TMM PyT has presented plans to address these issues and to demonstrate that the proposed project will, upon implementation of the specific measures described below, comply with applicable Mexican laws and regulations, and World Bank/IFC policies and guidelines. Detail on how these potential issues are addressed by TMM PyT follows:
- Environmental, Health and Safety Management
At the Manzanillo Terminal, overall responsibility for environmental and health and safety (EHS) matters rests with the General Manager, who, in turn, relies on the Operations Manager for technical support and the safety department for assistance with employee training programs and emergency planning. Operational procedures are designed in accordance with the Terminal’s legal and contractual requirements established by the Mexican environmental impact assessment process, relevant national and local standards and regulations, and environmental permits and licenses. Mexican environmental authorities regularly inspect the Terminal’s activities and compliance status.
TMM PyT’s EHS activities at Veracruz are effectively managed and integrated into the Port of Veracruz’ port-wide environmental management system, which will be certified to ISO 14001 (the international EMS standard) in the near future. Cruise terminal operations have appropriate EHS management in place – the Cozumel terminal’s quality management system is certified to ISO 9001. At all three locations, relevant and appropriate legal and other requirements are being followed. In particular and because of the nearby coral reefs, TMM PyT monitors water quality at the Cozumel terminal to ensure no adverse impacts occur as a result of its operations. The Company submits quarterly monitoring reports to the environmental authorities.
- Maintenance Dredging and Dredge Spoil Disposal
At Manzanillo, ongoing maintenance dredging of the approach channel and harbor is the responsibility of the Port Authority of Manzanillo (API). API disposes dredge spoil at designated marine sites in the open sea away from the channel in compliance with requirements. The respective public port authorities also have responsibility for maintenance dredging at the other three terminals.
- Stormwater Management
Stormwater is collected from the various operating areas of the Manzanillo terminal with uncontaminated runoff directed to the harbor through a main outfall. The stormwater drainage system is fitted with a manually operated valve at the outfall which can be closed to contain any spills or leaks that may occur in the container yard. Any contaminated material entering the drainage system is removed upstream of the closed valve, and subsequently disposed through an approved, licensed waste disposal contractor.
- Oil/Hazardous Materials Storage and Handling
Because of the day-to-day equipment maintenance activities conducted at the Manzanillo and Veracruz terminal operations, only incidental amounts of hazardous materials – paints, solvents, and petroleum lubricants – are stored and handled in the workshop areas (no significant equipment maintenance is conducted at the two cruise ship terminals). In addition, at Manzanillo, there are truck fueling facilities and associated diesel and gasoline storage in three underground storage tanks. The double-walled, steel tanks are constructed within concrete secondary containment structures to contain and prevent any leaks from being released to the subsurface. TMM PyT does not provide truck fueling facilities at the other three terminals.
- Liquid, Solid and Hazardous Waste Disposal
At Manzanillo, sanitary sewage generated by employees is treated in two septic tank and subsurface drainfield systems serving various buildings and areas of the terminal. The tanks are periodically pumped to maintain the systems’ effectiveness. Sewage generated at Veracruz is managed by the port-wide sewerage collection and treatment system operated by API. TMM PyT operates a small sewage treatment plant at the Progresso cruise ship terminal that recycles treated effluent for use in irrigating the landscaping on the property. Cozumel terminal sewage discharges to the municipal system.
Oily wastewaters generated from the equipment maintenance and washing in the maintenance workshops at Manzanillo and Veracruz are treated in oil/water separators. In addition, Veracruz’ car washing activity relies on a self-contained recycle unit in which all washwaters are reused. The small amounts of waste oils and other solid and hazardous wastes generated by the workshop along with any oils recovered by the oil/water separator are stored in tanks and/or containers provided with secondary containment, and periodically collected by a licensed contractor and appropriately recycled as fuel, or disposed at approved government-operated landfills.
- Ship Support Operations
API controls and has responsibility for vessel support operations involving bilge and other ship-generated wastewaters and wastes management, and relies on licensed contractors to provide these services to vessels. The ship’s agent arranges for supply of provisions, potable water, fuel with responsible third parties while berthed at the terminals. API does not permit vessels to discharge oily bilges, sludges, and water containing oily mixtures into the harbor, and conducts inspections regularly to ensure that vessel operators comply with all laws and regulations.
- Handling and Storage of Dangerous Cargoes
Some of the containerized cargo handled at TMM PyT’s Manzanillo terminal is considered to be hazardous under the International Maritime Organization’s (IMO) Dangerous Goods Code. This material includes flammable gases, poisons, flammable liquids, corrosives, reactive and spontaneously combustible substances, oxidizing substances, etc. Containerized hazardous cargo is stored by material class in segregated areas within the container storage yard with good access to containment resources and emergency response equipment; no radioactive materials or explosives are handled. The majority of containers with dangerous cargoes are handled as full containers, and the inventory is monitored continuously.
The three other terminals do not handle or store dangerous cargoes.
- Emergency Preparedness and Response
At Manzanillo and Veracruz, API is responsible for coordinating the planning and response to hazardous materials accidents and emergencies at their respective ports, and have put in place port-wide emergency action plans consistent with international maritime conventions (MARPOL 73/78). As such, API is responsible for responding to general shipboard emergency response needs and related marine spill response activities. With regard to the Terminal operations for which they are responsible, TMM PyT has established procedures, trained personnel, and equipment in place for responding to emergencies, including fire, chemical spills and mishaps, accidental release of petroleum products, and medical emergencies. At Manzanillo, TMM PyT is updating its terminal emergency response plans and procedures consistent with SSA’s other related operations in Panama and Chile. These include:
- Procedures for plan review, periodic training of employees, schedules for drills, and a emergency planning Committee function;
- Spill recordkeeping requirements;
- Procedures for conducting annual “area threat analyses”;
- Description of the emergency response organization;
- Description of hazardous material cargo segregation program;
- Documentation and reporting requirements (including notification requirements and contacts, incident reports and post incident reviews);
- Emergency equipment inventory;
- Resource and agency directory ; and
- Internal and external communications plan.
TMM PyT coordinates with API to ensure that the respective terminal and port plans are consistent and that the terminal plans meet API requirements.
- Employee Health and Safety
TMM PyT has implemented programs to ensure the health and safety of all employees. Pre-employment and periodic medical evaluations are conducted for all employees. Personnel are issued appropriate Personal Protective Equipment (PPE), briefed on its mandatory use, and regularly monitored to ensure it is used properly. Safety rules and guidelines have been established and are regularly communicated to employees through internal circulars and training programs. All new employees will receive a basic safety and security presentation and regular training will be conducted for first aid and CPR, fire fighting, and emergency response. At Manzanillo, an on-site team of designated personnel are trained in handling oil and chemical spill equipment for spills which occur in the terminal yard areas.