air Quality Station, as well as through the Environmental Evaluation Laboratory of the Specialized Analysis Institute of the University of Panama (UP). The ACP’s air quality standards are set forth in Regulation 2610-ESM-109, “Norma de calidad del aire ambiente” [Ambient Air Quality Standard], as follows: for 24h: PM10 = 150 µg/m3, SO2 = 365 µg/m3, NO2 = 150 µg/m3, monthly average: PM10 = 50 µg/m3, SO2 = 80 µg/m3, NO2 = 100 µg/m3, and for 1h: CO = 30,000 µg/m3 and O3 = 235 µg/m3.

Point 8.4.3.1, Air Quality Monitoring, of the environmental impact study approved for the construction and operation of the Third Set of Locks, provides that: “For the operation phase, said monitoring will have a cost of B/ 30.500.00. Assuming that passive monitoring is performed at the sites four (4) times per year, and based on the results


48

obtained, after the first year, this could be reduced to 2 annual samplings, one of which would be performed during the dry season while the other would be performed during the rainy season for all the points stipulated in the environmental impact study.

The results of the air quality report delivered by the ACP for this period are presented in Table 4, below.

Table 4. Summary of Average Air Quality Monitoring Results

Location NO2 (μg/m³) SO2 μg/m³ PM10 μg/m³ CO

Paraíso/ Pedro Miguel

5.9 10.14

10.30

315.06

Miraflores Locks

43.2

11.3

34 --

Agua Clara, water reutilization basin

20.3 -- 34.4 --

South T6 disposal site

-- -- 24.2 --

Ancón 25.9 -- 23.4 --

Source: Air Quality Report, Expansion Program-Third Set of Locks, Environmental Assessment Section,

Environmental Division, ACP, January-June 2018 period.

Note: Some sites have no data as established in the EMP.

Based on the results obtained from PM10, NO2, and SO2 monitors, no environmental

pollution was recorded at the monitoring sites according to the ACP’s Ambient Air

Quality Regulation 2610-ESM-109. By verifying the results from previous years, it can be

noted that the AF concentration for this period, Fiscal Year 17, and Fiscal Year 18, has

remained relatively at the same level compared to previous years. There were slight

fluctuations at some monitoring stations, such as the ones at Miraflores, Agua Clara, T6,

and Ancón. However, they are within the maximum permissible limits. There are no

previous records for the T6 and Ancón stations, since this is the first time that

measurements are taken during this period as part of the EIA requirements for the

Expansion Program’s operational phase. (See Appendix H, Air Quality Monitoring Reports).


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5.2.9.2 MONITORING OF CHLORIDES AND OTHER PARAMETERS RELATED TO THE GATÚN LAKE

As recommended in the EMP, the ACP continues to carry out the following monitoring

campaigns:

Total Dissolved Solids, Sulfates, and Chlorides Monitoring. This monitoring work

continues on a regular basis, both in the dry and the rainy season, using a

Hydrolab DS5 multiparametric probe at two depths (surface and bottom) for field

parameters, and using a Van Dorn sampling collection bottle. The samples were

collected and analyzed by the Laboratory of Water Quality Unit of ACP. A total

of 181 water samples were collected for analysis during this audit period at 14

sampling stations. It is important to mention that the results obtained regarding

chloride concentrations state that the Gatún reservoir shows no signs of saline

intrusion (<25 mg/L). The average chloride concentration was 55.4 mg/L.

Vertical salinity, conductivity, and temperature profile monitoring. The ACP continues

to hold regular campaigns during the dry and the rainy season in at least 60

stations located within the Gatún Reservoir, using Sbe19 plus equipment. The

results obtained from the vertical salinity and conductivity profiles indicate that

the Gatún Reservoir shows no signs of saline intrusion associated to the Third Set

of Locks’ operational phase. The average conductivity recorded at the Gatún

reservoir was 579.5 micro-siemens per centimeter (uS/cm); while average salinity

was 0.26 practical salinity units (PSU).

Ongoing, real-time salinity, conductivity, and temperature monitoring. This real-time

monitoring continues to be carried out every 15 minutes at 30 stations located on

the buoys of the Gatún reservoir navigational channel and in the chambers and

basins of the new Cocolí and Agua Clara locks, with Seabird MicroCAT SBE37-

SMP probes. The results of this ongoing monitoring also indicate that the Gatún

Reservoir shows no saline intrusion problems that may affect the crude water

supply for drinking water production and/or aquatic habitats. Average

conductivity was 627 uS/cm; while average salinity was 0.286 PSU.

According to ACP reports regarding the monitoring campaigns, the Gatún reservoir

preserves its freshwater condition. The ACP has managed to maintain said condition by

flushing locks whenever concentrations in the areas surrounding the locks record


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warning values (>0.45 ups which is used as reference to classify freshwater bodies and

for aquatic life conservation).

5.2.9.3 WASTEWATER DISCHARGE MONITORING

In their field visit from July 17-19, 2018, which included interviews with ACP

environmental personnel and treatment plant operators, ERM noted that the ACP

continues to monitor treated effluents from the Wastewater Treatment Plants

(WWTP) in operation. The main purpose of the monitoring activities is to verify

compliance with Technical Regulation DGNTI-COPANIT 35-2000 “Water, the

Discharge of Liquid Effluents Directly to Bodies and Masses of Surface and Underground

Water,” and to ensure proper WWTP operation. This monitoring activities also

included control monitoring of the water and oil separators at both locks complexes.

The sampling and analysis of samples collected during this audit period were

conducted by INSPECTORATE PANAMA S.A., during the months of January and

February in 2018. From March to June 2018, PFR Environmental S.A. carried out

sampling and analysis activities. According to ACP personnel, the change of

laboratories came about because of the expiration of the contract with Inspectorata

Panama S.A. and, as a result of a new bidding process. Both laboratories are

accredited by the National Accreditation Council of the Republic of Panama. Based

on the reviewed material and the interviews conducted by ERM, the following

findings were made:

Cocolí WWTPs:

o The reported results show a 61% compliance of the Continental plant

with the analyzed parameters with the limits established under

Technical Regulation DGNTI-COPANIT 35-2000. The parameters that

were most often exceeded included nitrates, total suspended solids

(TSS), total coliforms, and total phosphorus.

o As for the Island WWTP, it showed an 88% compliance level for the

entire period, with TSS and turbidity being the parameters most often

exceeded.

o In June 2018, the ACP hired BA-Químicos S.A. to operate the WWTP.

o Notable improvements in the reduction of parameters that exceed the

maximum permissible levels have been achieved compared to the last

semester audited.

Agua Clara WWTPs:


51

o These WWTPs reported better results in terms of compliance with the

regulation, as compared to the Cocolí WWTPs. The Continental

WWTP reported an 82% compliance of the parameters established in

the regulation, with nitrates being the parameter with the highest

exceedance occurrence level. On the other hand, the plant on the

Island side reported 78% compliance, with TSS being the parameter

that continues to exceed limits most often.

o For these treatment plants, the ACP continues to evaluate the

implementation of measures that will allow the fine-tuning of the

nitrate-removal process (denitrification) and the TSS. In June 2018, the

ACP hired BA-Químicos S.A. to operate the WWTP. During the visit

to the WWTPs, technical personnel from the ACP and BA-Químicos

S.A. indicated that they continue to perform technical tests to optimize

the WWTP and achieve complete compliance with the maximum

permissible limits.

In addition to the aforementioned measures, the ACP is implementing the following

general measures to improve WWTP efficiency and compliance with the

regulations, as well as to apply the recommendations provided by ERM during the

previous audit period:

BA-Químicos S.A. keeps an up-to-date calibration log of the equipment they

use to take measurements in the field. During its field visit, ERM verified that

these logs are duly maintained properly and in a timely manner. This was

one of the improvement areas proposed during the previous audit period.

The remote monitoring of the WWTPs using SCADA has been initiated.

During the audited period, they began with the Cocolí (island) plant to allow

for permanent monitoring of the WWTP’s operating parameters.

Work is underway in cooperation with the ACP’s Engineering Division to

produce a design that allows for the interconnection of operating plant’s

discharge with the second plant’s pump station. The purpose of this is to

assess the feasibility of using water that has been treated to water green areas.

The ACP is collaborating with the company BA-Químicos S.A. to establish a

verification plan and a results registry.


52

Work is underway to identify the point where the rainwater drainage comes

into contact with the residual water drainage during events that produce a

large amount of precipitation.

On the other hand, the ACP reported that there has been no generation of sludge

from the WWTPs at a volume that requires external disposal. Sludge has been

recirculated at all WWTPs in order to keep the biomass active. At the Agua Clara

plant (continental side) sludge was transferred to the Cocolí plants in the Pacific.

In general, the ACP is aware of the areas of opportunity regarding the treatment of

wastewater and they continue on the right path to close the gap between the EMP

requirements and the efficient operation of their WWTPs. According to the water

monitoring results of the effluents from the WWTPs, it has been noted that since

January 2018 there have been performance improvements at the WWTPs. The

number of parameters that exceed the maximum permissible discharge limits have

decreased. The results indicate that control is being achieved over nitrates, and that

coliform levels are below the maximum permissible limits established by the

regulation. ERM recommends that the ACP continue to implement improvement

measures and that the personnel responsible for operating the WWTPs maintain

constant communication with the ACP to achieve compliance with 100% of the

maximum permissible limits for the next period (July-December 2018). (Appendix I,

ACP WWTP Reports).

5.2.9.4 LANDSLIDE MONITORING

As described in the EMP, the Soil Protection Program lays down the measures to

prevent and minimize negative impacts associated to the Third Set of Locks’

operations on the soil, and indirectly, on the quality of water. The impact on quality

of water may be due to the generation of sediment, mainly during the rainy season.

For the period from January to June 2018, the ACP continued with the

implementation of the landslide monitoring protocol by using the LIDAR (Light

Detection and Ranging o Laser Imaging Detection and Ranging) technology. During

the audited period, the ACP installed two new Casagrande piezometers , in the

Cucaracha Sector, for a total of 111 underground instruments currently in operation

to date for the monitoring of landslides, as well as a total of 2,716 EDMs


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(instruments on the surface), distributed among the Culebra Cut, the Pacific and

Atlantic dams, and the Davis and Cuipo sectors in Colón.

During the audited period, from January to June 2018, there were no reports of

significant landslides at the banks of the Culebra Cut. Some landslides took place in

the Paraíso sector due to the heavy rainfall that occurred in June 2018 caused by

Tropical Wave #8. In order to stabilize this area, a Rockfall Control stabilization

project has been planned for Paraíso, which is in its bidding process. From January

to June 2018, alerts were reported in the Culebra and Sardinilla sectors, which were

handled without significant repercussions.

During the period from January to June 2018, two stabilization projects were

concluded. In March 2018, the execution of the operation project “Rehabilitation of

the Summit Canals” finalized; and early in June 2018, work finished on the

excavation for the “East Whitehouse Slide Landslide Stabilization” project. The

“Stabilization of slope south of building operation project 33 in Gamboa” operation

project was scheduled to be executed in fiscal year 2018, but was rescheduled for

fiscal year 2019. The “Rockfall Control in Paraíso” operation project is in its bidding

process and is to be executed towards the end of the fiscal year or early in fiscal year

2019.

5.3 REVIEW OF THE DIEORA IA-632-2007 ANAM RESOLUTION REQUIREMENTS

As for the commitments established in the EIA approval resolution, it was verified that all measures established therein are essentially met, since most of the Resolution’s requirements are included in the EMP. The ANAM Resolution (currently MiAmbiente) specifies compliance with the following main principles for the operational phase:

Installation of an air emission monitoring station network. This station network monitors the following parameters: nitrogen oxide (NOx), particulate matter (PM), particulate matter of less than 10 microns (PM10), sulfur dioxide (SO2), and carbon monoxide (CO).

Technical Regulation DGNTI COPANIT 44-2000, established for hygiene and safety conditions in noise-generating work environments.


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Complying with Technical Regulation DGNTI-COPANIT-43-2001, which regulates the hygiene and safety conditions for chemical substance air pollution control in work environments.

Complying with Law No. 6 of January 11, 2007, which provides for the management of oily waste from synthetic hydrocarbons in the national territory.

Compliance with Executive Order 225 of November 16, 1998, "Which regulates Law No. 7 of January 3, related to the protection of the ozone layer."

Law No. 36 of May 17, 1996, “which sets controls to prevent environmental pollution caused by fuel and hydrocarbon use.”

The matrices presented in Section 7 for each component detail the level of implementation or compliance of the different applicable requirements according to the Category III EIA approval resolution.

5.3.1 SEMIANNUAL REPORT

The resolution sets forth the requirements of the Expansion Program report.

ERM conducts semiannual verifications of the mitigation measures and monitoring programs. The third and last semiannual report for he operational phase was submitted by the ACP to MiAmbiente at its Headquarters on May 24, 2018; at the Panama West Regional Office on May 28, 2018, and at the Colón Regional Office on May 29, 2018.

During this period, the MiAmbiente Regional West Panamá Office visited the Cocolí locks on Wednesday, January 10 and on Tuesday, January 16, . MiAmbiente also visited the Velázquez and Camacho dredged material disposal sites, the flooded area of Vía Centenario at the North T-6 deposit site, and the WWTPs, and conducted a tour of the facilities of the Third Set of Locks in Cocolí. The purpose of the visit carried out by employees from the Ministry of Environment’s Western Regional Office is to follow up on the second report on the “Implementation and Effectiveness of the Mitigation Measures for the Environmental Impact Assessment of the Expansion Program, Third Set of Locks,” submitted in August 2017.

The submission letter to MiAmbiente is included in Appendix K.


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5.3.2 MODIFICATIONS TO THE EXPANSION PROGRAM

Under the Resolution, MiAmbiente requires that the ACP notify any changes to the Expansion Program that are not included in the Category III EIA.

According to the information reviewed by ERM for the period between July and December 2017, no modifications were made to the Expansion Program that were not contemplated in the Category III EIA.

5.3.3 REFORESTATION PLAN

The reforestation requirements are outlined in the Category III EIA Approval Resolution and are included in the EMP. It states that, as a compensatory measure, the ACP must replant two hectares for each hectare affected during the program’s development. ERM verified that the reforestation program has been executed in the areas designated by the Ministry of Environment and in the number of hectares required in the EMP.

The following staff members participated in this audit: for the ACP, Eng. Alejandro Figueroa, representing the ACP Environmental Division. The reforestation projects visited included:

The Wuacuco No.1 reforestation project,

The Agua Clara-Chilibre reforestation project,

The Camping Resort-Chilibre reforestation Project,

The Alto Playón reforestation project, located in Darién.

As part of the ACP’s Ecological Compensation Program, twenty-one (21) reforestation projects have been implemented to date for the Expansion Program, seven (7) of which are currently underway, while fourteen (14) already concluded and were transferred to the Ministry of Environment for their administration in accordance with the agreements under the Ecological Compensation Program.

At present, seven (7) reforestation projects are being implemented in different areas and at different execution stages (ranging from their inception to their fourth year of execution). All of them are in their maintenance period (three in their first year of maintenance and two in their second year). Only one project has reached its third year of maintenance and one is in its fourth year of maintenance. Table 5, below, details the different stages of the ongoing projects.


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Table 5. Reforestation Projects Summary

No Project Location Area (ha)

Province Contractor Phase

1 PAC 1 PNCC 115 Panamá MIAMBIENTE Completed

2 PAC 2 PNAC 30 Panamá MIAMBIENTE Completed

3 PAC 2 PNOT 60 Coclé MIAMBIENTE Completed



6 PAC 3 CIFO 50 Chiriquí MIAMBIENTE Completed

7 PAC 3 PNCH 40 Panamá MIAMBIENTE Completed


9 Gatún Lake PNVB 30 Chiriquí MIAMBIENTE Completed

10 PAC 4 RFM 50 Herrera MIAMBIENTE Completed


12 Locks Chiriquí Viejo 50 Chiriquí MIAMBIENTE Completed

13 PAC 4 ZPUMBCH 59 Panamá CAREFORSA Completed

14 Locks Tapagra 61 Panamá CAREFORSA

Completed /Pend.

MiAmbiente Resol.

15 Locks PNS-Camping

Resort 65 Panamá CAREFORSA 3rd year Maint.

16

PAC 4

PNS-Agua Clara

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Panamá CAREFORSA 4th year Maint. Navigation towers 14

Atlantic Dredging 3

17 PAC 4 Wuacuco No. 1 42 Panamá ACCIÓN FORESTAL 2nd year Maint.

18 Atlantic Dredging Ciénaga del

Mangle 54 Herrera 1st year Maint

19 Locks Arimae/Emberú

Purú 83 Darién APASAN 2nd year Maint.

20 Locks/PAC 4 Alto Playón 130 Comarca-

Darién APASAN 1st year Maint.

21 Locks/PAC 4 Nuevo Vigía 122.5 Comarca-

Darién APASAN 1st year Maint.

Reforestation Report, June 2018.

FIRST DAY OF VISIT – July/17/18


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The communities visited are located in the Provinces of Colón and Darién.

Communities visited: Agua Clara, El Camping, and Wuacuco No1.

ACP engineers in charge: Alejandro Figueroa and Luis Alvarado.

General observations: The tour began at the Soberanía National Park, where we visited the Agua Clara community, which is located in the Province of Colón. We then continued our tour of the Soberanía National Park and visited the reforested lot located at the Camping, adjacent to the Panamá Colón highway. The tour ended at the Wuacuco No. 1 community, located in the Madugandí region on the route to Darién. On the second day of the tour, we visited the Alto Playón Community in Darién.

In general, during the tour it was possible to observe a variety of native forest trees, as well as fruit-bearing trees that are part of the reforestation programs. Said programs are in their third and fourth year of maintenance.

The rainy season continues to have a positive effect on the saplings, which are developing well. The lot in Agua Clara stands out; there, vegetation and regrowth have progressed a great deal, which is evidence of the project’s success. This site is currently in its maintenance phase.

The Camping reforestation project is in its maintenance and control phase, during which it is possible to see the development of saplings and the rainy season’s influence.

It is worth noting that the Wuacuco No. 1 community’s collaboration with the contractor in charge has produced good management and control of sapling cleaning and counting activities. Species such as cocoa and coffee are the most numerous and are developing excellently.

It is important to stress how complicated access to the reforested plots of land can be during the rainy season, which has impeded work in these areas, although it has not been an obstacle to maintain control and good development of these activities.

Table 6. Visited Location’s Coordinates – UTM (WGS 84)

Site Name Zone East Coordinate

(X)

North

Coordinate (Y)


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Agua Clara 17 P 0644640 1014537

Camping 17 P 0650380 1010809

Wuacuco No1. 17 P 0783174 40991545

Detailed observations of the Agua Clara area:

The Agua Clara area is located at the Soberanía National Park in the Agua Clara community, in the Province of Colón, and it spans 62 hectares. The Agua Clara reforestation project is in its fourth year of maintenance and is being operated by contractor Environmental Consulting & Services, Inc.

At the lots, we observed native and fruit-bearing saplings that show good development, as well as dense groundcover directly influenced by the rainy season, which is characterized by constant rain. This has a direct impact on all of the water sources, such as brooks and streams, within the reforested hectares that were dry in the dry season. During the tour, we were able to observe a good volume of water in the water sources.

One of the site’s features that should be highlighted is the great development the saplings are exhibiting (2 or more meters) and the phasing out of the well-known Kans grass (Saccharum spontaneum). This groundcover prevents the growth of Kans grass.

The dense foliage dominates the area and has even covered the old firebreaks and exhibits new species, such as fern and orchids. These flowers had not been observed in previous visits, which is an indication of the project’s successful development.

Detailed observations from the location in the Camping Resort area:

The Camping Resort area is located at the Soberanía National Park, adjacent to the Panamá Colón highway, and is composed of 65 total hectares. The reforestation project at the Camping Resort area is in its third year of maintenance and is being managed by contractor Environmental Consulting & Services, Inc., which indicates they continue to carry out maintenance and fumigation activities at the lots.

At the lots, we observed native saplings measuring approximately 1.5m that appeared to be developing well thanks to the rainy season. The presence of pests has not been detected, which reflects the control and care of the saplings.


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In general, this project’s progress can be considered successful based on the good management of the area and the development achieved by the various species used in the reforestation.

Detailed observations from the location in the Wuacuco No. 1 area:

The Wuacuco No1 area is located within the Madugandí Region, on the side of the road that leads towards the Province of Darién. The reforestation project in the Wuacuco No. 1 area is in its maintenance and cleaning phase, which is being managed by CAREFORSA.

The owners of the lots have provided maintenance to the saplings in collaboration with the contractor, which is why, during the visit, we were able to observe that the reforested areas are kept clean, showing a progress of approximately 90% for this activity.

Coffee, cacao, and plantain saplings are seen at the lots, which predominantly seem to be developing well thanks to the great amount of rain recorded during the rainy season currently in effect. It should be noted that the cacao saplings are, for the most part, already bearing fruit, which is why a good harvest is projected. This is a result of the follow-up work that has been carried out by the team involved.

The commitment shown by the community appears to be positive and is directly reflected in the development of the reforested lots. The contractor should continue its program of activities and should continue counting the saplings, pruning the area, and replanting in areas that have been adversely affected.

SECOND DAY OF VISIT – July/28/18

The community visited is located in the Province of Darién.

Community Visited: Alto Playón.

ACP engineers in charge: Alejandro Figueroa and Luis Alvarado.

Contractor: Consultores Ambientales y Reforestadores, S.A. (CAREFORSA).

Detailed Observations:

The Alto Playón area is located within a regional area of the Province of Darién, on the side of the road that leads to the Province of Darién, Northeast of the small town


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of Metetí. The Alto Playón reforestation project is in its maintenance phase and it spans 130 hectares split into 29 lots owned by locals.

The contractor in charge has, in collaboration with the beneficiaries, carried out the work of cleaning the lots and, in line with the program, will be performing counting activities and replanting in adversely affected areas. Because of how difficult it is to reach this area, most of the work has been performed using boats. The lots in the project must be reached on foot, which shows how difficult it is to carry out the project’s activities.

At the lots, we mostly observed coffee saplings and stems, but they also had fruit-bearing trees and other species, such as pineapple, sugar cane, and native trees.

During the tour, we were able to observe that firebreaks have been maintained and that the area is kept clean, and also how the rainy season is helping the saplings develop.

Based on what was discussed with the work group, they have a replanting plan to compensate for losses resulting from the lack of rain during the dry season.

Table 7. Visited Locations’ Coordinates – UTM (WGS 84)

Site Name Zone East Coordinate

Este (X)

North

Coordinate (Y)

Alto Playón 18 P 40182634 0944812

Lots Point 1 18 P 0184190 0945155

Lots Point 2 18 P 0184066 0945170


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6 CONCLUSIONS

This report was prepared by ERM for the purpose of evaluating the degree of compliance in the implementation and efficiency of the environmental and social impact mitigation measures of the Expansion Program in its operational phase. The Expansion Program’s environmental and social requirements can be found in the following documents:

Environmental Management Plans, which form part of the Expansion Program’s Environmental Impact Assessments; and

DIEORA Resolution IA-632-2007, enacted by the National Environmental Authority, which authorizes the execution of the Expansion Program.

ERM evaluated the degree of compliance with the specific requirements of the EMP and the Resolution for the operational phase of the new locks of the Expansion Program. This evaluation was carried out by verifying the implementation of the mitigation measures and monitoring plans through field visits, document reviews, and interviews with key ACP personnel and GUPCSA safety and environment personnel.

As a result of the previously mentioned activities, ERM has confirmed that the mitigation measures and environmental monitoring plans have been adequately and efficiently implemented in all of the evaluated areas at both locks (Pacific and Atlantic Sites). These measures and plans have been implemented based on the agreements established in the EMP and the ANAM’s Approval Resolution (currently MiAmbiente).

It is important to highlight the work carried out by the personnel assigned to provide environmental monitoring services for the Agua Clara Locks in the Atlantic and the Cocolí Locks in the Pacific. The Work of the personnel from the Environmental Division’s Environmental Assessment Section and the Basin Management Section; personnel from the Water Division; in collaboration with Hygiene and Safety personnel, and personnel from the Locks and Operations divisions; among others, periodically perform monitoring work on actions carried out by the contractor and the application of mitigation measures, as well as the improvement opportunities or recommendations made by the independent consultant. They also follow up on corrective measures in contingency situations in order to comply with the agreements undertaken within the Equator Principles, as well as national regulations and those specific to the ACP. During the operation of the Third Set of Locks, programs, and on-site actions to safeguard installations and the personnel that operate them appeared to be performing well. This shows the effectiveness of the occupational health and safety programs implemented by the contractor and the effectiveness of the


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occupational health and safety oversight and monitoring carried out by the Panama Canal Authority.

This report was prepared by ERM in order to evaluate the degree of compliance. Based on field visits and the review of documents provided by ACP, ERM concludes and recommends the following:

ACP continues to carry out actions framed to the fulfilment of the commitments agreed with financial agencies, on the effective implementation of the Equator Principles and the IFC Performance Standards. In this regard, it highlights compliance with the PS1, concerning the evaluation and systems of social and environmental management through the different environmental and social programs implemented in the Panama Canal basin, in coordination with the communities through platforms of participation, 29 local committees and 6 advisory councils on basins, the establishment of a grievance mechanism system, and the support of government agencies and NGOs. In addition, the Environmental Division is actively involved in environmental assessment and management of projects in the basin and the operational areas of the locks.

In relation to the PS2, Labor and Working Conditions, the ACP provides recruitment opportunities and improves their employees’ work conditions; and regarding the PS4, the agency complies with security measures for the communities related to transit of the seaway and locks operations.

In relation to the PS3 and PS6, relating to the prevention and abatement of pollution and the protection of biodiversity; ERM confirmed that the ACP implements programs and actions aimed to ensure compliance with the EMP and the commitments of the Equator Principles and the IFC Performance Standards.

The ACP reported compliance for this period with PS5 and PS8 and continues to undertake actions to ensure the continuity of the actions performed on the construction phase, mainly in relation to the PS8 of cultural heritage. This is in line with the Equator Principles and the IFC Performance Standards.

The ACP is adequately implementing the mitigation and monitoring measures designed to protect water resources. Operation of the wastewater treatment facilities has improved noticeably compared to the previously audited period. The ACP, along with its contractor in charge of optimizing the WWTPs, are working on optimizing them so that they comply with national regulations concerning treated water. For the next period, a 90% compliance with the monitored parameters for the discharges produced by the WWTPs is expected.


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The ACP continues to supply and execute programs for the control of landslides at the Culebra Cut through a specialized system with sensors installed at different risk points and collaborates with Civil Works division in order to improve access roads to underground water instrumentation and to horizontal drains throughout the Cut.

During this period, no significant landslides or alerts were reported in the Culebra Cut area. This is due to rainfall variations during the audited period from January to June 2018.

The rainy season continues to have a visible and positive effect on the saplings, which are developing well—especially the lots visited in Agua Clara and Camping. Vegetation and regrowth were found to have progressed considerably at these sites, which underscores the success of this site’s reforestation project, which is in its maintenance phase.

At the Wuacuco No.1 community, we must highlight the community’s collaboration, which, along with the contractor in charge, is properly maintaining and controlling the sapling cleaning and counting activities. Species such as cocoa and coffee are the most numerous, and they are developing excellently.

At the Alto Playón community, we observed that cleaning activities are progressing well; we also observed the community’s commitment to helping the reforestation project succeed; if they follow the scheduled established for counting, cleaning, and replanting saplings, then the saplings should not be negatively affected in a significant way.

Opportunities for Improvement

ERM offers the following opportunities for improvement based on its site visit and document review for the current reporting period:

Continue following the stabilization measures for the WWTPs until 100% compliance with the LMPs is achieved.

Arrange for the evaluation of storm drainage and wastewater systems in order to identify whether these systems are connecting or intersecting each other, thus affecting water flow to the Agua Clara locks’ WWTPs, on the island side.


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Monitor compliance with hygiene and safety rules concerning the storage of hazardous and non-hazardous materials at the Warehouse.

Recommendations:

Continuing with the monitoring campaigns for chloride and related parameters at the Gatún Lake is recommended, as well as the monitoring of WWTP discharges.

Continue to maintain an updated log of the calibration of the monitoring equipment used at the WWTPs by the contractor in charge of optimizing said plants.

Continue to clean the storm drains in a timely manner in order to prevent blockage and/or accumulation of sediment from areas not covered with grass.

In the case of the Agua Clara WWTP on the Island side, checking the current drainage system to prevent storm water from discharging into the wastewater collection systems.


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7 TABLES

ENVIRONMENTAL RESOURCES MANAGEMENT PANAMA CANAL AUTHORITY- August 2018

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Table 1 Operational Phase of the Third Set of Locks

SEMI ANNUAL VERIFICATION REPORT OF THE IMPLEMENTATION AND EFFECTIVENESS OF THE MITIGATION MEASURES OF THE

ENVIRONMENTAL IMPACT STUDY – CATEGORY III-

OPERATIONAL PHASE OF THE THIRD SET OF LOCKS

ACTIVITY: Operating Stage of the Third Set of Locks

DEVELOPER: Autoridad del Canal de Panama [Panama Canal Authority

ENVIRONMENTAL MONITORING: Environmental Assessment Section

- Environment Division

LOCATION:

Pacific: Corregimiento of Arraijan and Burunga, District of Arraijan, Province of

Panama Oeste.

Atlantic: Corregimiento of Cristobal, District of Colon, Province of Colon

REPORT: ERM 04-August 2018, measures implemented from January to

June 2018. PHASE: □ CONSTRUCTION■ OPERATION □ ABANDONED

ANAM APPROVAL RESOLUTION No. : DIEORA IA-632-2007. EIA APPROVAL DATE: November 9th 2007


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MITIGATION, MONITORING, FOLLOW UP, SURVEILLANCE AND CONTROL MEASURES

DESCRIBED IN THE EMP APPROVAL RESOLUTION ACTIVITIES/COMMENTS

Compliance

Yes No Not

Applicable

Air Quality, Noise and Vibrations Control Program

Measures for Air Quality Control

1. All motors will be properly maintained according to manufacturer´s specification in order to maximize

combustion efficiency and minimize pollutants emissions. It must be requested proof or record of maintenance to It must be requested proof or record of maintenance to equipment suppliers and contractors/sub-contractors.

ERM examined GUPCSA's vehicles maintenance log and the review of ACP's vehicle and tugboat fleet maintenance log for the operation of that is keep by the Land and Water Vehicle Maintenance Section for the locks in the Pacific and Atlantic area. See Appendix D, Land and Water Vehicle Maintenance Log.

X

2. Combustion engines must have muffler systems, filters (if applicable) in good operating conditions.

This measure is complied with GUPCSA's and ACP's maintenance log for the marine and vehicle fleet of Agua Clara and Cocolí locks.

X

3. A schedule for the operation of engines will be set in order to minimize, to the extent possible, the time of operation of emission sources.

The use of engine powered equipment in the operation phase of the locks is based on the operational needs and the frequency of scheduled activities outlined in the inspection and vigilance protocols; this contributes to a reduction in emissions.

X

Measures to Control Unpleasant Odors

1. Establish a preventive maintenance program of the equipment used in maintenance works, duly documented, and demand the same from contractors and subcontractors.

ERM was able to verify compliance with this measure in the preventive maintenance reports of the ACP’s equipment and marine and vehicle fleet.

X

2. All engines will be properly maintained to minimize polluting gases emissions.

ERM was able to verify compliance with this measure through the preventive maintenance reports of the ACP’s equipment and marine and vehicle fleet.

X

3. Minimize, where possible, the operating time of sources of gas emissions.

The use of motorized equipment and vehicles is limited to vehicular traffic through the locks, the operation of tugboats, inspection and surveillance of facilities and scheduled maintenance. Emissions by mobile sources are

X


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Compliance

Yes No Not

Applicable

carried out from June 12 to July 5 for 300 gasoline and diesel vehicles from the ACP's vehicle fleet; of which part of them operate in the Cocolí locks and Agua Clara Locks. The results show compliance with the maximum permissible limits established by applicable national regulations.

4. Apply measures included in the waste management program, specifically, those measures aimed to ensure the fulfillment of regulations on waste management and their suitable deposit.

ERM made sure that in the facilities of the locks, in both, the Pacific the Atlantic sectors, there are labeled bins with garbage bags and lids, depending on the type of waste and it was verified the collection frequency in the contractor´s records.

X

Measures for Noise Control

1. To maintain all mobile and construction equipment in good conditions and with adequate noise silencers. All project suppliers and contractors shall submit proof or record of equipment maintenance.

This measured is accomplished in the Contractor´s maintenance records, as well as the maintenance records of the and marine fleet for the ACP’s operations at the Cocolí and Agua Clara locks.

X

2. To minimize, to the extent possible, the length of operation of noise-emitting sources, and to avoid having idle equipment in operation.

The facilities’ inspection and surveillance protocols establish that equipment that is not in operation must be shut down.

X

3. To avoid the unnecessary use of alarms, horns, sirens, etc.

This measure is accomplished during the operation. X

Soil Protection Program

Landslide Risk Control Measures

1. Adequate maintenance of slopes and drainages formed during the operation.

During the audited period, 2 operational projects were completed: “East Whitehouse Slide Landslide Stabilization” and “Summit Canals Rehabilitation.” Project 3 (Stabilization of slope south of building 33 at Gamboa) is scheduled for fiscal year 2019.

Landslides were not reported at the banks of the Culebra Cut, and landslide monitoring plans remain implemented.

X

Measures for the Control of Soil Erosion and Sedimentation


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Compliance

Yes No Not

Applicable

1. Provide maintenance to drainages, ditches and other infrastructures built during the construction stage.

TREBOL INC., S. A. was hired to maintain and clean sites including green areas, ditches, and sediments for a period of 5 years as of 2016.

X

2. Provide maintenance to the zones where vegetation has been restored

TREBOL INC., S. A. was hired to maintain and clean sites including green areas, ditches, and sediments for a period of 5 years as of 2016. The removal of sediment from surface drainage is being carried out every 21 days. Stabilization and hydroseeding projects are also being carried out at the Cocolí and Agua Clara locks, and measures for preventing the sedimentation of drains.

X

Measures to Control Soil Contamination

1. Minimizing by means of proper handling of materials and wastes used in maintenance routine operations, according to the Materials and Waste Management Programs.

This measure is carried out in the facilities for both locks (Atlantic and Pacific sector); there are 55-gallon labeled bins, with garbage bags and lids, depending on the type of waste. ERM verified on site that in industrial areas there are 16-yard boxes for waste handling, that are removed by PWM and the Autoridad de Aseo in the Pacific Sector and carried to Cerro Patacón landfill. At the Agua Clara locks in the Atlantic sector, the company, AGUASEO, provides waste collection services and takes the waste to the Monte Esperanza (Mount Hope) landfill in Colon for its final disposal.

X

Water Resources Protection Program

Measures to Reduce Water Quality Deterioration due to the Operation of the Third Set of Locks

1. Monitoring of the Lake’s banks in order to identify critical areas possibly contributing solids, and based on the soil and subsoil’s characteristics, propose corrective measures for stabilization.

The ACP has a monitoring and analysis program for suspended sediments that originate from the main rivers that flow into the Gatún reservoir. During the January-June 2018 period, data was collected at the Ciento, Chorro, Cañones, and Caño Quebrado stations. So far, the parameters being reported are suspended solid concentrations and flow curves vs solid flow.

X


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Compliance

Yes No Not

Applicable

The ACP is also working on the development of a sedimentation model for the Pacific entrance; the purpose of this model would primarily be to evaluate the contribution the Curundú river and its tributaries have on sedimentation in the Panama Canal. The ACP is planning to use the model as a tool to approximately predict sedimentation patterns, which would be used for scheduling dredging activities and for implementing measures for reducing the volume of dredging. During the audited period, information was collected, activities that are to be carried out were identified, a schedule of activities and meetings was presented, and progress was made on the model’s development.

2. To continue with the current plan for spill control and wastewater and rainwater treatment, and to adapt this plan to the new types of vessels and locks.

For this period, January-June 2018, no leaks have been reported at the Third Set of Locks. The adaptation of equipment deposits at both locks continues, specifically the installation of shelves designed for said buildings (we have attached correspondence from the contractor with confirmation of the date). OPPD-C has not had to remove oily water or used oil from Agua Clara, but it had to collect two tanks of used oil from Cocolí.

According to the log being kept by the captain at the canal’s port, a total of 4 deficiencies were identified in the wastewater treatment systems on vessels passing through during this period. Deficiencies in vessels’ wastewater treatment systems during the inspection protocol are recorded in the canal port’s log. The deficiencies that were identified were resolved by following ACP’s protocol and instructions, without any complications. These vessels comply with the regulation that prohibits discharges into the Gatún.

3. Monitoring of water quality through continuous evaluation samples for parameters that allow for the

Monitoring campaigns continue to be carried out efficiently. During the audited period, no indications of saline intrusion were detected. However, the ACP


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Compliance

Yes No Not

Applicable

detection of any changes that may occur in chloride ion concentrations.

continues to implement mitigation measures such as cleaning when chloride concentrations in the areas surrounding the locks reach critical levels; as well reducing the amount of time the lock-gates remain open.

Measures to control the water flow regime

1. Control drainage patterns. During the field visit, ERM was able to verify that ACP provides maintenance and controls the drainage patterns through the implementation of a soil protection program that includes measures for the detection and mitigation of landslides, and the control of sediments in drains. It is recommended that the verification and cleaning of the rainwater collection systems be reinforced in order to prevent them from becoming clogged and/or accumulating sediments originating from nearby areas lacking groundcover.

X

2. Channel runoff through new drainage The ACP has a facility maintenance contract to continue to channel the runoff of rainwater through the new drainage.

X

3. Use retention dikes, infiltration ditches, among others, to retain solids and prevent them from deteriorating water quality and settling in the Canal.

ERM team was able to verify that there are retention dikes to control spills and prevent flow toward water bodies. The origin of the Centenario reservoir, which has been recently reported, lies at the obstruction of the discharge point of the French drain network constructed for channeling the flow of water that moved through the disposal areas that would be filled because of the expansion project.

In addition, studies are being conducted and steps are taken to channel these waters.

X

4. Provide adequate and timely maintenance to the works.

During the field visit, ERM verified that the works for the conveyance of rainwater is in acceptable condition and litter-free. However, the works in the vicinity lacking groundcover were showing small quantities of sediment

X


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Compliance

Yes No Not

Applicable

accumulation. A company was hired to maintain the grounds.

Flora and Wildlife Protection Program

Measures to Control the Loss of Vegetation Cover (Increase in Gatún Lake’s water level)

1. Carry out a study on the existing species on the shores of the Gatun Lake in order to evaluate their resistance to fluctuations in the lake’s water level.

As reported by the Water Division, this measure is related to the operational level of the Gatún lake, which has not reached its 89-feet level, since they lack the capacity to discharge water to prevent flooding in the event of heavy rains. A construction project for a water spillway is being carried out in the Atlantic sector, which will help flow and control the operating levels of the Gatún lake during heavy rains.

X

2. Define, according to the results of the preceding study, the expected loss or impact on vegetation.


X

Measures to Control the Loss of Forestry Potential and Terrestrial Habitat

1. Prepare a further study to evaluate the impacts that the increase of the maximum operating level (MOP) of the Lake might have on vegetation, mainly, based on the increase of the level, seasonal fluctuations of water level and the type of existing vegetation, and possible mitigation measures that may be necessary.


X

Measures to Control Disturbances to Wildlife


73



Compliance

Yes No Not

Applicable

1. Keep the angle of inclination of the lights pointing towards the facilities, so that the lighting radius is localized.

ERM was able to verify on site, the fulfillment of this measure.

X

2. Intensity of light should be dimmed, provided that navigation operations allow it so that the impact is not magnified.

ERM was able to verify on site, the fulfillment of this measure.to Control Disturbances to Wildlife

X

Control Measures for the Risk of Running Over Wild Animals

1. It will be implemented a strict speed control to all vehicles of the project, in general.

There are speed limit warning signs. Staff move around according to the locks operating protocol. Also, there are signs about animal crossing in both, Atlantic and Pacific sectors.

X

2. In order to prevent vegetation from blocking visibility, maintenance will be provided to road shoulders.

A company was hired to carry out soil and landscaping maintenance the facilities of both locks for a 5-year period (Pacific and Atlantic).

X

3. Warning sings must be placed indicating animal crossing on relevant stretches of the road.

There are warning signs indicating animal crossing in both, Atlantic and Pacific sectors.

X

Measures to Control Direct Elimination of Wildlife

1. Comply with the air, noise, and vibration quality control program; soil protection programs; water resources protection programs; materials management program; and waste management program, to prevent impact on aquatic ecosystems.

The ACP has, through its contractors, implemented environmental and environmental monitoring programs as part of its environmental management, which is supervised by specialized staff from the Environmental Division and the Water Division.

X

Solid Waste Management

1. Pursuant to the activities that will be carried out in the Project during the operating stage, different types of waste will be produced. This waste must be handled in such a way to prevent its accumulation that can favor the proliferation of diseases that affect workers health.

The Contractor and ACP carry out regular facility inspections and nebulization and spraying activities for vector control. Wastes are deposited in labeled bins with lids depending on the type of waste according to ACP's materials and solid waste management manual (2014), as well as 2610EAC105 Rule for solid waste management.

X


74



Compliance

Yes No Not

Applicable

The companies hired for waste management in the Atlantic and the Pacific, have boxes for the management of industrial waste in the facilities and carry out regular waste collection. ACP hired the services of a company for soil and landscaping maintenance.

2. Waste from the Pacific zone will be disposed of at Cerro Patacón landfill, and waste from the Atlantic zone at the Monte Esperanza landfill.

PWM carries out waste collection and final disposal in the Pacific sector for GUPCSA, while AGUASEO is in charge of waste collection for the ACP, which are carried for final disposal to the Cerro Patacón landfill. AGUASEO collects waste from the Atlantic site and takes it to the Monte Esperanza landfill for its final disposal. According to GUPCSA's monthly reports, for this January-June term, 197 tons of organic solid waste were produced at the Cocolí locks and 192 tons were produced at the Agua Clara Locks.

X

3. Hazardous waste management provided, must be carried out in an environmental safe manner. All hazardous waste must be properly collected, inventoried, and secured in temporary storage areas within the working facilities, specifically in places designated in advance for this purpose.

Contracting companies keep places in their workshops and storage areas for hazardous waste management according to ACP's materials and waste management manual(2014). Tanks for used oil management are labeled and they have containment basins and spill management and security measures kit. Absorbent sheets used for maintenance activities are deposited in 55-gal labeled black tanks and they are removed by STI. During this period, 3.13m3 of hazardous waste were produced in the Atlantic sector. A report was not produced for the Pacific. Used oil is handled at both sectors (Atlantic and Pacific), but its disposal was not reported.

X

4. Final disposal for hazardous waste must be authorized and carried out in facilities designed for hazardous waste or recycling centers.

ERM verified the Contractor's monthly reports with the information of the hazardous waste management, as well as the evidence of final disposal certificates by the subcontractor. During the field visit it was verified the sites for hazardous waste management; requirements stated by the rule in terms of storage, packing. It was

X


75



Compliance

Yes No Not

Applicable

reported that 3.13m3 of hazardous waste were handled in the Atlantic Sector.

5. Before the transportation of hazardous waste for its final disposal or recycling, contractors or subcontractor must pack and label all hazardous waste in a safe manner.

During the field visit spanning July 17 thru 19, 2018, the sites for hazardous waste management were verified; requirements stated by the rule in terms of storage, packing, secondary containment, and emergency kit. Compliance with this measure was verified through an interview with GUPCSA's Industrial Hygiene and Safety staff.

X

6. Used oil is considered to be hazardous waste and shall be collected in tanks or oil collection tanks properly marked with safety labels.

During the field visit carried out from July 17 to 19, 2018, the sites for hazardous waste management were verified; requirements stated by the rule in terms of storage, packing, secondary containment, and emergency kit.

X

7. These used oils are to be placed in safe zones within the hazardous waste storage area, which must have warning signs, until their final disposal, or until they are delivered to the authorized entity for incineration or recycling.

During the field visit carried out from July 17 to 19, 2018, the sites for hazardous waste management were verified; requirements stated by the rule in terms of storage, packing, secondary containment, and emergency , signaling and access kit where observed, according to the ACP Rule 2610EAC103 for the management and use of lubricant oils and hydrocarbon products.

X

8. Mixture of used oil with antifreeze substances , paint residues, degreasing solvents, synthetic lube oils or any other liquid, except water is prohibited.

Temporary storage and segregation are carried out depending of the type of hazardous waste pursuant to ACP Rule 2610EAC103 for the management and use of oil lubricants and hydrocarbon derivatives.

X

9. Gas cylinders must be returned to the contractor or to the provider. However, before returning them, they must be labeled indicating: The material contained or that they contain, in case the cylinders have not been emptied, supplier data, cylinder serial number, pressure, date of last hydrostatic testing and any additional identification mark deems necessary.

During the field visit carried out from July 17 to 19, 2018, ERM verified that the cylinders where stored in indicated areas, secured with chains, and identified with labels.

X

10. Alkaline batteries or those of carbon-zinc, are not considered hazardous waste and their disposal should

In both operating sectors for the locks, there are sites labelled for final disposal or temporary storage of

X


76



Compliance

Yes No Not

Applicable

be the same as for common waste. During the operation of the project they will be sent to the asset quality and disposal department.

pursuant to ACP’s 2014 materials and waste management manual and its reference Rule 2600SEG220 concerning the for changing, charging, and storing batteries.

11. When filters are replaced, these are not to be discarded at the storage site without making sure that they are not contaminated with hydrocarbons or other substances considered hazardous. Filters that can be completely drained and triturated may be disposed of at authorized landfills.

Staff has areas for the management of used oils and discarded materials from maintenance activities in workshops of both sectors (Atlantic and Pacific); these are handled following the ACP’s Materials and Waste Management Manual.

X

12. Contaminated sheets and materials must be handled with the same criteria and methodologies as the product they absorbed, pursuant to 2005 ACP 's Materials and Waste Management Manual.

During its July 17-19, 2018 visit, ERM verified that contaminated sheets and materials are stored and handled pursuant ACP's 2014 Materials and Waste Manual.

X

13. he contractor that handles these types of materials or substances must built a hazardous waste storage area pursuant to ACP'S 2015 Materials and Waste Management Manual.

During its July 17-19, 2018 visit, ERM verified the fulfillment of this measure and that workshops and storage holds have specific sign posted sites and with the safety measures and contingency care pursuant to ACP's Materials and Waste Management Manual.

X

Materials Management Program

1. The use of hazardous materials during the construction and operation of the Project will be regulated by the information rule on hazardous materials (2600ESS-201), among other rules specific to the works to be carried out.

As part of the commitments of the contracting company is the compliance of ACP rules, which include the handling of hazardous materials. During its July 17-19, 2018 visit, ERM was able to verify that, at GUPCSA`s warehouses at the locks in Cocolí and in the Atlantic, there are specific areas with signage corresponding to hazardous materials which adhere to the requirements of the rule and have their inventory in the system and safety sheets (MSDS) available for the staff to use. Also, the containers are properly labelled according to the HAZCOM system. All areas have kits to take care of spills and contingencies, as well as fire extinguishers.

X

2. Measures set forth for compressed gas, is based on safety measures for the management and storage of

The contractor complies with this measure, and the Contractor's Industrial Hygiene staff, as well as the ACP’s

X


77



Compliance

Yes No Not

Applicable

compressed gas storage3 (2600ESS-116) and the rule for the management hazardous materials (2600ESS-201), both set forth by ACP.

staff, verify compliance with this measure during their routine field inspections at the locks.

3. ACP Order and Sanitation in Working Sites Rule (2600 ESS-285), sets uniform practices and requirements of industrial sanitation and order in working areas which is of mandatory compliance to all contractors.

During its July 17-19, 2018 visit, ERM was able to verify the conditions of the operating areas of locks, including workshops and storage areas, which are in the required working order and sanitation conditions. The workshops are cleaned daily and fumigated twice per week. On Saturdays, the facilities undergo a deep cleaning.

X

Socioeconomic and Cultural Program

Measures to Boost Job Generation and Improve Labor Conditions

1. With the commissioning of the new facilities, and a reduction in staff requirements, support to current existing training programs with educational institutions, will continue, so that job offers are maintained for new needs in the Canal.

According to information provided in July 2018 by the Community Relations Team (RHRX-OPE) of the Locks and Facilities Maintenance Division, as of June 2018, the Cocolí and Agua Clara Locks had 108 and 102 direct ACP employees, respectively.

The number of employees at each lock fluctuated between 99 and 108 during the current reporting period (January to June 2018). A summary of hiring and training documents showed the following :

Recruitment events which led to the hiring of 100 new employees (line handlers, “pasacables”);

Enrollment of 23 candidates in advanced training programs such as those required for welders and lathe operators, and for other skilled positions;

Maintenance of a publicly accessible employment portal on the ACP website.

X


78



Compliance

Yes No Not

Applicable

ERM’s site visit and document review indicate that the Third Set of Locks continues to generate employment in compliance with the EMP.

Measures for the Increase in Population and Migration Flows

1. Maintain measures set forth, regarding the collaboration and provisions established with the National Police [Policía Nacional], the Arraiján, Colón and Panamá Municipalities, the communities, and the ACP to prevent squatters from settling in the AES.

ERM found evidence during the site visit and its documentary review that the Third Set of Locks’ operational phase is currently implementing corrective measures to address the risk of increases in population and migratory flows. ERM’s July 2018 site visit and document review indicate that the operational phase of the Third Set of Locks continues to mitigate possible increases in population and migratory flows in compliance with the EMP.

X

Measures to Minimize Land Use Changes

1. The application and improvement of the comprehensive management plan for actual. the watershed must be continued; this must boost the benefits offered by the increase of the lake's level (transport and fishing facilities), as well as considering the impact on economic activities (agriculture and plantations), that may occur with the changes produced at the actual level.

ACP has a Land Use Plan for heritage areas and of privative management. This Plan Completes the Regional Plan for the Development of the Interoceanic Region and the General Plan on Land Use, Conservation and Development of the Panama Canal Area (Law 21 of July 2, 1997).

ERM was provided with and reviewed a PowerPoint presentation on the Project’s “Management and Conservation of Water Resources in the Panama Canal Watershed” (Manejo y Conservación de los Recursos Hídricos en la Cuenca Hidrográfica del Canal de Panamá) during the April 2018 reporting period. Most of the programs described in this presentation address changes in land use.

Going beyond an effort to simply avoid environmentally and socially negative land use changes the programs , reflect an effort to make land use in the watershed more efficient, productive, and sustainable. ERM’s site visit and document review indicate that the Panama Canal Watershed program, developed during construction, has

X


79



Compliance

Yes No Not

Applicable

continued into operations and has been effectively managed, and has in fact improved the use of soil in the Panama Canal Watershed. During the July 2018 visit, ERM reviewed additional information proving the continued successful functioning of these programs. It is ERM’s opinion that the ACP’s programs are ensuring that activities developed within the operative/heritage land areas and in the watershed are consistent with the existing land use law in heritage land areas of the ACP, in compliance with the EMP.

Measures to Reduce Impact on Vehicular Traffic Due to the Increase on Demand for Transportation

1. Establish alternative measures to Costa Abajo communities in Colon, for cases where is necessary to limit the use of the land pass through Colon locks.

ERM received and reviewed a document during its April 2018 monitoring visit that addresses the implementation of the measures for the Third Set of Locks’ operational phase to mitigate impacts on vehicular traffic. The document provided information on the days and hours that the public can cross the Agua Clara and Gatún Locks, as well as the days and hours that the public can cross the canal via ferries provided by the ACP. This document also describes a mechanism for disclosing these schedules. Under improvement for the current reporting period, the document states that special hours have been established for crossing the Agua Clara and Gatún Locks during important events on days when traffic flow is lower. Moreover, the ACP, through the Atlantic Bridge Project, is in the process of establishing a permanent measure to diminish the effects of traffic. During the July 2018 visit, ERM confirmed through direct observation that the application of these measures is reducing impact.

X

Measures to Minimize the Overburden of Utilities

1. 1. To promote at ACP's in-house level, resource saving campaigns (energy and water) among the Canal employees.

ERM found no evidence during its site visit and document review that the operation of the Third Set of Locks has contributed to an overload of public services during the current monitoring period (January – June 2018). The

X


80



Compliance

Yes No Not

Applicable

mitigation measures required under the EMP continue to be implemented during the operational phase.

Measures to Minimize Impact on Structures

1. Continue to implement the lake shorelines' long-term socio-environmental management plan.

ERM reviewed documents in July 2018 that show that there are legal control mechanisms to prevent settlements, migratory flows and to prevent structures from being affected in ACP heritage lands. Among the documents reviewed in July 2018 was a report of the most recent annual inspection of the shoreline area by aquatic patrol. Several recent unauthorized land uses were noted for correction, that will be followed up in the next monitoring visit. ERM confirms that there is a robust monitoring program in place to ensure no long-term impacts. ERM believes that the operational phase of the Third Set of Locks is compensating for the impacts in accordance with the EMP and the Equator Principles and IFC Performance Standards. ACP has a Watershed Management Section that maintains permanent programs to approach socio-environmental issues not only on the Gatun Lake shorelines, but throughout the Panama Canal Watershed.

X

Measures to Mitigate Impact on the Landscape

1. To encourage the access of public to strategic observation points of the Canal and its structures.

During its July 2018 visit, ERM confirmed that the ACP continues to operate publicly accessible observation areas at both the Cocolí and Agua Clara Locks. With this information, ERM was able to verify compliance with this measure.

X


81



Compliance

Yes No Not

Applicable

2. To introduce explanatory material about the works and operations of the Canal and its importance for international commerce.

In April 2018, ERM was provided with a DVD containing copies of a number of publications related to the Third Set of Locks. These included three environmental videos, three radio spots, and nine “Ecotip” fliers. The DVD also included three issues of the magazine Mi Cuenca (June/July 2017, August/September 2017, and September/October 2017). During the July 2018 visit, ERM also reviewed more recent versions of all these periodical publications, including issues of El Faro (a monthly magazine with general information on the Panama Canal) and issues of Tu Canal (a biweekly magazine by Panama Canal collaborators). ACP staff also provided ERM with evidence of a number of public workshops it had sponsored in support of the Third Set of Locks’ social programs. ERM confirms compliance with this measure as of July 2018.

X

3. To carry out the adequate maintenance and permanent revegetation of excavated slopes and landfills, to the extent possible.

The ACP contracted the services of Trébol Services Inc. for the maintenance of the locks’ facilities. Also, during ERM’s visits in April 2018 and July 2018, it could be clearly seen in the field and the documents reviewed that the hydro-seeding was progressing well in sloped areas at the Cocolí an Agua Clara locks.

X

4. Provide observatories with observation facilities such as telescopes and others.

ERM visited the Cocolí Exhibition Center and the Atlantic Observation Center and verified the implementation of this measure as in April 2018. The Third Set of Locks was seen to have continued similarly during ERM’s latest site visit in July 2018 and is considered to remain in compliance as of the current reporting period.

X

Contingency Plan

EMERGENCY SITUATION AFTER DELIVERY OF CONSTRUCTION BY CONTRACTOR AND DURING THE OPERATION


82



Compliance

Yes No Not

Applicable

1. For the operation of new works, the ACP’s contingency plan will be reviewed and incorporated to the new structures, analyzing new risks, and identifying responses to new risks.

The ACP has an Emergency Plan and a Protocol of Early Warning and Emergencies for both the Cocolí and Agua Clara locks. Emergency system tests were performed at the Gatun facilities on November and December. There are Operations and Spill Control Units and a Spill Control building at both locks’ facilities, Agua Clara in the Atlantic and Cocolí in the Pacific.

Evacuation plans have been developed and evacuation drills are carried out at the locks in Cocolí and Agua Clara.

In addition, storage areas have been built for spill control equipment used to control hydrocarbon spills.

In terms of preparedness to handle vessels carrying natural gas, new fire control equipment was purchased, including dry chemical powder tugboats and high-expansion foam systems. First responders such as firefighters, CPC, tugboat captains, and locks personnel also receive regular training on subjects concerning the risks involved with and the appropriate response to natural gas emergencies. The annual drills and seminars held since 2016 have been aimed at preparing to respond to natural gas emergencies at the Expanded Canal due to natural gas being a new, hazardous type of cargo in transit through the canal.

The procurement of services for updating the Canal’s vulnerable areas, analyzing the Panama Canal’s risks, and updating hydrocarbon collecting strategies is pending.

X

Environmental Monitoring Plan

Ambient Air Quality Monitoring


83



Compliance

Yes No Not

Applicable

1. During the operation of the Project, the monitoring of air quality shall be carried annually, until the Canal operates at is maximum capacity.

The ACP carries out air quality monitoring for PM10, SO2, NO2 and CO parameters. According to the report submitted by the ACP for the term January to June 2018, at the monitored sites: Miraflores, Paraiso-Pedro Miguel, South of the T6 disposal site, Agua Clara locks located in the Water Reutilization Basins; indicates that, although some sites saw increases in values, all parameters comply with the maximum permissible limits pursuant to Rule 2610-ESM-109, Environment Air Quality Rule.

X

2. Monitoring will be carried out at six points, including the South of the T6 disposal site, Paraiso, Pedro Miguel, Clayton, Ancon, and Gatun-Futura, where the water reutilization basins are located.

ERM verified compliance with this measure in the Air Quality report prepared by Environmental Assessment Section of the Environment Division for the January to June 2018 period.

X

3. The parameter to be monitored at the monitoring point located south of the T6 disposal site is PM10.

The average PM10 µg/m3 value for the January to June 2018 period was of 24.2 µg/m3, which is below the maximum permissible limits.

X

4. Parameters to be monitored at the points located in Paraiso and Pedro Miguel: PM10, SO2, NO2 and CO.

There is compliance with this measure. Table No. 3 of section 5.2.9.1 – Air Quality Monitoring, shows the monitoring results for the January to June 2018 period.

X

5. The parameters to be monitored at points located in Clayton and Ancon are NOx and PM10.

There is compliance with this measure. Table No. 3 of section 5.2.9.1 – Air Quality Monitoring, shows monitoring results for the January to June 2018 period. Miraflores station replaces the measurements from Clayton station.

X

6. Parameter to be monitored in point located in Gatun-future location of water reutilization basins is NOx.

There is compliance with this measure. Table No. 3 of section 5.2.9.1 – Air Quality Monitoring, shows monitoring results for the January to June 2018 period.

X

7. In the sites of passive monitoring, there will be carried out 4 monitoring sessions per annum. Depending on results obtained, after the first year, these might be reduced to twice per annum

During this period, monitoring was carried out from January to June 2018. The ACP will perform monitoring twice a year, taking into consideration compliance with the regulations, for two consecutive years during the operational phase. See Table 3, Section 5.2.9.1, Air Quality Monitoring.

X


84



Compliance

Yes No Not

Applicable

Landslide Monitoring

1. The measurement of horizontal displacement of slopes at the Corte Culebra Sector will be measured with distance measurement electronic systems.

For the January to June 2018 period, the ACP continued with the implementation of the monitoring protocol by means of LIDAR technology.

X

2. Visual inspections by trained staff and record of evidence of the existence of surface activity, a precursor of landslides.

In addition, the ACP uses ground equipment that are used as a total station and the equipment performs a scanning that provides the topography so that the equipment can have a linear view. During the audited period, ACP installed two new piezometers at the Culebra Cut, which raises to 111 the total underground instruments used for landslide monitoring in operation to date, as well as a total of 2,716 EDMs.

X

3. Record of the amount and intensity of rainfall by means of rain gauges.

The ACP continues to submit monthly reports of daily precipitation, in millimeters, at the Cocolí 326 and Gatun West (GTW) stations.

X

Monitoring of chloride and related parameters at Lake Gatún

1. Selection of a set of sampling sites and water quality permanent parameter measurement stations to monitor chlorides and some complementary parameters.

The ACP continues to monitor Total Dissolved Solids (TDS), sulfates and chlorides, measure the use of multi-parameter probe and Van Dorn water sampler at two depths (surface and bottom). The ACP continues to carry out these regular campaigns during the dry and rainy seasons in at least 60 stations located within the Gatun Lake Reservoir with the Sbe19 plus equipment; and real time monitoring is continue to be carried out in 30 stations located in navigation channel buoys of the Gatun Lake Reservoir and in the chambers and basins of the new locks of Cocolí and Agua Clara with a frequency of every 15 minutes with the Seabird Micro CAT SBE37-SMP probes.

X

Measures Indicated in Environmental Resolution 632-2007

1. In terms of ecological compensation due to the impact on mangrove ecosystems, secondary forests, stubbles and others that are found in terrestrial deposit sites,

With regard to the reforestation requirements, these are set forth in the EIA Category III Resolution approval, and are included in the EMP. This states that, as remedial

X


85



Compliance

Yes No Not

Applicable

double the amount of vegetation and mangrove ecosystem affected shall be reforested with native species at sites chosen in coordination with the ANAM, and proper maintenance shall be given to these areas.

action, ACP shall reforest 2 hectares for each hectare affected during the development of the program. ERM verified that the reforestation program. has been running in areas designated by Ministerio de Ambiente [Ministry of Environment] and in the number of hectares required by the EMP. As of the date, most of the sites have been completed in 100% (See Chart 4, section 5.3.3. Reforestation Plan) and there are 7 sites in maintenance stage, completing around 1244 reforested hectares including native species, mangroves, and coffee and cacao plantations.

2. Submit a report on the application and effectiveness of mitigation measures set forth in the Environmental Management Plan every six (6) months to the corresponding Environmental Regional Administration, for their evaluation and approval, for the duration of the implementation of said measures, as well as of those included in the operative part of this Resolution, as noted in the Category III Environmental Impact Study and in this Resolution. Said report shall be prepared by a suitable and independent professional from the Project Developer to whom the Environmental Impact Study in question corresponds.

This report corresponds to the fourth Verification and Follow-Up Report on the Mitigation and Compensation Measures included in the EMP of the Category III Study Expansion Program - Third Set of Locks, that was approved by means of Resolution DIEORA IA-632-2007.

X

3. Implement effective measures to protect all underground water sources and aquifers that are located in the area of influence of the project.

Through the Water Division and the Environmental Division, the ACP operates a series of environmental programs geared towards the protection of all underground water sources and aquifers, among them the programs from the Watershed Management Section with its environmental training programs and Environmental Economic Incentive Program, as well as Environmental Evaluation and Follow-up Programs by the Evaluation Section, and Monitoring Program of Water Quality of the Canal Water Tables by the Water Division.

X

4. In any conflict that may arise concerning the population affected by the development of the project,

The ACP has established mechanisms for processing complaints concerning the operations of the Third Set of

X


86



Compliance

Yes No Not

Applicable

the developer shall always act in their best disposition to reach a settlement with the affected parties and acting in good faith.

Locks. Through the Integrated Watershed Management Section’s environmental programs, mechanisms for community complaints have been integrated into the Consulting Council’s participatory platform. These are addressed every quarter, according to the relevant institutions where applicable.

5. Implement effective measures for sediment control during the construction and operational phases of the project, so as not to affect the water quality of the Colon, Sabanitas, and Corte Culebra water purification plants.

The ACP has a collapse prevention program in at the Culebra Cut, as well as a program for monitoring landslides through sensor installation.

X

6. Implement risk and contingency prevention methods to control seawater chloride intrusion, in the event that allowable limits in surface water bodies in areas of influence and in the water intakes installed in several points of Gatun Lake and Corte Culebra are exceeded.

During the audited period, a total of 159 water samples were collected for analyses at 14 sampling stations. It is important to mention that the results obtained for chloride concentrations indicate that the Gatún Reservoir shows no sign of saltwater intrusion.

X

7. The developer is required to prevent erosive effects on land soil where dredge material will be deposited, in addition to implementing effective measures and actions to control surface run-offs and sedimentation.

Does not apply during this term, only disposal in underwater sites.

X

8. Annually submit to the ANAM reports with results on monitoring carried out to water, soil, air and vibration quality during the construction and operational phases of the project, using recognized reference methodologies, submit the corresponding custody chain, the analysis methodologies used, the specifications of measurement equipment and corresponding calibration certificate. These reports shall be submitted in Spanish.

The ACP has carried out water quality, effluent quality (WWTP), ambient air quality program for the January to June 2018 term, pursuant to the EMP’s requirements and the Environmental Monitoring Program for the operation phase, and which results are in section 5.2.9. Environmental Monitoring Plans.

X


87



Compliance

Yes No Not

Applicable

9. The project developer shall be responsible for the comprehensive management of the waste that will be produced in the project area during its construction and operational phase. Temporary and/or final disposal of these wastes near or within water bodies channels is prohibited. Disposals shall be deposited in sites authorized by enforcing authority.

The ACP and its contractors will apply the procedures set forth in the Materials and Wastes Management Disposal Manual and Rule 210EACE103 Solid Waste Management Regular inspections to the operating facilities of Cocolí and Agua Clara, will take place. Subcontracting companies: PWM and AguAseo will take care of the removal of solid waste from the Cocolí and Agua Clara locks, respectively. Trébol Services, Inc. is in charge of cleaning the premises and removing sediments.

X

10. To have the proper use of water concession and permits and approvals issued by a competent authority, prior to any water use or water supply required by the project.

Not applicable. Agreement 116 of July 27, 2006, Regulation on Environment, Watershed and Panama Canal Watershed International Commission. The ACP keeps up-to-date water extraction records from the Gatún Reservoir. The records include geographical coordinates and the maximum authorized extraction volumes.

X

11. Comply with Technical Regulation DGNTI COPANIT 44-2000, which sets forth the hygiene and safety conditions in working environments where nose is generated.

Control measures are in place and maintenance is given to equipment and vehicle and marine engines.

X

12. Comply with Law 6 of January 11, 2007 that states about the management of oily wastes derived from synthetic based hydrocarbons in the national territory.

The ACP has environmental rule 2610 EAC-103, Environmental Rule for the Management and Use of Lubricant Oils and Hydrocarbon Products.

X

13. The developer is required to provide safety and protection to users, fishermen, boats, merchants, and others who transit through the Pacific and Atlantic entrances of the Panama Canal during the development of the project.

Through an email received on July 16, 2018, ERM was able to check a report of the communications and security systems for vessels passing through the Panama Canal’s operating area (PEC LOG ENTRY), which showed different actions and events related to the operating areas and the navigation channel (buoys out of position, metalwork falling from the third bridge over the navigation route, and hazards caused by fallen trees). This system is administrated by the Transit Operations Division.

X

14. The developer is responsible for enforcing compliance of these environmental measures for protection of

The ACP has environmental rule 2610 EAC-103, Rule for Environmental Protection of Biodiversity and Cultural

X


88



Compliance

Yes No Not

Applicable

biodiversity in all project stages and will advise all people occupying and transiting the areas of the project of the necessary conservation and protection rules for the maintenance of biodiversity.

Resources, which is strictly enforced; periodic inspections are performed at the operating facilities for the Cocolí and Agua Clara locks to ensure compliance with the measures included in the EMP concerning the protection of wildlife and flora. There are signs for animal crossings and speed limit signs. Green areas near to operating facilities receive regular maintenance.

In addition, the ACP conducts training on Regulation 2610ESM-102 for the protection of biodiversity, as part of the ACP’s Environmental Responsibility program. These training is provided through the Office of the Executive Vice President of Human Resources’ Training Section, and is aimed at new employees, ACP employees, and contractors who will enter the operating areas.

15. Comply with Law No. 36 of May 17, 1996, "whereby controls are set forth to prevent environmental pollution caused by fuel and hydrocarbons.”

The ACP has environmental rule 2610 EAC-103, environmental Rule for the management and use of lubricant oils and hydrocarbon products.

X

16. Comply with Technical Regulation DGNTI-COPANIT-49-2001 by which hygiene and safety conditions to control of air pollution in working environments, produced by chemical substances are regulated.

The ACP has rules for Industrial Hygiene and Safety: 2600SEG205 Rule for respiratory Protection, 1410SAL210 Rule for Breathing Air, 1410SAL208 Rule for the Quality of Office Indoor Environment.

X

17. Comply with Executive Decree 25 of November 16, 1998, “Which regulates Law No. 7 of January 3, 1989, regarding the protection to the ozone layer.”

The ACP has strictly enforced rules for Industrial Hygiene and Safety: 2600SEG205 Rule for respiratory Protection, 1410SAL210 Rule for Breathing Air, 1410SAL208 Rule for the Quality of Office Indoor Environment., 2600SEG116 Safety Rule for the Management and Storage of Compressed Gas Cylinders, 2600SEG247 Rule for Dust Control and environmental rules 2610 ESM-109, Rule for Ambient Air Quality, 2610 ESM-110 Environmental Rule for Fix Source Emissions, 2610 EAC-112, Rule for Motor Vehicle Emissions.

X


89



Compliance

Yes No Not

Applicable

18. Comply with all Laws, Rules, Decrees, Regulations, and Administrative Resolutions existing in the Republic of Panama, as applicable to the development of these type of projects.

ERM verified that the ACP complies with all national regulations and international agreements, as well as with the institution’s internal rules and its legal framework. On this particular point, it is worth noting that the ACP complies with the application of its Special Legal Regime. All areas pertaining to the canal’s operation and forming part of the Panama Canal are governed "exclusively" by the ACP’s Special Legal Regime, as provided in Title XIV of the Constitution, Law No. 19 of June 13, 1997, as well as in the rules and regulations that have been developed in compliance with this mandate, including the ACP’s environmental rules and regulations.

X


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8 APPENDICES


91

Appendix A: Photographic Record


92

Appendix B: List of Documents Reviewed


93

Appendix C: List of Meetings Held


94

Appendix D: Land and Water Vehicle Maintenance Log


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Appendix E: Dam and Landslide Control Log


96

Appendix F: Wildlife and Flora Rescue and Vector Control Report


97

Appendix G: Solid, Liquid, and Hazardous Waste Management Log


98

Appendix H: Air Quality Monitoring Reports


99

Appendix I: ACP WWTP Reports


100

Appendix J: ACP Water Quality Reports


101

Appendix K: Third Semiannual MiAmbiente Report Submission Note


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Appendix L: Training List


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Appendix M: Socioeconomic and Cultural Program Activity Log