Mozambique - Railways and Ports Restructuring Project : environmental assessment (Vol. 1 of 2) : Executive summary

E-375 VOL. 1 Prjecos e s ArTbientais W INDD, a 1999 Nlaputo, Mlarch 1999   Executive Summary: Environmental Audit SManaqement-Plan,for the Rail & Port Restnrctunrin Prpiect The purpose of this report is to provide guidelines for implementing an Environmental Management Plan (EMP) for CFM controlled ports harbours and railway corridors in Mozambique and future concessionaires. The report comprises two principal components. The first presents the results of a legislative, institutional and environmental audit relating to all facilities, operations and activities at the ports, harbours and railway corridors of Maputo, Beira, Nacala and Quelimane (the latter only the port) which are currently under CFM control. The results of the audit are a combination of data collected from site visits and desktop studies. The outputs from the analysis of the results have been synthesis6u and presenited ais X~.y.. ksues of primary concern; A seriez. or recommendations are then suggested, in the broad context of mitigating negative environmental impacts, risks to the health and safety of employees, emergency response procedures and conducting operations in compliance with existing environmental. polibies, relevant legislation and regulations. These summary recommendations are used to generate a suite of strategic objectives and associated actions to formulate an Environmental Management Plan (EMP) that encompasses the diverse range of activities and operations currently under CFM control. This forms the second major component of this report. The target goal is to implement an EMP that meets the standards of environmental management recommended by the World Bank and IS04001. Costing exercises for suggested mitigation against actual and potential impacts identified during the audit process, and management and capacity- building prerequisites for successful implementation of the EMP have been carried out. This information is presented in a series of summary tables in chapters 5 and 6 (Table a-VII). Impact5o Projectos e Estudos Ambientais - March 1999  Executive Summary: Environmental Audit & Management Plan for the Rai7 & Port Restnucturinq Project As necessary background information on the ports, harbours, and railway corridors, this report also incorporates: > Comprehensive biophysical descriptions; > Current socio-economic conditions; > Infrastructures and services; > Detailed analysis of legal and institutional framework for environmental Management THE ENVIRONMENTAL AUDIT AND MANAGEMENT PLAN IN THE CONTEXT OF NATIONAL ENVIRONMENTAL POLICY Mozambique has recently adopted the National Environmental Management Programme (NEMP) which seeks to promote and implement sound environmental policy. The NEMP is an integral component of the Mozambican government's five-year Development Programme (1995-1999) the main objective of which is the eradication of poverty through sustainable development. A specific Action identified in the NEMP for coastal and marine protection is: "To promote the creation of conditions for national ports, especially the ports of Maputo, Beira and Nacala to deal with wastes arising from shipping activities". In July 1997 the Framework Environmental Law, arising from the NEMP was passed which requires the incorporation of environmental considerations into sectoral plans, programs and policies. In this context CFM is required by law to ensure that it adopts sound environmental policies and practices. LEGISLATIVE AND INSTITUTIONAL FRAMEWORK Mozambique possesses a wide array of legislative diplomas, decrees and regulations related to environmental management and protection. In addition, Mozambique has acceded to several international conventions. The Framework Environmental Law is a broad law covering all aspects of environmental protection. Specific regulations are currently being formulated. Nevertheless, it is incumbent upon CFM to review and where necessary revise sectoral policies, plans, operations and regulations to ensure that these are in conformance with the Environmental Law. Impacto, Projectos e Estudos Ambientais - March 1999  Executive Summarv: Environmental Audit & Management Plan for the Rail g Pbrt Restrrctunn- Proiect It follows that: > CFM must review, revise and update port, harbour and railway regulations to ensure that they adequately address environmental protection, workers health and safety and emergency situations. > CFM must up-date and reformulate the Employees Safety and Health Document and ensure that workers are fully cognisant of safety and health procedures. > CFM must formulate an Operation Emergency Response manual and establish procedures for implementing measures to deal with emergency responses. Independent of CFM, individual concessionaires are obliged to be in compliance with the Framework Environmental Law which requires regular environmental audits and ElAs for projects that may result in significant negative environmental impacts. In general, institutions in Mozambique lack operational capacity to carry out effective environmental management, control and enforcement. In addition, there is a lack of formal co-ordination between institutions. Institutional strengthening and improved inter-institutional co-ordination is required to ensure- propcr m3nar'ement, .nntrol and enforcement with regards to environmental monitoring, ElAs, land-based pollution, oil spills'and dredging. Under the restructuring programme CFM, as a holding company, will enter into contractual agreements with concessionaires who will operate components of CFM's current operations for an agreed period. An Independent Authority will be created to oversee CFM's manageThent and operations to ensure that CFM is performing in the public interest. Following restructuring the implementation sound environmental practices can be promoted at various levels: 1. Clear Terms of Reference for the Independent Authority to evaluate the environmental performance of CFM and concessionaires and where necessary to regulate. This will be contingent upon the Independent Authority being legally constituted with statutory powers to take actions where necessary. 2. Monitoring of CFM's own environmental performance as well as the performance of concessionaires through the already established environmental unit. 3. The inclusion of clauses in contractual agreements between CFM and concessionaires that specify compliance with environmental legislation and regulations. Impacto, Projectos e Estudos Ambientais - March 1999  Executive Summary: Environmental Audit & Management Plan for the Rail & Port Restructuring Project 4. Individual concessionaires are obliged to be in compliance with environmental legislation and regulations and must, therefore, adopt sound environmental management policies and practices. 5. Notwithstanding the establishment of internal regulatory mechanisms, agencies such as SAFMAR and MICOA have statutory authority to control and enforce compliance with existing legislation and regulations. I SUMMARY FINDINGS OF THE ENVIRONMENTAL AUDIT The results of the environmental audit reveal a range of issues that are summarised below. 1. Dredging That dredging is of critical importance in the continued use of Mozambique's ports is clearly illustrated by the situation at Quelimane where no maintenance dredging has occurred over the past five years. The current heavy sedimentation has resulted in the turning basin in front of the quay getting too shallow to receive vessels. However, of even greater concern is that currently, dredging and spoil disposal is being conducted with limited knowledge of '^o-P ' inprnics and estuarine ecologv (which varies between ports). For example in Maputo, dredging spoil are currently disposed along the westem margins of Baia da Capitania where fine sediments can be easily re- suspended and migrate to the channel areas from which they have just been dredged. A similar scenario emerges where mangrove communities are depleted as they function as natural sediment traps. This general lack of knowledge of coastal zone dynamics is a particularly sensitive matter in cities like Beira, which suffer from severe coastal erosion. Based on the findings of this report we recommend: . The development of National Environmental Plan for dredging and site disposal activities as a guide to the opening and maintenance operations of port access channels in sound and sustainable way. * Monitoring programmes and, where necessary, ElAs for all dredge-related activities for all of Mozambique's ports. Beira port is the only site for which an EIA has been conducted. * That special consideration should be given to ecologically sensitive areas, notably mangroves and other wetlands, seagrass beds, and coral reef communities, and mitigation measures are taken wherever possible. Impact5, Projectos e Estudos Ambientais - March 1999 iv  Executive Summary: Environmental Audit & Manaaement Pfan foKthe Mail'S Port Restructuinna Pmiect Careful selection of disposal sites, routine analysis of dredged sediments for contaminants, and consideration of the possibility for using the dredged material to rehabilitate ecosystems or to help erosion control. 2. Environmental and safety issues relating to general cargoes, raw materials and waste management at Mozambican ports and transport corridors In countries throughout the world, ports and associated transport corridors have to handle, and store a diverse range of raw materials and products; Mozambique is no exception. This diversity of activities poses potential risks to the environment viz. pollution via oil and hazardous materials spills (in ports and at sea) and unsound waste management practices and to the health and safety of employees viz. handling of hazardous materials and operating transport and loading equipment and other machinery. Other problems surrounding such large-scale operations include the occurrence of unforeseen emergency situations such as fires or explosions at oil terminals and natural disasters such as floods, cyclones etc. Depending on the context, this range of impacts can occur on a local, regional, National or global scale. Based on the findings of this report, we recommend: . Implementation of air pollution control measures. Employees and the environment are currently at risk from uncontrolled storage of asbestos containing materials (all ports), ammonia emissions (Maputo only), dust from the unbunded storage of coal (al! ports), silica frorn unhnded wheat storage (Nacala only) and dust from the CFM-Sul quarry (Maputo). . An assessment of the degree of disrepair of all storage and transfer facilities for petroleum products and food oils at all ports and an EIA at facilities where leaks and spills have already occurred. v * Implementation of formal guidelines for the safe handling and storage of both hazardous waste and hazardous products. . A review and revision of current waste management practices. It is essential to collect, store and dispose the myriad variety of general and hazardous waste materials on a routine basis. Recycling options should also be carefully considered. Waste-related management practices are currently non-existent; hence there are a range of serious potential risks to both employees and the immediate environment. . An assessment of storm water drainage systems at all ports, as there is currently a lack of adequate facilities. This introduces the risk of pollution through groundwater and soil contamination, runoff to the marine environment as well as risk to the health and safety of employees. * An environmental audit of domestic sewage waste management practices. Currently sewage is stored and processed in septic tanks, French drains Impacro, Projectos e Estudos Ambientais - March 1999 v  Executive Summary: Environmental Audit & Mana-cement Plan for the Rail & Port Restructunna Proiect etc. However, untreated stored sewage represents a potential health hazard and a risk to the environment. Hence all such facilities should be subject to regular checks, routine maintenance and EIA if spillage or leaks are reported. . Review existing guidelines for employee safety and health under all working conditions. This problem is highlighted when considering the state of disrepair of General Workshop areas and repair facilities which suffer from inadequate mechanical and electrical safety, fire protection, ventilation (especially in paint workshops) and storage and disposal of waste oils etc. which accumulate on a day to day basis. Furthermore, There appears to be no formal system of permit use when operating equipment and no provisioning of protective clothing where appropriate. 3. Rail corridors Materials transported along the Maputo, Beira and Nacala rail corridors include chemicals, and petroleum products and other potentially hazardous materials and herbicides are used to control vegetation along the tracks. Rail sidings are littered with abandoned and neglected rolling stock, trucks and coaches. There has been haphazard dumping of waste such as asbestos and cther puauiit.-.Is espec ': ang the Maputo Corridor. The poor condition of the track at Maputo and Matola leads to regular derailments with attenaant risks of pollution and accidents to employees. There is an employee health and safety manual for CFM railway employees but it is out of date and rarely consulted. The volume and nature of cargo transported within the corridors c6tupled with inadequate maintenance constitutes a major risk to adjacent environments along the corridors as well as to the health and safety of employees. Based on the findings of this report we recommend: * ElAs with special reference to soil erosion in mountainous regions and all protected areas that these rail corridors traverse. Deforestation is already occurring as a consequence of informal settlement along rail corridors. Of special importance are the controlled hunting areas south of Gorongosa, and forest reserves in Manica and Sofala provinces. Any EIA should be conducted in co-ordination with DNFFB to ensure that they are carried out in accordance with ongoing conservation programmes. * Handling and transport of hazardous materials to be in concordance with CFM policy for handling similar materials in ports. * Implementing routine maintenance along all corridors in order to reduce the frequency of occurrence of derailments and accidents to employees. Impacto, Projectos e Estudos Ambientais - March 1999 vi  Executive Summary: Environmental Audit & Management Plan for the Rail & Port Restructunna Project. . Implementing waste management practices in concordance with CFM policy for ports. * An assessment of the state of disrepair of all CFM rolling stock currently used to transport fuels and other potentially hazardous materials. Repairs should be carried out and a programme of routine maintenance implemented thereafter. | THE ENVIRONMENTAL MANAGEMENT PLAN CFM's Environmental Management Plan is based upon a suite of objectives each comprising a series of actions. The overall objective of the EMP is: To ensure that environmental considerations are incorporated into all plans, programs and activities carried out by CFM and concessionaires so that these are in compliance with existing Mozambican environmental policies, legislation and regulations Strategic Objective I To formulate an environmental policy clearly indicating CFM's commitment to incorporate environmental dimensions into all plans, -programmes and activities in compliance with existing legislation, regulations and conventions. ACTION 1. Draw up and formalise an environmental policy related to CFM's plans, programs and activities. Impacto, Projectos e Estudos Ambientais - March 1999 vii  Executive Summary: Environmental Audit & Management Plan for the Ral7 & Port Restructurinn Proiect CFM Policy should state clearly the companies firn commitment to compliance with all applicable laws and regulations, the promotion of waste reduction, resource and property conservation and environmental protection and the training of employees to be knowledgeable about all environmental matters relevant to their work. Strategic Objective 2 To ensure that CFM and concessionaires are in compliance with existing policies, legislation, regulations and regional and international conventions. ACTIONS 1. Review where necessary, current CFM policy to be in compliance with existing laws, regulations and licensing procedures. 2. Include contractual obligations to comply with environmental norms and regulations in contracts drawn up between CFM and concessionaires. Strategic Objective 3 To define and develop institutional roles, responsibilities f-Eand Jisdictional competencies in order to co-ordinate activities for the impiement.ation .ofthe EMP. ACTIONS 1. Review institutional roles and responsibilities. 2. Identify inter-institutional mechanisms for improved environmental monitoring, enforcement and control. Impac?o, Projectos e Estudos Ambientais - March 1999 viii  Executive Summary: Environmental Audit,& Management Plan for the Rai & Port Restructunng Proiect Strategic Objective 4 To reduce and prevent negative environmental impacts arising from operations and activities performed by CFM and concessionaires. ACTIONS 1. Document base-line environmental conditions of areas affected by operations and activities carried by CFM and concessionaires, based on the information presented in this report. 2. Develop procedures for environmental screening of operations and activities carried by CFM and concessionaires. 3. Develop guidelines for Environmental Impact Assessment procedures associated with ports, harbour and railways operations that may have significant environmental impacts. These will identify appropriate mitigation measures to reduce/eliminate actual/potential environmental impacts. 4. Develop a monitoring program to ensure that environmental impacts are detected at all levels and stages of the project operations and activities. 5. Develop best practices ariu piotocols for the transport, handling, treatment and disposal of general and hazardous materials and wastes to minimise/eliminate risk of environmental and human health risks. Strategic Objective 5 To update employee health and safety guidelines and develop procedures. for their implementation. ACTIONS 1. Update guidelines and implement procedures for employee health and safety. 2. Through awareness and training ensure that workers are fully familiar with employee health and safety regulations and procedures. Impacto Projectos e Estudos Ambientais - March 1999 iX  Executive Summary. Environmental Audit & Management Plan for the Rail & Port Restructunno Project Strategic Objective 6 To ensure that CFM/concessionaires are able to cope with emergency situations that may impact on human and environmental well being. ACTIONS 1. Formulate a policy and guidelines for emergency response for emergency situations. 2. Develop adequate procedures for emergency responses for disasters and accidents. Strategic Objective 7 To ensure that environmental considerations are incorporated into dredging operations associated with Maputo, Beira and Quelimane Ports ACTION 1. In collaboration with relevant national institutions develop a National Policy on dredging and dredged material disposal associated with CFM's ,Yorts and harbours Strategic Objective 8 To formulate, in collaboration with relevant national institutions, a National Oil Spill Contingency Plan. ACTION 1. In collaboration and consultation with SAFMAR and MICOA, formulate a national oil spill contingency plan. Impacte, Projectos e Estudos Ambientais - March 1999 x  Executive Summarv: Environmental Audit. & Management Plan for the Rail & Port Restructunrin Project Strategic Objective 9 To formulate and implement a human resources development strategy for environmental management through appropriate training. ACTIONS 1. Carry out training needs assessment of CFM staff and associated agencies. 2. Based on the training, needs assessment, develop, design and/or identify appropriate training courses for CFM staff and associated agencies. Strategic Objective 10 In the long term, formulate an environmental management system based on Internationally accepted criteria and standards, specifically ISO 14001. ACTION 1. Through a process of refinement and revision to the EMP to d6velop an environmental management plan that is in full conformance with ISO 14001 Based on these actions, a series of detailed plans and recommendations for implementation have been formulated, viz. > An outline policy for CFM > Contractual obligations of concessionaires > Institutional roles in co-ordinating improved environmental screening, monitoring, enforcement and control > Detailed environmental assessment and monitoring > Environmental impact assessment procedures/ requirements Impacto, Projectos e Estudos Ambientais - March 1999 xi  Executive Summarv. Environmental Audit & Management Plan for the Rail & Port Restructurinca Project > Waste management plan > Employee safety and health policy for the ports, harbours and railways of Mozambique > Operational emergency organisation > Establishment of norms and guidelines for dredging > Oil spill management > Training > Conformance with ISO 14001 Standards Impactcr, Projectos e Estudos Ambientais - March 1999 xii