environmental monitoring report · 4. the ministry of transport and vec will prepare periodic...

Environmental Monitoring Report

Second External Environmental Monitoring Report

September 2016

Viet Nam: Greater Mekong Subregion Ben Luc-Long Thanh Expressway Project - Tranche 1

Prepared by the External Environmental Monitoring Consultant for the Viet Nam Expressway Corporation and the Asian Development Bank.

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NOTE

(i) In this report, "$" refers to US dollars.

This environmental monitoring report is a document of the borrower. The views expressed herein do not necessarily represent those of ADB's Board of Directors, Management, or staff, and may be preliminary in nature.

In preparing any country program or strategy, financing any project, or by making any designation of or reference to a particular territory or geographic area in this document, the Asian Development Bank does not intend to make any judgments as to the legal or other status of any territory or area.

BL-LT Expressway Project, Construction Stage – Package C2: External Environmental Monitoring, March-April 2016; Revised September 2016.

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ABBREVIATIONS

ADB Asian Development Bank

CSC Construction Supervision Consultants

CEMPs Construction Environmental Management Plans

EPMU BLLT Ben Luc – Long Thanh Expressway Project Management Unit

EIA Environmental Impact Assessment

EMP Environmental Management Plan

EEMC External Environmental Monitoring Consultants

HSE Health, Safety and Environment

IEMC Independent Environmental Monitoring Consultants = External Environmental

Monitoring Consultants

JICA Japan International Cooperation Agency

GoV Government of the Socialist Republic of Vietnam

LEP Law on Environmental Protection of Vietnam

MFF Multi Tranche Financing Facility

PC People Committee

PFR2 Periodic Financing Request for Loan 2

SES Site Environment Supervisor

VESDEC Institute for Environmental Science and Development

USD United State Dollar

VEC Vietnamese Expressway Corporation

VND Vietnam Dong

WHO World Health Organization


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LIST OF CONTENTS

PART ONE: ....................................................................................................................................................................................... 1 INTRODUCTION ON IMPLEMENTATION OF THE EXTERNAL ENVIRONMENTAL MONITORING (PACKAGE C2) IN THE SECOND MOBILIZATION, MARCH – APRIL 2016 .......................................................................................................................... 1

1.1. INTRODUCTION OF THE PRESENT CONSTRUCTION PROGRESS AND ENVIRONMENTAL MANAGEMENT SYSTEMS OF THE PROJECT ...................................................................................................................................................... 1 1.2. INTRODUCTION OF EXTERNAL ENVIRONMENTAL MONITORING, 2016 ........................................................................ 7

PART TWO: ..................................................................................................................................................................................... 20

ASSESSEMENT OF ENVIRONMENTAL MANAGEMENT AND COMPLIANCE OF BEN LUC - LONG THANH EXPRESSWAY PROJECT MANAGEMENT UNIT WITH THE ENVIRONMENTAL MANAGEMENT PLAN ........................................................... 20

2.1. TASKS OF BEN LUC – LONG THANH EXPRESSWAY PROJECT MANAGEMENT UNIT (EPMU) IN ENVIRONMENTAL MANAGEMENT ........................................................................................................................................................................... 20 2.2. ORGANIZATION OF ENVIRONMENTAL MANAGEMENT ................................................................................................. 20 2.3. ACTIVITIES IN PROJECT ENVIRONMENTAL MANAGEMENT ......................................................................................... 21 2.4. EVALUATION OF EEMC ON COMPLIANCE OF EPMU WITH THE EMP ........................................................................... 22

PART THREE: ................................................................................................................................................................................. 23 ASSESSMENT OF COMPLIANCE OF THE CONSTRUCTION SUPERVISION CONSULTING (CSCS) WITH THE ENVIRONMENTAL MANAGEMENT PLAN .................................................................................................................................... 23

3.1. TASKS OF CSCS IN ENVIRONMENTAL SUPERVISION ................................................................................................... 23 3.2. ACTIVITIES OF CSCS IN ENVIRONMENTAL SUPERVISION............................................................................................ 23 3.3. EVALUATION OF EEMC ON ENVIRONMENTAL SUPERVISION OF CSCS...................................................................... 27

PART FOUR: ................................................................................................................................................................................... 30 ASSESSMENT OF ENVIRONMENTAL MANAGEMENT AND COMPLIANCE OF THE CONTRACTORS WITH THE ENVIRONMENTAL MANAGEMENT PLAN (BY PACKAGE)......................................................................................................... 30

4.1. ENVIRONMENTAL MANAGEMENT AND COMPLIANCE OF PACKAGE A1 WITH THE ENVIRONMENTAL MANAGEMENT PLAN ................................................................................................................................................................ 30 4.2. ENVIRONMENTAL MANAGEMENT AND COMPLIANCE OF PACKAGE A2-1 WITH THE ENVIRONMENTAL MANAGEMENT PLAN ................................................................................................................................................................ 34 4.3. ENVIRONMENTAL MANAGEMENT AND COMPLIANCE OF PACKAGE A2-2 WITH THE ENVIRONMENTAL MANAGEMENT PLAN ................................................................................................................................................................ 37 4.4. ENVIRONMENTAL MANAGEMENT AND COMPLIANCE OF PACKAGE A3 WITH THE ENVIRONMENTAL MANAGEMENT PLAN ................................................................................................................................................................ 41 4.6. ENVIRONMENTAL MANAGEMENT AND COMPLIANCE OF PACKAGE J2 WITH THE ENVIRONMENTAL MANAGEMENT PLAN ................................................................................................................................................................ 47 OVERALL ASSESSMENT ON COMPLIANCE WITH EMP REQUIREMENTS ................................................................................................ 50 4.7. ENVIRONMENTAL MANAGEMENT AND COMPLIANCE OF PACKAGE J3 WITH THE ENVIRONMENTAL MANAGEMENT PLAN ................................................................................................................................................................ 54

PART FIVE: ..................................................................................................................................................................................... 59 PUBLIC CONSULTATION .............................................................................................................................................................. 59

5.1. ORGANIZATION OF PUBLIC CONSULTATION .................................................................................................................. 59 5.2. PUBLIC CONSULTATION AT THE SELECTED COMMUNES ........................................................................................... 59


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CONCLUSIONS AND SUGGESTIONS .......................................................................................................................................... 72 APPENDIXES: ASSESSMENT OF COMPLIANCES OF THE CONSTRUCTION CONTRACTORS WITH THE EMP REQUIREMENTS ............................................................................................................................................................................ 78

APPENDIX 1: ASSESSMENT OF THE COMPLIANCE OF CONTRACTORS OF PACKAGE A1 WITH THE EMP REQUIREMENTS ....................................................................................................................................................................... 78 APPENDIX 2: ASSESSMENT OF THE COMPLIANCE OF PACKAGE A2-1 WITH THE EMP REQUIREMENTS .................... 120 APPENDIX 3: ASSESSMENT OF THE COMPLIANCE OF PACKAGE A2-2 WITH THE EMP REQUIREMENTS .................... 162 APPENDIX 4: ASSESSMENT OF THE COMPLIANCE OF PACKAGE A3 WITH THE EMP REQUIREMENTS ....................... 196 APPENDIX 5: ASSESSMENT OF THE COMPLIANCE OF PACKAGE A4 WITH THE EMP REQUIREMENTS, APRIL 2016 .. 239 APPENDIX 6: ASSESSMENT OF THE COMPLIANCE OF PACKAGE J2 WITH THE EMP REQUIREMENTS ........................ 242 APPENDIX 7: ASSESSMENT OF THE COMPLIANCE OF PACKAGE J3 WITH THE EMP REQUIREMENTS ........................ 281

PERSONS MET BY THE EEMC SPECIALISTS DURING IMPLEMENTATION OF EXTERNAL ENVIRONMENTAL MONITORING IN MARCH AND APRIL 2016 ........................................................................................................................................................ 320


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LIST OF FIGURES Figure 1: Alignment of Ben Luc – Long Thanh Expressway ............................................................................................................ 1 Figure 2: Environmental Management Organization in the Construction Stage ............................................................................... 5 Figure 3: Organization Chart of Environmental Management for ADB Section ................................................................................ 6 Figure 4: Organization Chart of Environmental Management for JICA Section ................................................................................ 6 Figure 5: Organization Chart of BL-LT Expressway Project Management, included environmental and safety management system ........................................................................................................................................................................................................ 21 Figure 6: Organization Chart of Environmental Supervision for ADB Packages ............................................................................. 24 Figure 7: Organization Chart of Environmental Supervision for ADB Packages ............................................................................. 24 Figure 8: Organization of the Contractor, included environmental and safety management system .............................................. 31 Figure 9: Organization of the Contractor of Package A2-1, included environmental and safety management system .................. 35 Figure 10: Organization of the Contractor of Package A2-2, included environmental and safety management system ................ 38 Figure 11: Organization of the Contractor of Package A3, included environmental and safety management system ....................................................................................................................................................................... 45 Figure 12: Organization of safety and environmental management of A4 Contractor .................................................................... 46 Figure 13: Organization of the Contractor of Package J2, included environmental and safety management system ....................................................................................................................................................................... 48 Figure 14: Organization of the Contractor of Package J3, included environmental and safety management system ....................................................................................................................................................................... 56


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LIST OF TABLES

Table 1. Updated stations of sub-divisions of packages .................................................................................................................. 2 Table 2. Summary of the civil contract packages of A1, A2-1, A2-2 and A3 .................................................................................... 2 Table 3. Summary of the Civil Contract Packages of J1, J2 and J3 ................................................................................................ 4 Table 4. Definitions of major and minor category of EMP Infringements at construction sites ...................................................... 10 Table 5. Definition of some environmental non-compliance activities (examples) ......................................................................... 11 Table 6. Main quantity of Package A2-1 ......................................................................................................................................... 34 Table 7. Works and progress of Section A4 by early April 2016 ..................................................................................................... 44 Table 8: List of local government and residents in public consultation meeting at Hung Long commune ...................................... 60 Table 9 Comments and complaints of participants in consultation meeting at Hung Long commune ............................................ 61 Table 10: List of local government and residents in public consultation meeting at Binh Khanh commune ................................... 64 Table 11: Comments and complaints of participants in consultation meeting at Binh Khanh commune ........................................ 65 Table 12: List of local government and residents in public consultation meeting at My Yen commune ......................................... 67 Table 13. Comments and complaints of participants in consultation meeting at My Yen commune .............................................. 68 Table 14. ADB general comments on the external environmental monitoring report and responses of EEMC………………………………………………………………………………………………………………..75


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PART ONE:

INTRODUCTION ON IMPLEMENTATION OF THE EXTERNAL ENVIRONMENTAL MONITORING (PACKAGE C2) IN THE SECOND MOBILIZATION, MARCH – APRIL 2016

1.1. INTRODUCTION OF THE PRESENT CONSTRUCTION PROGRESS AND ENVIRONMENTAL MANAGEMENT SYSTEMS OF THE PROJECT

1.1.1. Project Alignment 1. The Government of the Socialist Republic of Vietnam (GOV) represented by Vietnam Expressway Corporation (VEC) is implementing Ben Luc – Long Thanh Expressway Project (hereafter: the Project). The Project constructs a 57.1 km of an expressway connecting Ben Luc in Long An Province, Southern Ho Chi Minh City and Long Thanh in Dong Nai Province, which is a short link of the GMS Southern Economic Corridor. 2. The expressway is divided into a Western section (19.8 km), a middle section (11.0 km), and an Eastern section (26.3 km). The expressway traverses through 16 communes in 7 districts of 3 provinces. The project alignment is started from My Yen commune and part of an access-road in Tan Buu commune, Ben Luc district, Long An province; then it goes through Binh Chanh commune, Tan Quy Tay commune, Hung Long commune, Da Phuoc commune in Binhchanh district; Nhon Duc commune, Long Thoi commune in Nha Be district, and Binh Khanh commune in Can Gio district, in Ho Chi Minh City; then goes through Vinh Thanh commune, Phuoc An commune in Nhon Trach district, Long Phuoc commune, Phuoc Thai commune in Long Thanh district of Dong Nai Province. The land acquisition area along the route varies from 56m - 73m wide.

Figure 1: Alignment of Ben Luc – Long Thanh Expressway


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For the expressway construction, Asian Development Bank (ADB) finances the Western and Eastern sections, and Japan International Cooperation Agency (JICA) finances the middle section.

3. A multi tranche financing facility (MFF) is applied to the Project. MFF 0053-VIE was approved by ADB for $636 million on 14 December 2010. In response to the Government’s periodic financing request, Loan 2730-VIE (Loan 1) to construct the western section of the Expressway was approved for $350 million on 21 December 2011. The Loan and Project Agreements for Loan 2730-VIE were signed on 5 May 2011 and 25 May 2011, respectively, and became effective on 2 December 2011.

4. The Ministry of Transport and VEC will prepare Periodic Financing Request for Loan 2 (PFR2) and submit it to the ADB. Due diligence reports for environment and resettlement, among others, will be attached to PFR2.

5. The project includes 11 construction packages (table 1) and 01 ITS package (Intelligent Transportation System).

1.1.2. Summary of Construction Progress of the Construction Packages

6. Summaries of construction progress of the construction packages are given in tables 2 and 3.

Table 1. Updated stations of sub-divisions of the packages

New Name of packages (DD)

Updated station

Length (m)

Remarks Beginning point Ending point

A1 Km 00+600.0 Km 07+900.0 7,300.00 ABD fund

A2 A2-1 Km 07+900.0 Km 11+200.0 3,300.00 ABD fund

A2-2 Km 11+200.0 Km 16+599.0 5,399.00 ABD fund

A3 Km 16+599.0 Km 18+709.5 2,110.50 ABD fund

A4 Km 18+709.5 Km 21+743.0 3,034.00 ABD fund

JICA

J1 Km 21+743.0 Km 24+506.0 2,764.00 JICA fund

J2 Km 24+506.0 Km 29+256.5 4,750.00 JICA fund

J3 Km 29+256.5 Km 32+445.5 3,189.00 JICA fund

A5 Km 32+445.5 Km 35+900.0 3,455.00 ABD fund

A6 Km 35+900.0 Km 52+400.0 16,500.00 ABD fund

A7 Km 52+400.0 Km 57+700.0 5,300.00 ABD fund


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Table 2. Summary of the civil contract packages A1, A2-1, A2-2 and A3

Description

Packages

A1 A2-1 A2-2 A3 A4

Location Km 0+600 – Km7+900

Km 7+900 – Km11+200

Km11+200.0-Km16+600.0

Km 16+600 – Km18+7135

Km 18+7135 - Km21 + 739.5

Description

- Package A1 starts at Km 0.600 and ends at Km7+900 with a length of 7.3 km lasting from Ben Luc to Can Giuoc district, Long An province. - Construction works: 4 viaducts (Interchange with HCM-Trung Luong Expressway; interchange with National Highway N1; Phuoc Ly bridge and Ong Thoang brigge).

- Package A2-1 starts at Km7+900 and ends at Km11+200 with a length of 3.3 km - Construction works: 1 viaduct over Hai Son Residential Area and 2.000m of expressway.

- Package A2-2 starts at Km11+200.0 (Hung Long commune, Binh Chanh district) and ends at Km16+600.0 (Da Phuoc commune, Binh Chanh district, HCMC ) with a length of 5,400m. - Main works: 5.4 km of expressway and 4 bridges (Ong Thin: 711 m; Viaduct over NH50; Viaduct over interchange with NH50; Ong Nam bridge)

- Package A3 starts at Km 16+600 and ends at Km18+7135 in Binh Chanh district, HCMC with a length of 2.100 km.

- Main works:

1 viaduct and 1,500 m of expressway.

- Package A4 starts at Km 18+7135 and ends at Km21 + 739.5 in Nha Be district, HCMC with a total length of 3.026km.

- Main works:

2 viaduct and 2,200m of expressway

Contract Number

03/HDXD-VEC/2015

04/HDXD-VEC/2015

067/HDXD-VEC/2014

67/HDXD-VEC/2015

39/HDXD-VEC/2015

Contract Length 7.300 Km 3.300 Km 5.400 Km 2.100 Km 3.026 Km

Contractor

JV Halla Corp –Vinaconex Eng.Cons.& Invest.JSC.

JV Kukdong Eng.Consrt. Co.-Trung Chinh T.C.

JV of Samwhan Corporation - Van Cuong

JV Halla Corp –Vinaconex Eng.Cons.&Invest.JSC.

JV Kukdong Engineering & Construction Co., Ltd & Dong Mekong Construction Manufacture


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NTP May 26th,2015 May 19th, 2015 Aug 15th 2015 May 19th, 2015 Feb 17th, 2016

Contract Period 1080 days 1076 days 1050 days 1095 days 900 days

Progress (%), by April 2016

17 17 3 16 0.06

Table 3. Summary of the civil contract packages J1, J2 and J3

Information Packages

J1 J2 J3

Location Km 21+739.5-Km 24+503. Km24+506.5 – Km29+256.5 Km29+256.5-Km32+445.5

Description

Package J1 starts at Km 21+739.5 and ends at Km 24+503. The structure of the main bridge with the length of spans of 187.25m+375m+187.25m over the Soai Rap River.

Package J2 located in Can Gio district, Ho Chi Minh City, starts at Km24+506.5 and ends at Km29+256.5 with a length of 4,7 km, included Cha river bridge and viaduct crossing Can Gio district

Package J3 located in Can Gio district, Ho Chi Minh City, starts at Km 29+256.5 and ends at Km 32+445.5, included Phuoc Khanh bridge with length of spans of 149.5 + 300 + 149.5 m = 599m length.

Contract Number

No.15/HDXD-VEC/2015 dated 9th June, 2015

No. 46/HDXD-VEC/2014 Dated 30th June, 2014

No.17/HDXD-VEC/2015 dated June17th, 2015

Contractor JO of Shimizu – VINACONEX E&C

JO of Sumitomo Mitsui – CIENCO4

JO of Sumitomo Mitsui – CIENCO4

NTP April 1st 2016 October 28th 2014 January 1st 2016

Contract Period 47 months 32 months 42 months

Progress (%) by April

2016 - 78 14

Source: EPMU Ben Luc-Long Thanh, April 2016.


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1.1.3. Organization of Environmental Management of the Project

7. In this construction stage environmental management and monitoring organization of the Project is defined in figure 2. Environmental management organization of the JICA and ADB sections is shown in figures 3 and 4. The following diagram describes the parties involved and their reporting relationships.

Figure 2: Environmental Management Organization in the Construction Stage

Note: (a) By the LAP (2014) and Decree 18/2015/ND-CP of the GoV in environmental supervision for projects in the construction and operation phases the provincial DONREs can supervise PMUs and commune PCs can supervise the Site Engineers and Contractors in their environmental management activities.

(b) Effect Environmental Monitoring Consultants are not External Environmental Monitoring Consultant (EEMC)

VEC

EPMU BLLT

Project Supervision Consultants (Environmental

specialist)

Effect Environmental Monitoring Consultants

Qua

rterly

CONTRACTOR

Constructor’s Env. Monitoring

Site Engineers

Mon

thly

PROJECT SITE

Mon

thly

m

onito

rin

DoNREs of Long An,

HCMC and Dong Nai

Quarterly report

Commune PCs

Environmental Division of

Districts

Report line

Supervision line Frequency monitoring Random monitoring line


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Figure 3: Organization Chart of Environmental Management for ADB Section

Figure 4: Organization Chart of Environmental Management for JICA Section

Note: In the Agreement of JICA and VEC in the JICA sections international environmental specialist is not required.

CSC C5 Main Office

National Env. Specialist

Trained Inspectors of J1 site office of CSC C5



Construction sites of J1



CSC C1 Main Office

International Env. Specialist

National Env. Specialist for Western Sub-section

National Env. Specialist for Eastern Sub-section

Trained Inspectors of Eastern Site office

Trained Inspector No.1 of Western Site office

Trained Inspector No.2 of Western Side office

Construction sites of A5, A6 and A7

Construction sites of A3, A4

Construction sites of A1, A2-1 and A2-2


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1.2. INTRODUCTION OF EXTERNAL ENVIRONMENTAL MONITORING, 2016

1.2.1. Requirements of External Environmental Monitoring

1.2.1.1. Objectives of the Consulting Services

8. Objectives of the Consulting Services for external (independent) environmental monitoring consultant (EEMC) are given in the TOR for Package C-2 are as below.

- To assess compliance of the project implementation with the ADB Safeguard Policy Statement 2009 (ADB SPS) and the Project environmental management plan (EMP) which is included in the ADB-cleared environmental impact assessment (EIA) dated September 2010. - To periodically perform independent review for determining monitoring information of EMP’s implementation and evaluate whether EMP’s terms was made as requested or not.

- To prepare a monitoring report provides details of the method used; results (check profile implementation process of the contractor and supervision consultant, site observation, consultation, and interview), petition; and other relevant information to support the result (minutes of meetings, photo documentation, etc,).

- To provide technical supports for VEC and PMU, develop periodic reports on environmental management and monitoring of compliance of contractors.

- To propose and strengthen environmental management and monitoring of contractors, supervision and PMU.

1.2.1.2. Scope of Work

9. In general, the scopes of work of independent environmental monitoring services include the tasks as follows:

(i) To consider and verify accuracy, breadth, depth and relevance of information that is provided by VEC to ADB concerning implementation of EMP.

(ii) Determine whether EMP’s terms (monitoring, mitigation, supervision, reports, etc) have been done right and on time or not and complied with budget which is identified in EMP or not.

- The tasks above are carried out every year during the construction process and during the first year of expressway operation by reviews of environmental monitoring reports, site visits and interviews with affected households, local authorities and other stakeholders’ agency or other appropriate actions in order to attain full and proper objectives and scope of work as mentioned above.

- External environmental monitoring consultant is mobilized every year during construction process and during the first year of expressway operation. Monitoring report prepared by the Consultant will provide details of used method; outcomes (reports, site observation, advice/interview); recommendations, and relevant information to support results (meeting minutes, documents, etc.). These reports will be submitted to VEC and ADB two weeks after completion of each monitoring activity.

- Monitoring process is performed by reviews of environmental monitoring reports, site visits and interviews with affected households, local authorities and other stakeholders:


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1.2.2. Methodology Used in External Environmental Monitoring, 2016

1.2.2.1. Desk Review

10. The EEMC reviewed the fulfillment and completeness of the environmental records, reports and documents prepared by EPMU, Construction Supervision Consultants (CSC), and the contractors related to:

- environmental permission papers provided by the environmental management authorities for EMPU and the contractors;

- environmental and safety requirements in the construction contracts between VEC and the contractors;

- the activities carried out and the records and documents created/update/ maintained by the EPMU.

- the activities carried out and the records and documents created/update/ maintained by the CSC.

- the activities carried out and the records and documents created/update/ maintained by the contractors;

- the status of implementation of environmental protection measures against the EMP and contract documents of the contractors;

- the effectiveness of environmental mitigation measures and project environmental performance of the contractors.

1.2.2.2. Random Site Inspection

11. As part of the monitoring process, in this second mobilization the EEMC carried out random checks at the sites of 7 construction packages:

- 5 ADB packages: A1, A2-1, A2-2; A3 and A4;

- 2 JICA packages: J2 and J3.

12. The EEMC environmentalists visually looked at the construction sites, access roads, worker’s camps, disposal sites, batching plants of all above mentioned packages and made notes related to the following environmental issues:

(i) Compliance/violation of contractors to Environmental Specifications, EMP provisions included in the ADB’ cleared EIA, and approved Site Specific (Construction) EMP’s (CEMPs). (ii) Application of mitigation measures for or sign of soil erosion along the expressway due to excavation. (iii) Waste management practices at worker’s camps, at the construction sites. (iv) Disruption of exiting services during construction. (v) Status of construction worker camps and sanitation facilities for them. (vi) Water quality control facilities at and surrounding the worker’s camp. (vii) General clean up after construction works. (viii) Status of landscape rehabilitation, re-vegetation in the disturbed areas, particularly at borrow pits and quarries, and disposal sites. (ix) Impact of construction works (level of noise, dust, vibration) on surrounding residential areas, and damage roads due to earthworks and transportation of building materials.


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(x) Status of implementation of safety measures (signboards, restricted zone, fences, the use of protective equipment, etc.), particularly at the intersections and other traffic hotspots.

1.2.2.3. Public Consultation

13. In the second mobilization (March – April 2014) the EEMC with participation of EPMU representatives have conducted 3 public consultations at 3 representative communes at the ADB and JICA sections in order to:

(i) assess level of involvement by the local authorities in dealing with environmental issues (dust, noise, and damage to roads due to the transport of construction materials, tree cutting on public lands and protected areas).

(ii) identify any other environmental issues and record environmental complaints from the affected people. (iii) obtain responses (if any) from EPMU, Construction Supervision Consultants (CSC) and the contractors on environmental complaints incompliance. (iv) obtain comments and complaints from local residents and authorities on environmental and safety issues. 14. All comments and complaints from local residents and authorities were noted. Name of participants are recorded; photos of consultation meetings are made (see Part Five: Public Consultation). Comments and complaints obtained in the meetings are informed to EPMU. 1.2.2.4. Use of Technical Guidelines for Environmental Monitoring 15. The Technical guidelines for environmental monitoring has been set up by the EEMC in 2015 and it is used in environmental monitoring in the second mobilization (March – April 2016).

Methods Used for Random Site Monitoring

16. Because time for independent environmental monitoring only 1 month/year, site environmental visit is not conducted daily, weekly, monthly but only randomly and annually.

17. The annual random site monitoring conducted by EEMC is mainly for rapid checking the results of the EPMU in environmental management; CSCs in environmental monitoring/supervision; contractors in implementation of the mitigation measures required in the EMP (2010) and giving recommendations on corrective measures if non-compliances of EPMU, CSCs and contractors will be found.

18. In this external monitoring in 2016 the EEMC has used the following method for random environmental monitoring.

Before site visit:

- Study on the construction contract of the Package to identify any specification on environmental management to be followed by the contractor.

- Study to well understand the environmental requirements in the EIA reports approved by MONRE and ADB.

- Obtain information from the Contractors and EPMU on construction activities and activities of the contractors in environmental management.

- Obtain letters from local authorities and residents, complaining about environmental impacts, if any.

- Study to well understand classification of environmental compliance to be applied for environmental monitoring for this Project.

During site visit:


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- Carefully check all environmental and safety issues at the contractor’ construction sites, disposal sites, roads used for material transport and worker camps

- Carefully record all good and bad measures applied by the contractors to comply with the EMP requirements;

- Advice the contractors in improvement and/or correction of environmental and safety measures;

- Conduct consultation with local residents on environmental and safety issues.

After site visit:

- Prepare reports, indicating on the state of implementation of measures for pollution and safety control used by each contractor in each package and their efficiencies (7 separate reports for 7 packages);

- Prepare a synthetic (summary) external environmental monitoring report, combining the thematic reports for 7 packages to assess the compliance of the EPMU, CSCs and the Contractors with the EMP requirements and the Vietnamese laws, regulations on environmental protection.

19. This External Environmental Monitoring Report for 2016 will be submitted to VEC and ADB.

1.2.2.5. Classification of Environmental Compliance of the Contractors

Environmental Compliance Framework

20. This compliance framework to the approved EMP is in place for addressing non-compliance issues by contractors, and will be applied to the Contractor’s Contract. It is based on the environmental requirements established by the EMP approved by ADB (2010) and Environmental Specifications included in bidding documents and/or construction contracts and will be strictly enforced by the Employer and monitored by its CSC. This Environmental Compliance Framework is applied by EEMC in its environmental monitoring in 2016. This Environmental Compliance Framework is suggested to be used also by CSC in its daily environmental monitoring for the construction packages.

21. In this environmental monitoring for this project in the construction stage 3 categories of evaluation on compliance and non – compliance are applied:

(i) Compliance;

(ii) Minor infringement;

(iii) Major infringement.

22. Whether an infringement is minor or major will be determined as set out in table 4 below.

Table 4. Definitions of major and minor category of EMP Infringements at construction sites

Category of Compliance/ of Infringement

Definition Remediation/Correction

Compliance No adverse impact or slight impacts accepted in the practical construction conditions

No requirement for remediation

Minor Infringement Incident which causes temporary but reversible damage to the

- Minor clean up operations


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environment, community property, people.

- Minor restoration activities

- Adjustments/eliminations to construction practices.

Major Infringement Incident where there is long-term or evident damage to the environment or community property, or people; or infringements in hazardous waste management. Some major Infringements are stipulated in Table 5 but not limited to them.

- Major clean up operations

- Major restoration requiring engineering measures

- Major restoration of community property

- Compensation to affected communities or persons.

Source: Proposed by EEMC (VESDEC), 2015

Table 5. Definition of some environmental non-compliance activities (examples)

Environmental issues

Location

Assessment methods

Supervision results

Assessment

Construction waste dump outside the designed location

Area of waste dumps

Visual monitoring and photo documentation as evidence

Construction waste, such as rip-rap, waste soil, muddy materials and cut off trees are well collected, segregated, reused or dumped in designed areas and safely installed in approved facilities /locations in safe and stable conditions

Compliance

A part of construction waste are not well collected. But this does not cause evident impactson the surrounding areas

Minor infringement

Construction waste is dumped outside approved facilities or locations, and / or in unsafe and unstable conditions, causing evident environmental impact (e.g. creation of high salinity or acidity damaging agricuture or aquaculture, or other economic/health sectors)

Major infringement


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Location

Assessment methods

Supervision results

Assessment

Solid waste dump outside the specified location

Area of waste dumps


Solid waste is segregated into recyclable as well as non-hazardous and hazardous waste, disposed in approved locations or via regulated and approved pathways.

Compliance

A small amount of domestic solid waste is not segregated into recyclable as well as non-hazardous and hazardous waste

Minor infringement

Hazardous solid waste is not segregated, or a great amount of construction or domestic solid waste disposed outside approved areas or to rivers, canal, aquaculture ponds, fields, residentail areas or via unapproved pathways (e.g. by indiscriminate burning)

Major infringement

Accidental spills of hazardous substances (e.g. fuels, lubricants, chemicals)

Fuel and or chemical storage sites and surrounding areas


No accidental spills or discharges (excluding small leaks on machinery and vehicles) into the environment

Compliance

Accidental spills or discharges into the environment occur in significant quantities and are not immediately contained before reaching sensitive environement (river, canals, production, residental lands) or human receptors

Major infringement

Hazardous waste

Originated sources

Visual monitoring and photo

Hazardous (oily waste, bentonite wastes): no segregation with non-

Major infringement


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Location

Assessment methods

Supervision results

Assessment

management and surrounding areas

documentation as evidence

hazardous wastes; disposal without control: any case

Erosion at construction sites

Construction sites


All construction sites have effective erosion control measures; erosion is kept at a minimum

Compliance

Erosion control measures have low efficiency but do not cause evident enviornmental impact

Minor infringement

Clear evidence of soil erosion and or geotechnical insabilities (slumping, cracking, sliding,...) at construction sites causing constraint for traffic or serious damage the environment or local land use or harm to human health or property

Major infringement

Sedimentation and siltation

Construction sites


All construction sites have effective sedimentation and siltation control measures as required per design and EMP. From no open area can runoff water reach natural water courses without passing a sedimentation pond or a silt barrier.

Compliance

Sediment management measures are not employed, resulting in uncontrolled sediment transport into drainage network

Major infringement

Vegetation clearance

Construction sites and surrounding areas

Visual

- No cutting mangrove forest outside the ROW.

- If mangrove forest outside the ROW will be cut off implementation of a Mangrove Reforestation Plan (MRF) to

Compliance


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Location

Assessment methods

Supervision results

Assessment

monitoring and photo documentation as evidence

replant mangroves for compensation of the lost mangrove area at river, canal banks was done

Cutting a small area of mangrove forest (less than 1.0ha) outside the ROW and no evident ecological impact

Minor infringement

Cutting large area of mangrove forest (over 1.0ha) outside the ROW but no implementation of a MRF

Major infringement

Using the personal protective equipments (PPE) of personnel

Construction sites


All of contractor’s personnel use all prescribed PPE at all times on any area dedicated as construction site, or operating construction machinery at anytime.

Compliance

A small number of workers (less than 10% of the total workers at each inspection) does not use PPE at construction site, or operating construction machinery at anytime

Minor infringement

Failure to use all prescribed PPE at all times when on any area dedicated as construction site, or operating construction machinery at anytime (if more than 10% or total number of workers at each construction site in one inspection)

Major infringement

Air , noise and vibration pollution

Residential areas surrounding construction sites

Analysis of air quality, measurement of noise, vibration

All concentrations of air pollutants and levels of noise, vibration do not exceed the National Technical Regulations

Compliance

Concentration of one of air Minor


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Location

Assessment methods

Supervision results

Assessment

pollutants exceeds the National Technical Regulations at under 1.5 times; or levels of noise, vibration exceed the National Technical Regulations in 10%

infringement

Concentration of one of air pollutants exceeds the National Technical Regulations at over 1.5 times; or levels of noise, vibration exceed the National Technical Regulations in over 10%.

Major infringement

Water pollution

Rivers, canals, creeks, ponds surrounding construction sites

Analysis of water quality

Concentrations of all water pollutants do not exceed the National Technical Regualtion for Surface Water Quality

Compliance

Concentrations of some non hazardous pollutants exceed the National Technical Regualtion for Surface Water Quality in under 20% of permissible limits.

Minor infringement

Concentrations of some non hazardous water pollutants exceed the National Technical Regualtion for Surface Water Quality in over 20% or concentration of one of hazardous pollutants (oils, heavy metals, ...) exeeds the National Technical Regualtion for Surface Water Quality

Major infringement


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Location

Assessment methods

Supervision results

Assessment

Damage local aquatic ecosystems

Rivers, canals creeks, fish ponds receiving wastes from construction sites


Shrimp, fish and other aquatic organisms can normally survive

Compliance

Evidence of massive death of shrimps, fish

Major infringement

Damage of local infrastructural facilities

Areas surrounding construction sites


No evident damage of local infrastructural facilities (roads, bridges, irrigation systems, electric supply systems, water supply systems, etc…)

Compliance

Evident damage of local infrastructural facilities (roads, bridges, irrigation systems, electric supply systems, water supply systems, etc…): Correct complaint from local authorities or residents

Major infringement

Complaints from local residents on any environmental incident

Areas surrounding construction sites

Verbal in the consultation meeting or writen letters

One time; but the incident is resolved by the contractor(s)

Minor infringement

More than one time for the same incident; but it is not fully resolved by the contractor(s)

Major infringement

Source: Proposed by EEMC (VESDEC), 2015

23. Note: So far, there are not international or national regulations/guidelines for quantification of levels of environmental non-compliance, therefore, to evaluate the non-compliance as clear as possible, EEMC has proposed these quantified indicators for evaluation of levels of infringement (for examples: cutting over 1.0 ha of mangrove forest; concentrations of some non hazardous pollutants exceed the National Technical Regualtion for Surface Water Quality at over 20% of permissible limits or concentration of one of hazardous pollutants exceeds the National Technical Regualtion for Surface Water Quality or concentration of one of air pollutants exceeds the National Technical Regulations at over 1.5 times; or levels of noise, vibration exceed the National Technical Regulations


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at over 10%; over 10% or total number of workers at each construction site in one inspection… are evaluated as major infringement). Basic for establishing is based on the importance of mangrove ecosystem in the project area; the present surface water quality & requirements of water quality for aquaculture & domestic use; the present air quality & air quality for public heath and importance of labor safety management. The similar quantified indication system, prepared by WB specialists and applied also by VESDEC for external environmental monitoring for the WB project of Construction of Trungson Hydropower Plant (2012-2017) was referred for preparation of this quantified indication system. This quantified indication system is suggested only for this environmental monitoring for BL-LT Expressway project; for other projects at other areas some indicators in this quantified indication system may be modified to suite with the practical conditions.

Proposal of EEMC on application of the compliance framework:

24. This Environmental Compliance Framework is applied not only by EEMC only one time per year but also by CSC in its daily environmental supervision therefore, CSC should implement the following activities.

- CSC should identify or be notified of an infringement (by a community member, local government, daily or weekly inspections). A grievance redress mechanism (GRM) should be established by the Contractors or CSC, so that there will be a clear procedure to notify and file complaints if necessary.

- CSC in consultation with the PMU should assess whether it is a minor or major infringement.

For minor infringements:

25. CSC should establish the required mitigation measures for the contractor(s), and the time period, which is a maximum of two months (this could be extended at the judgment of CSC, to remedy the situation).

26. CSC should confirm (i) the level of infringement (minor/major); (ii) the mitigation measures; and (iii) the mitigation time period. If the contractor(s) do not agree, they will work with the EPMU to reach mutually acceptable recommendations.

27. The Contractor (s) will be informed of the infringement, the required mitigation measures, and time period for resolution. The Contractor(s) should remedy the infringement in accordance with the recommendations within the agreed time period. CSC of CSC shall confirm the infringement is satisfactory remedied in the time period, and inform the CSC and EPMU.

28. If the infringement is not remedied satisfactorily in the time period SES shall inform the CSC and EPMU. EPMU shall immediately arrange for a separate contractor to undertake the necessary works and the cost of this shall be deducted from the next payment to the offending contractor.

For major infringements:

29. CSC shall immediately inform the EPMU of the incident.

30. CSC shall consult with the EPMU and agree upon mitigation and clean up measures to be undertaken immediately by the Contractor or by a separate contractor to be procured at the Contractor’s expense. To minimize the environmental impacts the restoration activities should be completed as soon as possible (deadlines are determined by CSC, to remedy the situation).

31. The EPMU shall apply a financial penalty, if this condition was agreed in the construction contracts.

32. Any conflicts between the Contractor and EPMU will be resolved by VEC.

33. The Contractor will adhere to the Vietnam’s environmental legislation and ADB Safeguard Policy Statement (2009) and all related regulations, standards and good practice guidelines. In case of


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significant differences between ADB policies and Vietnam’s environmental legislation, which are relevant to the conduct of the project, the Contractor will notify the EPMU, who, after consultation with ADB and relevant authorities, will inform the Contractor how to proceed.

34. Unscheduled inspections of all works and installations may be carried out by representatives from EPMU and CSCs at any time. The country’s relevant authorities (provincial DONREs, district and commune PCs) will have the right for unscheduled site inspections and compliance checks.

35. The Contractor will employ sufficient numbers of qualified SEOs to set up their ensure environmental compliance with the EMP and the EIAs, perform day-to-day management and supervision of works, conduct dialogue with designers, construction management and authorities, and manage environmental monitoring and reporting. The CVs of SEOs will have to be approved by the EPMU before staff may be mobilized to site.

Proposal on EEMC on treatment with infringements

For minor infringements:

36. An incident which causes temporary but reversible damage - the Contractor will be given a reasonable period of time to remediate the problem and to restore the environment. If restoration is done satisfactorily during this period, no further actions will be taken. If it is not done during this period, the CSCs, will immediately arrange for another contractor to do the restoration, and ask EPMU to deduct the cost from the offending Contractor’s next payment, if this condition was agreed in the construction contracts.

For major infringements:

37. An incident where there is long-term or irreversible damage—there will be a financial penalty in addition to the cost for restoration activities, if this condition was agreed in the construction contracts. To minimize the damage, the restoration activities will be implemented without delay.

1.2.3. Implementation Schedule

38. In 2016 EEMC is mobilized from 21st March to 21st April 2016. The external environmental monitoring by EEMC on EPMU, CSC and the contractors was implemented from 23 March to 15 April 2016; public consultation by meetings was conducted from 13 April to 21 April 2016, a synthetic report (English version, over 300 pages) on the results of external environmental monitoring was prepared from 15 April and on 2 May 2016; it was submitted to EPMU for review and then it was translated into Vietnamese. On 31 May 2016 all revised reports of EEMC (in English and Vietnamese) were resubmitted to EPMU. Thus, in fact, duration of EEMC activities was two (2) continuous months but not only 1.0 month as indicated in the contract and mobilization.

1.2.4. Reporting and Documentation Requirements

39. Monitoring report prepared by EEMC provides details on:

(i) Used methodology; (ii) Results of evaluation on compliances of EPMU, CSCs, contractors on the approved EMP and other laws, regulations on environmental protection (reviewed their reports on environmental monitoring and management; field observation; consultations/interviews with affected households, local authorities and other stakeholders); (iii) Suggestions, recommendations of EEMC for EPMU, CSCs and contractors to improve environmental management and supervision; (iv) Provision of other relevant information to support results (meeting minutes, documents, etc.).

40. In detail, the report prepared by the EEMC includes the following parts:


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(i) Part One: Introduction of implementation of the external environmental monitoring in the second mobilization (March-April 2016), included description of the project, used methodology, implementation duration etc. (ii) Part Two: Status of compliance of EPMU with EMP requirements and other regulations. (iii) Part Three: Status of compliance with the EMP requirements on environmental monitoring of CSCs (iv) Part Four: Status of compliance with the EMP requirements on mitigation and monitoring of the contractors (per package), included:

- Assessment of actual environmental impacts based on field visits (per package); - Assessment of effectiveness/adequacy of EMP implementation on mitigation and monitoring measures (per package).

(v) Part Five: Results of public consultation (vi) Conclusions and suggestions (vii) ADB comments on the report and responses of EEMC. (viii) Appendixes: - Appendix 1: Assessment of compliance of Package A1 with the EMP requirements - Appendix 2: Assessment of compliance of Package A2-1 with the EMP requirements - Appendix 3: Assessment of compliance of Package A2-2 with the EMP requirements - Appendix 4: Assessment of compliance of Package A3 with the EMP requirements - Appendix 5: Assessment of compliance of Package A4 with the EMP requirements - Appendix 6: Assessment of compliance of Package J2 with the EMP requirements - Appendix 7: Assessment of compliance of Package J3 with the EMP requirements. Each of the above appendix includes photo-documentation during field investigation for demonstration. In the external environmental monitoring time (March 2016) Package J1 did not get Notice to Process (NTP), assessment of compliance was not implemented for this package. (ix) List of persons met by EEMC specialists during implementation of external environmental monitoring in March and April 2016.

1.2.5. Organization of External Environmental Monitoring 41. This external environmental monitoring (Package C2), included data collection, report review, field visits, public consultation, thematic report preparation and synthetic report preparation, was implemented by Institute for Environmental Science and Development (VESDEC) from 21st March 2016 to 30th May 2016. Thematic report is report on the results of external environmental monitoring for each package (7 thematic reports for 7 packages, in total). They are not required in the TOR (therefore, they were not submitted to EPMU) but they are only materials for preparation of synthetic report, combining data, information, evaluations from 7 reports of 7 packages. 42. EEMC is led by Mr. Le Trinh, Assoc. Prof. Dr., EEMC Leader (K1) with participation of the following main environmentalists: - Mr. Pham Hong Nhat, Assoc. Prof. Dr., National environmental specialist, K2 - Mr. Nguyen Vu Khai, Bach., Env. Science., Environmental specialist, K3 - Mr. Phan Nhat Cuong. Bach., Env. Science, Assistant - Mr. Nguyen Vu Phong, Bach., Env. Science., Assistant. and some other staffs of VESDEC (which are not named in the list of personnel in the package C2) have involved in supporting the work of logistics and public consultation.


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PART TWO:

ASSESSEMENT OF ENVIRONMENTAL MANAGEMENT AND COMPLIANCE OF BEN LUC - LONG THANH EXPRESSWAY PROJECT MANAGEMENT UNIT WITH THE ENVIRONMENTAL MANAGEMENT PLAN 2.1. TASKS OF BEN LUC – LONG THANH EXPRESSWAY PROJECT MANAGEMENT UNIT (EPMU) IN ENVIRONMENTAL MANAGEMENT

43. Ben Luc - Long Thanh Expressway Project Management Unit (EMPU BL-LT) of VEC is responsible for implementation of the project with responsibilities as below:

(i) Ensuring that all environmental protection and mitigation measures of environmental impacts are carried out in accordance with policies regulations on environment and other relevant laws.

(ii) Coordinating with Ho Chi Minh City, Dong Nai and Long An DONREs environmental management activities.

(iii) Supervising and providing budge for monitoring activities.

(iv) Reporting on environmental information to VEC and the international donors (ADB and others).

(v) Implement changes or adjustments according to MONRE recommendation to protect the environment according to Vietnam’s standards, laws, and regulations.

(vi) Ensure that Project implementation complies with ADB's environmental policy principles and requirements

(vii) Review and approve the Construction Environmental Management Plans (CEMPs) with assistance from the Project Supervision Engineer (or Consultant) (PSE or CSC),

(viii) Based on the results of EMP monitoring, identify environmental corrective actions and prepare a corrective action plan, as necessary, for submission to ADB

(ix) Establish an environmental grievance redress mechanism, acceptable to ADB, to receive and facilitate resolution of affected peoples' concerns, complaints, and grievances about the Project's environmental performance

(x) Submit quarterly environmental reports to ADB

(xi) Submit quarterly environmental monitoring reports to MONRE/DONREs.

2.2. ORGANIZATION OF ENVIRONMENTAL MANAGEMENT

44. Since establishment of BL-LT Expressway Project Management Unit (EPMU) a Technical – Supervisory – Environmental Section was set up. Up to present, name of this section has been changed to Construction Management and Land Acquisition Department. In 2015 this unit was led by Deputy Director of EPMU (Mr. Hoang Thanh Hai) from 2016 by Mr. Ngo Anh Sang. At present, in this department one environmental officer is charged for environmental management for the whole project.

45. Additionally, from 2016 EPMU has set up two (2) site offices: a site office for ADB West Sections and a site office for JICA Sections (figure 5).


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Figure 5. Organization Chart of BL-LT Expressway Project Management, included environmental and safety management system

2.3. ACTIVITIES IN PROJECT ENVIRONMENTAL MANAGEMENT

46. The main activities conducted by VEC and its EPMU in environmental management from March 2015 to April 2016 are:

(i) Inclusion of environmental requirements into the construction contracts: reviewing the construction contracts EEMC found that requirements in environmental management were included in: - Clause 4.18 “Protection of the environment” in all Contract Packages between VEC and all contractors for all construction packages. - Clause 2.4 “Assisting VEC in environmental management consideration/monitoring” in Contract for construction supervision consulting service between VEC and all contractors for all construction packages. (ii) Supervision on environmental management activities of the contractors: EPMU regularly checks up environmental management implemented by the Contractors of ADB and JICA sections. (iii) Supervision on activities in environmental monitoring of CSC: checking quarterly environmental monitoring reports submitted by CSC; checking environmental monitoring activities of CSC in its office and at the sites. (iv) EPMU coordinates with the CSC to monitor the relevant environmental works on site. CSC had proposed the inspectors to carry out the mentioned work every day and the CSC Environmental Specialist supervises every month and randomly to meet the requirements of EMP. (v) If EPMU and/ or CSC find the non-compliance issue, EPMU/CSC requires/reminds the Contractors to carry out measures for correction immediately and report to EPMU /CSC after finishing. (vi) In addition, EPMU proposed the environmental management system/procedures and asked the contractors to apply. Receiving the EPMU requirements for the resolution of environmental problems

EPMU BL-LT

Main office the Construction

Management and Land Acquisition Dept

Mr. Ngo Anh Sang

environmental and safety management

Mr. Le Van Dung

Western site office of ADB

Deputy Director EPMU Mr. Pham Nhu Tuan

environmental and safety management

Ms. Phan Anh Thy

Site office of JICA

Deputy Director EPMU Mr. Hoang Thanh Hai

Charged in environmental and safety management


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the Contractors should carry out counter measures, then report to EPMU /CSC after improving with attached figures or images for proving. If the Contractors have not still improved the mentioned issues, EPMU will stop the construction works on site until the issues will be properly improved. (vii) EMPU required CSC to implement an environmental training for EMPU staffs. At present (September 2016) CSC has prepared and submitted to VEC a full environmental training program with a cost of about USD15,000. The training program is planned to be implemented from October 2016 after receiving an approval from VEC.

2.4. EVALUATION OF EEMC ON COMPLIANCE OF EPMU WITH THE EMP

47. From above mentioned activities of EPMU in environmental management, it may evaluate that so far EMPU complies with the main EMP’s requirements in organization of environmental management system and activities in environmental management.

48. However, from 2016 all construction packages will be implemented various environmental and social impacts would be caused.

49. To properly manage environmental, social and safety issues EEMC suggests the following measures:

(i) Environmental and safety officers of EPMU should be improved their knowledge and experiences in environmental management following the international guidelines to comply with the ADB requirements. Participation into some short-term training programs overseas, included theory and field studies, is necessary for them (and other VEC environmentalists).

(ii) Unit in charged in environmental management of EPMU should store in long-term all data, information on the environmental and safety management obtained by EPMU and submitted by CSC, EEMC, the contractors and others to be used as baseline data for evaluation of the changes in environment and social impacts at the whole alignment and at each package. These documents are also provided for VEC, ADB, other agencies when required. All hard copies should be stored at filing cabinets; all soft copies should be stored in specific computers. All hard copies and soft copies should be systematically classified (e.g. data on the state of environmental management; data on environmental monitoring, data on environmental risks, data on public consultation etc.)


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PART THREE:

ASSESSMENT OF COMPLIANCE OF THE CONSTRUCTION SUPERVISION CONSULTING (CSCs) WITH THE ENVIRONMENTAL MANAGEMENT PLAN 3.1. TASKS OF CSCs IN ENVIRONMENTAL SUPERVISION 50. Tasks in environmental monitoring of CSCs (Package C1: JV of Dasan-Kunhwa-ITC JV for ADB packages and Package C5; JV of KEI-NE-OCG-TEDI for JICA packages are clearly given in TOR in the contract between CSCs and VEC.

51. In the TOR 5 (five) tasks were given to CSCs:

a. Review and approve SEMP prepared by the contractors;

b. Monitor the implementation of mitigation measures in EIA and EMP; prepare quarterly report on the environment during the construction stage;

c. Monitor and report environmental impacts during the construction and propose measures, guide and supervise the corrective activities of the contractors;

d. Set up an unit/mechanism to monitor and inform the environmental issues to the affected communities ; this unit shall guide local residents to participate in to environmental supervision and environmental management implemented by the contractors.

e. According to the requirement of EMP, the Supervision consultant shall manage the environmental quality related to air, water, groundwater quality, vibration, inundation, aquatic animals and wild animals.

52. In this external monitoring EEMC will evaluate the activities and effectiveness of the CSCs in implementation of the above 5 tasks from May 2015 to March 2016.

3.2. ACTIVITIES OF CSCs IN ENVIRONMENTAL SUPERVISION 53. According to report on environmental management prepared by CSC’ National environmental specialist (April 2016) the main activities in environmental management following the EMP requirements are summarized as follow.

3.2.1. Organization of Environmental Supervision

54. In Ben Luc- Long Thanh Expressway project there are packages funded by different international donors: ADB and JICA. Environmental supervision for ADB packages is responsible by a CSC (Dasan-Kunhwa-ITC JV) and Environmental supervision for JICA packages is responsible by other CSC (KEI-NE-OCG-TEDI JV). Therefore, there are two systems of environmental supervision organization, which are indicated in figures 6 and 7.


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Figure 6: Organization Chart of Environmental Supervision for ADB Packages

Figure 7: Organization Chart of Environmental Supervision for JICA Packages

National Env. Specialist for Eastern Sub-Section

CSC C1 Main office

International Env. Specialist

National Env. Specialist for Western Sub-Section

Training Inspectors of CSC's Eastern Site office

Training Inspector No.1 of CSC's Western Site office

Training Inspector No.2 of CSC's Western Side office

Construction sites of A5, A6 and A7

Construction sites of A3, A4

Construction sites of A1, A2-1 and A2-2

CSC C5 Main office

National Env. Specialist

Training Inspectors of J1 site office of CSC C5







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55. The National environmental specialist of ADB Western section was mobilized half-monthly since 15th February 2016. The National environmental specialist of JICA section was mobilized since 15 December 2014 with 01 week per month.

3.2.2. Implementation of Site Inspection and Environmental Monitoring Program

Daily/Weekly inspection

56. The CSCs of ADB and JICA sections has developed a simple checklist for inspection of environmental activities of contractor.

57. The supervision consultant’s inspectors have been trained to monitor the day to day activities at batching plant, worker camps, construction sites of contractors. The checklist is very simple in order to record the site activities and any non-compliance with the EMP and SEMP. The CSC inspectors will record the activities on site and submit the checklist in CSC office on weekly basis.

58. The weekly inspection will be implemented from April 2016.

59. At present, daily, the supervision consultant’s inspectors monitored the activities at construction sites for dust prevention (watering the access and service road), solid waste storing, landslide, leakage chemical/bentonite.

Monthly inspection

60. The monthly inspection should be carried out by the Effective Environmental Monitoring Consultant with a fully checklist as presented in approved EIA/EMP. Effective Environmental Monitoring Consultant is a consulting unit in charge of evaluation of the impacts of the project construction on the environment by measurement of noise, vibration, sampling and analysis of air, water and wastes at the impacted sites with the planned monitoring parameter and frequency.

61. At present, CSC C1 of ADB section was chosen by VEC/EPMU to carry out this Effective Environmental Monitoring program.

62. The Effective Environmental Monitoring was planned to be started from June 2016.

At the moment, the environmental specialist of CSCs and EPMU has conducted monthly site inspection to finalise the evaluation sheet for Quarterly Report.

Quarterly environmental monitoring

63. The quarterly environmental monitoring will be carried out by the Effective Environmental Monitoring Consultant with a program as presented in approved EIA/EMP.

CSC C1 of ADB section was chosen to carry out this Effective Environmental Monitoring program.

The Effective Environmental Monitoring is planned to start from June 2016.

3.2.3. Reports on Supervision Results

Daily/Weekly inspection results 64. At construction sites, the inspectors monitor and inspect the construction activities, when detecting non-compliant activities on environment protection, they will remind, warn and require Contractor to fix and comply with the requirements. For major infringement (violations), inspector will be report to the Environmental Specialist of CSC and PMU for a warning and corrective measures letters if necessary.

Monthly inspection results

65. CSCs' Environmental Specialist has inspected the construction site monthly to assess the compliance of the contractors, the assessment of the overall aggregated into a final assessment and


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it is presented in the Quarterly Environmental Report of the CSCs.

Quarterly environmental monitoring:

66. CSC of JICA Section has submitted 4 Quarterly Reports of Q.1, Q.2, Q.3 and Q.4 of 2015 to EPMU/ADB/JICA for reviewing. CSC of ADB Section has submitted 2 Quarterly Reports of Q.3 and Q.4 of 2015 to EPMU/ADB for reviewing.

3.2.4. Violations (Infringements) Found by CSCs

67. Overall evaluation of CSCs on the Contractors’ violation is given below.

Minor infringements

68. In construction, the Contractors did not comply with the environmental requirements:

(a) do not carrying out watering or watering with insufficient required times, causing dust pollution;

(b) do not cover truck transporting soils and other construction materials with tarpaulin;

(c) leave domestic rubbish out of regulated positions;

(d) do no install separate toilets for women;

(e) remain excavated materials etc.

69. These violations have been reminded, warned by the Consultant’s site engineers and they were recovered by the Contractors from 01 day to 01 week (however, from observation of EEMC during field visit in March and April 2016, in fact, most of the above found infringements still occur; additionally from consultation meetings with various communes at ADB and JICA sections in April 2016 many complaints from local residents on environmental pollution: dust, noise, vibration, spoil transport, safety, obstruction of local transport etc..but they were not indicated in the supervision reports of CSC).

Major infringements

(a) Fresh concrete batching plant of Packages A3 and A2-1 fails to comply with requirements for safety distance of 300m from residential area as stipulated in the Project EIA/EMP. The two bathing plants have been inspected and approved by ADB’s specialists since the Contractors implemented mitigation measures by installing net with 6m high at area nearby residential area.

(b) Disposal area of the Contractor J2 located in an area of Rung Sac Road did not comply with EMP requirement, causing pollution. The Consultant has issued letter and proposed countermeasures to the Contractor J2 for remediation. The Contractor J2 implemented mitigation measures in duration of 2 weeks. At present, disposal area of the Contractor J2 has been finished and leveled according to the approved elevation.

(c) Poor management of hazardous waste: even though most of the contractors place specialized bins for hazardous waste (mostly engine oil, contaminated objects), mixture of non-hazardous waste and hazardous waste still happen. The Consultant has given advice and reminder many times, however, at present it was not fully improved.

(d) Out of the above important violations, there is no other severe effects to environment such as leaking oil and bentonite to water bodies, cutting trees on site etc. except a case of Package J2, there is a dispute about polluted water causing dead of shrimp of shrimp farm nearby construction sites in May and June, 2015. However Can Gio PPC and district Department of Economic has held an inspection to examine and evaluate the reason causing dead of shrimp and they concluded that white fungus causes the dead of shrimp, the quality of runoff water from construction site to shrimp farms is good enough.


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3.3. EVALUATION OF EEMC ON ENVIRONMENTAL SUPERVISION OF CSCs

70. Basing on:

(i) Comparing the activities of CSCs with 5 tasks of CSCs given in the contract with VEC;

(ii) Reviewing the monitoring reports submitted by CSCs

(iii) Observation during the field visits at the construction sites of the JICA and ADB packages

(iv) Comments/complaints of local residents in 3 public consultation meetings in April 2016 (see Part “Public Consultation”)

71. EEMC may give the following evaluations and recommendations on CSCs activities in environmental monitoring and supervision.

1. Organization system in environmental management for JICA and ADB sections is fair and suitable for implementation of 5 tasks in the TOR in the contract with VEC.

2. CSCs have tried to properly implement the tasks in the TOR and its activities in environmental are generally complied with the EMP and TOR requirements:

(i) Daily, weekly, monthly checking environmental and safety issues at all construction sites, worker camps, batching plants, disposal sites etc. From daily environmental monitoring CSC has found various minor and major infringements, indicated in its above report, and has asked the contractor to remedy.

(ii) CSCs have guided the contractors in measures for pollution control and noticed their implementation and efficiencies.

(iii) CSCs have prepared environmental monitoring reports complied with EPMU requirements: so far, CSCs have prepared and submitted to EPMU 4 quarterly reports for JICA section, 2 quarterly reports for ADB section (but report for the first quarter 2016 is not completed).

3. With the above mentioned activities in environmental and safety monitoring of CSCs and EPMU the contractors have implemented various measures for pollution control and adverse impact mitigation.

4. However, efficiencies of CSCs monitoring are not high:

(i) Various environmental infringements and adverse impacts on local communities caused by construction activities at many packages were not noted and indicated in the quarterly monitoring reports;

(ii) No any strong measures, e.g. no suggestion to EPMU on penalty to the contractors who repeatedly violated the environmental requirements in EMP an SEMP, so various infringements were not corrected;

(iii) So far, CSCs still did not implement a task “Set up an unit/mechanism to monitor and inform the environmental issues to the affected communities; this unit shall guide local residents to participate into environmental supervision and environmental management implemented by the contractor” required in the Contract with VEC. This type of unit or mechanism was not really set up.

3.4. SUGGESTION OF EEMC TO CSCs

72. To better implement 5 tasks in environmental monitoring required in the TOR in the contract with VEC the following recommendations should be implemented by CSCs:


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(i) Although in the organization of environmental management for the project there are two (2) national environmentalists: one for ADB Western Sections, other one for ADB Eastern Sections (figure 3). At present, only one national specialist is mobilized for supervision for ADB Western Sections (packages A1, A2-1. A2-2, A3, A4) and JICA Sections (packages J1, J2. J3). One environmentalist, responsible for environmental supervision for 7 packages, may not well guide the contractor’ environmental and safety sections in environmental management in detail; he/she may not carefully review and find errors in the environmental reports submitted by the contractors and may not weekly carefully monitor the environmental and safety issues at all packages. In the coming months the ADB Eastern Sections will be started to be constructed, the second national environmentalist will be mobilized. This may improve quality of environmental supervision, but to increase the efficiencies in environmental supervision number of national environmentalists should be increased, e.g. one for the JICA Packages and two for the ADB packages. In case of no increase of number of national environmentalists, number of working days and working months of the national environmentalists should be increased.

(ii) CSCs should carefully review the environmental and safety reports submitted by the contractors. Randomly reviewing some environmental monitoring reports prepared by the contractors EEMC has found various errors or no reasonable in monitoring methodology, calculation formulas and monitoring data. If CSCs fully believe the results in the environmental reports of the contractors it may make wrong or incorrect evaluation for CSCs, EPMU, VEC on the compliance of the contractors with the EMP. Therefore, CSCs should not accept the environmental reports of the contractors, if mistakes in methodology and/or data will be found. In these cases CSCs should guide the contractors in methodology of environmental monitoring and reporting. If the contractors will again have mistakes in environmental report preparation, CSCs shall not approve the reports but inform to EPMU immediately and ask the contractors to revise.

(iii) CSCs should implement a task “Set up an unit/mechanism to monitor and inform the environmental issues to the affected communities ; this unit shall guide local residents to participate into environmental supervision and environmental management implemented by the contractor”. So far, this type of unit or mechanism was not really set up. The contractors were asked to prepare Grievance Redress Mechanism (GRM) but this task was not completed. Only at some construction sites hotline telephone numbers of the leaders of the contractor are indicated on a board installed at the gate; but this is not an unit/mechanism to monitor and inform the environmental issues to the affected communities.

To properly implement this task CSCs in May 2016 should prepare a plan to set up an unit/mechanism to monitor and inform the environmental issues to the affected communities, complying with ADB requirement.

(iv) An unit in charge of environmental impact monitoring (effect environmental monitoring consultant) under JV of Dasan-Kunhwa-ITC should be selected as soon as possible to start quarterly (and random) monitoring on air, water, runoff-water, noise, vibration, aquatic organisms. This consultant should have well-trained manpower in environmental sampling and analysis, well equipped laboratories and field devices complying with the MONRE requirements. CSC should check the laboratories, manpower and monitoring experiences of the candidates before VEC decision to select one of them to be an environmental impact monitoring consultant. Additionally, CSC should review quarterly environmental monitoring reports carried out by the impact monitoring consultant before submission to EPMU/VEC/ADB. The baseline environmental quality monitoring before construction at the sections, where construction activities are not implemented yet, should be conducted to obtain data for evaluation of the change in the environment in the construction stage of the project.


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(v) From public consultation meetings in April 2016, it is found that there are many complaints of local communities on environmental pollution and social impacts, caused by the contractors. The main nature of the complaints are on improper disposal of spoils, damaging rice fields; serious dust pollution and damage of local roads, obstruction of water drainage system …(see Part “Public Consultation” in this report for detail). The CSCs should carefully check these environmental problems and indicate in their next monitoring reports.

(vi) To objectively and correctly evaluate the compliances of the contractors with the EMP CSCs (and EPMU) not only regularly check environmental issues at the sites but it is necessary to carry out random check at the sites in the peak construction activity without prior information to the contractors. This recommendation should be supported by EPMU.

(vii) As reported by CSCs various infringements of the contractors were not fully corrected, although CSCs have noticed and asked them to remedy. This problem should not be continued. To stop the non-compliances of the contractors, in the coming months CSCs should set up a regulation on Treatment of Infringements, in which penalty measures should be applied by EPMU (or VEC) to treat the contractor(s) who do not carry out proper measures for correction of the noticed infringements. For example: in case of serious environmental pollution caused by spoil transport: first and second time of infringement: only notice to the contractor to apply corrected measure; the third infringement: report to EPMU and ask EPMU to give a penalty etc…). Kinds of penalties shall be suggested by VEC/EPMU and discussed with the contractors. This regulation shall be approved by EPMU and informed to contractors for implementation from October 2016.

(viii) It is necessary for CSCs in collaboration with EPMU and contractors to have regularly meetings (for example, 2 months/meeting) with commune People Committees and local residents to inform them on the construction activities, measures used for pollution prevention and hearing comments, suggestions from local people. This measure will improve relation between the contractors and local residents and it well help the contractors in implementation of mitigation measures.


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PART FOUR:

ASSESSMENT OF ENVIRONMENTAL MANAGEMENT AND COMPLIANCE OF THE CONTRACTORS WITH THE ENVIRONMENTAL MANAGEMENT PLAN (BY PACKAGE)

4.1. ENVIRONMENTAL MANAGEMENT AND COMPLIANCE OF PACKAGE A1 WITH THE ENVIRONMENTAL MANAGEMENT PLAN 4.1.1. General Information 73. The present state of construction activities are as follow. - Contractor: Halla-Vinaconex JV. - Sub-contractors: Bridge Construction Co N14; Bridge Construction Co N75; Nam Tan Construction Co. - Length : 7.3 km from Km 0.600 to Km7+900. - Location: Ben Luc and Can Giuoc districts, Long An province. - Construction works: 4 viaducts (Interchange with HCM-Trung Luong Expressway; Interchange with National Highway N1; Phuoc Ly bridge and Ong Thoang bridge). - Start day: September 2015. - Construction works: Excavation of unsuitable material: Total excavation of unsuitable material completed 336,863/382,521 m3 Construction of sand embankment: Total construction of sand embankment of main line completed 160,261/563,671 m3 Construction of PVD: Total construction of PVD completed 42,326/308,772m. Total site clearing completed 341,047/341,047 m2 Bridge works: Bored piles 1,200mm diameter (on land):

+ HCM-TL interchange completed 145/269 piles

+ Ong Thoan bridge completed 28/32 piles

+ NH1A Interchange completed 32/144 piles

+ Phuoc Ly bridge completed 88/104 piles

4.1.2. Activities in Environmental and Safety Management of the Contractor

a. Organization of environmental management

74. The Contractor (Halla - Vinaconex JV) set up a Section of Safety – Environment and Health (HSE), included 3 engineers, responsible for checking environmental, safety management of the sub-contractors (Figure 8).

b. Environmental monitoring activity

- Prepared CEMP (May 2015) and Safety and Health Plan (October 2015). These 2 documents have been approved by the Construction Supervision Consulting (CSC, Dasan-Kunhwa-ICT JV). A copy of CEMP was submitted to EPMU by CSC. - Conducted daily environmental and safety monitoring at the main construction works. - Conducted training for new workers. Total 7 groups of 125 workers have been trained in environmental and safety.


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- Regularly reported to the team leaders of Halla - Vinaconex JV about the safety and environmental infringements of the sub-contractors.

F

Figure 8: Organization of the Contractor, included environmental and safety management system

c. Findings of Contractor’ HSE in safety and environmental management at the construction sites

75. The HSE evaluated that so far, at the construction sites no problems of soil erosion, noise, vibration pollution; no problems of waste management; no labor accidents occurred. There were not complaints from local residents on pollution and safety issues (however, this is not true evaluation: in public consultation meeting on 21 April 2016 many participants from My Yen commune complained about air, noise, vibration pollution, obstruction of water drainage system and damage of houses caused by the contractor: see Part ”Public Consultation” below).

76. Only some infringements were found by the Contractor HSE section:

(i) Some workers did not use labor protection devices;

(ii) At some deep holes no fences or marks installed for warning

(iii) Dust pollution at the access roads.

(iv) Managers of the contractor and sub-contractors did not deeply pay attention on implementation of proper measures for pollution control.

Environmental Manager

Construction sites

Project Manager

Construction Manager

Compact Team Area N1 Team Area N3 Team

Sub-Contractor Sub-Contractor Sub-Contractor

Sub-Contractor of Environment

Area N2 Team

Sub-Contractor

Safety Manager

Project Deputy Manager Project Deputy Manager


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d. Reporting

77. The contactor has prepared the following reports:

(i) Monthly Environmental Reports

(ii) Quarterly Environmental Management Report (December 2015)

4.1.3. Evaluation and Recommendations of EEMC

78. On 28th March 2016 the EEMC (VESDEC) has checked activities of the Contractor of Package A1 (Halla - Vinaconex JV) in environmental and safety management. Based on results of checking documents in its office and observation at the construction sites, worker camps, disposal site and comments/complaints of local residents from public consultation on 21 April 2016 the following evaluation may be given. Detailed evaluation on the compliance of the contractor with the measures required in the EMP approved by ADB in 2010 is indicated in Appendix 1 below. From this table the main evaluation on environmental management of the Package A1 are summarized as follow.

a. Organization of environmental and safety management is suitable for the practical condition of construction.

b. Environmental management at the construction area and worker camps

79. In general, environmental management at the construction sites, worker camps are fair: only some serious (major infringement) environmental and safety matters at the worker camps and at construction area were found. However, during the field visit of EEMC and EPMU environmentalists batching plants did not operate. But answering on the question of the EEMC on the daily impacts of the batching plants people living closely to the plants said that they do not get serious noise and dust pollution. c. Common minor infringements

80. The common minor infringements are identified as follow.

- While at some deep holes alarming signs were installed, at some other deep sites there were not alarming signs and fences, causing danger for local people. - Solid wastes and hazardous are not well segregated at worker camp and at construction sites. - Dust pollution at the access roads (roads used for material transport) because watering conducted only 1-2 times/dry day. - Vibration pollution is strong: some householders at hamlets N6 complained that vibration from truck movement cracks their houses but no reasonable compensation was done (this should be checked by the CSC). - No marks for alarming at many deep sites causing danger for local people. - Solid wastes and hazardous are not well segregated at worker camp and at construction sites. - Sanitation conditions in some worker rooms and at toilets are poor. - Land relocation at hamlet N7 caused inundation because of drainage system was blocked up. d. Major infringements 81. Because of measures in environmental and safety management of the contractor is not effective or the contractor did not well paid attention on environmental protection various major infringements occurred: - Spoil disposal at the construction site without covers, causing dust pollution and leakage of spoil on the roads; in the rainy days this may affect the surrounding rice fields or aquaculture ponds due to acidic run-off water. This incident was complained several time by local residents but the contractor did not used effective measure for correction. Therefore, this violation is evaluated as major infringement


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- Sandy pumping caused salinity for the rice field affecting on rice growth. This will damage agricultural production of people in My Yen commune, This is a major infringement. On 12 May 2016 the sub-contractor (Vicomex and Thai Binh Duong Co) and people of villages 6, 7A have negotiated on compensation and support to the householders affected by non-controlled spoil disposal. However, land desalinization was committed by the sub-contractor but it is not implemented, yet . - Damage of 300-400 m of road on the canal bank at hamlet N7a due to truck movement but the contractor did not repair. - Detailed evaluation on the environmental compliance of Package A1 are indicated in Appendix 1.

c. Report preparation

82. The following reports were prepared.

- CEMP and Safety & Health Plan were prepared and approved by the CSC (Supervision Consultant). - Monthly environmental reports were prepared be the contractor; but contents of the reports should be revised because some formulas used for pollution calculation may not be correct and some monitoring results, comments and conclusions in the reports should be re-considered. Environmental sampling and measurement should be implemented at the normal or peak construction times.

83. The CSCs should guide the contractors in environmental monitoring methodology and carefully check the monthly and quarterly environmental monitoring reports submitted by the contractors.

Overall assessment on Compliance with EMP requirements

84. From the detailed assessment on the contractor's compliance (JV of Halla Corporation-Vinaconex E&C) with EMP in Appendix 1, it can be concluded that, at present, the contractor has implemented various measures to minimize pollution and mitigate the adverse impacts. But in the total over 100 measures evaluated 27 measures were not complied, of which 18 measures as minor infringement and 9 measures as major infringement were evaluated. The main major infringement relates with disposal of spoils and sandy pumping causing salinity for rice field; no segregation of hazardous wastes and damage of roads. They must be properly corrected as soon as possible.

4.1.4. Suggestions of EEMC: Environmental Corrective Requirements for Package A1

85. From the results of field visit, the EEMC may suggest the following environmental corrective requirements for Package A1. All the requirements suggested by EEMC should be completed by the Contractor before 30th June 2016 and they should be supervised by CSC.

(i) In dry days installation of covers for spoil disposal sites at the construction area to avoid dust dispersion.

(ii) Do not pump saline sand to the rice field and other lands without permission of local PCs. Immediately compensate the loss of rice damaged by the contractor.

(iii) Immediately repair local road on the canal bank at hamlet N7a damaged by the contractor.

(iv) Solid wastes must be well segregated into hazardous and non - hazardous. Hazardous wastes must be well managed following the MONRE regulation on hazardous management.

(v) Install danger alarming signs and fences at deep sites. (vi) Improve sanitation conditions in worker rooms and at toilets. (vii) Immediately prepare GRM following the ADB requirements and disclose to local PC and residents. (viii) Other measures suggested in Appendix 1.


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(x) Contractor should hold meetings with PAHs and local authorities to resolve the risen environmental issues as soon as possible.

4.2. ENVIRONMENTAL MANAGEMENT AND COMPLIANCE OF PACKAGE A2-1 WITH THE ENVIRONMENTAL MANAGEMENT PLAN 4.2.1. General Information 86. The present state of construction activities are as follow. - Contractor: Joint Venture of Kukdong Engineer & Construction Co. and Trung Chinh Co. - Sub-contractors: Tranimexco Co. - Length : 3.3 km from Km7+900 to Km11+200 - Construction works: 1 viaduct over Hai Son Residential Area and 2.000m of expressway. - Start day: May 2015; estimated construction duration: 3 years.

87. Based on information from Contractor, the situation of construction progress in March 2016 as bellow:

- Planned Implementation Schedule: 19 May 2015 to 29 May 2018 (1076 days). - Main quantities of the Package is shown in table 6.

Table 6. Main quantity of Package A2-1

Items Unit Quantity Remark

I. Bridge work: Haison Bridge (1.32km)

1. Bored pile D1200 Pile 288 14896 m

2. Concrete m3 m3 32,519.32

3. Reinforcing Steel Ton 3,597.61

II. Road work (1.98km)

1. Excavation m3 112,955

2. Embankment m3 158,664

3. Base and Sub-base m3 41,652

3. PVD m 218,577

4. Culverts Ea. 09

Source: Data provided by JV Kukdong Engineer & Construction Co and Trung Chinh Co, March 2016. 4.2.2. Activities of Environmental and Safety Management of the Contractor


88. The Contractor set up a Section of Safety, included 5 engineers, responsible for checking environmental, safety management of the sub-contractors (figure 9).


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Figure 9: Organization of the Contractor of Package A2-1, included environmental and safety management system b. Environmental monitoring activity

89. Environmental monitoring activity was implemented as follow.

- CEMP and Safety and Health Plan (July 2015) were prepared in May and July 2015. respectively. These 2 documents have been approved by the CSC (Dasan – Kunhwa – ICT JV). - Daily environmental and safety monitoring at the main construction works is implemented . - Training for new workers was conducted. Total 7 groups of 125 workers have been trained in environmental and safety. - Regularly reported to the co-team leaders of the Contractor about the safety and environmental infringements of the sub-contractors and asked the sub-contractors to correct the infringements, when they were found.

c. Findings of Contractor’ Section of Safety in safety and environmental management at the construction sites

90. The Section of Safety of the Contractor evaluated that so far, there are not environmental and safety infringement at the construction sites, batching plant, disposal site and worker camps.

Project Manager Kim Young Rak

Tel: 0934.681.238

Deputy pm Tran Van Giau

Tel: 0912.822.411

Health safety DEPT Environmental DEPT

Safety manager

Le Van Luong

Tel: 0164.963.2220

DEPUTY HS manager

Bui Van Tu

Tel: 0968.290.989

Environmental specicalist Vu Thi Hong Phong Tel: 0902.706.690

Environmental engineer

Safety engineer Safety engineer Safety engineer Environmental monitoring subcontractor

CONSTRUCTION TEAM

Dong Van Ha Tel: 0916.773.474

Dinh Cong Toan Tel: 0918.710.810

Pham Van Loi Tel:0126.409.26890

Nguyen Le Anh Vu Tel:01666.515.676 Center for analysis & environment

Tel: 08.372.45.728

Vang Truc Phuong Tel: 01657.684.781

Safety engineer


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91. This Section required the sub-contractors to carry out watering 3-4 times/day at the roads used for material transport; at the boring site dikes for preventing run –off water were installed.

92. So far, no receiving any complaint letter from local residents. Some minor infringements in safety and environmental management which ADB’s mission team indicated during site checking from 29 February to 7 March 2016 were corrected by the contractor. Up to now, contractor has strictly followed safety and environmental requirements and carry out the works to minimize environmental impacts.

d. Reporting:

93. The contactor has prepared and submitted to the Supervision Consultants the following reports:

(i) Baseline environmental monitoring report: September 2015

(ii) Quarterly environmental management and monitoring reports: Third and fourth Quarters of 2015, First Quarter of 2016.

(iii) Monthly environmental management & monitoring reports: October 2015, November 2015, January 2016, February 2016.

(iv) Monthly safety report: October, November, December 2015; January and February 2016.


94. On 29th March 2016 the EEMC (VESDEC) has implemented checking activities of the Contractor of Package A2-1 (Kukdong – Trung Chinh JV) in environmental and safety management. Based on results of checking documents in its office and observation at the construction sites, worker camps, disposal site and consultation with some householders living closed to the construction site the following evaluation may be given. Detailed evaluation on the compliance of the contractor with the measures required in the EMP approved by ADB in 2010 is indicated in Appendix 2 below. From this table the main evaluation on environmental management of the Package A2-1 are summarized as follow.


b. In general, environmental management at the construction sites, worker camps are rather well implemented.

c. Spoil disposal site at Hai Son industrial clusters was permitted by Can Giuoc District People’s Committee.

e. Infringements 95. At present, the contractor has implemented various measures to prevent pollution and waste management. Most of the measures are complied with EMP but various non-complied items can be found at the construction site, worker’s camps and concrete batching plants. (i) At worker camps: - Washing and bathing areas are not clean. It is a favorable environment for the growth of mosquitoes and flies. - Segregation of domestic waste, hazardous waste is not well implemented. - Drainage ditch was not installed at worker’s camps.

(ii) At construction sites:

- Culverts and drainage systems at viaduct construction sites were not installed;

- Lack of noise control walls at many places along construction sites;


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- Watering is not properly implemented at construction sites and concrete batching plant; - Dredged spoil was not compacted. The surface of dredged spoil storage sites was not covered by dense plastic sheets to prevent dust dispersion.

- There is no storage area for hazardous waste : major infringement.

- Disposal area is located near residential area and without fences or walls.

- Watering was implemented but dust pollution at the access roads is evident. This is reason of complaints from local residents.

- Sand pumping to surrounding areas caused land salinity damaging rice field: major infringement.

Detailed assessment of the contractor's compliance with measures in EMP are shown in Appendix 2.

Overall assessment on compliance with EMP requirements

96. From the detailed assessment (see Appendix 2) on the contractor's compliance (Joint Venture of Kukdong Engineer & Construction Co., Ltd and Trung Chinh Trading & Construction Co., Ltd.) with EMP, it can be concluded that, at present, the contractor has implemented various measures to minimize pollution and mitigate the adverse impacts. However, some incidents, complained by local people, occurred. In the total over 100 measures evaluated 23 measures were not complied, of which 19 measures as minor infringement and 4 measures as major infringement are evaluated. The main major infringement relates with improper management of hazardous wastes and damage of rice field caused by sand pumping. They must be properly corrected immediately.

4.2.4. Suggestions of EEMC: Environmental Corrective Measures for Package A2-1

97. From the results of field visit, the EEMC may suggest the following main environmental corrective requirements for Package A2-1. All the requirements suggested by EEMC should be implemented and completed by the Contractor before 30th June 2016 and they should be supervised by CSC.

(i) Proper design and installation of culverts and drainage systems at viaduct construction sites.

(ii) Implementation of segregation of non-hazardous and hazardous wastes and safe storage of hazardous waste at construction sites and worker camps.

(iii) Stop sand pumping to the areas outside the project area and immediately compensate the loss in agriculture of local farmers.

(iv) Improvement of watering in dry days at construction sites, roads and concrete batching plant to minimize dust pollution.

(v) Cover dredged spoil area by plastic sheets to prevent dust dispersion.

(vi) Installation of fence at the disposal area to avoid environmental risk.

(vii) Improvement of sanitation conditions at worker camps. (viii) Immediately prepare GRM following the ADB requirements and disclose to local PC and residents.

(ixi) Others requirements are indicated in Appendix 2.

4.3. ENVIRONMENTAL MANAGEMENT AND COMPLIANCE OF PACKAGE A2-2 WITH THE ENVIRONMENTAL MANAGEMENT PLAN 4.3.1. General Information 98. The present state of construction at Package A2-2 are summarized as follow.


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- Contractor: JV Samwhan Corporation (Korea) and Vancuong Construction Co (Vietnam) - Sub-contractor: Transport Construction Investment Co N1 (TRICO) - Length: Form Km 11+200 (Hunglong commune, Binhchanh district, HCMC) to Km 16+600 (Da Phuoc commune, Binh Chanh district, Ho Chi Minh City). - Construction duration: 1,050 days. - Main works: 5.4 km of expressway and 4 bridges (Ong Thin: 711 m; Viaduct over NH50; Viaduct over interchange with NH50; Ong Nam bridge). - Start day: September 2015. - Number of workers/engineers: 190 persons. - Main environmental pollution sources: construction sites; 2 batching plants; 1 disposal site (at Haison New Industrial Cluster area); 5 workers camps.


a. Organization of environmental management:

99. The Contractor set up a Section of Safety and a Section of Environment Management (figure 10), responsible for checking environmental, safety management of the sub-contractors.

Figure 10: Organization of the Contractor of Package A2-2, included environmental and safety management system

b. Environmental monitoring activity of the Contractor

100. Up to now the Contractor has implemented the following activities for environmental monitoring.

- Prepared CEMP (May 2015) and Safety and Health Plan (October 2015). These 2 documents have been approved by the Supervision Consultant (Dasan – Kunhwa – ICT JV). - Conducted daily environmental and safety monitoring at the main construction works. - Conducted training for new workers in environmental and safety. No training in health and social diseases prevention. - Conducted weekly meeting on the issues of safety in construction sites

Head of control material

Head of control and quality assurance

Safety Manager Nguyen Van Thuy

Construction Manager

Chief Engineer Environmental Engineer Team

Derection

Comment

Sub-contractor’s: Center for analysis & environment

Enviromental monitoring at the construction sites

Nguyen Minh Quoc

Environmental Manager

Nguyen Trung Tuyen

Project Derector Associate Samwhan-Van Cuong


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- Prepared monthly reports on environmental and safety management and submitted to the Supervision Consultant.


101. The Environmental and Safety Sections of the Contractor evaluated that so far, at the construction sites no problems of soil erosion, noise, vibration pollution; no problems of waste management; no labor accidents occurred. There were no complaints from local residents on pollution and safety issues. Only a problem of spoil disposal occurs but the site is managed by Hai Son Industrial Cluster managers, not by the contractor.

d. Reporting


(i) Monthly Environmental Monitoring Reports (from October 2015 to February 2016)

(ii) Quarterly Environmental Management Report (4st Quarter, 2015 and 1st Quarter 2016).

4.3.3. Evaluation and recommendations of EEMC

103. On 29th March 2016 the EEMC (VESDEC) has implemented checking activities of the Contractor of Package A2-2 in environmental and safety management. Based on results of checking documents in its office and observation at the construction sites, worker camps, disposal site and consultation with some householders living closed to the construction site the following evaluation may be given. Detailed evaluation on the compliance of the contractor with the measures required in the EMP approved by ADB in 2010 is indicated in Appendix 3 below.


b. The Contractor implemented most of measures required in the EMP and SEMP for pollution control and environmental protection.

c. In general, environmental management at the construction sites, worker camps and at batching plants are well implemented.

104. However, at other areas (access roads and disposal sites) there were some complaints on environmental issues from local residents obtained by the EEMC during field visit and public consultation meeting: e.g. pumping sand blocked entrance of the household; damage of local road, noise pollution during night time caused by truck movement…etc.

d. Report preparation:

- CEMP and Safety & Health Plan were prepared and approved by the Supervision Consultant. - Monthly environmental monitoring reports were prepared; but contents of the reports should be revised because some formulas used for pollution calculation may not be correct and some monitoring results; some comments and conclusions in the reports should be re-considered. Environmental sampling and noise, vibration measurement should be implemented at the normal or peak construction times.

105. The Construction Supervision Consultant (CSC) should guide the contractors in environmental monitoring methodology and carefully check the monthly and quarterly environmental monitoring reports submitted by the contractors.

e. Common infringements in environmental and safety management:


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106. Although the Contractor has implemented most of measure suggested in the EMP for protection of the environment but various infringements were found during the field visit of EEMC in March 2016. Detailed information on compliance and no-compliance of the contractor with the EMP approved by ADB (September 2010) are indicated in Appendix 3.

107. The followings are the common infringements:

(i) Dust pollution at the access roads (roads used for material transport) because watering conducted only 1-2 times/dry day and amount of water is not enough for humidify the road face. (ii) Without covers of dredged spoils at the construction site and at the disposal area at Hai Son site. It may cause serious impact to the surrounding rice fields or aquaculture ponds due to acidic run-off water in the rainy days. (iii) Solid wastes and hazardous are not well segregated at worker camp and at construction sites. (iv) Sanitation conditions in the worker rooms and at toilets are poor. No separate toilet for women. (v) No specific measures to avoid proliferation of disease vectors such as flies, mosquitoes, rats, etc. (vi) No conduction of orientation for construction workers regarding health and safety measures, emergency response in case of accidents, fire, etc., and prevention of HIV/AIDS and other related diseases

(vii) Water logging/ accumulation of stagnant water is found at worker camp area, this may form breeding sites for mosquitoes.

(viii) The contractor has provided workers with appropriate safety equipment/devices (such as dust mask, helmets, safety shoes, goggles, ear plugs, etc.) but some workers do not use.

(ix) No pave, roof and embankment at fuel storage site.

(x) No proper segregation of hazardous and non-hazardous wastes at the construction sites and worker camps: major infringements.

(xi) No GRM prepared and applied.

(xii) Batching plants did not operated at the time of field visit of the EEMC, but answering on the question of the EEMC on the daily impacts of the batching plants people living closely to the plants said that they do not get serious noise and dust pollution.

Overall assessment on compliance with EMP requirements 108. From the detailed assessment on the contractor's compliance (JO of SMCC-CIENCO 4) with EMP, it can be concluded that, at present, the contractor has implemented various measures to minimize pollution and mitigate the adverse impacts. Most of the measures are complied with EMP. However, in the total over 100 measures evaluated 24 measures were not complied, of which 22 measures as minor infringement and 2 measures as major infringement are evaluated. The main major infringement relates with improper management of hazardous wastes. They must be properly corrected immediately.

4.3.4. Suggestions of EEMC: Environmental Corrective Requirements for Package A2-2

109. From the results of field visit, the EEMC may suggest the main following environmental corrective requirements for Package A2-2. All the measurers suggested by EEMC should be implemented and completed by the Contractor before 30th June 2016 and they should be supervised by CSC.

(i) Improve watering at the access roads to minimize dust pollution. (ii) Cooperate with Hai Son Industrial Cluster Management Board to cover surface of the disposal area at Hai Son site to avoid impact of polluted runoff water to the surrounding rice field.


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(iii) Improve segregation of non – hazardous and hazardous wastes at worker camps and at construction sites. (iv) Improve sanitation conditions at worker camp areas. (v) Implement training programs on safety, pollution control, risk management and prevention of HIV/AIDS and other related diseases

(vi) Install proper roofs, walls, floor at fuel and hazardous storage sites complying with MONRE guidelines.

(vii) Immediately prepare GRM following the ADB requirements and disclose to local PC and residents.

(viii) Others requirements are indicated in Appendix 3.

4.4. ENVIRONMENTAL MANAGEMENT AND COMPLIANCE OF PACKAGE A3 WITH THE ENVIRONMENTAL MANAGEMENT PLAN

4.4.1. Status of Construction at Package A3

110. Information and reports from the contractor indicate the actual works and progress of Section A3 by early April 2016 can be summarized below.

Mobilization and demobilization: 0.15%

Construction and maintenance of access and temporary roads: 0.60%

Provision and maintenance of laboratory and equipment: 0.27%

Survey and design of construction drawings: 0.38%

Clearing and grubbing: 0.01%

Excavation of unsuitable Material: 0.01%

Construction of embankment: 0.08%

Bored pile 1,200mm diameter (on land):9.9%

Geologic investigation borings: 0.36%

Total progress: 14.43%

4.4.2. Activities in Environmental and Safety Management of the Contractor Organization of environmental management 111. The contractor has set up a framework of safety and environmental management as shown in figure 11.


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Project DirectorJEONG WOO HEO

Assistant cum Office SecretaryPHAM THANH TUNG

Head, A3 Executing Board PHAM VAN DU

Construction ManagerDAO VAN HUY

Safety ManagerTRAN LE VIET HAU

Environmental ManagerTRAN DAI NGHIA

Chief Engineer Safety Staff Environmental Engineer

Sub-contractor’s Safety StaffLAM VUONG ANH

Sub-contractor’s Environmentalist

Sub-contractor’s Safety StaffLE VAN BANG

Engineer Engineer Engineer Engineer

Worker Worker Worker Worker

Figure 11: Organization of the Contractor of Package A3, included environmental and safety management system

4.4.3. Evaluation of EEMC on Compliance of the Contractor with the EMP

112. From information provided by EPMU, results of the quarterly environmental monitoring reports (December 2015 and March 2016), provided by the environmental monitoring consultants and reports of CSCs it may indicate that, in general, the contractor has so far been complying with the environmental requirements as in the EMP included in the EIA, approved by MONRE and cleared by ADB (September 2010).

113. At present the contractor has implemented various measures for impact mitigation, pollution prevention and waste management. Most of the implemented measures comply with the EMP. However, 21 measures were not complied, of which 16 measures as minor infringement and 5 measures as major infringement were evaluated by EEMC.

114. The major infringement are mainly related to the spoil management and hazardous waste, containing oil, lubricant and grease. Hazardous waste is often found mixed with non-hazardous waste.


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115. All the infringements were pointed out by the EEMC on-site and accepted by the accompanying team, including the Director of A3 Section - Mr. Jeong Woo Heo. Soon after the EEMC’s field visit, the contractor on April 11th2016 took some corrective action addressing some of the shortcomings pointed out by the EEMC. The corrective actions, with illustration photos, were made into a “Report on Correction of Shortcomings for Environmental and Safety Works” and submitted to the CSC together with official letter Ref. No BLLT/A3/C/16-127 on April 11th 2016. Through the report, it is acknowledged that some shortcomings have been fixed and/or improved as result of the corrective actions. In spite of that, however, a number of other shortcomings, which were also identified as infringements, still remain as described in detail in Appendix 4 below.

116. The minor infringements are mainly related with pollution issues at worker camps and construction sites:

(i) Specific training for management of hazardous wastes was not implemented.

(ii) Dredged spoil was not compacted. The surface of dredged spoil sites was not covered by dense plastic sheets to prevent dust dispersion.

(iii) Dredged spoils are partly re-used for leveling onsite and currently reach a Nipa palm water body nearby, without adequate protection for dust control and erosion. The situation could be worse during the coming rainy season.

(iv) There is insufficient amount of waste containers at the project site.

(v) Part of excavated materials is still around.

(vi) Waste soil generated from bored piles has partly been used for leveling onsite and currently reaches a Nipa palm water body nearby, without being isolated by an embankment. The situation could be worse during the coming rainy season.

(vii) No GRM and hotline provided for local residents for directly receiving complaints from local residents.

117. Detailed evaluations on the contractor compliance with the measures in the EMP are given in Appendix 4.

Overall assessment on compliance with EMP requirements 118. From the above evaluation on compliance of the A3 Package’s contractor (Joint Venture of Halla Corp – Vinaconex Eng.Cons. & Invest.JSC) with the EMP it may conclude that at present the contractor has implemented various measures for impact mitigation, pollution prevention and waste management. However, in the total of over 100 evaluated measures 21 measures were not complied, of which 16 measures as minor infringement and 5 measures as major infringement are evaluated. The main major infringement relates with improper management of hazardous wastes. They must be properly corrected immediately. It is very good that after receiving verbal recommendations from EEMC during the field visit the contractor has rapidly took some measures for correction of some infringements.

4.4.4. Suggestions of EEMC: Environmental Corrective Requirements for Package A3

119. Based on studying the relevant reports, discussing with relevant parties, and visiting the project construction and worker camp sites, the EEMC suggest the following measures for environmental improvement for Package A3. All the requirements suggested by EEMC should be implemented and completed by the Contractor before 30th June 2016 and they should be supervised by CSC.

(i) The contractor is to urgently improve hazardous waste handling and management at the construction sites. This should include, but not necessarily are limited to:


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- Urgently organize an appropriate storage for hazardous waste; - Immediately clean up the oil polluted soil at the equipment maintenance sites; - Immediately provide prevention measures (e.g. liners, absorption pads etc.) and have them applied at the equipment maintenance sites; - Immediately provide embankments sourrounding the concrete additive tanks; - Provide a sufficient amount of containers/bins for colleting both hazardous and domestic waste; - Consider the installation of an oil-water separator at the construction site; and - Train workers in segregation and handling of hazardous waste. (ii) The contractor is to sign contracts with licensed local service companies for regular transport of both hazardous and non-hazardous solid waste to approved treatment sites. (iii) The contractor is to provide an embankment to isolate the leveling waste soil from the nearby water body; compact the dredged soil and cover the spoil storage sites with dense plastic sheets; and reuse or give the remaining excavated materials to local residents as soon as possible. (iv) The contractor is to monitor dust and noise at the residential area near batching No. 2 and implement countermeasures if the dust and noise actually exceed the allowable levels. (v) The contractor is to establish a GRM and provide a hotline for receiving complaints from local residents. (vi) The contractor to have the HIV Prevention Program for Construction Workers approved and subsequently to implement the program as soon as possible.

4.5. ENVIRONMENTAL MANAGEMENT AND COMPLIANCE OF PACKAGE A4 WITH THE ENVIRONMENTAL MANAGEMENT PLAN

4.5.1. General Information 120. The construction of Package A4 starts from Km 18+7135and ends at Km21 + 739.5. It passes Nha Be - Ho Chi Minh City, with a total length of 3.026km, which includes roads, bridges and viaducts. Contractor of the package is Joint Venture of Kukdong Engineering & Construction Co., Ltd & Dong Mekong Construction Manufacture, while construction supervision consultant is the Dasan – Kunhwa – ICT JV. 121. Since the package just started construction activities on February 17th 2016, not many environmental issues have so far been raised. As such the EEMC team has based on the evidences observed during the field visit, included with photos taken at the project site, only made some notices on environmental aspects of the on-going activities, instead of producing a detailed assessment using the ready set up form (template) for environmental supervision, like it was applied for some other packages. 4.5.2. Status of Construction Implementation at Package A4 122. Information and reports from the contractor indicate the works and progress of Section A4 by early April 2016 can be summarized in Table 7 below.


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Table 7. Works and progress of Section A4 by early April 2016

Achieved (%)

Mobilization and Demobilization 20

Construction and Maintenance of Access and Temporary Road

Temporary Road on Main Route 20

Site Laboratory

Site Cleaning and Project Management Office and Casting Yard for Super T-

Site Cleaning on Site 100

Casting Yard for Super T-Girder 80

Geological Investigation

2 more equipment for SPT was mobilized on site

Soil sampling at P11, P13, P15, P16, P21-10, P22, P23,P24, P25, P26, P27,P28 and

Total Progress (%) 0.06

Source: Data provided by JV Kukdong Engineering & Construction Co., Ltd & Dong Mekong Construction Manufacture, April 2016. 4.5.3. Activities in Environmental and Safety Management of the Contractor

123. To properly evaluate the efficiencies in environmental management and compliance of the Contractor with the EMP, on April 6th 2016 the EEMC has, accompanied by the EPMU’s and engineer’s representatives, undertaken a site visit to the Package A4’s project site.

124. Since the package just started construction activities on February 29th 2016, not many environmental issues have so far been raised.

125. As such the EEMC team has based on the evidences observed during the field visit, included with photos taken at the project site, only made some notices on environmental aspects of the on-going activities, instead of producing a detailed assessment using the ready set up form (template) for environmental supervision, like it was applied for some other packages. In addition, it should be mentioned that public consultations at Package A4 area has not been planned for this input.

Organization of environmental management 126. The contractor has set up a framework of safety and environmental management as shown in figure 12 below.


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Project ManagerMr. Seo Sang Seob

Construction ManagerMr. Tran Van Nhi

Safety Engineer Mr. Tran Van Hoa

Bridge EngineerMr. Truong Van Nam

Highway EnginererMr. Phung Dinh Dan

Environmental EngineerMs. Tran Thi Bich

Construction site

Environmental Subcontractor

(Monthly, Quarterly)

Area 1 Team

Subcontractor

Area 2 Team Area 3 Team Area 4 Team

Subcontractor Subcontractor Subcontractor

Figure 12: Organization of safety and environmental management of A4 Contractor

Compliance of the contractor with the EMP during construction

127. Since Package A4 has just started its construction activities, the contractor has only recently completed some major tasks for environmental compliance, while still are preparing for the remaining requirements. So far, the situation of the package in relation to compliance with the EMP can be summarized in Appendix 5 below.

128. From information and reports provided by the contractor, together with information provided by the CSC’s environmental engineer and the EPMU as summarized above, in addition to the field visit to the project site conducted on April 6th2016 helped, the EEMC produces the following findings:

(i) Although Package A4 has just started construction activities, the contractor is already implements many appropriate measures for mitigation of impacts generated by the project construction activities. Various management and technical measures suggested in the EMP have been and/or are being applied by the contractor.

(ii) A CEMP was prepared and submitted to CSC.

(iii) Nevertheless, at present, some measures suggested in the EMP have not yet been applied by the contractor and some infringements are found, both at the project construction site and in the managerial works, as analyzed in the above mentioned in Appendix 5.


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(iv) As for assessing the capacity and experience of the contractor's Environmental Manager and Safety Manager EPMU's, the EEMC makes the following conclusions: - Ms. Tran Thi Bich, the contractor’s Environmental Manager, holds a university degree as Engineer on Environmental Technology from Van Lang University in 2001. - Mr. Tran Van Hoa, the contractor’s Safety Manager, has got certificate of attendance at a two-day training course on Labor Safety and Hygiene issued on February 19th 2016 which is valid for two years. There is however no company profile available to prove his experiences in similar works, nor evidence of having a university degree. 129. From the above evaluation on compliance of the A4 Package’s contractor (Joint Venture of Kukdong Engineering & Construction Co., Ltd & Dong Mekong Construction Manufacture) with the EMP it may conclude that at present the contractor has implemented various measures for impact mitigation, pollution prevention and waste management. Most of the implemented measures comply with the EMP. However, five measures have not yet been implemented so far, are identified as non-compliance which are all classified as “Minor Infringement”. 4.5.4. Suggestion of EEMC: Environmental Corrective Requirements for Package A4

130. Based on studying the relevant reports, discussing with relevant parties, and visiting the project construction site, the EEMC suggest the following main requirements for environmental improvement for Package A4. All the requirements suggested by EEMC should be implemented and completed by the Contractor before 30th June 2016 and they should be supervised by CSC.

(i) The contractor is to sign contracts with licensed local service companies for regular transport of both hazardous and non-hazardous solid waste to approved treatment sites. (ii) The contractor is to urgently start handling and management of both hazardous and non-hazardous waste at the construction sites. This should include, but not necessarily are limited to: - Provide a sufficient amount of containers/bins for collecting both hazardous and domestic waste; - Organize an appropriate storage for hazardous waste; - Provide prevention measures (e.g. liners, absorption pads etc.) and have them applied at the equipment maintenance sites; - Provide embankments surrounding the concrete additive tanks; - Installation of oil-water separator(s) where necessary at the construction site; and - Provide training to workers in segregation and handling of hazardous waste. (iii) The contractor is to compact the dredged soil and cover the waste soil storage sites with dense plastic sheets; and reuse or give the excavated organic (vegetation) materials to local residents as soon as possible. (iv) The contractor is to urgently prepare a HIV Prevention Program for Construction Workers, have it approved and subsequently to implement the program as soon as possible. (v) The contractor is to urgently prepare a training program on health, safety and environment for workers and subsequently to implement the program as soon as possible. (vi) The contractor is to establish a GRM and provide a hotline for receiving complaints from local residents. 4.6. ENVIRONMENTAL MANAGEMENT AND COMPLIANCE OF PACKAGE J2 WITH THE ENVIRONMENTAL MANAGEMENT PLAN

4.6.1. General Information

131. Information on the Package J2 is given below.

- Contractor: JO SMCC-CIENCO4.

- Sub-contractors: 479 JSC, 499 transportation company, Tuan Loc company.


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- Length : 4.7 km from Km 24+503 to Km29+264 (including Cha Bridge and viaduct)

- Location: Can Gio District, Ho Chi Minh City

- Construction works: western approach bridge, Cha bridge, eastern approach bridge.

- Start day: 28th October 2014



132. The Contractor (JO SMCC-CIENCO4) set up a Section of Safety – Environment and Health (HSE), included 3 engineers, responsible for checking environmental, safety management of the sub-contractors (figure 13).

Figure 13: Organization of the Contractor of Package J2, included environmental and safety management system

Environmental Manager Pham ThanhToan

Construction site

PROJECT MANAGER KazumitsuTahara

Construction Manager Hagashi

Cantilever Team Area 1 Team Area 3 Team




Area 2 Team

Subcontractor

Safety Manager Le Ngoc Xuan

DE. PROJECT MANAGER Dam Xuan Toan

DE. PROJECT MANAGER Shimoyama


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b. Environmental management activity

133. The Contractor has:

- prepared CEMP (November 2014) and Safety and Health Plan (December 2014). These 2 documents have been approved by the Supervision Consultant (KEI-NE-OCG-TEDI JV).

- conducted daily environmental and safety monitoring at the main construction works.

- conducted training for new workers.

- regularly reported to the team leaders of JO SMCC-CIENCO4 about the safety and environmental infringements of the sub-contractors.


134. The HSE evaluated that so far, at the construction sites no problems of soil erosion, noise, vibration pollution; no problems of waste management; no labor accidents occurred.

135. There were some complaints from local residents on noise and dust.

d. Reporting


(i) Monthly Environmental Monitoring and Management Reports (till February, 2016)

(ii) Quarterly Environmental Monitoring and Management Reports (till December, 2015

4.6.3. Evaluation of EEMC on Compliance of the Contractor with the EMP

137. On 30th March 2016, the EEMC (VESDEC) has implemented checking activities of the Contractor of Package J2 (JO SMCC-CIENCO4) in environmental and safety management. Based on results of checking documents in its office and observation at the construction sites, worker camps, disposal site and consultation with some householders living closed to the construction site, the following evaluation may be given. Detailed evaluation on the compliance of the contractor with the measures required in the EMP approved by ADB in 2010 is indicated in Appendix 6 below. From this table the main evaluation on environmental management of the Package A1 are summarized as follow.


b. In general, environmental management at the construction sites, worker camps and at batching plants are well implemented; no serious (major infringement) environmental and safety matters were found.

c. Report preparation:

- CEMP and Safety & Health Plan were prepared and approved by the Construction Supervision Consultants.

- Monthly environmental reports were prepared; but contents of the reports should be revised because some formulas used for pollution calculation (e.g formulas for air pollution and water pollution loads) may not be correct and some monitoring results should be explained; some comments and conclusions in the reports should be re-considered combining monitoring data and field observation. Environmental sampling and measurement should be implemented at the normal or peak construction time, but not in low construction days.


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d. Infringements in environmental and safety management:

138. Various infringements, included 3 major and 9 minor infringements were found during the field visit of EEMC in March 2016 and from public consultation meeting.

139. Three major infringements are:

(i) Concrete mixers and batching plants generated dust all day and night long (at different levels), affecting the living activities of some households (complaints from local residents). (ii) Still some households affected by the activities of the project but have not been compensated by the Contractor (complaints of local residents and local authorities in Binh Khanh commune in the public consultation meetings in April 2016). (iii) Poor management of hazardous wastes. 140. The minor infringements are: (i) No name plates in some waste bins; (ii) Contract for collecting and treating solid waste was invalid by December 2015 (but solid waste is still regularly collected and treated by this environmental service company, therefore, it does not cause evident pollution problem). (iii) Although the Contractor already set up along temporary bridge and culvert with hotline number (+84) 0983343547 and contact person (Mr. Xuan - Safety Officer), some local residents still complain about this. (iv) There is no embankment surrounding the chemical tank (concrete additives). (v) No measures for preventing waste oil spillage during vehicle/equipment maintenance on site. (vi) There is no proof that the barge owner does not have an oil spill prevention and response plan and relevant technical facilities for its implementation. (vii) No GRM prepared. (viii) Others. 141. Detailed evaluations on the contractor compliance with the measures in the EMP are given in Appendix 6. Overall assessment on compliance with EMP requirements 142. From the detailed assessment on the contractor's (JO of Sumitomo Mitsui – CIENCO4) compliance with EMP, it can be concluded that, at the present time, the contractor has implemented various measures to prevent pollution and waste management. Most of the measures are complied with EMP. However, in the total of over 100 evaluated measures 12 measures were not complied, of which 9 measures as minor infringement and 3 measures as major infringement are evaluated. The main major infringement relates with improper management of hazardous wastes. They must be properly corrected immediately. It is very good that after receiving verbal recommendations from EEMC during the field visit the contractor has rapidly took some measures for correction of some infringements. In comparison with other packages (A1, A2-1, A2-2), environmental management of Package J2 (JO of Sumitomo Mitsui – CIENCO4) is likely better.

4.6.4. Suggestions of EEMC: Environmental Corrective Requirements for Package J2

143. From the field visit, the EEMC may suggest the following main environmental corrective measurements for Package J2. All the requirements suggested by EEMC should be implemented and completed by the Contractor before 30th June 2016 and they should be supervised by CSC.

(i) Strictly apply appropriate measures for dust pollution at the batching plants

(ii) Cooperate with Binh Khanh PC and householders affected by the construction activities to fully resolve the incidents complained by local people.


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(iii) Solid wastes must be well segregated into hazardous and non - hazardous. Hazardous wastes must be well managed following the MONRE regulation on hazardous management.

(iv) Name plates must be mounted on every rubbish bin.

(v) The contractor must prepare a new contract for treating domestic solid waste from the project

(vi) Chemical tanks must be surrounded by appropriate concrete protection walls.

(vii) Provide 01 rubbish bin for every toilet room and ask workers to keep sanitation

(viii) A hotline should be provided for local residents through Binhkhanh PC and along the project ROW.

(ix) The EPMU and the contractors should pay more attention to complaints from local residents and governments and deal with them as soon as possible.

(x) The contractor should immediately implements appropriate mitigation measures to minimize impact of dust to living activities of local residents.

(xi) The contractor should hold meetings with PAHs and local authorities to resolve these issues as soon as possible.

(xii) The barge owner must get approval for their oil spill prevention and response plan and they have to equip all relevant technical facilities for its implementation.

(xiii) The contractor should immediately prepare a GRM and disclose to local residents.

4.6.5. Corrective Measures Applied by J2 Contractor

144. Rapidly implementing the measures suggested by the EEMC in April 2016 J2 Contractor has corrected various incidents found during the EEMC field visit (in March 2016) 145. Till now, some non-compliances were corrected by the contractor, as shown in pictures below.

No. Before After

1

Leakage of oil cause pollution to ground Contractor provided ground cover when repairing machines


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No. Before After

2

Hazardous material wasn't stocked in right position Contractor collected and cleaned the place

3

Used oil tankers were't stored in right way Contractor installed a warehouse for storage of used oil tankers

4

Oily wastes were't stored in right way Contractor segrgated oily wastes


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No. Before After

5

Protection wall for chemical tankers was broken

Contractor built edge to prevent leakage of chemicals

6

Repairing work on the ground was not in right way

Contractor installed a cover sheet at ground and used bucket for storing waste materials

7

Repairing work on the ground caused leakage of oil to ground

Contractor installed a cover sheet at ground when repairing machines


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No. Before After

8

Oil leakage to ground Contractor treated and cleaned the ground

9

Bucket for storing oil wasn't in right regulation

Contractor collected and arranged in a place with roof and walls

Source: Photos provided by SMCC-CIENCO4 JO, April 2016

146. From the above information it may evaluate that the J2 Contractor (SMCC-CIENCO4 JO) has well and fast implemented the measures suggested by the EEMC to correct various environmental infringements. This is a very good example for other contractors in environmental management.

4.7. ENVIRONMENTAL MANAGEMENT AND COMPLIANCE OF PACKAGE J3 WITH THE ENVIRONMENTAL MANAGEMENT PLAN

4.7.1. General Information

147. Information on the Package J3 is given below.

- Contractor: JO SMCC-CIENCO4

- Sub-contractors: Cienco4- Branch 412; 415 investment & construction company limited, 419 investment & construction JSC, 479 JSC, 499 transportation company, Antara Koh (I) PTE.

- Length : 3.186 km from Km 29+264 to Km32+450 (including Phuoc Khanh Bridge and approach)

- Location: Nha Be District, HCMC and Nhon Trach District, Dong Nai Province.


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- Construction works: western approach bridge, Phuoc Khanh bridge, eastern approach bridge and eastern approach road.

- Start day: 04th January 2016

148. Information from the contractor indicated that:

(i) At this moment, the section J3 includes following works: - Division 1: General requirements - Division 3: Earth works - Division 7: Structural works (ii) As of April 2016: - Division 1 has been under implementation. Construction of electric system and water supply system of P1-P25 was completed, taking account of 54% of total plan for this item (P1~P12, P17~A2). Construction of access road: access road from Ong Keo dyke to P30 was completed; access road from P30 to A2 is under construction with about 31% of total plan achieved, embankment around piers with 49%, temporary bridge A with 30%, temporary bridge B under preparation and temporary pipe culvert of No.4 and No.5 is under preparation. - Division 3 has been under implementation with structural excavation reaching 12% of total plan. - Division 7 has been under implementation with Concrete Class C30 reaching 2.9% of total plan; standard penetration test (SPT) with 39%; coring and concrete testing at pile base with 20%; Cross hole sonic logging per section with 11%; Pile Dynamic Test for Bored Pile (Dia. 1,500mm) with 25%, Bored pile 1200mm diameter (on land) with 6%; Bored pile 1500mm diameter (on land) with 46%.

4.7.2. Activities of Environmental and Safety Management of the Contractor

a. Organization of environmental management:

149. The Contractor (SMCC-CIENCO4 JO) set up a Section of Safety – Environment and Health (HSE), included 3 engineers, responsible for checking environmental, safety management of the sub-contractors (Figure 14).

b. Environmental management activity

150. So far, the Contractor has:

- prepared CEMP (November 2015) and Safety and Health Plan (September 2015). These 2 documents have been approved by the Construction Supervision Consultant (KEI-NE-OC-TEDI JV).

- conducted daily environmental and safety monitoring at the main construction works.

- conducted training for new workers.

- regularly reported to the team leaders of SMCC-CIENCO4 JO about the safety and environmental infringements of the sub-contractors.

c. Findings of Contractor’ HSE in safety and environmental management at the construction sites:

151. The HSE evaluated that so far, at the construction sites no problems of soil erosion, noise, vibration pollution; no problems of waste management; no labor accidents occurred. There were not complaints from local residents on pollution and safety issues.


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152. However, the following infringements have been found:

(i) Local residents do not have public road, they must pass through the project area for their living activities and businesses;

(ii) Managers of the contractor and sub-contractors did not deeply pay attention on implementation of proper measures for pollution control.

(iii) Transport of spoil is a big problem for the contractor

d. Reporting:

Environmental Manager Mr. Dang Van Dien

Construction site

PROJECT MANAGER Mr. Osamu SAWATA

Construction Manager Mr. Tamihiko Kitayama

Cantilever Team Area 1 Team Area 3 Team




Area 2 Team

Subcontractor

Safety Manager Mr. Edwin Zipagan

DE. PROJECT MANAGER Mr. Nguyen Phuong Vinh

DE. PROJECT MANAGER Mr. Kotaro Mimura


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(i) Monthly Environmental Monitoring Reports (January, February and March 2016)

(ii) Quarterly Environmental Monitoring Reports (First Quarterly, March 2016)

(ii) Monthly Environmental Management Report (January, February 2016)


154. On 6th April 2016, the EEMC (VESDEC) has implemented checking activities of the Contractor of Package J3 (SMCC-CIENCO4 JO) in environmental and safety management.

155. Based on results of checking documents in its office and observation at the construction sites, worker camps, disposal site and consultation with local residents closed to the construction site, the following evaluation may be given. Detailed evaluation on the compliance of the contractor with the measures required in the EMP approved by ADB in 2010 is indicated in Appendix 7 below. From this table the main evaluation on environmental management of the Package A1 are summarized as follow.


b. In general, environmental management at the construction sites, worker camps and at batching plants are well implemented, but some infringements in environmental and safety management were found.

c. Report preparation:

(i) CEMP and Safety & Health Plan were prepared and approved by CSC (the Supervision Consultant).

(ii) Monthly environmental reports were prepared; but contents of the reports should be revised because some formulas used for pollution calculation may not be correct and some monitoring results; some comments and conclusions in the reports should be re-considered. Environmental sampling and measurement should be implemented at the normal or peak construction times.

(iii) Monthly environmental monitoring reports of January, February and March 2016 and Monthly Environmental Management Report of January 2016 have not been appraised and approved by Supervision Consultant.

d. Infringements in environmental and safety management:

156. At present the contractor has implemented various measures for pollution prevention and waste management. Most of measures complied with the EMP. However, during the construction various infringements, included 2 major and over 10 minor ones were found in the field visit of EEMC.

(I) Major infringements are related with hazardous waste management:

- Leakage of bentonite from a container.

- The barge owner does not have an oil spill prevention and response plan and relevant technical facilities for its implementation.

(ii) Minor infringements are related with waste management:

(iii) Open burning of domestic waste (the Western bank of Long Tau river)

(iv) No waste separation at source (the Western bank of Long Tau river)

(v) There is no embankment surrounding the chemical tank (concrete additives).


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(vi) There was no fences, gates, signs, car wash at Can Gio disposal area

(vii) Wastewater from cleaning construction equipment was not effectively collected. Wastewater discharged to Long Tau river.

(viii) Others

157. Detailed evaluations on the contractor compliance with the measures in the EMP are given in Appendix 7.

Overall assessment on compliance with EMP requirements

158. From the detailed assessment on the contractor's (JO of Sumitomo Mitsui – CIENCO4) compliance with EMP, can be concluded that, at the present time, the contractor has implemented various measures to prevent pollution and waste management. Most of the measures are complied with EMP. However, in the total of over 100 evaluated measures 13 measures were not complied, of which 11 measures as minor infringement and 2 measures as major infringement are evaluated. The main major infringement relates with improper management of hazardous wastes. They must be properly corrected immediately.

4.7.4. Suggestion of EEMC: Environmental Corrective Requirements for Package J3

159. From the field visit, EEMC has suggested the following main environmental corrective requirements for Package J3. They must be implemented and completed by the contractor before 30th June 2016 and supervised by CSC.

(i) Collect and dispose of waste soil (spoils) generated from bored piles daily. All spoil must be moved to disposal area before rainy season. (ii) Solid wastes must be well segregated into hazardous and non - hazardous. Hazardous wastes must be well managed following the MONRE regulation on hazardous management. (iii) Provide hazardous waste containers at the construction sites where hazardous waste may be generated. (iv) Contractor implements the strict control to garbage and burning domestic waste is prohibit. (v) Chemical tanks must be surrounded by appropriate concrete protection walls. (vi) Contractor should make dike along the Long Tau river within project area to prevent construction wastewater flowing into the Long Tau river. (vii) Settling tanks should be built 30 cm higher to prevent rainwater runoff into the tank as well as the tank does not overflow. (viii) All construction wastewater must be collected on the first settling tank.. (ix) The contractor must check the operation of the tank bentonite, ensure no spillage occurs. (v) Contractors need to install fences, gates, signs, car wash at Can Gio disposal area (vi) The barge owner must get approval for their oil spill prevention and response plan and they have to equip all relevant technical facilities for its implementation. (vii) The contractor should immediately prepare a GRM and disclose to local residents.


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PART FIVE:

PUBLIC CONSULTATION

5.1. ORGANIZATION OF PUBLIC CONSULTATION

5.1.1. Purposes

158. Purposes of public consultation are as follow.

- To inform to local governmental agencies, NGOs, affected people about the construction activities of the packages and measures applied by the contractors for pollution control and protection of the environment and life of people;

- To hear and record comments and complaints (if any) from local governmental agencies, NGOs, affected people;

- To answers the questions and suggestions of local governmantal agencies, NGOs, afected people;

5.1.2. Implementation of public consultation

159. In this mobilization (30 days in March and April 2016) 3 public consultation meetings were organized with the participation of:

- Representatives of EPMU

- EEMC specialists

- Representatives of CSC (consultants)

- Representatives of local governmental agencies of the communes

- Representatives of commune NGOs (Associations of Women, Associations of Farmers, Associations of Veterans, Associations of Youth...)

- Affected householders.

160. List of participants in each meeting is given below.

5.2. PUBLIC CONSULTATION AT THE SELECTED COMMUNES

5.2.1. Public Consultation at Hung Long commune, Binh Chanh district (A2-1 and A2-2 Packages)

161. Organization of public consultation at this commune is described below.

a. Time, venue

Time: from 8h30 AM to 11h30 AM, 14th April 2016.

Venue: People’s committee of Hung Long commune, Binh Chanh district, Ho Chi Minh City.

b. Participants

1. EEMC (VESDEC):

- Mr. Pham Hong Nhat, Environmental expert - K2, Head of EEMC Public Consultation Team

- Mr. Nguyen Vu Phong, Env. Engineer, Supporting staff.

- Ms. Dinh Kim Chi, Env. Engineer, VESDEC staff.

2. Representative of the project owner (EPMU):


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- Ms. Phan Anh Thy, Site office of ADB section, in charge of environment management of the project.

3. Representatives of the contractor :

- Mr. Nguyen Xuan Mau, Engineer of Package A2-1.

- Mr. Phan Hoai Bao, Engineer of Package A2-1.

- Mr. Le Van Luong, Engineer of Package A2-1.

- Mr Nguyen Minh Quoc, Safety staff of Package A2-2.

- Ms. Tran Thi Huong Giang, Environment staff of Package A2-2.

4. Representatives of local government and residents:

Representatives of local government and residents in this meeting are indicated in table 8.

Table 8: List of local government and residents in public consultation meeting at Hung Long commune

No. Name Position Contact information

1 Nguyen Van Ut Nam Vice President Hung Long commune PC – 0937.368.468

2 Tran Minh Hoan President of Fatherland Front Hung Long commune – 0907.374.303

3 Nguyen Kinh Cong Cadastral Officer Hung Long commune PC – 0908.400.807

4 Nguyen Van Nam Household 13/8 Hung Long

5 Ngo Minh Tham Household C7/34 Hamlet 3, Hung Long – 0916.206.913

6 Huynh Thi My Le Household Hung Long – 0918.367.566

7 Thai Thi Hương Farmer C13/22 Hung Long – 0908.149677

8 Do Van Loi Farmer C21/7 Hamlet 3, Hung Long

9 Huynh Thi Phuong Household C10/11 Hung Long

10 Nguyen Minh Rai Household C10/22 Hung Long – 0908752928

11 Nguyen Thanh Phong Farmer C3/34 Hung Long

12 Ngo Minh Thanh Farmer C10/34C Hung Long-0126.763.9609

13 Ngo Minh Thuan Dealer Hung Long – 0937.863.881

14 Ngo Thanh Hong Farmer C10/34 Hung Long

15 Nguyen Tien Phong Worker C6/24B Hamlet 3, Hung Long – 0983.039.534


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16 Do Van Phuc Farmer Hung Long – 0169.625.1134

17 Nguyen Van Tin Household Hung Long – 0167.5441.421

18 Nguyen Minh Hai Officer of Hung Long commune PC

Hung Long commune PC – 0166.904.1080

19 Dao Hoang Vu Head of Hamlet 3 Hung Long – 0909.172.038

c. Comments from the local government and project affected people and responses of Contractor

162. In the consultation meeting participants risen their comments, discussion about the environmental issues of the project. Some of them risen complaints on environmental and social incidents caused by the contractors. All of their comments and complaints are recorded in table 9 below.

Table 9: Comments and complaints of participants in consultation meeting at Hung Long commune

No. Name Comments Responses of Contractor

1 Nguyen Van Nam, Farmer, C15A/22, Hamlet 3, Hung Long

- Sand pumping at 18-19h caused electric power lack, affecting living activities of local residents; salt water entering ponds of local residents - Excavation work likely to cause accidents, especially during the coming rainy season.

- The contractor illegally sell the dredged soil to other company.

- The contractor commits to ensure safety and environment for the project

- Excavated soil is disposed of at the approved disposal site in Can Giuoc;

- The contractor did not sell the dredged soil.

- If any evidence of selling the excavated soil occurs, please inform the contractor immediately.

2 Huynh Thi My Le- Farmer, C15/A1, Hamlet 3, Hung Long - 0918367566

- Compensation for PAHs was not satisfactory (from 2.900.000d down to 1.150.000 VND). - Too much dust, road deterioration due to overloaded vehicles transporting with high intensity, - Trucks were not covered by canvas.

- No answer on compensation policy given by the contractor/CSC/EPMU.

- Contractor has applied some mitigation measures such as spraying water twice a day and installing dust proof fences but it is impossible to minimize dust dispersion. The contractor herewith apologized for the inconvenience and asked the PAHs for understanding and sharing the situation.

- With regard to the road damage caused by the project: this is a


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temporary road, so the contractor can and will only fix it temporarily, expecting sympathy from local residents.

- All trucks are required to be covered with canvas. Nevertheless, the Contractor will instruct truck drivers again to apply all necessary mitigation measures specified in EMP, as well as maintain the required limit speed when transporting.

3 Nguyen Thanh Phong, Farmer-C3/34, Hamlet 3, Hung Long

- Trucks were not covered by canvas. - Construction of the project at night made noise, vibration

All trucks are required to be covered with canvas. Nevertheless, the Contractor will instruct truck drivers again to apply all necessary mitigation measures specified in EMP, as well as maintain the required limit speed when transporting;

4 Nguyen Minh Hai, Farmer, C10/22, Hamlet 3, Hung Long – 0908752928

- Pumping sand blocked entrance of the household. - After clearance, PAHs do not have another house to live because they are not allowed to build house on their remaining land.

- Pumping sand made blocking entrance: the contractor will examine and correct immediately; - No answer on the second complaint given. This complaint on policies of land clearance shall be answered by the Land Clearance/Resettlement Unit of Binh Chanh district People Committee.

5 Nguyen Tien Phong, Worker, C6/34B Hamlet 3, Hung Long – 0983.039.539

- Road has a lot of potholes, difficult for travelling, can cause accidents (Road T10 / D1). - Please level large pot holes by stone, instead of sand, so it is easier to travel.

- The Contractor commits to ensure safety and environment for local people;

- With regard to the road damage caused by the construction: this is a temporary road, so the contractor can and will only repair it temporarily, expecting sympathy from local residents.

6 Tran Minh Hoan, President of Fatherland Front of Hung Long commune – 0907.374.303

- Overloaded trucks damaged Tan Lieu road. - Driving too fast, endangering people. - Too much dust, watering one

- Contractor has applied some mitigation measures such as spraying water twice a day and installing dustproof fences but it is impossible to minimize dust dispersion. The contractor herewith


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time in the morning and one in the afternoon is not enough (especially in the dry season) - Pumping sand caused salinity, adversely affect crop of farmers. - A meeting between the contractor, EPMU, local government and PAHs should be hold soon to solve arisen issues.

apologized for the inconvenience and asked the PAHs for understanding and sharing the situation. The contractor will increase water spraying frequencies where and when found necessary, but will not be able to do this all day. - The contractor commits to ensure safety and environment for the project; - For activities of pumping sand causing saltwater intrusion and blocking entrance: the contractor will examine and correct immediately

7 Nguyen Van Ut Nam, Vice President of Hung Long PC – 0937.368.468

- The CPC has no information about the project, EMPU and contractors should provide information about design, progress of the project. - Project-related information should be disseminated to local government and residents. - There should be local hotline to contact the EPMU, Contractors, supervision Consultants.

Contractors have attached 02 signboards to show information of the project, so local people can know about the project.

5.2.2. Results of Public Consultation at Binh Khanh commune, Can Gio district (J2 Package)


a. Time, venue

Time: from 2.00 PM to 4.30 PM, 14th April 2016.

Venue: People’s committee of Binh Khanh commune, Can Gio district, Ho Chi Minh City.

b. Participants

1. EEMC (VESDEC)

- Mr. Pham Hong Nhat, Environmental expert - K2, EEMC Public Consultation Team Leader

- Mr. Nguyen Vu Phong, Env. Engineer, supporting staff.

- Ms. Đinh Kim Chi, VESDEC staff.

2. Representative of EPMU

- Ms. Phan Anh Thy, Site office of ADB section

- Mr. Bui Huu Dung, Site Engineer

3. Representatives of main contractor


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- Mr. Dam Xuan Toan, SMC-C4 manager

- Mr. Le Ngoc Xuan, Safety manager of SMC-C4

- Mr. Pham Thanh Toan, Environment staff of SMC-C4

- Mr. Vo Ngoc Anh, civil engineer of 499 Construction company

- Mr. Nguyen Cong Lam, JO officer

4. Representatives of local government and residents


Table 10. List of local government and residents in public consultation meeting at Binh Khanh commune


1 Huynh Van Thanh Vice president of the commune PC

Binh Khanh commune PC - 0983.098.434

2 Nguyen Hoang Vu Farmer Binh Truong - 0165.956.4707

3 Tran Van Phuc Head of Binh Truong hamlet

Binh Truong – 0165.489.0891

4 Huynh Thien Hoa Farmer Binh Phuoc – 0934.861.299

5 Truong Van Dang Farmer Binh Truong – 0169.3628.744

6 Nguyen Van Hoa Shrimp cultivation 232, Binh Truong – 0938.243.929

7 Nguyen Van Tam Shrimp cultivation Binh Truong – 0961.372.045

8 Huynh Van Sam Shrimp cultivation 291, Binh My - 0902.504.119

9 Duong Van Dau Shrimp cultivation Binh My - 01678.205.234

10 Nguyen Van Lieng Shrimp cultivation Binh My - 0165.411.8368

11 Nguyen Thanh Tam Shrimp cultivation Binh My - 0902.796.494

12 Ho Mong Hai Shrimp cultivation Binh My - 098.7473541

13 Nguyen Van Chinh Shrimp cultivation 65 Binh Truong – 0164.918.6287

14 Nguyen Van Hong Shrimp cultivation 651 Bình Thuận –0169.8028.519

15 Nguyen Van Luom Shrimp cultivation Binh My

16 Tran Van Xay Shrimp cultivation Binh My - 01265.658.579

17 Ho Van Ba Shrimp cultivation 806 Binh My - 0983.242.307

18 Nguyen Dong Long Shrimp cultivation Binh My - 0972.161.890

19 Nguyen Van Tuu President of Binh Khanh Red Cross

Binh Khanh commune PC – 0987.473.471

20 Vo Thanh Liem Vice President of Binh Binh Khanh commune PC –


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Khanh Fatherland Front 01698.519.598

21 Cao Van Gioi Farmer

22 Nguyen Thanh Moi Shrimp cultivation Binh My - 0120.850.4747

23 Trang Minh Tan Shrimp cultivation Binh My - 0976.287.287

24 Nguyen Van Tinh Shrimp cultivation Binh Truong

25 Nguyen Thi Hong Xuan Deputy president of the Women


26 Nguyen Van Dang Head of Binh Phuoc hamlet Binh Phuoc – 0907.993.069

27 Nguyen Van Nhanh President of Binh Khanh Fatherland Front


28 Le Ngoc Ngoi Head of Binh Trung hamlet Binh Trung

29 Nguyen Van Phuoc Deputy Head of Binh Thuan hamlet

Binh Thuan – 0165.478.6329

30 Nguyen Thanh Am Communist Youth Union Binh Khanh commune PC – 0969.204.141

31 Nguyen The Dinh Shrimp cultivation 440, Binh Phuoc

32 Ho Thanh Phương Farmer Binh My

c. Comments from the local government and project-affected people and responses of Contractor

164. In the consultation meeting participants risen their comments, discussion about the environmental issues of the project. Some of them risen complaints on environmental and social incidents caused by the Contractors. All of their comments and complaints are recorded in table 11 below.

Table 11. Comments and complaints of participants in consultation meeting at Binh Khanh commune

No. Name Comments Responses of

Contractor

1 Nguyen Dong Long, Shrimp cultivation , Binh My, 0972.161.890

Local residents can’t access their shrimp ponds due to low temporary bridge. The complaint has not been resolved for a long time.

In this meeting the Contractor did not clearly answered on the comments or complaints of local people.

The Contractor only recorded all comments of the PC and residents and committed to correct the

2 Ho Van Ba, Shrimp cultivation, 806 Binh Truong (0983.242.307)

Farmers can’t cultivate shrimp due to dust, traffic block caused by the project.

3 Nguyen Van Tam-Shrimp cultivation, Binh Truong –

- Dust from batching plant impacts seriously living activities of people living next to the plant.


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0961.372.045 - A hotline must be provided to local government and resident so they can send their complaints directly to the main contractor and EPMU.

incidents.

4 Nguyen Hoang Vu, Farmer, Binh Truong,- 0165.956.4707

Dust from batching plant impacts seriously living activities of people living next to the project.

5 Vo Thanh Liem - Vice President of Binh Khanh Fatherland Front , 01698.519.598

- Contractors should take measures to solve environmental problems in order to minimize the impacts on people's livelihood immediately. - Local residents should show understanding, sharing and collaboration with the construction company and vice versa.

6 Tran Van Phuc, Head of Binh Truong hamlet, 0165.489.0891

- The contractor should plan to minimize dust pollution - The contractor should resolve arisen issues early.

7 Nguyen Van Dang, Head of Binh Phuoc hamlet, 0907.993.069

- Late in resolving complaints from local residents. - The contractor should resolve arisen issues early.

8 Nguyen Van Tuu - President of Binh Khanh Red Cross – 0987.473.471

Many complaints from local residents to the Red Cross. The contractor should verify and resolve arisen issues immediately.

9 Huynh Van Thanh, Vice President of commune PC, 0983.098.434

- Construction of the highway is a national project, it needs support from local residents. - The People’s Committee has received 116 complaints of 188 households. - In 2015, the contractor has completed the compensation for affected households at the temporary bridge area. - Currently, there are 67 cases affected by the Contractor are under consideration by the PC.


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5.2.3. Results of Public Consultation at My Yen, Ben Luc district, Long An province (Packages A1 and A2-1)


a. Time, venue

Time: from 8h30 AM to 11h30 AM, 21st April 2016.

Venue: People’s committee of My Yen commune, Ben Luc district, Long An province.

b. Participants

1. EEMC (VESDEC)

- Mr. Pham Hong Nhat, Environmental expert - K2, EEMC Public Consultation Team Leader.

- Mr. Nguyen Vu Phong, Environmental engineer, supporting staff;

- Ms. Dinh Kim Chi, VESDEC staff.

2. Representative of EPMU

Ms. Phan Anh Thy, Site office of ADB section, in charge of environment management of the project.

3. Representatives of main contractor

- Mr. Le Tien Dan, engineer

- Mr. Tran Ngoc Nguyen, engineer

4. Representatives of local government and residents


Table 12. List of local government and residents in public consultation meeting at My Yen commune


1 Pham Van Hung Farmer, rice cultivation

Hamlet 7A, My Yen – 098.72.82.367

2 Pham Tien Dung Farmer, rice cultivation

Hamlet 7A, My Yen – 0166.875.2550

3 Pham Van Quan Farmer, rice cultivation

Hamlet 7A, My Yen – 0168.730.7659

4 Tran Lu Y Farmer, rice cultivation

Hamlet 7A, My Yen

5 Phan Dinh Phung Head of hamlet 7A Hamlet 7A, My Yen – 0908564819

6 Le Thanh Xang Small enterprise Hamlet 6, My Yen - 0903730017

7 Nguyen Tan Luc Farmer, rice cultivation

Hamlet 6, My Yen – 0908844754

8 Le Thanh Do Small enterprise Hamlet 6, My Yen – 01648870517

9 Tran Thi To Quyen Representative of Hamlet 2, My Yen – 0933991804


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Youth Union

10 Nguyen Mac Trac Farmer Hamlet 7A, My Yen – 0908856412

11 Nguyen Huu Loc Small enterprise Hamlet 7A, My Yen – 0913162360

12 Le Minh Khai Farmer Hamlet 6, My Yen – 0937989258

13 Le Van Bảy Dealer Hamlet 6, My Yen – 0723.648568

14 Le Thị Hong Dealer Hamlet 6, My Yen – 0723.648269

15 Chung Van Len Worker Hamlet 7A, My Yen

16 Nguyen Hoang Son Environment officer My Yen PC - 0933326916

17 Duong Van Du Head of hamlet 6 Hamlet 6, My Yen – 0918172589

18 Duong Thi Nho Dealer Hamlet 6, My Yen – 0723648383

19 Le Van Ngot Farmer Hamlet 6, My Yen

20 Le Van Do Farmer Hamlet 6, My Yen – 0903983150

21 Nguyen Hoang Minh Secretary of hamlet 7A, My Yen

Hamlet 7A, My Yen - 0903857301

22 Do Van Lanh Veteran Hamlet 7A, My Yen – 0909518023

23 Nguyen Van Dang Representative of Farmers Union

Hamlet 7A, My Yen

24 Trương Van Sau President of Fatherland Front of My Yen commune

Hamlet 7A, My Yen - 0909013707

25 Nguyen Thanh Nhan Farmer Hamlet 7A, My Yen - 0909464458

26 Nguyen Minh Chi Farmer Hamlet 7A, My Yen – 01697001269

27 Nguyen Van Pho Farmer Hamlet 7A, My Yen

28 Nguyen Thanh Hien Farmer Hamlet 7A, My Yen – 01686232487

29 Tran Thi Le Farmer Hamlet 7A, My Yen - 098906062

30 Nguyen Thi Thu Loan Farmer 57A2, Hamlet 7A, My Yen – 0934173486

31 Huynh Thanh Phong Cadastral officer My Yen PC – 0972141628

32 Nguyen Thai Hoc Officer of My Yen PC

My Yen PC

33 Pham Duy An President of My Yen PC

My Yen PC


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c. Comments from the local government and project affected people and responses of Contractor

166. In the consultation meeting participants risen their comments, discussion about the environmental issues of the project. Some of them risen complaints on environmental and social incidents caused by the contractors. All of their comments and complaints, but also responses from the Contractor are recorded and given in table 13 below.

Table 13. Comments and complaints of participants in consultation meeting at My Yen commune

No. Name Comments Responses of Contractor

1 Le Van Ngot - Hamlet 6, My Yen -

- Trucks caused too much dust, road damage. The contractor must repair the road. - Barriers impact vision, can cause traffic accidents - No watering caused dust but watering caused slippery, can cause traffic accidents. - The project sub-contractors sold spoil for money, not transport to the disposal area. - Pumping sand: salt water spills into the field of farmers, affecting their crop. The contractor must pay compensation for farmers.

- The contractor has installed 10 km/h limit speed signs to reduce vibration. Trucks have been required to be attached with nameplate, project signs. If drivers violate the rules, they will be fined and/or forced to stop operating. A number of drivers have already been fined for their violation.

- Recently, water spraying from 6-8 times/day, but it can no way to completely stop all dust. - Contractors have installed 2 (two) billboards to show the project information with a hotline, so local people can inform contractors when they have complaints, thereafter the contractor will try to resolve it soon.

- The contractor has 02 disposal sites and has never sold the excavated soil. If any evidence of selling excavated soil occurs (by subcontractors), please immediately inform the main contractor and/or the PMU.

- Pumping sand: if such situation occurs, please immediately inform the main contractor and request for compensation.

2 Le Van Do - Hamlet 6, My Yen - 0903983150

- Serious dust pollution caused by spoil transport. - Watering caused slippery. - The contractor should level the road with stone. - Construction of the project

- Recently, water spraying from 6-8 times/day, but it can no way to completely stop all dust, expecting sympathy from local residents. - Power lines on the surface of the field: the main contractor will soon inform the subcontractor for a proper


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made cracks of the walls of 2 households in Hamlet 6. Compensation is requested. - VinaConex, the contractor, have placed electric cable on the field without warning sign.

action; - No answer on cracks of the walls of 2 households.

3 Do Van Lanh - Hamlet 7A, My Yen- 0909518023

- Deep hole dug by contractors can cause drowning during the rainy season; fencing, warning signs are requested. - Overloaded vehicles impact local traffic - Pumping sand: salt water spills into the field of farmers, affecting their crop.

No answers were given by Contractor on the first two comments; - Pumping sand: if such situation occurs, please immediately inform the main contractor and request for compensation.

4 Nguyen Minh Chi– Hamlet 7A, My Yen- 01697001269

- Construction of the project caused water logging. Winter-spring crop is also affected, some farmers had to seed 2-3 times. - Construction of the culvert made deep hole. But the contractor did not notice, no warning signs, no barriers, caused accident to Mr. Chung Van Len - Hamlet 7A (ligaments broken). The contractor paid a compliment to him but not satisfactory compared to his loss. - Pumping sand: salt water spills into the field of farmers, affecting their crop. Compensation is requested.

No answers were given by Contractor on the first two comments. - Pumping sand: if such situation occurs, please immediately inform the main contractor and request for compensation.

5 Pham Đinh Phung - Hamlet 7A, My Yen-0908564819

- The contractor arbitrarily moves graves. The local government and related households did not know about it. - Please completely repair the public road.

No answers were given by Contractor on these 2 comments

6 Nguyen Hoang Minh- Secretary of Hamlet 7A, My Yen

- There are over 40 graves in Hamlet 7A within the project site. The contractor must have a plan to move them. - Construction caused damage

- The main contractor also required subcontractors to keep sanitation and traffic control at the intersections, however, it was done not well enough at


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to the road at canal bank at Hamlet 7A, but the contractor did not repair, yet. - The contractor sold dredged soil for illegal money, - Invest some public works for local residents is required. - The batching plants caused too much dust.

the intersection of Hamlet 7A.

- The contractor has 02 disposal sites and has never sold the excavated soil. If any evidence of selling excavated soil (by subcontractors) occurs, please immediately inform the main contractor and/or the PMU.

- No answers on the last two comments.

7 Ngo Tho Ngoc An- Hamlet 7A, My Yen

- Noise affects quail breeding activity: growth retardation, premature birth. - Not enough light at the intersection. - Trucks caused electric wires broken - Trucks caused noise, vibration, house crack - Public order at the project at night is very bad.

- For the honk affect quail farming, the contractor expect sympathy from the PAHs because at intersections the trucks have to honk in order to prevent traffic accidents.

- Power lines on the surface of the field: the main contractor will soon inform the subcontractor for a proper action; - The contractor will request the subcontractor to install two additional lights at the intersections.

8 Duong Van Du - Hamlet 6, My Yen

- The contractor did not pay clearance fee for the local residents to move graves. - There are 10 households having no way to travel due to obstruction of construction activities. - Batching plant causes a lot of dust.

No answers were given by Contractor on these 3 comments.


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CONCLUSIONS AND SUGGESTIONS 1. CONCLUSIONS

From the above results of environmental monitoring at the EPMU, CSCs and 7 construction packages obtained by EEMC in March and April 2016 the following conclusions may be given.

1. The EMP in the EIA report cleared by ADB (2010) and Vietnam legal environmental regulations were used as basic documents for evaluation/assessment of compliances of the Ben Luc - Long Thanh Expressway Project Management Unit (EPMU), Construction Supervision Consultants (CSCs) and construction contractors with the requirements of ADB and Vietnam in pollution control and environmental protection in the construction stage of the Project.

2. To properly assess compliance of the contractors with the EMP requirements appropriate method and environmental compliance classification system for environmental monitoring were developed and applied by the External Environmental Monitoring Consultant (EEMC). Based on the method and compliance classification system all environmental issues required in the EMP were monitored and clearly assessed at 7 construction packages although the time for field visits were short. This compliance classification system is suggested to be applied also by CSCs during their regular environmental monitoring/supervision.

3. The monitoring results indicate that at present (March 2016) EMPU activities complied with the main EMP’s requirements in organization of environmental management system and in environmental management. However, in the coming months with increased construction activities number of environmental officers and their knowledge and experiences in environmental management should be improved by increase of environmental and safety management staffs and by implementation of short-term environmental management training programs. Additionally, data base related with environmental monitoring and management of the Project should by well managed.

4. CSCs have implemented various good activities in environmental monitoring and supervision:

(i) Organization system in environmental management for JICA and ADB sections is suitable for regular environmental and safety supervision for all packages.

(ii) Almost all the tasks given in the TOR in the Contract with VEC for environmental monitoring were implemented and many their activities in environmental supervision complied with the tasks given in TOR in the Contract with Vietnam Expressway Corporation (VEC).

(ii) However, efficiencies of CSCs monitoring were not high, for example, various environmental infringements of the contractors and adverse impacts on local communities caused by construction activities at many packages were not noted and indicated in the quarterly monitoring reports; no any strong measures, suggested by CSCs to EPMU on punishment to the contractors who repeatedly violated the environmental requirements in EMP an CEMP; and so far, CSCs still did not implement a task “Set up an unit/mechanism to monitor and inform the environmental issues to the affected communities; this unit shall guide local residents to participate into environmental supervision and environmental management implemented by the contractor” required in the Contract with VEC.

5. From results of checking documents and field visits to 7 construction packages it may indicate that, in general, the contractors has so far been complying with many environmental requirements in the EMP included in the EIA, approved by MONRE and cleared by ADB (in 2010). The contractors have implemented various measures for impact mitigation, pollution prevention and waste management. Most of the implemented measures (over 70% of the total measures required to be applied in the EMP) complied with the EMP. However, environmental infringements (non-compliance) were evidently


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found at all packages. Most of infringements are minor, but some of them are major. The major infringements mainly related to the improper disposal of spoils, causing damage of rice field; damage of public roads; no segregation of hazardous and non-hazardous wastes; poor management of hazardous wastes; and serious dust pollution at the access roads closed to residential sites. All minor and major infringements at each package are clearly shown in Part Four and appendixes 1 -7 in this report. 6. It may found that all contractors did not prepare a grievance redress mechanism (GRM) following the ADB requirement. GRM is very good tool for receiving comments and complaints from local residents and for complaining resolution of the contractors and EPMU. Therefore, EPMU should ask the contractors to immediately prepare GRM. CSCs may help contractors in GRM preparation and implementation.

7. During the field visits and in this report EEMC has suggested requirements on corrected measures with each package/contractor and asked them to implement immediately and duration for completion of correction was proposed. Rapidly responding to the EEMC’ verbal recommendations some contractors have implemented proper measures for remediation of some their infringements.

8. In comparison of 7 main contractors of 7 construction packages, in the monitoring time (March 2016) environmental management conducted by the contractor of Packages J2 (JO of Sumitomo Mitsui – CIENCO4) was better than the others. A good example: this contractor (and contractor of Package A3) have immediately corrected various infringements only 10 days after receiving verbal requirements from EEMC. That are good lessons for other contractors

2. SUGGESTIONS

1. CSCs should carefully consider the EEMC’ evaluations on their environmental management to correct all non-compliance activities and effectively improve their measures in environmental monitoring, so that the project construction would not cause significant environmental and social impacts.

2. EPMU, CSCs and contractors should carefully consider the EEMC evaluation on compliance and infringements of 7 construction packages with the EMP and Vietnam environmental protection requirements. CSCs and EPMU should require the contractors to immediately implement the corrected measures indicated by EEMC and supervise their correction activities.

3. CSCs must suggest to EPMU a regulation for punishing contractors who caused major infringements but without proper correction and EPMU should implement penalty for the major infringements.

4. Based on the practical construction conditions EEMC suggests that at some packages various measures required in the EMP (2010) are not necessary or must be revised. For examples, measures for mangrove replanting are not needed for packages A1, A2-1, A2-2, A3, A4 because of no mangrove forests in the areas of these packages; distance of 300 m from a batching plant to residential site is not practical at the West Sections (from district of Ben Luc to Nha Be) because of dense population; or meeting with local PCs and residents twice/month can’t be implemented by contractors, they can have meeting with a frequency of 1 or 2 months/time, etc.

5. In the Contract of Package C-2 between VEC and EEMC (Institute for Environmental Science and Development, VESDEC) time of only 1.0 month (30 calendar days) for external environmental monitoring activities, included meetings with EEMC, CSCs, seven contractors, checking their environmental & safety management and monitoring reports, field visits to various sites at 7 packages, public consultation meetings at some communes and especially report preparation & revision in


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English and Vietnamese, is too short. In fact, in the second mobilization (March and April 2016) EEMC have spent over 2.0 months for implementation of the above mentioned activities, excepted over 10 days for revision of the report of over 320 pages, following the ADB comments. Therefore, EEMC strongly asks ADB and VEC from 2017 to revise the Contract to increase time for external environmental monitoring to minimum 2.0 month/year. This is a reasonable duration for proper implement all activities required by ADB in external environmental monitoring for EPMU, CSCs and 7 – 9 construction packages in the coming years.

6. EEMC (VESDEC) has very actively and successfully implemented its task in the first mobilization (in 2015) and the second mobilization (2016). In September 2015 the external environmental monitoring report for 2015 had been accepted by VEC and ADB. VESDEC has expensed a lot of money for monitoring activities in the first and second mobilizations. Documents for remuneration and other expenses were prepared following the guidelines of EPMU and VEC, But so far, VEC / ADB did not provide any payment, even for the completed first mobilization (2015), this causes very financial difficulty for VESDEC. Therefore, VESDEC strongly requires VEC / ADB to follow the payment condition agreed in the Contract N 62/HDTV-VEC/2014 signed in October 2014 with VESDEC. This requirement should be fairly considered by VEC and ADB so that the external environmental monitoring could be well implemented in the next mobilizations.


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COMMENTS OF ADB ON EXTERNAL ENVIRONMENTAL MONITORING REPORT, 2016 AND RESPONSES BY EEMC On 18 September 2016 after 3 months from the day EMMC submitting the revised external environmental monitoring report to EPMU ADB environmentalists have sent General Comments and detailed comments/answers on chapter by chapter of the EEMC report. Strictly considering the comments and questions EEMC has carefully revised all paragraphs where there are ADB comments and added various new items. The revised words and paragraphs in all pages of the report and appendixes are highlighted in red color. Table 14 indicates the ADB general comments and responses of EEMC.

Table 14. ADB general comments on the external environmental monitoring report and responses of EEMC N General Comments of

ADB Responses of EEMC At pages

1 The quality of the report

should be further improved. Some parts are difficult to understand. The way it is presented is not systematic like in the section on public consultation, wherein there are two separate tables for the information on the complainants and their complaints. Additional paragraphs are provided for the response of contractors/CSC/EPMU. A single matrix would have been more effective.

- The report has carefully revised, corrected and a lot of new items, evaluations were added, to get the best quality, as possible. All comments and questions from ADB specialists to all parts of the report were revised and answered as clear as possible, - A single matrix was prepared to more clear indicate the comments/complaints of local residents and responses of the contractors

- Please see the revised sentences and paragraphs in red color at all parts. - Please see tables 9, 11 and 13, Part Five.

2 The revised report should use paragraph numbers for easy tracking of comments

The revised report used paragraph numbers for easy tracking of comments

Please see all pages of the revised report.

3 There are inconsistences in the report, such as the number of national environment specialist(s)

All comments of ADB on inconsistences in the report and conflicting observations on the EMP implementation compliance matrix in appendixes were revised and corrected.

Please see all pages of the report and all


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and conflicting observations on the EMP implementation compliance matrix. These should be corrected.

appendixes,

4 Among the major issues that need to be addressed immediately are:

(i) Batching plants that are located <300 m from residential areas contrary to EMP requirements. There are already complaints from residents in package J2 while no assessment was made on other packages because the plants were not operating during EEMC inspection. EEMC should have interviewed residents in these packages.

As indicated above distance of 300 m from a batching plant to residential area is not practical. This requirement should be revised. In case of location is less than 300 m, to minimize noise and dust dispersion to residential area the main measure are installation of thick brick or concrete walls with appropriate height and technical measures for noise and dust reduction at the batching plant should be applied by the contractors . In fact, there are already complaints from residents in package J2. At other packages A1, A2-1, A2-2 in March 2016 EEMC has interviewed the householders living closed to the plants but the answers from them were: “no serious noise and dust pollution”. Dust and noise pollution caused by batching plants should be monitored regularly by CSCs and by the Effect Environmental Monitoring Consultants to get more clear evaluation.

See Part Four and Appendixes 1-7.

(ii) The absence of a grievance redress mechanism (GRM) in almost all packages. This is also a major EMP requirement. The contractors with the assistance of CSC and EPMU should immediately organize this.

In this revised report has required the contractors to immediately prepare and disclose grievance redress mechanism (GRM)

See sections 4.1.4, 4.2.4, 4.3.4, 4.4.4, 4.5.4. 4.6.4 and 4.7.4 in Part Four and above Part “Conclustions”.

(iii) It is noted that many complaints remain unresolved. Among these are improper spoils

It is noted that many complaints remain unresolved. It is indicated in the EEMC report. They should be immediately solved by the contractors with strict supervision of

See sections 4.1 to 4.7 in Part Four,


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disposal and storage, causing adverse effects to agricultural and aquaculture land and damage to access roads.

EPMU and CSCs. EEMC has asked CSCs to help EPMU to prepare a regulation for penalty and EMPU must implement penalty to the contractor(s) who have major infringements but no proper correction. .

and above Part “Conclustions”.

(iv) Some observations in the matrix only relied on what the contractor told EEMC. No validation was made.

Yes, some observations in the matrix only relied on what the contractor told EEMC because time for external monitoring for each package was very limited. But many observations were confirmed by checking the monitoring reports provided by EPMU, CSCs and contractors and by public consultations. Main important information were collected by EEMC from direct observations/photos at the construction sites, worker camps and access roads. Therefore, EEMC believes on its evaluations on the state of environmental management of each package.

Please see the selected photos in appendixes and reports on environmental management and environmental monitoring of the contractors and CSCs.

(v)Some recommendations have no implementation deadline.

In the revised report deadlines for almost all required corrective measures were given. For measures for correction of some major infringements no deadline but “immediately implement” was required.

They may be found in Part Four and appendixes 1 to 7.

5 Specific comments on the report are provided on the following pages. Some comments are in the form of questions and EEMC should provide answers in the revised report. Please note that comments for similar mitigation measures are applicable to all packages.

All ADB specific comments provided on all parts and all pages of the report and appendixes were carefully considered and revised. All question were answered as clear as possible. Comments on mitigation measures for all packages were revised. Meaning of compliance, minor infringement, major infringement; quantified indicators for evaluation of levels of infringement are identified in Section 1.2.2.5 and tables 4 and 5, Part One.

- Please see all your comments and according EEMC revisions in all parts and appendixes. - Section 1.2.2.5 and tables 4 and 5, Part One.


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APPENDIXES: ASSESSMENT OF COMPLIANCES OF THE CONSTRUCTION CONTRACTORS WITH THE EMP REQUIREMENTS The appendixes indicate results of assessment on the compliance (as classified in Section 1.2.2.5 “Classification of Environmental Compliance of the Contractors” in this report 3 levels of compliance, minor infringement, major infringement are applied) of the contractors with the requirements in the EPM approved by ADB in 2010. Basics for assessment on the level of compliance are (a) the state of environmental management observed by EEMC during its field visits at each package; (b) comments for local residents from public consultation meetings or interviews during the field visits and (c) comparison with the definition of compliance, minor infringement, major infringement in Tables 4 and 5 in Part One. Meaning of compliance, minor infringement, major infringement is identified in Section 1.2.2.5 and the above tables.

This procedure of classification of compliance levels was applied in the external environmental monitoring report in 2015, which was cleared by ADB.

Because time for EEMC for external monitoring for 7 construction packages is only 30 days, included a lot of monitoring activities and report preparation, time for field visits were limited, therefore, very clear assessments is impossible. However, the rapid assessment and classification of levels of compliance for each contractor may help VEC/EPMU in the project environmental management and the contractors in correction of their infringements to comply with the Vietnam and ADB requirements in environmental protection during the construction stage.

APPENDIX 1: ASSESSMENT OF THE COMPLIANCE OF CONTRACTORS OF PACKAGE A1 WITH THE EMP REQUIREMENTS

Project activities

(1)

Potential Environme

ntal Negative Impacts

(2)

Proposed Mitigation Measures in EMP and approved by ADB

(3)

Location (4)

Level of Compliance Assessed by

EEMC (5)

CorrectionActions

Proposed by EEMC

(6)

1.Environmental protection requirements in the contract

1. Prior to commencement of any site works, each contractor shall prepare a site-specific or construction EMP (CEMP) which specifies the responsibilities, location associated costs, schedule/timeframe and other relevant information for implementing its provisions which will include the following: (i) selection of sites for material exploitation and storing, as well as sites for concrete, crushing and asphalt plants, (ii) plans for material transportation routes and timing, (iii) identification of specific disposal sites for unsuitable soils,

Project office of contractor

Construction Environmental Management Plan (CEMP) was prepared by Contractor and approved by Consultant (KEI-NE-OC-TEDI JV). Construction Environmental Management Plan (CEMP) report is being considered by


79

Project activities

(1)

Potential Environme


(2)


(3)

Location (4)


EEMC (5)

CorrectionActions

Proposed by EEMC

(6)

(iv) soil erosion control measures including soil stabilization measures at disposal sites, (v) treatment of acid sulfate soils and resulting run-off, (vi) wastewater collection and treatment, (vii) construction camp management, (viii) quarry/aggregate/borrow site management and restoration, (ix) traffic management, (x) noise reduction measures including construction of temporary noise barriers, (xi) dust suppression measures, (xii) handling and storage of hazardous substances such as fuel, etc. (xiii) solid waste collection and disposal, (xiv) replanting measures, (xv) occupational and community health and safety, (xiv) repair of damaged community facilities such as irrigation canals, etc. (xvii) emergency response plan in case of spills and other accidents involving workers and the community, (xviii) chance-find procedures measures and other applicable mitigation measures indicated in the Project EMP included in the EIA approved by ADB. The CEMP should be fully consistent with the Project EMP. Before civil works begin, the CEMP shall be reviewed by the Project Supervision Consultant and endorsed to ADB.

ADB. (CEMPs for Packages A1, A2-1. A2-2, A3, A4, J2 and J3 were submitted by EPMU to ADB on 25th January 2016) Compliance

2. Cutting down vegetation

Biological waste disposal can pollute the water, obstructing navigation,

2. Prohibit disposal of cut vegetation into canals, rivers and other water courses.

Project sites All measures in third column were implemented by Contractor of Package A1.

3. Collect vegetation wastes (tree trunks, branches etc.) and give away to local residents as needed.


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Project activities

(1)

Potential Environme


(2)


(3)

Location (4)


EEMC (5)

CorrectionActions

Proposed by EEMC

(6)

aesthetic. Compliance 4. Burn the cut trees in accordance with national and local regulations, and only in limited cases with strict conditions (less than 100 kg at a time; more than 500m from residential areas and other sensitive receptors such as schools, hospital, culturally significant sites, etc. and fuel storage sites, 200 m from worker camps; with available and sufficient fire prevention devices and manpower for fire extinguishing and ensuring that surrounding vegetation are protected from fire; will not cause nuisance and safety risks to sensitive receptors (houses, schools, etc.) and road users in the surrounding areas.)

2. Cutting down vegetation (as above)

Reduce the area of vegetation, damaging wetland ecosystems.

5. Prohibit vegetation clearing outside the project’s ROW

Outside the project’s ROW

Not detected vegetation clearing activities outside the project’s ROW. Compliance

6. Design viaducts to go over the mangrove areas at the Eastern bank and the Western bank of the Soai Rap river; the Western bank and the Eastern bank of the Long Tau river and at the Eastern bank of the Thi Vai river

Project site under Package A1.

In Package A1 there is not mangrove forest, so that this measure is not necessary.

7. Implement a Mangrove Reforestation Plan (MRF) to replant mangroves for compensation of the lost mangrove area at river, canal banks due to site clearance

Project’s riverside

Mangrove Reforestation Plan (MRF) is not necessary because in Package A1


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Project activities

(1)

Potential Environme


(2)


(3)

Location (4)


EEMC (5)

CorrectionActions

Proposed by EEMC

(6)

(mainly at river, canal banks in Nha Be, Can Gio, Nhon Trach, Long Thanh districts). Detailed MRF is found in Section V.B.2. of the EIA Report.

there is not mangrove forest

3. Worker camp

Generation of domestic solid waste, causing land, water, air pollution and adverse effects on public health.

8. Implement proper solid waste management through implementation of the following measures: (i) Prohibit burning of construction and domestic wastes. (ii) Do not permit disposal of solid wastes into canals, rivers, other watercourses, agricultural field and public areas. Disposal shall only be to areas approved/licensed by local authorities. (iii) Properly collect and segregate domestic wastes at worker camps and offices. Use rubbish bins for containing domestic solid wastes. (iv) Sign contract with local environmental service units for regular transport (weekly) of solid wastes to disposal sites. (iv) Ensure that wastes are disposed to sites approved by local authority. (iv) Use of pits with proper lining for disposal of domestic solid wastes. Location of the pits shall be over 200m from residential sites and over 100m from workers’ eating area. Before the team moves to a new construction site, trash pits shall be disinfected with lime or hypochlorite solution, then firmly covered with a 20 – 30 cm layer of soil.

Worker’s camp (Bridge Construction Joint Stock Company No.75)

8th measure was implemented. Compliance

Sanitary wastes (sewage)

9. Provide efficient and clean mobile toilets for each construction site (separate

Project site - Use two-compartment septic tank to

- Toilet as well as bathing


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Project activities

(1)

Potential Environme


(2)


(3)

Location (4)


EEMC (5)

CorrectionActions

Proposed by EEMC

(6)

from workers, causing water, air, land pollution, and diseases.

facilities shall be provided for male and female workers).

replace for mobile toilets. - There is a toilet for female workers but it is not separated with male workers. - Washing and bathing areas are not separated for male and female workers. Minor infringement

area must be separated for male and female workers. - Contractor should implement before June 30th, 2016.

10. Alternatively, install sanitary 2-chamber septic tanks toilets for each construction team of 50 - 100 workers.

Project site

11. At worker camps located far (over 500m) from residential areas, bench latrines may be installed. Latrines should be located over 100m from living places and 50 m from canal, river. Daily use lime for disinfection. Well fill up and disinfect before moving the camp to other site.

Worker’ camp (Bridge Construction Joint Stock Company No.75)

12. Provide clean water for hand washing at each toilet area. Provide sufficient water for bathing and sanitation purposes. Separate toilets/bathing areas shall be provided for male and female workers.


13. Provide rubbish bins in toilet area for collection of used sanitary paper.


Toilets areas are not provided rubbish bins for collecting of used sanitary paper. Minor infringement

Contractor should: - Provide rubbish bins for collecting of used sanitary paper at toilet areas. - Implement


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Project activities

(1)

Potential Environme


(2)


(3)

Location (4)


EEMC (5)

CorrectionActions

Proposed by EEMC

(6)

before June 30th, 2016.

Conflict between workers and local residents and community disturbance

14. Employ, as much as possible, local people as construction workers and prioritize opportunities for the PAHs. Implement suitable training programs for local workers.

Project communes (My Yen, Ben Luc, Long An).

There are local employers. There is no conflict between the workers and the local population and no disturbance of community. Compliance

15. Organize orientation/training for workers, particularly for those from other provinces on maintaining good relationship with local residents. Educate workers on morality, avoiding alcoholism, gambling etc.

Project communes

15th measure was not implemented. Minor infringement

Contractor should organize orientation and training for workers before June 30th, 2016.

16. Establish a grievance redress mechanism (GRM), well guide local residents to apply GRM; provide local communities information on upcoming construction activities; record any complaints received and respond to them based on the GRM, properly cooperate with local PCs, DONREs, social associations to properly solve claims of the PAHs and problems related to environmental issues related to the project.

Project communes

- Grievance redress mechanism (GRM) is not established. - Project information boards are installed at the construction site. In that, supply to local people information about Employer, Consultant and Contractor units and hotline to receive complaints and grievances of

Contractor should establish a grievance redress mechanism (GRM) and submit Consultant before June 30th, 2016.


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Project activities

(1)

Potential Environme


(2)


(3)

Location (4)


EEMC (5)

CorrectionActions

Proposed by EEMC

(6)

local authority and local residents. Minor infringement

17. Regularly inform in advance the local PCs and local residents on the location and schedule of construction activities which may cause impacts on the environment and life of people (e.g., road sections to be constructed; roads used for transport, locations of worker camps etc.)



18. Undertake regular meetings (e.g., twice a month) between contractor and Commune PCs on matters that may affect local residents such as presence of workers, construction activities and schedule, etc.


Participate in meetings with local authority and local residents about related issues. But no regular (twice/month ) meeting Minor infringement

Transmission of infectious diseases from local people to workers and vice versa and other health and safety issues.

19. Conduct orientation for construction workers regarding health and safety measures, emergency response in case of accidents, fire, etc., and prevention of HIV/AIDS and other related diseases.

Project communes.

Conduct orientation for workers regarding health and safety measures, emergency response in case of accidents, fire, etc., Prevention of HIV/AIDS were

- Prevention of HIV/AIDS program was sent by the Contractor to EPMU and waiting for approval. After that,


85

Project activities

(1)

Potential Environme


(2)


(3)

Location (4)


EEMC (5)

CorrectionActions

Proposed by EEMC

(6)

not fully implemented. Minor infringement

Contractors have to implement this program.

20. Provide workers with clean and safe food supply and potable water supply in sufficient amount.


Clean and safe food supply and potable water supply in sufficient amount were provided for workers. Compliance

21. Provide large - sized rubbish bins at construction sites and worker camps and weekly transport (by local environmental service unit) to district's treatment sites.

Project site and worker’s camp (Bridge Construction Joint Stock Company No.75)

21st measure was implemented. Compliance

22. Ensure cleanliness of work sites and camps, and undertake proper maintenance of sanitation facilities. Implement measures to avoid proliferation of disease vectors such as flies, mosquitoes, rats, etc.

Worker’s camp and construction site (Bridge Construction Joint Stock Company No.75)

Measures to avoid proliferation of disease vectors such as mosquitoes were not implemented. Example: In front of worker’s camp, there is a pond of stagnant water where is a favorable environment for the reproduction

Contractors should install a drainage system and clean stagnant water pond in front of the worker camps before June 30, 2016.


86

Project activities

(1)

Potential Environme


(2)


(3)

Location (4)


EEMC (5)

CorrectionActions

Proposed by EEMC

(6)

and development of mosquitoes. Minor infringement

23. Provide first-aid facilities and fire-fighting equipment at appropriate areas within the the construction site and workers camps.


23rd measure was implemented. Compliance

24. Provide clean eating and cooking areas



25. Install sign boards, lighting system at the construction sites, borrow pits, or places which may cause accidents for people and workers.

Project site Lack of danger warning signs at some deep holes, lack of safety lines or safety lines is unclear at some of construction sites. Minor infringement

Contractor should install and repair danger warning signs, safety lines at the construction sites. - This should be implemented before June 30th, 2016.

26. Provide drainage at construction sites and workers camps to prevent water logging/ accumulation of stagnant water and formation of breeding sites for

Worker’s camp and construction site (Bridge Construction

Lack of drainage system at worker’s camp of Bridge

Contractor should install drainage system at


87

Project activities

(1)

Potential Environme


(2)


(3)

Location (4)


EEMC (5)

CorrectionActions

Proposed by EEMC

(6)

mosquitoes. Joint Stock Company No.75)

Construction Joint Stock Company No.75. Minor infringement

worker’s camps before June 30th, 2016.

27. Provide adequate housing for workers at the construction camps.



4. Construction of road embankment, access roads, borrow pits, and auxiliary facilities (excavating, filling cutting activities, material transport):

Storm water from construction sites, improper stockpiling of spoils and construction materials, haphazard spoils disposal, soil erosion and land slide at construction sites, causing damage to roads, polluting of canals, rivers and pond; and obstruction of flow of

28. Ensure proper design of road embankment so that soil storm water could be well controlled; erosion and land slide could be minimized.

Project site

Contractors reported that the design of road embankment is good for erosion and storm water control. This was confirmed by CSC. Compliance

29. Maintain and replant mangroves along rivers, canals for erosion control.

Project site

This measure is not necessary because Package A1 there is not mangrove area.

30. (i) Provide grass cover and other suitable slope stabilization measures on road embankment slopes and on long term stockpile of spoils. (ii) Spoil disposal shall not cause

Project site (Ong Thoan viaduct construction site)

- Excavated soil with bentonite arising from bored pile process has not been collected and properly

- Excavated soil with bentonite must be contained in tankers with


88

Project activities

(1)

Potential Environme


(2)


(3)

Location (4)


EEMC (5)

CorrectionActions

Proposed by EEMC

(6)

water courses.

sedimentation and obstruction of flow of watercourses, damage to agricultural land and densely vegetated areas. (iii) The spoils disposal site shall be located at least 50 m from surface water courses and shall be protected from erosion by avoiding formation of steep slopes and grassing. (iv) Spoils shall only be disposed to areas approved by local authority. (v) Water courses (rivers, canals, etc.) shall be kept free of excavation spoil and construction debris, floating and submerged. (vi) Spoil and construction materials stockpile area shall be located away from water bodies and under no circumstances will these materials be dumped into watercourses. (vii) Dredged and excavated materials shall be reused or provided to local residents as soon as possible, if they require such materials, for land reclamation. The remaining spoils can be disposed into low elevation sites for road construction. (viii) Provide temporary sediment traps (ditches and ponds) if high sediment laden runoff are observed.

disposed but was discharged directly into the ground near Ong Thoan canal. Minor infringement

waterproof, then dried and transported to disposal area where approved by local authorities. - Contractor should implement before June 30th, 2016.

31. Design and install culverts and drainage systems to avoid flooding

Project site (Ong Thoan viaduct construction site)

Culverts and drainage systems at Ong Thoan viaduct construction site were installed.


89

Project activities

(1)

Potential Environme


(2)


(3)

Location (4)


EEMC (5)

CorrectionActions

Proposed by EEMC

(6)

Compliance

Activities at borrow pits may cause environmental pollution, soil erosion, damage local natural habitats, agricultural production, residential, commercial, cultural sites, and safety problems.

32. (i) Select proper places for setting up borrow pits to avoid areas of serious acid sulfate and saline soils and to avoid encroachment into forest, cultivation, commercial and residential areas. Borrow sites shall be covered by necessary environmental permits/licenses and shall be located over 300m away from residential, commercial, cultural sites and other sensitive receptors (schools, hospital, etc.). (ii) Proper soil erosion control during borrow pits construction and operation by proper design and installation of adequate drainage system. (iii) Proper control of storm water at borrow sites in the rainy season by using sediment traps, treatment of turbidity, strong acidic water (by lime) and oil separation water if high turbidity, high acidity or high oil content were found. (iv) Proper dust control during dredging, excavation at borrow sites and earth transport. (v) Topsoil (about 15 cm) will be kept and refilled after excavation is over. (vi) Long – term material stockpiles will be covered to prevent wind erosion. (vii) Upon completion of extraction activities, re-contour borrow/quarry pit wall or fill-up when there are available and suitable materials such as

Borrow areas Up to now, there are not any operation of borrow pits at Package A1 area.


90

Project activities

(1)

Potential Environme


(2)


(3)

Location (4)


EEMC (5)

CorrectionActions

Proposed by EEMC

(6)

excavation spoils , replace topsoil, and re-vegetate with native species such as grasses and fast-growing shrubs. (viii) Quarries and borrow pits will not be established in national, provincial, district and village conservation forests and other protected sites. (ix) Operation of existing quarry/borrow sites shall be preferred over establishment of new sites, as much as possible. (x) In case the Project will involve new quarry/borrow sites, necessary approvals from environmental authorities shall be obtained prior to operation of such sites. (xi) During borrow site operation, provide adequate drainage to avoid accumulation of stagnant water. (xii) Borrow/quarry sites shall not be located in productive land and forested areas. (xiii) Upon completion of extraction activities, borrow pits shall be dewatered and fences shall be installed, as appropriate, to minimize health and safety risks. (xiv) Borrow pits will be left in a tidy state with stable side slopes and proper drainage in order to avoid erosion. (xv) To avoid drowning when pits become water-filled, measures such as fencing, providing flotation devices such as a buoy tied to a rope, etc. shall be implemented. (xvi) It is possible that villagers


91

Project activities

(1)

Potential Environme


(2)


(3)

Location (4)


EEMC (5)

CorrectionActions

Proposed by EEMC

(6)

may request borrow pits to be excavated so that they may be used as water reservoirs or fishponds. If this were to be agreed between the contractors and the villagers, all the full safety measures detailed above must be observed. Such agreements would be formalized in writing between the contractors and the villagers after full discussion with all concerned parties.

Noise and vibration pollution, affecting public health

33. No noisy construction-related activities (e.g., construction works, piling, use of jackhammer, transport of materials along residential areas and other sensitive receptors, piling, etc.) will be carried out during night-time (10PM-6AM) near sensitive receptors (residences, hospital, etc.). As much as possible, locate high vibration generation sources over 50m from residential sites, offices, buildings, etc.

Construction site

Complaint on noise and vibration affecting living of people, was given by local residents (this was recorded in public consultation at My Yen Commune, April 2016). Minor infringement

Contractor must implement appropriatemeasures for noise and vibration control during operation of heavy machines at the residential areas.

34. Concrete mixers and asphalt stations shall be covered by necessary environmental permits/licenses and shall be established at least 300 m from residential areas, hospital, schools and other sensitive receptors. The distance ensures that the impacts of dust emissions, noise and offensive smells on residential areas are minor.

Concrete batching plant (Bridge Construction Joint Stock Company No.75)

- Concrete batching plant is located near residential area. However, up to now, there are not any complaints from local residents regarding operation of concrete batching plant. - Environmental

- Contractor has to finish environmental permits of concrete batching plant as soon as possible.


92

Project activities

(1)

Potential Environme


(2)


(3)

Location (4)


EEMC (5)

CorrectionActions

Proposed by EEMC

(6)

permits/licenses: pending Minor infringement

35. Inform in advance local residents on time/schedule and plan of construction activities.

Construction site


36. Impose speed limits on construction vehicles to minimize noise emission along areas where sensitive receptors are located (houses, schools, hospitals...).

Project site 36th measure was implemented. At this Package no complaints of local residents about noise pollution caused by trucks. Compliance

37. Proper organization of construction plan, so that the loud noise generation machines would not operate during 10PM to 6AM at residential areas.

Construction site

Complaint about noise pollution during night time is recorded. Minor infringement

Contractor should properly organize construction plan, so that the loud noise generation machines would not operate during 10PM to 6AM at residential areas

38. Install noise control walls (3.0-4.5m high, thick materials) at high

Construction site

- Lack of noise control walls at many places

- The contractor should


93

Project activities

(1)

Potential Environme


(2)


(3)

Location (4)


EEMC (5)

CorrectionActions

Proposed by EEMC

(6)

noise sources that affect sensitive receptors (temples, pagodas, churches, schools).

along construction sites. - At the places, where noise control wall installed, the high of noise control walls is only about 2 meter. Minor infringement

install and improve noise control walls to meet the requirement(3.0-4.5m high, thick materials) at sensitive areas. - Contractor will implement before June 30th, 2016.

39. Ensure that operation of trucks and other construction equipment and vehicles do not create high noise levels during movement through densely populated areas.

Project communes.


40. Undertake regular maintenance of vehicles and construction machines.

The maintenance of vehicles and construction machinery is done regularly. Compliance

41. Provide workers near sources of loud noise with protection devices such as ear plugs.

Construction site.

Ear plugs are provided for workers near sources of loud noise. Compliance

Air pollution (dust, NOx, SO2, CO,

42. On rainless day undertake watering, at least twice per day, on dusty and exposed areas at

Construction site, concrete batching

- Dust pollution is found at many places at

Watering must be done some


94

Project activities

(1)

Potential Environme


(2)


(3)

Location (4)


EEMC (5)

CorrectionActions

Proposed by EEMC

(6)

Pb, VOC) caused by earth works and other construction activities

construction yards, materials stockpile, within and in the vicinity of concrete mixing stations, construction sites and access roads where residential areas and other sensitive receptors (e.g., schools, populated areas adjacent to National Road 1A and Provincial Road 50 in districts of Binh Chanh, Nha Be and Long Thanh, etc.) are located nearby. At each construction site, contractors shall ensure availability of a tanker truck for this purpose. Higher watering frequency (e.g., 4 to 6 times per day) shall be implemented by the contractor as the need to arises to ensure that impacts to sensitive receptors are minimized.

plant, materials storage and service road.

excess road. (Ong Thoan viaduct construction site). - Watering is not properly implemented at many places. Minor infringement

times/dry day to minimize dust pollution. This measure must be implemented immediately.

43. In addition to watering the zones in front of and inside concrete mixing stations, the following measures shall also be implemented to reduce impacts due to dust emissions: i) Concrete mixers and asphalt stations shall be located at least 300 m from residential areas, hospitals, schools, and other sensitive receptors. ii) ditches of 4 x 10 x 0.3 m (L x W x D) would be made by contractors in order to wash vehicles before they go out of the stations. This measure is necessary for concrete mixing stations where the dust content is very high as it keeps down soil and sand adhering to vehicle wheels. These are highly feasible measures. The best measure is to wash truck body and tires before

Concrete batching plant and asphalt stations, construction site (Bridge Construction Joint Stock Company No.75)

- Concrete batching plant is located near residential area with distance <300 meter. - (53.ii) measure was not implemented at concrete batching plant. - (53.iii) measure was not implemented at concrete batching plant. Major infringement

- Contractor should install ditches at of concrete batching plant to wash vehicles before they go out of the station. - Contractor should install enclosing walls (3.0 – 4.0 m in high) around the the station before June 30th, 2016.


95

Project activities

(1)

Potential Environme


(2)


(3)

Location (4)


EEMC (5)

CorrectionActions

Proposed by EEMC

(6)

moving out of the construction to urban areas. iii) Provide enclosing walls (3.0 – 4.0 m in high) around the construction sites that are near sensitive receptors (schools, populated areas, churches, pagodas, etc). 44. Tightly cover construction materials (sand, soil, cement, gravel, etc.) during transport with tarpaulins or similar sheet materials.

Access roads 44th measure was implemented. Compliance

45. Dredged spoil shall be compacted to minimize dust dispersion to surrounding residential areas. The surface of dredged spoil storage sites may be covered by dense plastic sheets to prevent dust dispersion. This sheet is also good for soil erosion prevention in the rainy months. Dredged spoils shall be disposed to sites approved by local authority.

Spoils disposal site

Dredged spoil was not compacted. The surface of dredged spoil storage sites was not covered by dense plastic sheets to prevent dust dispersion. Minor infringement

The grass should be planted at the disposal areas to prevent the emission of dust and erosion. At places closed to aquaculture ponds, rice field, residential sites compaction of dredged spoil should be done.

46. All vehicles, construction machines used for the project should have license of the Vietnam Register or Police approving compliance to Vietnam Standard on vehicle emission.

Construction site and access roads

Contractors reported that all equipments and construction machinery which be used for Package A1,


96

Project activities

(1)

Potential Environme


(2)


(3)

Location (4)


EEMC (5)

CorrectionActions

Proposed by EEMC

(6)

have license of the Vietnam register as well as certification on technical safety and environmental protection. Compliance

Damage to local terrestrial ecosystems

47. Expanding the project ROW to the wetland and mangrove forest area particularly, at the Thivai river bank shall be prohibited.

Construction site and surrounding area.

Up to now, not detected any expanding activity to outside the project’s ROW. Compliance

48. Cutting trees outside the project area shall be forbidden.


In Package A1 there is not mangrove area. Cutting trees outside the project area was not found. Compliance

49. Prior to commencement of construction activities on site identify and mark with suitable visual reminders the areas of mangroves that are not to be disturbed during the works. This measure is recommended for the construction site at Package A7 (the banks of Thi Vai rivers) where is mangroves area.


This measure is recommended for the construction site at Package A7 (the banks of Thi Vai rivers) but not for Package A1, where A1 there is not mangrove area


97

Project activities

(1)

Potential Environme


(2)


(3)

Location (4)


EEMC (5)

CorrectionActions

Proposed by EEMC

(6)

50. Do not dispose dredging spoils and all types of wastes onto mangrove forest areas, agricultural land, densely vegetated areas, and water courses.


At present, dredged soil is piled up at temporary dumps along the service road and wait for transport to disposal area. But sometimes spoil containing high salinity was disposed into the fields damaging rice Major infringement

The contractor should completely transport excavated soils before the rainy season. Spoil disposed in agricultural land should be immediately removed. Measures should also be in place to ensure that runoff from temporary dump do not go into agricultural land. Compensation for the affected households due to land salinity and land de-salinization should be completed before August 2016

51. Prohibit workers from collecting firewood and

Construction site and

51st measure was


98

Project activities

(1)

Potential Environme


(2)


(3)

Location (4)


EEMC (5)

CorrectionActions

Proposed by EEMC

(6)

construction materials from surrounding forests, and from hunting wild animals.

surrounding area.

implemented. Compliance

Health and safety risks

52. Provide fire fighting equipment at the work areas, as appropriate, and at construction camps.

Project site Fire extinguishers were provided at the worker’s camps and temporary fuel depots ... Compliance

53. Provide workers with appropriate safety equipment/devices (such as dust mask, hard hats, safety shoes, goggles, ear plugs, etc.) and strictly require them to use these as necessary.

Project site 53rd measure was implemented. Compliance

54. Strictly impose speed limits on construction vehicles along residential areas and where other sensitive receptors such as schools, hospitals, and other populated areas are located. Educate drivers on safe driving practices to minimize accidents and to prevent spill of hazardous substances and other construction materials during transport.

Project site and access road.


55. Barriers (e.g., temporary fence) shall be installed at construction areas to deter pedestrian access to these areas except at designated crossing points. Sufficient lighting at night as well as warning signs shall be provided in the periphery of the construction site.

Project site 55th measure was implemented. Compliance

56. The general public/local Project site 56th measure


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Project activities

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(2)


(3)

Location (4)


EEMC (5)

CorrectionActions

Proposed by EEMC

(6)

residents shall not be allowed in high – risk areas, e.g., excavation sites and areas where heavy equipment is in operation.

was implemented. Compliance

5. Specific issues: Dredging, filling, cutting activities during road construction at ASS areas

Q Acidification of soil and water caused by earth filling/cutting activities at acid sulfate soil (ASS) area. Consequently, aquaculture and aquatic organisms in the acidified canals, ponds could be affected.

57. Install temporary shallow ponds (ground for containing dredged materials) and settlement pond at the construction sites which are highly affected by acidic water, to receive run-off water containing acidic materials, neutralize acidic water if its pH <5 or lower than pH value of surrounding water prior to discharge into fields or canals.

Project site In March 2016, no discharge of storm water containing high acidity found at construction site. However, this may occur in the rainy season

Dredged soil should be transported to disposal area and settlement ponds should be installed before rainy season (before June 2016).

58. Use lime to neutralize acidic storm water and run-off from construction site with pH<5 (if this acidity is created by the project activities) at places close to water intake site for domestic use, agricultural land, aquaculture pond and in other areas where acidic water is generated by project activities.

Project site In March 2016, no high acidic water and storm water found at construction site because this is the middle of dry season. So that, this measure is not necessary.

59. Cover road bed with high actual acid sulfate soil using uncontaminated soil, clay or sand (as appropriate).

Project site In March 2016, no leakage of high acidic water from soil. So that, this measure is not necessary.

60. In case that ASS spoil is heaped up along the road, in order to avoid of the transfer of sulfate acid water to agriculture

Project site In March 2016, no leakage of high acidic water from soil.


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Project activities

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Potential Environme


(2)


(3)

Location (4)


EEMC (5)

CorrectionActions

Proposed by EEMC

(6)

and aquaculture land, construction contractors shall design and utilize storing grounds with enclosure of suitable width and height. The capacity of a storing ground is determined on a case by case basis to adequately accommodate spoils and shall be compacted to avoid erosion and percolation.

So that, this measure is not necessary.

61. The enclosure shall preferably include settling or sedimentation reservoirs to reduce turbidity and suspended solid and to treat leachate of acidic water (including neutralization with lime if pH of water in the reservoir is lower than that of the surrounding environment).

Project site In March 2016, no runoff water containing high turbidity and acidity from construction sites So that, these measures are not necessary.

62. Any construction contractor who causes soil or water acidification that kills fish, shrimp or other aquaculture species or damages crops shall be subject to fines and payment of compensation under Vietnam laws.

Project site Death of fish, shrimp or aquatic organisms by acidification is not found. Damage of rice caused by salinity created by spoil disposal is mentioned in Item 50. Major infringement

Contractor should well compensate for the affected households due to rice damage by salinity and well conduct land de-salinization. This should be completed before August 2016

6. Use of hazardous substances

- Surface water, groundwate

63. During dry days, undertake watering of dredged soil storage sites when such sites are close to

Project site

Dredged soil is reused for backfilling at


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Project activities

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(2)


(3)

Location (4)


EEMC (5)

CorrectionActions

Proposed by EEMC

(6)

(fuel, oil, etc.), generation of construction and domestic wastes

r, air, land pollution caused by spills and construction wastes and excavation spoils - Adverse impacts on cultivated areas and aquaculture - Aesthetic issues

residential areas.

Five Star New City area, so that this measure is not necessary.

64. Arrange different kinds of rubbish bins for collection and segregation of domestic waste, hazardous waste around construction, and workers’ camp sites.

Worker’s camp and construction site (Bridge Construction Joint Stock Company No.75).

Different kinds of rubbish bins for collection and segregation of domestic waste, hazardous waste around construction and workers’ camp sites were not enough. Major infringement

Contractor should provide bins for collection and segregation of domestic solid waste and hazardous waste at construction sites and worker camps. This measure should be done before June 30th, 2016.

65. In cases when construction sites that last for more than 6 months (for building bridges), construction contractors can build pits for receiving and disposing of domestic solid wastes. The pit should be located over 100m from boundary of the nearest residential area.

Worker’s camp and construction site (Bridge Construction Joint Stock Company No.75).

Contractor contracted with the functional units to collect, transport and treat domestic solid waste, so that this measure is not necessary.

66. Make drainage ditches at worker camp sites and construction sites to prevent flow of storm water to cultivated land

Worker’s camp and construction site (Bridge

Drainage ditch was not constructed at worker’s camp

Contractor should install drainage


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(2)


(3)

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CorrectionActions

Proposed by EEMC

(6)

and aquaculture areas. Construction Joint Stock Company No.75).

of Bridge Construction Joint Stock Company No.75. But at monitoring day no discharge of storm water to cultivated land found. Minor infringement

system at workers camps before June 30th, 2016.

67. Implement the following measures for handling hazardous substances and wastes: (i) Store fuel and hazardous substances in paved areas with roof and embankment. If spills or leaks do occur, undertake immediate clean up. (ii) Ensure availability of spill clean up materials (e.g., absorbent pads, etc.) specifically designed for petroleum products and other hazardous substances where such materials are being stored. (iii) Segregate hazardous wastes (oily wastes, used batteries, fuel drums) and ensure that storage, transport and disposal shall not cause pollution and shall be undertaken consistent with national and local regulations. (iv) Ensure all storage containers are in good condition with proper labeling. (v) Regularly check containers for leakage and undertake necessary repair or replacement. (vi) Store hazardous materials

Concrete batching plant area (Bridge Construction Joint Stock Company No.75).

- Fuel storage area without roof. - There is no storage area for hazardous waste. - Segregation of hazardous waste was not implemented in accordance with regulations. Major infringement

- Contractor should improve fuel and hazardous waste store sites following the MONRE regulations. - Segregation of hazardous waste should be done following the MONRE regulations


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Project activities

(1)

Potential Environme


(2)


(3)

Location (4)


EEMC (5)

CorrectionActions

Proposed by EEMC

(6)

above flood level. (vii) Equipment maintenance areas shall be provided with drainage leading to an oil-water separator that will be regularly skimmed of oil and maintained to ensure efficiency. Discharge of oil contaminated water shall be prohibited. 68. Provide information on waste management in training program for workers, including how to manage hazardous wastes. Train relevant construction personnel in handling of fuels and spill control procedures.

Worker’s camp and construction site


69. All excavation spoils that will be re-used shall be collected and stored with adequate protection for dust control and erosion. The spoils shall be temporarily stored in areas close to the construction site but more than 200m from residential, commercial, cultural sites and other sensitive receptors.

Project site The spoils were temporarily stored in areas close to the construction site but near residential areas. Minor infringement

Contractor should quickly transport excavated soils to disposal area before the rainy season.

70. Disposal of construction waste into fields, ponds, rivers and canals shall be prohibited.

Project site No disposal of construction waste into fields, ponds, rivers and canals. Compliance

71. Where significant amount of oily wastewater or spill/leakage of oil and grease may occur (e.g., equipment maintenance areas), oil/water separators shall be provided for treatment of

Project site At present, there is not evident oily wastewater pollution or spill/leakage of


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Project activities

(1)

Potential Environme


(2)


(3)

Location (4)


EEMC (5)

CorrectionActions

Proposed by EEMC

(6)

wastewater. oil at Package A1 area . Compliance

72. Contractors would employ sanitary workers for collecting and segregating sanitary waste, hazardous waste and construction waste at each construction site. Contractors should sign contract with environmental service enterprises of districts for safe disposal of construction excavation wastes that are not reused for site leveling.

Project site The collection and segregation of domestic solid waste, hazardous waste and construction solid waste have not yet been fully implemented and properly. Major infringement

Contractor should provide different kinds of bins for collection and segregation of domestic solid waste and hazardous waste Contractor should improve fuel and hazardous waste store sites following the MONRE regulations. The above measures should be done before June 30th, 2016.

73. Burning wastes at the construction site is prohibited. Except for burning cut trees with following conditions: only a small volume (<100kg/time); far from camps, fuel storage, residential sites (over 500m); with availability

Project site Burning wastes at the construction site is not found. Compliance


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Project activities

(1)

Potential Environme


(2)


(3)

Location (4)


EEMC (5)

CorrectionActions

Proposed by EEMC

(6)

of fire control facilities and manpower. 74. Properly plan a spoils disposal area at each construction site. This area shall be approved by the local authority and shall be located 300m from residential sites and well protected by fences or walls.


75. Contractors shall keep at an appropriate place the volume of dredged spoil (with high contents of organic matters) that is not used for leveling, and allow local people or companies to take it away for soil reclamation or forestation (farmers in the project districts like to use this type of soil for field reclamation of filling low land area).

Project site and surrounding area.


- Increased river/canal/pond siltation affecting local aquaculture, aquatic ecosystem.

76. Organize a team for collection and segregation of construction wastes at each construction site.


77. Properly collect and segregate construction wastes into non-hazardous and hazardous wastes.

Project site Collection and segregation of construction wastes into non-hazardous and hazardous wastes were not implemented. There are not containers, storage area for hazardous waste in accordance with regulations. Major infringement

- Contractor should provide different bins for collection and classification of domestic solid waste and hazardous waste - Contractor should segregate and store


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Project activities

(1)

Potential Environme


(2)


(3)

Location (4)


EEMC (5)

CorrectionActions

Proposed by EEMC

(6)

wastes following the MONRE guideline. - Contractor should implement the above measures before June 30th, 2016.

78. Sign a contract with district or provincial environmental service unit, to weekly transport all amount of hazardous solid wastes to the provincial/ district treatment sites.

Project site Signed a contract with environmental service unit to collect and transport hazardous solid wastes to treatment site. Compliance

79. Collect non-hazardous dredged materials to be used for road construction or provided to local residents for land reclamation.

Project site


80. Temporarily grow grass on excavated soil storage site and implement other suitable slope stabilization measures.

Project site

Temporarily grow grass on excavated soil storage site is not necessary because excavated soil will be quickly transported to disposal area.


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Project activities

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Potential Environme


(2)


(3)

Location (4)


EEMC (5)

CorrectionActions

Proposed by EEMC

(6)

7. Cutting trees within and outside the project ROW

Reduction of vegetation cover, affecting local biological resource, creating increased soil erosion.

81. Cutting trees outside the project ROW shall be prohibited.

Project site No cutting activities of trees outside the project’s ROW . Compliance

82. Undertake compensatory planting at suitable places close to the project site using native species to replace trees cleared by construction activities. The main area of mangrove replanting is the Thi Vai river banks

Project site This measure is not necessary because Package A1 is not in mangroves area.

8. Transport of construction materials

- Damage to access roads and increased traffic congestion provincial Road 50 and other roads. - Traffic accidents.

83. In cooperation with provincial Department of Transport (DOT) and Transport Police to properly organize transport of materials for the project. As much as possible, schedule delivery of construction materials and equipment during non-peak hours.

Project communes

Local residents complained that: damage of 300-400 m of road on the canal bank at hamlet N7a due to truck movement but the contractor did not repair. Major infringement

Contractor should cooperate with provincial Department of Transport (DOT) and Transport Police to properly organize transport of materials for the project.

84. In coordination with local authorities, set up clear traffic signal boards and traffic advisory signs at the roads going in and out the road and bridge construction sites to minimize traffic build-up. Provide sufficient lighting at night within and in the vicinity of construction sites.

Project communes



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Project activities

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Potential Environme


(2)


(3)

Location (4)


EEMC (5)

CorrectionActions

Proposed by EEMC

(6)

85. Access roads damaged during transport of construction materials and other project-related activities shall be reinstated upon completion of construction works at each section.

Project communes

Local residents complained that: damage of 300-400 m of road on the canal bank at hamlet N7a due to truck movement but the contractor did not repair. Major infringement

Proper repair of the damaged road if it was caused by the contractor. Cause of road damage shall be determined by representatives of commune PC, CSC and contractor.

- Noise, dust pollution

86. Truck drivers and equipment operators shall avoid, as much as possible, the use of horns in densely populated areas and where there other sensitive receptors are found such as schools, temples, hospital, etc. are located.

Project communes


87. Watering of access roads during dry days shall be undertaken along densely populated areas and where there other sensitive receptors are found such as schools, temples, hospital, etc.

Project communes

Watering was implemented but dust pollution was serious problem. Minor infringement

Watering along densely populated areas should be done many times by contractor

9. Specific issue: Establishme

Road embankment could obstruct

88. Design and construct appropriate cross drainage systems with suitable dimensions and appropriate location to avoid

Project communes

88th measure was implemented.


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(2)


(3)

Location (4)


EEMC (5)

CorrectionActions

Proposed by EEMC

(6)

nt of road embankment

water flow, causing inundation of surrounding areas

flooding on areas alongside the road embankment.

Compliance

89. Do not fill up canals and creeks at the construction site. In case filling of local drainage system is extremely necessary, consultation with local authorities shall be undertaken and their permission obtained beforehand. An alternative drainage shall be established before the existing canal is filled-up.

Project communes

Canals and creeks at the construction site are not filled up. Compliance

10. Specific issue: Construction of bridges In this Package 2 small bridges: Phuoc Ly bridge and Ong Thoang bridge are under construction.

Construction worker camps: causing impacts similar with those at road construction.

90. Similar mitigation measures suggested in items 19-37

Bridge construction site.

The bridges are constructed at the same time by the same time with road construction by the same contractor. Construction worker camps: causing impacts similar with those at road construction. Therefore, assessment of the compliance of the contractor with each measure required in the EMP is the same as one in items 19-37 above.

Increased noise and vibration causing



Noise and vibration causing impacts similar with


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Project activities

(1)

Potential Environme


(2)


(3)

Location (4)


EEMC (5)

CorrectionActions

Proposed by EEMC

(6)

impacts similar with those at road construction.

those at road construction. Therefore, assessment of the compliance of the contractor with each measure required in the EMP is the same as one in items 40-45 above.

Domestic and construction waste generation causing the impacts similar to those at road construction.



Domestic and construction waste generation causing the impacts similar to those at road construction. Therefore, assessment of the compliance of the contractor with each measure required in the EMP is the same as one in items 74-85.

Air pollution caused by earth works and material transport.



Air pollution caused by earth works and material transport causing the impacts similar to those at road construction. Therefore,


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Project activities

(1)

Potential Environme


(2)


(3)

Location (4)


EEMC (5)

CorrectionActions

Proposed by EEMC

(6)

assessment of the compliance of the contractor with each measure required in the EMP is the same as one in items 52-56 above.

Land erosion and land slide at bridge construction site. Obstruction of waterways.

94. Confine vegetation clearing within the areas required for construction.


Vegetation clearing within the bridge construction areas was done before construction.

95. Firmly consolidate river banks using stones, concrete and other suitable retaining measures at each bridge construction site and ensure that water courses (rivers, canals, etc.) shall be kept free of excavation spoil and construction debris, floating and submerged. Spoil and construction materials stockpile area shall be located away from waterbodies and under no circumstances will these materials be dumped into watercourses.


At the field visit (March 2016) no construction at the river banks implemented.

96. Plant mangrove trees along the river/canal banks close to the bridge construction sites. Width and length of mangrove area to be planted are about 5m*100m (each site at each river bank), depending on each location.


At the proposed sites for bridge construction no mangrove trees (only very few Nipa palm trees grown). Mangrove replanting plan is not


112

Project activities

(1)

Potential Environme


(2)


(3)

Location (4)


EEMC (5)

CorrectionActions

Proposed by EEMC

(6)

necessary.

Operation of barges for material transport, causing water pollution by wastes, fuel leakage

97. Discharge of untreated waste water and release of rubbish from barges shall be prohibited. Solid wastes shall be periodically collected and transported to disposal sites approved/licensed by local authorities.


At the field visit (March 2016) no construction at the river banks implemented. No operation of barges for material transport

98. Each barge shall have rubbish bins for solid waste collection, oil separator for proper collection of oily wastewater and fire control facilities.


99. Coordinate wih provincial Department of Transport and Waterway Police to properly organize barge and floating crane activities at each bridge construction site.


Operation of barges and floating crane in bridge construction, causing inland waterway traffic congestion and environmental risks in case of oil spill.

100. Do not encroach on the navigation channels (at Binh Khanh and especially Phuoc Khanh Bridges).


At the field visit (March 2016) no construction at the river banks implemented. No operation of barges and floating cranes

101. Set up temporary signaling stations to warn boats at the location of floating cranes and pier construction sites.


102. The contractor shall ensure that barge owners involved in bridge construction shall have an oil spill prevention and response plan and relevant technical facilities for its implementation. In case of spills of oil and other hazardous substances, the contractor shall implement the following measures: (i) Immediately inform the Sai Gon Port Authority, who is responsible for waterway transport in Ho Chi Minh City and surrounding region.



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Project activities

(1)

Potential Environme


(2)


(3)

Location (4)


EEMC (5)

CorrectionActions

Proposed by EEMC

(6)

(ii) Engage oil spill removal companies and local authorities to immediately respond to oil spill incidents caused by the Project. (iii) Immediately inform communes which may be affected by oil the spill. (iv) After the oil spill has been controlled/removed, the contractor will coordinate with the relevant local communes to address land and water pollution caused by the spill, and to provide compensation for environmental and economic damages, following the relevant Vietnamese laws and guidelines.

11. Specific issue: Impacts of Construction Worker Influx and Unplanned Migration

-Social impacts (employment/livelihood, health risks).

103. - Implementation of proper measures to maximize local employment to minimize the numbers of non-local workers employed at the project site. - Severely affected and vulnerable affected persons will be prioritized in gaining employment in the works. As a minimum, in each severely affected household, one person of working age will be prioritized in gaining employment during the construction phase, if he/she is qualified.

Project site This measure will be carried out when Contractor mobilize the large number of workers.

104. In recognition of the fact that despite implementation of the above measures, large numbers of non-local workers will still be required, construction contractors will work with the local authorities to develop a range of measures to minimize the adverse effects of the planned construction force and unplanned migrants.

Project site Contractor worked with the commune PCs in cooperation on resolution of relation between workers and local communities.


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Project activities

(1)

Potential Environme


(2)


(3)

Location (4)


EEMC (5)

CorrectionActions

Proposed by EEMC

(6)

So far, no any conflict between workers and local residents occurred. Compliance

105. Conduct orientation for construction workers on prevention of HIV/AIDs, epidemic diseases such as water-borne and vector-borne diseases,, and other related diseases.

Project site

105th measure was not fully implemented. Minor infringement

- Prevention of HIV/AIDS program was sent EPMU and waiting for approval. After that, Contractors have to implement this program.

12. Impacts on Cultural Heritage Sites

Potential damage to cultural and historical relics

106. Alert district or provincial Departments of Culture and Information (DCI) on discovery of any objects of possible archaeological significance that may be uncovered during construction.

Project site

There aren't any cultural and historical structures in the project area. No objects of possible archaeological significance were discovered.

107. Immediately suspend construction activities affecting the area of the find until a qualified site assessment has been made and contractors have been given permission by DCI to proceed.

From the detailed assessment on the contractor's compliance (JV of Halla Corporation-Vinaconex E&C) with EMP, can be concluded that, at the present time, the contractor has implemented various measures to prevent pollution and waste management. Most of the measures are complied with EMP. In the total of over 100 evaluated measures 27 measures were not complied, of which 18 measures as minor


115

infringement and 9 measures as major infringement are evaluated. The main major infringement relates with disposal of spoils causing salinity for rice field; no segregation of hazardous wastes and damage of roads. They must be properly corrected.


116

Figures on the situation of environmental management at Packages A1, March 2016

Meeting and working of EEMC with representatives of EPMU, Construction Supervision Consultant (CSC) and Contractor.

Watering on the service road to avoid dust pollution at Package A1.

Drainage system at Ong Thoan viaduct construction site (Nam Tan).

Dredged soil with bentonite on the ground at Ong Thoan viaduct construction site (Nam Tan).

Ong Thoan viaduct construction site (Nam Tan) Construction site at Km2 + 090 location


117

Dust arise on service road at Ong Thoan viaduct construction site (Nam Tan).

Sediment tanks at concrete batching plant of Bridge Construction Joint Stock Company No.75

Storage area of concrete addives without roof and concrete floor (Bridge Construction Joint Stock Company No.75)

Lack of danger warning signs at Phuoc Ly viaduct construction site (Bridge Construction Joint Stock Company No.75).

Storage area of fuel with unsafe temporary roof at concrete batching plant (Bridge Construction Joint

Rubbish bins for collecting domestic solid waste at worker’s camp (Bridge Construction Joint Stock


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Stock Company No.75) Company No.75).

Fire extinguishers were equipped at a worker's camps (Bridge Construction Joint Stock Company No.75).

First aid box was equipped at a worker's camp (Bridge Construction Joint Stock Company No.75), but medicines are not available.

Pond of stagnant water in front of a worker’s camp (Bridge Construction Joint Stock Company No.75)

Clean potable water supply in sufficient amount were provided for workers (Bridge Construction Joint Stock Company No.75).


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Toilets areas are not provided rubbish bins for collecting of used sanitary paper and not separated for males and females (Bridge Construction Joint Stock Company No.75)

Washing and bathing areas are not separated for males and females (Bridge Construction Joint Stock Company No.75). The contractor explained that there is only 1 woman in worker camp.

Transporting vehicles of excavated soil are covered tightly by tarpaulin or similar sheet materials

Disposal area at Five Star New City in Phuoc Ly commune, Giuoc District, Long An Province

The spoils are temporarily stored in areas closed to the construction site but near residential areas, lack of danger warning sign system and no compaction.

Warning sign is installed at a deep hole at intersection between local roads and construction sites. At some other deep holes there are not warning signs.


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APPENDIX 2: ASSESSMENT OF THE COMPLIANCE OF PACKAGE A2-1 WITH THE EMP REQUIREMENTS

Project Activities

(1)

Potential Environmental Negative

Impacts (2)

Proposed Mitigation Measures in EMP and

approved by ADB (3)

Location (4)

Level of compliance assessed by

EEMC (5)

Correction Measures Proposed

by EEMC (6)

1. Environmental protection requirements in the contract

1. Prior to commencement of any site works, each contractor shall prepare a site-specific or construction EMP (CEMP) which specifies the responsibilities, location associated costs, schedule/timeframe and other relevant information for implementing its provisions which will include the following: (i) selection of sites for material exploitation and storing, as well as sites for concrete, crushing and asphalt plants, (ii) plans for material transportation routes and timing, (iii) identification of specific disposal sites for unsuitable soils, (iv) soil erosion control measures including soil stabilization measures at disposal sites, (v) treatment of acid sulfate soils and resulting run-off, (vi) wastewater collection and treatment, (vii) construction camp management, (viii) quarry/aggregate/borrow site management and restoration, (ix) traffic management, (x) noise reduction measures including construction of temporary noise barriers, (xi) dust suppression measures, (xii) handling and storage of hazardous substances such as fuel, etc. (xiii) solid waste collection and disposal, (xiv) replanting measures, (xv) occupational and community

Project office of contractor

Construction Environmental Management Plan (CEMP) was prepared by Contractor and approved by Consultant (KEI-NE-OC-TEDI JV). It was submitted to ADB in Dec. 2015. Compliance


121

Project Activities

(1)


Impacts (2)


approved by ADB (3)

Location (4)


EEMC (5)


by EEMC (6)

health and safety, (xiv) repair of damaged community facilities such as irrigation canals, etc. (xvii) emergency response plan in case of spills and other accidents involving workers and the community, (xviii) chance-find procedures measures and other applicable mitigation measures indicated in the Project EMP included in the EIA approved by ADB. The CEMP should be fully consistent with the Project EMP. Before civil works begin, the CEMP shall be reviewed by the Project Supervision Consultant and endorsed to ADB.


Biological waste disposal can pollute the water, obstructing navigation, aesthetic.


Project sites

All measures in third column were implemented by Contractor of Package A2-1. Compliance


4. Burn the cut trees in accordance with national and local regulations, and only in limited cases with strict conditions (less than 100 kg at a time; more than 500m from residential areas and other sensitive receptors such as schools, hospital, culturally significant sites, etc. and fuel storage sites, 200 m from worker camps; with available and sufficient fire prevention devices and manpower for fire


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Project Activities

(1)


Impacts (2)


approved by ADB (3)

Location (4)


EEMC (5)


by EEMC (6)

extinguishing and ensuring that surrounding vegetation are protected from fire; will not cause nuisance and safety risks to sensitive receptors (houses, schools, etc.) and road users in the surrounding areas.

2. Cutting down vegetation (as above)


5. Prohibit vegetation clearing outside the project’s ROW.

Outside the project’s ROW

No vegetation clearing activities outside the project’s ROW Compliance

6. Design viaducts to go over the mangrove areas at the Eastern bank and the Western bank of the Soai Rap river; the Western bank and the Eastern bank of the Thi Vai river.

Project site under Package A2-1.

There is not mangrove area in Package A2-1. This measure is not necessary.

7. Implement a Mangrove Reforestation Plan (MRF) to replant mangroves for compensation of the lost mangrove area at river, canal banks due to site clearance (mainly at river, canal banks in Nha Be, Can Gio, Nhon Trach, Long Thanh districts). Detailed MRF is found in Section V.B.2. of the EIA Report.


There is not mangrove area in Package A2-1. This measure is not necessary.

3. Worker camp

Generation of domestic solid waste, causing land, water, air pollution and

8. Implement proper solid waste management through implementation of the following measures: (i) Prohibit burning of construction and domestic

Worker’s camp (Trung Chinh Trading & Constructi



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Project Activities

(1)


Impacts (2)


approved by ADB (3)

Location (4)


EEMC (5)


by EEMC (6)

advserse effects on public health.

wastes. (ii) Do not permit disposal of solid wastes into canals, rivers, other watercourses, agricultural field and public areas. Disposal shall only be to areas approved/licensed by local authorities. (iii) Properly collect and segregate domestic wastes at worker camps and offices. Use rubbish bins for containing domestic solid wastes. (iv) Sign contract with local environmental service units for regular transport (weekly) of solid wastes to disposal sites. (iv) Ensure that wastes are disposed to sites approved by local authority. (iv) Use of pits with proper lining for disposal of domestic solid wastes. Location of the pits shall be over 200m from residential sites and over 100m from workers’ eating area. Before the team moves to a new construction site, trash pits shall be disinfected with lime or hypochlorite solution, then firmly covered with a 20 – 30 cm layer of soil.

on Co., Ltd.).

Sanitary wastes (sewage) from workers, causing water, air, land pollution, and

9. Provide efficient and clean mobile toilets for each construction site (separate facilities shall be provided for male and female workers).

Project site - 9th measure was implemented. - 10th measure was implemented. - 11th measure is not necessary.


Project site


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Project Activities

(1)


Impacts (2)


approved by ADB (3)

Location (4)


EEMC (5)


by EEMC (6)

diseases. 11. At worker camps located far (over 500m) from residential areas, bench latrines may be installed. Latrines should be located over 100m from living places and 50 m from canal, river. Daily use lime for disinfection. Well fill up and disinfect before moving the camp to other site.

Worker’ camp (Trung Chinh Trading & Construction Co., Ltd.)

- 12th measure was implemented. Compliance


Worker’s camp (Trung Chinh Trading & Construction Co., Ltd.)


Worker’s camp (Trung Chinh Trading & Construction Co., Ltd.).

13th measure was implemented by contractor. Compliance



Project communes.

Up to now no conflict between the workers and the local residents as well as disturbance of community. In the future, the contractor will employ more local people as construction workers.


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Project Activities

(1)


Impacts (2)


approved by ADB (3)

Location (4)


EEMC (5)


by EEMC (6)


Project communes


16. Establish a grievance redress mechanism (GRM), well guide local residents to apply GRM; provide local communities information on up coming construction activities; record any complaints received and respond to them based on the GRM, properly cooperate with local PCs, DONREs, social associations to properly solve claims of the PAHs and problems related to environmental issues related to the project.

Project communes

- Grievance redress mechanism (GRM) is not established. - Project information boards are installed at the construction site to provide for local people information about Employer, Consultant and Contractor and hotline to receive complaints and grievances of local authority and local residents. Minor infringement

Contractor should establish a grievance redress mechanism (GRM) and submit CSC before June 30th, 2016.

17. Regularly inform in advance the local PCs and local residents on the location and schedule of construction activities which may cause impacts on the environment and life of people (e.g., road sections to be constructed; roads used for transport, locations of worker

Project communes (Long Thuong and Hung Long communes, Binh Chanh



126

Project Activities

(1)


Impacts (2)


approved by ADB (3)

Location (4)


EEMC (5)


by EEMC (6)

camps etc.) District).


Project communes (Hung Long commune, Binh Chanh District).

The contractor has regular meeting with local authority and residents of Hung Long commune, Binh Chanh district about related issues. Compliance



Project communes.

Conduct orientation for workers regarding health and safety measures, emergency response in case of accidents, fire, etc., was implemented. However, prevention of HIV/AIDS and other related diseases were not implemented. Minor infringement

- Prevention of HIV/AIDS program was sent EPMU and waiting for approval. After that, Contractor have to implement this program.


Worker’s camp (Trung Chinh Trading & Construction Co.,



127

Project Activities

(1)


Impacts (2)


approved by ADB (3)

Location (4)


EEMC (5)


by EEMC (6)

Ltd.)


Project site and worker’s camp (Trung Chinh Trading & Construction Co., Ltd.)



Worker’s camp and construction site (Trung Chinh Trading & Construction Co., Ltd.).

Washing and bathing areas are not clean. It is a favorable environment for growth of mosquitoes and flies. Minor infringement

- Contractor should regularly clean the washing and bathing areas. - This measure should be implemented before June 30th, 2016.

23. Provide first-aid facilities and fire-fighting equipment at appropriate areas within the the construction site and workers camps.

Worker’s camp and construction site (Trung Chinh Trading & Construction Co., Ltd.)



Worker’s camp (Trung Chinh Trading &

24th measure was implemented.


128

Project Activities

(1)


Impacts (2)


approved by ADB (3)

Location (4)


EEMC (5)


by EEMC (6)

Construction Co., Ltd.)

Compliance

25. Install sign boards, lighting system at the construction sites, borrow pits, or places which may cause accidents for people and workers.

Project site Lighting systems and hazard warning signs at construction sites were installed. Compliance

26. Provide drainage at construction sites and workers camps to prevent water logging/ accumulation of stagnant water and formation of breeding sites for mosquitoes.


At the time of monitoring, some small stagnant water ponds at construction site were found. Minor infringement

Contractor should install drainage system at worker camps and construction site. This measures should be implemented before June 30th, 2016.




4. Construction of road embankment, access roads, borrow pits,

Storm water from construction sites, improper stockpiling of


Project site

Contractors reported that the design of road embankment is good for


129

Project Activities

(1)


Impacts (2)


approved by ADB (3)

Location (4)


EEMC (5)


by EEMC (6)

and auxiliary facilities (excavating, filling cutting activities, material transport):

spoils and construction materials, haphazard spoils disposal, soil erosion and land slide at construction sites, causing damage to roads, polluting of canals, rivers and pond; and obstruction of flow of water courses.

erosion and storm water control. This was confirmed by CSC Compliance

29. Maintain and replant mangroves along rivers, canals (2-10 m wide, 50-500 m long, depending on location) for erosion control.

Project site

This measure is not necessary because in Package A2-1 there is not mangrove area.

30. (i) Provide grass cover and other suitable slope stabilization measures on road embankment slopes and on long term stockpile of spoils. (ii) Spoil disposal shall not cause sedimentation and obstruction of flow of watercourses, damage to agricultural land and densely vegetated areas. (iii) The spoils disposal site shall be located at least 50 m from surface water courses and shall be protected from erosion by avoiding formation of steep slopes and grassing. (iv) Spoils shall only be disposed to areas approved by local authority. (v) Water courses (rivers, canals, etc.) shall be kept free of excavation spoil and construction debris, floating and

Project site (viaduct construction site)

Almost all of the measures in column 3 were applied, but excavated soil with bentonite from bored piles has not been properly collected and disposed. It is disposed into the ground. Minor infringement

- Excavated soil with bentonite must be contained in tankers with waterproof, then dried and transported to disposal area where approved by local authorities. This measures should be implemented before June 30th, 2016.


130

Project Activities

(1)


Impacts (2)


approved by ADB (3)

Location (4)


EEMC (5)


by EEMC (6)

submerged. (vi) Spoil and construction materials stockpile area shall be located away from water bodies and under no circumstances will these materials be dumped into watercourses. (vii) Dredged and excavated materials shall be reused or provided to local residents as soon as possible, if they require such materials, for land reclamation. The remaining spoils can be disposed into low elevation sites for road construction. (viii) Provide temporary sediment traps (ditches and ponds) if high sediment laden runoff are observed.

31. Design and install culverts and drainage systems to avoid flooding.

Project site (viaduct construction site)

Culverts and drainage systems at viaduct construction sites were not installed. But no flooding occurred. Minor infringement

Contractor should install culverts and drainage systems at viaduct construction sites. This measures should be implemented before June 30th, 2016.

Activities at borrow pits may cause environmental pollution, soil erosion, damage local

32. (i) Select proper places for setting up borrow pits to avoid areas of serious acid sulfate and saline soils and to avoid encroachment into forest, cultivation, commercial and

Borrow areas

Up to now, there are not any operation of borrow pits at Package A2-1 area. So that, evaluating


131

Project Activities

(1)


Impacts (2)


approved by ADB (3)

Location (4)


EEMC (5)


by EEMC (6)

natural habitats, agricultural production, residential, commercial, cultural sites, and safety problems.

residential areas. Borrow sites shall be covered by necessary environmental permits/licenses and shall be located over 300m away from residential, commercial, cultural sites and other sensitive receptors (schools, hospital, etc.). (ii) Proper soil erosion control during borrow pits construction and operation by proper design and installation of adequate drainage system. (iii) Proper control of storm water at borrow sites in the rainy season by using sediment traps, treatment of turbidity, strong acidic water (by lime) and oil separation water if high turbidity, high acidity or high oil content were found. (iv) Proper dust control during dredging, excavation at borrow sites and earth transport. (v) Topsoil (about 15 cm) will be kept and refilled after excavation is over. (vi) Long – term material stockpiles will be covered to prevent wind erosion. (vii) Upon completion of extraction activities, re-contour borrow/quarry pit wall or fill-up when there are available and suitable materials such as excavation spoils , replace topsoil, and re-vegetate with native species such as grasses and fast-growing shrubs. (viii) Quarries and borrow pits will not be established in national, provincial, district and

compliance of this measure is not necessary.


132

Project Activities

(1)


Impacts (2)


approved by ADB (3)

Location (4)


EEMC (5)


by EEMC (6)

village conservation forests and other protected sites. (ix) Operation of existing quarry/borrow sites shall be preferred over establishment of new sites, as much as possible. (x) In case the Project will involve new quarry/borrow sites, necessary approvals from environmental authorities shall be obtained prior to operation of such sites. (xi) During borrow site operation, provide adequate drainage to avoid accumulation of stagnant water. (xii) Borrow/quarry sites shall not be located in productive land and forested areas. (xiii) Upon completion of extraction activities, borrow pits shall be dewatered and fences shall be installed, as appropriate, to minimize health and safety risks. (xiv) Borrow pits will be left in a tidy state with stable side slopes and proper drainage in order to avoid erosion. (xv) To avoid drowning when pits become water-filled, measures such as fencing, providing flotation devices such as a buoy tied to a rope, etc. shall be implemented. (xvi) It is possible that villagers may request borrow pits to be excavated so that they may be used as water reservoirs or fishponds. If this were to be agreed between the contractors


133

Project Activities

(1)


Impacts (2)


approved by ADB (3)

Location (4)


EEMC (5)


by EEMC (6)

and the villagers, all the full safety measures detailed above must be observed. Such agreements would be formalized in writing between the contractors and the villagers after full discussion with all concerned parties.

Noise and vibration pollution, affecting public health.


Construction site

Complaints on noise and vibration from local residents were recorded from interviewing householders along the excess road. Minor infringement

Contractor must implement as soon as possible measures for vibration control during operation of heavy machines at the residential areas. especially during night time.


Concrete batching plant (Trung Chinh Trading & Construction Co., Ltd.)

- Concrete batching plant is located only 20 m from a residential site. However, a dust control thin wall of 3-4 m was installed surrounding the station, therefore, up to now, there are not any complaints from local residents

Contractor should regularly implement the watering at batching plant and surrounding areas to avoid dust pollution. If noise and vibration will be complained by local residents the


134

Project Activities

(1)


Impacts (2)


approved by ADB (3)

Location (4)


EEMC (5)


by EEMC (6)

regarding operation of concrete batching plant. -Environmental permits/licenses: finished. Major infringement (too short distance to residential site).

batching plant should be moved to other site with 300 m from residential areas


Construction site


36. Impose speed limits on construction vehicles to minimize noise emission along areas where sensitive receptors are located (houses, schools, hospitals...).

Construction site (viaduct construction site)



Construction site

Up to now, at this Package there are not any complaints of local residents regarding construction plan; but complaint about noise pollution during night time is recorded. Minor

Contractor should properly organize construction plan, so that the loud noise generation machines would not operate during 10PM to 6AM at residential areas


135

Project Activities

(1)


Impacts (2)


approved by ADB (3)

Location (4)


EEMC (5)


by EEMC (6)

infringement

38. Install noise control walls (3.0-4.5m high, thick materials) at high noise sources that affect sensitive receptors (temples, pagodas, churches, schools).

Construction site

- There are not temples, pagodas, churches, schools closed to the construction sites or access roads. - At places closed to dense residential sites noise control walls were installed but their height is only about 2 meter. Minor infringement

At dense residential sites Contractor should improve noise control walls to minimize noise pollution. This measure should be implemented before June 30th, 2016.


Project communes.





Construction site.

Ear plugs were provided for people working near sources of loud noise. Compliance


136

Project Activities

(1)


Impacts (2)


approved by ADB (3)

Location (4)


EEMC (5)


by EEMC (6)

Air pollution (dust, NOx, SO2, CO, Pb, VOC) caused by earth works and other construction activities.

42. On rainless day undertake watering, at least twice per day, on dusty and exposed areas at construction yards, materials stockpile, within and in the vicinity of concrete mixing stations, construction sites and access roads where residential areas and other sensitive receptors (e.g., schools, populated areas adjacent to National Road 1A and Provincial Road 50 in districts of Binh Chanh, Nha Be and Long Thanh, etc.) are located nearby. At each construction site, contractors shall ensure availability of a tanker truck for this purpose. Higher watering frequency (e.g., 4 to 6 times per day) shall be implemented by the contractor as the need to arises to ensure that impacts to sensitive receptors are minimized.

Construction site, concrete batching plant, materials storage and service road.

Watering is not properly implemented at construction sites and concrete batching plant. (for example: local road in front of concrete batching plant). Minor infringement

Contractor should l implement the watering more time at construction sites and concrete batching plant. This measure should be implemented immediately.

43. In addition to watering the zones in front of and inside concrete mixing stations, the following measures shall also be implemented to reduce impacts due to dust emissions: i) Concrete mixers and asphalt stations shall be located at least 300 m from residential areas, hospitals, schools, and other sensitive receptors. ii) ditches of 4 x 10 x 0.3 m (L x W x D) would be made by contractors in order to wash vehicles before they go out of the stations. This measure is necessary for concrete mixing

Concrete batching plant and asphalt stations, construction site (Trung Chinh Trading & Construction Co., Ltd.)

- Concrete batching plant is located very near residential area -(53.ii) measure was not implemented at concrete batching plant. Minor infringement

Contractor should install ditches in order to wash vehicles before they go out of the stations. This measure should be done before June 30th, 2016.


137

Project Activities

(1)


Impacts (2)


approved by ADB (3)

Location (4)


EEMC (5)


by EEMC (6)

stations where the dust content is very high as it keeps down soil and sand adhering to vehicle wheels. These are highly feasible measures. The best measure is to wash truck body and tires before moving out of the construction to urban areas. iii) Provide enclosing walls (3.0 – 4.0 m in high) around the construction sites that are near sensitive receptors (schools, populated areas, churches, pagodas, etc).

44. Tightly cover construction materials (sand, soil, cement, gravel, etc.) during transport with tarpaulins or similar sheet materials.

Access roads



Disposal area of Package A2-1 (under Hai Son industrial clusters).

- Dredged spoil was not compacted. The surface of dredged spoil storage sites was not covered by dense plastic sheets to prevent dust dispersion. However, dust dispersion from the storage sites was not found during field visit. Minor infringement

Constructor should compact long term dredged spoil store sites located near by residential sites to avoid dust dispersion and acidic water leakage . This measure should be done immediately.


138

Project Activities

(1)


Impacts (2)


approved by ADB (3)

Location (4)


EEMC (5)


by EEMC (6)



Contractors reported that all equipments and construction machinery which be used for Package A2-1, have license of the Vietnam register as well as certification on technical safety and environmental protection. Compliance

For newly mobilized vehicles, construction machines CSC should check the licenses

Damage to local terrestrial ecosystems.

47. Expanding the project ROW to the wetland and mangrove forest area particularly, at the Thi Vai river bank shall be prohibited.


- Up to now, no expanding activity to outside the project’s ROW found. Compliance



No Cutting trees outside the project area Level of compliance: Compliance

49. Prior to commencement of construction activities on site identify and mark with suitable visual reminders the areas of mangroves that are not to be


This measure is not necessary because Package A2-1


139

Project Activities

(1)


Impacts (2)


approved by ADB (3)

Location (4)


EEMC (5)


by EEMC (6)

disturbed during the works. This measure is recommended for the construction site at Package A7 (the banks of Thi Vai rivers) where is mangroves area.

is not located in mangroves area.



At present, o disposal of dredging spoils and all types of wastes onto mangrove forest areas, agricultural land, densely vegetated areas, and water courses. Dredged soil is transported to disposal area (under Hai Son industrial clusters). Compliance

51. Prohibit workers from collecting firewood and construction materials from surrounding forests, and from hunting wild animals.



Health and safety risks.


Project site Fire extinguishers were provided at the worker’s camps and temporary fuel storage sites. Compliance

53. Provide workers with appropriate safety equipment/devices (such as

Project site 53rd measure was implemented.


140

Project Activities

(1)


Impacts (2)


approved by ADB (3)

Location (4)


EEMC (5)


by EEMC (6)

dust mask, hard hats, safety shoes, goggles, ear plugs, etc.) and strictly require them to use these as necessary.

Compliance


Project site and access road.




56. The general public/local residents shall not be allowed in high – risk areas, e.g., excavation sites and areas where heavy equipment is in operation.


5. Specific issues: Dredging, filling, cutting activities during road construction at ASS areas.

Acidification of soil and water caused by earth filling/cutting activities at acid sulfate soil (ASS) area.

57. Install temporary shallow ponds (ground for containing dredged materials) and settlement pond at the construction sites which are highly affected by acidic water, to receive run-off water containing acidic materials, neutralize acidic water if its pH

Project site In March 2016 no acidic water and storm water found at construction site. However, dredged soil should be


141

Project Activities

(1)


Impacts (2)


approved by ADB (3)

Location (4)


EEMC (5)


by EEMC (6)

Consequently, aquaculture and aquatic organisms in the acidified canals, ponds could be affected.

<5 or lower than pH value of surrounding water prior to discharge into fields or canals.

transported to disposal area before rainy season.

58. Use lime to neutralize acidic storm water and run-off from construction site with pH<5 (if this acidity is created by the project activities) at places close to water intake site for domestic use, agricultural land, aquaculture pond and in other areas where acidic water is generated by project activities.

Project site In March 2016 no acidic storm water found at construction sites. Therefore, application of this measure is not necessary.


Project site In March 2016 no evident leakage of acidic water from road bed. Therefore, application of this measure is not necessary.

60. In case that ASS spoil is heaped up along the road, in order to avoid of the transfer of sulfate water to agriculture and aquaculture land, construction contractors shall design and utilize storing grounds with enclosure of suitable width and height. The capacity of a storing ground is determined on a case by case basis to adequately accommodate spoils and shall be compacted to avoid erosion and percolation.

Project site In March 2016 no evident leakage of acidic water from ASS spoil Therefore, application of this measure is not necessary.

61. The enclosure shall preferably include settling or

Project site In March 2016 no evident


142

Project Activities

(1)


Impacts (2)


approved by ADB (3)

Location (4)


EEMC (5)


by EEMC (6)

sedimentation reservoirs to reduce turbidity and suspended solid and to treat leakage of acidic water (including neutralization with lime if pH of water in the reservoir is lower than that of the surrounding environment).

leakage of acidic water from ASS spoil. Therefore, application of this measure is not necessary.


Project site At present, no water acidification that kills fish, shrimp or other aquaculture species or damages crops found. Some areas of rice fields are polluted by salinity from spoils but not by acidity.

6. Use of hazardous substances (fuel, oil, etc.), generation of construction and domestic wastes.

- Surface water, groundwater, air, land pollution caused by spills and construction wastes and excavation spoils. - Adverse impacts on cultivated areas and aquaculture. - Aesthetic

63. During dry days, undertake watering of dredged soil storage sites when such sites are close to residential areas.

Project site

63rd measure was not implemented. Minor infringement

- Contractor should undertake watering of dredged soil storage sites closed to residential areas. This measure should be done immediately.

64. Arrange different kinds of rubbish bins for collection and segregation of domestic waste,

Worker’s camp and constructio

Different kinds of rubbish bins for collection

- Contractor should provide


143

Project Activities

(1)


Impacts (2)


approved by ADB (3)

Location (4)


EEMC (5)


by EEMC (6)

issues.

hazardous waste around construction, and workers’ camp sites.

n site (Trung Chinh Trading & Construction Co., Ltd.).

and segregation of domestic waste, hazardous waste around construction and workers’ camp sites were not provided fully. Minor infringement

different kinds of bins for collection and segregation of domestic solid waste and hazardous waste at sites and worker camps. Contractor should implement this measure before June 30th, 2016.

65. In cases when construction sites that last for more than 6 months (for building bridges), construction contractors can build pits for receiving and disposing of domestic solid wastes. The pit should be located over 100m from boundary of the nearest residential area.


Contractor contracted with the functional units to collect, transport and treat domestic solid waste, so that this measure is not necessary.

66. Make drainage ditches at worker camp sites and construction sites to prevent flow of storm water to cultivated land and aquaculture areas.


Drainage ditch was not installed at worker’s camp of Trung Chinh Trading & Construction Co., Ltd. and viaduct construction site. But in the dry months no flow of storm

Contractor should install drainage ditches at workers camps and construction sites before June 30th, 2016.


144

Project Activities

(1)


Impacts (2)


approved by ADB (3)

Location (4)


EEMC (5)


by EEMC (6)

water to cultivated land and aquaculture areas Minor infringement

67. Implement the following measures for handling hazardous substances and wastes: (i) Store fuel and hazardous substances in paved areas with roof and embankment. If spills or leaks do occur, undertake immediate clean up. (ii) Ensure availability of spill clean up materials (e.g., absorbent pads, etc.) specifically designed for petroleum products and other hazardous substances where such materials are being stored. (iii) Segregate hazardous wastes (oily wastes, used batteries, fuel drums) and ensure that storage, transport and disposal shall not cause pollution and shall be undertaken consistent with national and local regulations. (iv) Ensure all storage containers are in good condition with proper labeling. (v) Regularly check containers for leakage and undertake necessary repair or replacement. (vi) Store hazardous materials above flood level. (vii) Equipment maintenance

Concrete batching plant area (Trung Chinh Trading & Construction Co., Ltd.).

- Storage area of concrete additives without roof and concrete floor. - There is no storage area for hazardous waste. - Segregation of hazardous waste was not implemented in accordance with regulations. - Spills/leaks of fuel does not undertake immediate clean up. Major infringement

- Contractor should construct storage sites for chemical and concrete additives as regulations by MONRE. - Contractor should construct storage sites for hazardous waste and segregation as regulations by MONRE. -Spills/leaks of fuel should be treated immediately. These measures should be completed before June 30th, 2016.


145

Project Activities

(1)


Impacts (2)


approved by ADB (3)

Location (4)


EEMC (5)


by EEMC (6)

areas shall be provided with drainage leading to an oil-water separator that will be regularly skimmed of oil and maintained to ensure efficiency. Discharge of oil contaminated water shall be prohibited.

68. Provide information on waste management in training program for workers, including how to manage hazardous wastes. Train relevant construction personnel in handling of fuels and spill control procedures.

Worker’s camp and construction site



Project site 69th measure was not properly implemented (spoils are stored in areas close to the construction site but less than 200m from residential). Minor infringement

Contractor should find places located over 200m from residential to store spoils for reuse. This measure should be implementedbefore June 30th, 2016.


Project site Construction waste is not disposed into fields, ponds, rivers and canals Compliance

71. Where significant amount of oily wastewater or spill/leakage

Project site At present, no significant


146

Project Activities

(1)


Impacts (2)


approved by ADB (3)

Location (4)


EEMC (5)


by EEMC (6)

of oil and grease may occur (e.g., equipment maintenance areas), oil/water separators shall be provided for treatment of wastewater.

amount of oily wastewater or spill/leakage of oil and grease occurred. This measure is not applied.


Project site The collection and segregation of domestic solid waste, hazardous waste and construction solid waste are not properly fully implemented. Major infringement

Contractor should employ sanitary workers for collecting and segregating sanitary waste, hazardous waste and construction waste at each construction site This measure should be implemented before June 30th, 2016.

73. Burning wastes at the construction site is prohibited. Except for burning cut trees with following conditions: only a small volume (<100kg/time); far from camps, fuel storage, residential sites (over 500m); with availability of fire control facilities and manpower.

Project site 73rd measure was implemented. Compliance

74. Properly plan a spoils Project site Disposal area Contractor


147

Project Activities

(1)


Impacts (2)


approved by ADB (3)

Location (4)


EEMC (5)


by EEMC (6)

disposal area at each construction site. This area shall be approved by the local authority and shall be located 300m from residential sites and well protected by fences or walls.

is located 300m from residential sites and it was approved by the local authority but it is not protected by fences or walls. Minor infringement

should install fences or walls around the disposal area before June 30th, 2016.

75. Contractors shall keep at an appropriate place the volume of dredged spoil (with high contents of organic matters) that is not used for leveling, and allow local people or companies to take it away for soil reclamation or forestation.

Project site and surrounding area.


Increased river/canal/pond siltation affecting local aquaculture, aquatic ecosystem.




Project site Segregate construction wastes into non-hazardous and hazardous wastes were not implemented fully. There are not containers, storage sites for hazardous wastes in accordance with MONRE

- Contractor should provide different kind of tankers for collection and segregation of construction wastes into non-hazardous and hazardous wastes


148

Project Activities

(1)


Impacts (2)


approved by ADB (3)

Location (4)


EEMC (5)


by EEMC (6)

regulation. Major infringement

following the MONRE regulation. This measure should be implemented before June 30th, 2016.

78. Sign a contract with district or provincial environmental service unit, to weekly transport all amount of hazardous solid wastes to the provincial/ district treatment sites.





Project site Temporarily grow grass on excavated soil storage site is not necessary because excavated soil will be quickly transported to disposal area.

7. Cutting trees within and outside the project ROW.

Reduction of vegetation cover, affecting local biological resource, creating increased soil erosion.


Project site No cutting trees outside the project’s ROW. Compliance

82. Undertake compensatory planting at suitable places close to the project site using native species to replace trees cleared by construction activities. The

Project site This measure is not necessary because there is not


149

Project Activities

(1)


Impacts (2)


approved by ADB (3)

Location (4)


EEMC (5)


by EEMC (6)

main area of mangrove replanting is the Thi Vai river banks.

mangrove area in Package A2-1


- Damage to access roads and increased traffic congestion provincial Road 50 and other roads. - Traffic accidents.


Project communes



Project communes.



Project communes.

At this time, this measure is not implemented because the construction is not completed.

- Noise, dust pollution.


Project communes.


87. Watering of access roads during dry days shall be undertaken along densely

Project communes.

Watering is implemented but dust

Watering access roads along


150

Project Activities

(1)


Impacts (2)


approved by ADB (3)

Location (4)


EEMC (5)


by EEMC (6)

populated areas and where there other sensitive receptors are found such as schools, temples, hospital, etc.

pollution is still serious. Minor infringement

densely populated areas should be implemented 3-4 times/dry day.

9. Specific issue: Establishment of road embankment

Road embankment could obstruct water flow, causing inundation of surrounding areas.

88. Design and construct appropriate cross drainage systems with suitable dimensions and appropriate location to avoid flooding on areas alongside the road embankment.

Project communes

88th measure was not implemented fully. But no flooding occurred. Minor infringement

Contractor should design and construct appropriate cross drainage systems with suitable dimensions and appropriate location to avoid flooding on areas alongside the road embankment before June 30th, 2016.


Project communes.


10. Specific issue: Construction

Construction worker camps:

90. Similar mitigation measures suggested in items 19-37.


The viaduct is constructed at the same time


151

Project Activities

(1)


Impacts (2)


approved by ADB (3)

Location (4)


EEMC (5)


by EEMC (6)

of bridges At package A2-1 a viaduct over Haison Residential Area is under construction

causing impacts similar with those at road construction.

by the same contractor with road construction. Construction worker camps: cause impacts similar with those at road construction. Therefore, assessment of the compliance of the contractor with each measure required in the EMP is the same as one in items 19-37 above.

Increased noise and vibration causing impacts similar with those at road construction.



Noise and vibration cause impacts similar with those at road construction. Therefore, assessment of the compliance of the contractor with each measure required in the EMP is the same as one in items 40-45 above.

Domestic and construction



Domestic and construction waste


152

Project Activities

(1)


Impacts (2)


approved by ADB (3)

Location (4)


EEMC (5)


by EEMC (6)

waste generation causing the impacts similar to those at road construction.

generation cause the impacts similar to those at road construction. Therefore, assessment of the compliance of the contractor with each measure required in the EMP is the same as one in items 74-85.

Air pollution caused by earth works and material transport.



Air pollution generated by earth works and material transport cause the impacts similar to those at road construction. Therefore, assessment of the compliance of the contractor with each measure required in the EMP is the same as one in items 52-56 above.

Land erosion and land slide at bridge construction



Vegetation clearing within the bridge construction areas was done before


153

Project Activities

(1)


Impacts (2)


approved by ADB (3)

Location (4)


EEMC (5)


by EEMC (6)

site. Obstruction of waterways.

construction.

95. Firmly consolidate river banks using stones, concrete and other suitable retaining measures at each bridge construction site and ensure that water courses (rivers, canals, etc.) shall be kept free of excavation spoil and construction debris, floating and submerged. Spoil and construction materials stockpile area shall be located away from waterbodies and under no circumstances will these materials be dumped into watercourses.





At the proposed sites for bridge construction no mangrove trees (only very few Nipa palm trees grown). Mangrove replanting plan is not necessary.

Operation of barges for material transport, causing water pollution by wastes, fuel leakage.

97. Discharge of untreated waste water and release of rubbish from barges shall be prohibited. Solid wastes shall be periodically collected and transported to disposal sites approved/licensed by local authorities.


At the field visit (March 2016) no construction at the river banks implemented. No operation of barges for material transport

98. Each barge shall have rubbish bins for solid waste collection, oil separator for



154

Project Activities

(1)


Impacts (2)


approved by ADB (3)

Location (4)


EEMC (5)


by EEMC (6)

proper collection of oily wastewater and fire control facilities.

99. Coordinate with provincial Department of Transport and Waterway Police to properly organize barge and floating crane activities at each bridge construction site.








102. The contractor shall ensure that barge owners involved in bridge construction shall have an oil spill prevention and response plan and relevant technical facilities for its implementation. In case of spills of oil and other hazardous substances, the contractor shall implement the following measures: (i) Immediately inform the Saigon Port Authority, who is responsible for waterway transport in Ho Chi Minh City and surrounding region. (ii) Engage oil spill removal companies and local authorities to immediately respond to oil spill incidents caused by the Project. (iii) Immediately inform communes which may be affected by oil the spill.



155

Project Activities

(1)


Impacts (2)


approved by ADB (3)

Location (4)


EEMC (5)


by EEMC (6)

(iv) After the oil spill has been controlled/removed, the contractor will coordinate with the relevant local communes to address land and water pollution caused by the spill, and to provide compensation for environmental and economic damages, following the relevant Vietnamese laws and guidelines.

11. Specific issue: Impacts of Construction Worker Influx and Unplanned Migration.

- Social impacts (employment/livelihood, health risks).


Project site This measure will be carried out when Contractor mobilize the large number of workers.


Project site Contractor worked with the commune PCs to register number of workers and cooperate in resolution of relation between labor force and local communities. Compliance


156

Project Activities

(1)


Impacts (2)


approved by ADB (3)

Location (4)


EEMC (5)


by EEMC (6)


Project site

105th measure was implemented but not for all workers Compliance

Contractor should conduct training programs on prevention of HIV/AIDs, epidemic diseases for all workers. This measure should be implemented in 2016.




Project site



From the detailed assessment on the contractor's compliance (Joint Venture of Kukdong Engineer & Construction Co., Ltd and Trung Chinh Trading & Construction Co., Ltd.) with EMP, can be concluded that, at the present time, the contractor has implemented various measures to prevent pollution and waste management. Most of the measures are complied with EMP. However, some incidents, complained by local people, occurred. In the total of over 100 evaluated measures 23 measures were not complied, of which 19 measures as minor infringement and 4 measures as major infringement are evaluated. The main major infringement relates with improper management of hazardous wastes and short distance of batching plants to residential sites. They must be properly corrected immediately.


157

Figures on the situation of environmental management at Packages A2-1, March 2016

Meeting and working of EEMC staffs with representatives of PMU, CSC and Contractors.

PPEs are provided by PPEs for workers.

A pond was created at viaduct construction site because of poor drainage system

Excavated soil with bentonite from bored pile process is not well collected and disposed.

Safety barrier is installed at viaduct construction site.

Warning signs on speed limit are installed at viaduct construction site.


158

Mobile toilets and fire extinguishers are provided at viaduct construction site

Storage area of fuel and high pressure gas at viaduct construction site

Rubbish bins for collecting domestic solid waste at worker’s camp . No waste segregation carried out.

Washing and bathing area is not clean at a worker’s camp .

Toilet areas are separated for male and female workers at a worker’s camp.

Cooking area is clean and tidy at a worker’s camp


159

Bedroom area is clean and tidy at a worker’s camp First aid box is provided at a worker's camp, but medicines are not available!

Interview local residents regarding environmental impact of construction activities at viaduct construction site.

Disposal area at Hai Son industrial clusters in Long Thuong Commune, Can Giuoc District: this area was permitted for spoil disposal but no fence/wall installed.

Storage area of concrete additives without roof Storage area of fuel with roof and fire warning sign


160

and impermeable floor at a concrete batching plant.

Rubbish bins for collecting of solid waste are provided at a concrete batching plant. No tank for segregation of hazardous wastes. Major infringement

No clean up of fuel leakage at a concrete batching plant . Major infringement.

Storage area of materials at a concrete batching plant

Noise control walls and nets to prevent dust emission are installed at a concrete batching plant. The distance from batching plant to residential site is only 20 m. Major infringement.


161

Sedimentation pond at a concrete batching plant. Mobile toilet is provided at a concrete batching plant


162

APPENDIX 3: ASSESSMENT OF THE COMPLIANCE OF PACKAGE A2-2 WITH THE EMP REQUIREMENTS

Project activities

(1)


Impacts (2)

Proposed Mitigation Measures in EMP 2010 (3)

Location (4)


EEMC (5)

Correction Measure, Proposed by EEMC

(6) 1. Environmental protection requirements in the contract

1. Prior to commencement of any site works, each contractor shall prepare a site-specific or construction EMP (CEMP) which specifies the responsibilities, location associated costs, schedule/timeframe and other relevant information for implementing its provisions which will include the following: (i) selection of sites for material exploitation and storing, as well as sites for concrete, crushing and asphalt plants, (ii) plans for material transportation routes and timing, (iii) identification of specific disposal sites for unsuitable soils, (iv) soil erosion control measures including soil stabilization measures at disposal sites, (v) treatment of acid sulfate soils and resulting run-off, (vi) wastewater collection and treatment, (vii) construction camp management, (viii) quarry/aggregate/borrow site management and restoration, (ix) traffic management, (x) noise reduction measures including construction of temporary noise barriers, (xi) dust suppression measures, (xii) handling and storage of hazardous substances such as fuel, etc. (xiii) solid waste collection and disposal, (xiv) replanting measures, (xv) occupational and community health and safety, (xiv) repair of damaged community facilities such as irrigation canals, etc. (xvii) emergency response plan in case of spills and other accidents involving workers and the community, (xviii) chance-find procedures measures and other applicable mitigation measures indicated in the Project EMP included in the EIA approved by ADB. The CEMP should be fully consistent with the Project EMP. Before civil works begin,

Project office of

contractor

Construction Environmental Management Plan (CEMP) was prepared by Contractor and approved by Consultant (KEI-NE-OC-

TEDI JV). This was

submitted by EPMU to ADB in Dec. 2015

Compliance


163

Project activities

(1)


Impacts (2)


Location (4)


EEMC (5)


(6) the CEMP shall be reviewed by the Project Supervision Consultant and endorsed to ADB.


Biological waste disposal can pollute the water, obstructing navigation, aesthetic.


Project site

Measures 2,

3, 4 were well implemented


4. Burn the cut trees in accordance with national and local regulations, and only in limited cases with strict conditions (less than 100 kg at a time; more than 500m from residential areas and other sensitive receptors such as schools, hospital, culturally significant sites, etc. and fuel storage sites, 200 m from worker camps; with available and sufficient fire prevention devices and manpower for fire extinguishing and ensuring that surrounding vegetation are protected from fire; will not cause nuisance and safety risks to sensitive receptors (houses, schools, etc.) and road users in the surrounding areas.)

Compliance



Outsite the project’s ROW

No vegetation clearing outside the project’s ROW. Compliance


Project site under Package A2-2

In Package A2-2 there is not mangrove forest

7. Implement a Mangrove Reforestation Plan (MRF) to replant mangroves for compensation of the lost mangrove area at river, canal banks due to site clearance (mainly at river, canal banks


In Package A2-2 there is not mangrove forest


164

Project activities

(1)


Impacts (2)


Location (4)


EEMC (5)


(6) in Nha Be, Can Gio, Nhon Trach, Long Thanh districts). Detailed MRF is found in Section V.B.2. of the EIA Report.

3. Worker Camp sites


8. Implement proper solid waste management through implementation of the following measures: (i) Prohibit burning of construction and domestic wastes. (ii) Do not permit disposal of solid wastes into canals, rivers, other watercourses, agricultural field and public areas. Disposal shall only be to areas approved/licensed by local authorities. (iii) Properly collect and segregate domestic wastes at worker camps and offices. Use rubbish bins for containing domestic solid wastes (iv) Sign contract with local environmental service units for regular transport (weekly) of solid wastes to disposal sites. (iv) Ensure that wastes are disposed to sites approved by local authority. (v) Use of pits with proper lining for disposal of domestic solid wastes. Location of the pits shall be over 200m from residential sites and over 100m from workers’ eating area. Before the team moves to a new construction site, trash pits shall be disinfected with lime or hypochlorite solution, then firmly covered with a 20 – 30 cm layer of soil.

Worker camp sites

(i) No burning of construction and domestic wastes. Compliance (ii) No disposal of solid wastes into canals, rivers, agricultural field and public areas. Compliance (iii) No domestic waste segregation. Minor infringement

(iv) : This measure is implemented. Compliance (v) This measure is not necessary because all domestic waste is collected and transported by by a local environmental service unit.

Sanitary wastes

9. Provide efficient and clean mobile toilets for each construction site

Project site

There is a toilet but it is

Toilet as well as bathing


165

Project activities

(1)


Impacts (2)


Location (4)


EEMC (5)


(6) (sewage) from workers, causing water, air, land pollution, and diseases.

(separate facilities shall be provided for male and female workers).

not separated with male workers.

Minor

infringement

area must be separated for male and female workers. This measure should be implemented before June 30th, 2016.


Project site

2-chamber septic tanks toilets were installed at worker camps Compliance


Worker camp sites

This measure is not

necessary because

septic tank toilets were

installed


Worker camp sites

At monitoring time (March 2016) clean water supply is not enough for bathing.

Minor infringement

Contractor should improve clean water supply system immediately.


Worker camp sites

This measure is implemented Compliance

Conflict between workers and local

14. Employ, as much as possible, local people as construction workers and prioritize opportunities for the PAHs. Implement suitable training programs for

Prọject commun

es

Only a few local people was employed

When volume of construction will be


166

Project activities

(1)


Impacts (2)


Location (4)


EEMC (5)


(6) residents and community disturbance

local workers. because volume of construction is not big. Minor infringement

increased contractor must prioritize opportunities for the PAHs to work for the project.

15. Organize orientation /training for workers, particularly for those from other provinces on maintaining good relationship with local residents. Educate workers on morality, avoiding alcoholism, gambling etc.

Project commun

es

This measure was implemented. Compliance

16. Establish a grievance redress mechanism (GRM), well guide local residents to apply GRM; provide local communities information on up coming construction activities; record any complaints received and respond to them based on the GRM, properly cooperate with local PCs, DONREs, social associations to properly solve claims of the PAHs and problems related to environmental issues related to the project.

Project commun

es

A full grievance redress mechanism was not prepared. But contractor regularly informed local PCs and people about construction activities and solved complaints from local community. Minor infringement

Contractor should prepare and disclose GRM following the ADB guideline


Project commun

es


18. Undertake regular meetings (e.g., Project This measure


167

Project activities

(1)


Impacts (2)


Location (4)


EEMC (5)


(6) twice a month) between contractor and Commune PCs on matters that may affect local residents such as presence of workers, construction activities and schedule, etc.

communes

was implemented (monthly, twice/month is not necessary). Compliance



Project commun

es

Orientation for workers regarding health; HIV prevention measures was not done but guidance for labor safety , emergency response in case of accidents, fire was conducted. Minor infringement

Prevention of HIV/AIDS program was sent EPMU and waiting for approval. After that, Contractors have to implement this program.


Worker camp sites

Food poisoning was not occurred, but clean water supply was not satisfied by workers

Minor infringement

Contractor should improve clean water supply to meet worker demand. This measure should be implemented immediately.

21. Provide large - sized rubbish bins at construction sites and worker camps and weekly transport (by local

Construction and

This measure is implemented


168

Project activities

(1)


Impacts (2)


Location (4)


EEMC (5)


(6) environmental service unit) to district's treatment sites.

worker camp sites

Compliance


Construction and worker camp sites

Sanitation

conditions at worker rooms is not good.

Minor

infringement

Contractor should improve sanitation facilities to avoid proliferation of disease vectors

23. Provide first-aid facilities and fire-fighting equipment at appropriate areas within the construction site and workers camps.


This measure was implemented Compliance


Worker camp sites


25. Install sign boards, lighting system at the construction sites, borrow pits, or places which may cause accidents for people and workers Project

site

This measure

was implemented

Compliance



Water logging is occurred at some places. Minor infringement

Contractor should construct drainage system at worker’s camps before June 30th, 2016.

27. Provide adequate housing for Workers Housing Contractor


169

Project activities

(1)


Impacts (2)


Location (4)


EEMC (5)


(6) workers at the construction camps. camp

sites structure is not safe for

workers (some walls are installed by Nipa palm

leaves) Minor

infringement

should improve housing conditions before June 30th, 2016.

4.Construction of road embankment, access roads, borrow pits, and auxiliary facilities (excavating, filling cutting activities, material transport):

Storm water from construction sites, improper stockpiling of sopils and construction materials, haphazard spoils disposal, soil erosion and land slide at construction sites, causing damage to roads, polluting of canals, rivers and pond; and obstruction of flow of water courses.


Construction sites

Design of road embankment to avoid soil storm water; erosion and land slide was done (this confirmed by contractor and CSC) Compliance


Construction sites

In this package there is not mangrove belt along rivers, canals

30. Provide grass cover and other suitable slope stabilization measures on road embankment slopes and on long term stockpile of spoils

(i) Spoil disposal shall not cause sedimentation and obstruction of flow of watercourses, damage to agricultural land and densely vegetated areas. (ii) The spoils disposal site shall be located at least 50 m from surface water courses and shall be protected from erosion by avoiding formation of steep slopes and grassing.

Project site

Measures (i) to (vi) were well implemented. But planting grass cover on road embankment is impossible in this first stage of construction. Compliance


170

Project activities

(1)


Impacts (2)


Location (4)


EEMC (5)


(6) (iii) Spoils shall only be disposed to areas approved by local authority. (iv) Water courses (rivers, canals, etc.) shall be kept free of excavation spoil and construction debris, floating and submerged. (v) Spoil and construction materials stockpile area shall be located away from water bodies and under no circumstances will these materials be dumped into watercourses. (vi) Dredged and excavated materials shall be reused or provided to local residents as soon as possible, if they require such materials, for land reclamation. The remaining spoils can be disposed into low elevation sites for road construction. (vii) Provide temporary sediment traps (ditches and ponds) if high sediment laden runoff are observed.


Project site

This measure is implemented. Compliance

Activities at borrow pits may cause environmental pollution, soil erosion, damage local natural habitats, agricultural production, residential, commercial, cultural sites, and safety

32. Select proper places for setting up borrow pits to avoid areas of serious acid sulphate and saline soils and to avoid encroachment into forest, cultivation, commercial and residential areas. Borrow sites shall be covered by necessary environmental permits/licenses and shall be located over 300m away from residential, commercial, cultural sites and other sensitive receptors (schools, hospital, etc.). Proper soil erosion control during borrow pits construction and operation by proper design and installation of

Borrow areas

Up to now, there are not any operation of borrow pits at Package A2-2 area.


171

Project activities

(1)


Impacts (2)


Location (4)


EEMC (5)


(6) problems. adequate drainage system.

Proper control of storm water at borrow sites in the rainy season by using sediment traps, treatment of turbidity, strong acidic water (by lime) and oil separation water if high turbidity, high acidity or high oil content were found. Proper dust control during dredging, excavation at borrow sites and earth transport. Topsoil (about 15 cm) will be kept and refilled after excavation is over, Long – term material stockpiles will be covered to prevent wind erosion, Upon completion of extraction activities, re-contour borrow/quarry pit wall or fill-up when there are available and suitable materials such as excavation spoils , replace topsoil, and re-vegetate with native species such as grasses and fast-growing shrubs, Quarries and borrow pits will not be established in national, provincial, district and village conservation forests and other protected sites, Operation of existing quarry/borrow sites shall be preferred over establishment of new sites, as much as possible, In case the Project will involve new quarry/borrow sites, necessary approvals from environmental authorities shall be obtained prior to operation of such sites, During borrow site operation, provide adequate drainage to avoid accumulation of stagnant water, Borrow/quarry sites shall not be located in productive land and forested areas, Upon completion of extraction activities, borrow pits shall be dewatered and fences shall be installed, as appropriate, to minimize health and safety risks. Borrow pits will be left in a tidy state with stable side slopes and proper drainage


172

Project activities

(1)


Impacts (2)


Location (4)


EEMC (5)


(6) in order to avoid erosion To avoid drowning when pits become water-filled, measures such as fencing, providing flotation devices such as a buoy tied to a rope, etc. shall be implemented. It is possible that villagers may request borrow pits to be eft excavated so that they may be used as water reservoirs or fishponds. If this were to be agreed between the contractors and the villagers, all the full safety measures detailed above must be observed. Such agreements would be formalized in writing between the contractors and the villagers after full discussion with all concerned parties.



Construction site

At present, noise pollution caused by truck movement is complained by local residents. But it is difficult for control . No complaints about other construction activities. Minor infringement

Contractor should implement a proper plan for truck operation to avoid serious noise pollution during night-time.


Concrete batching

plant

The concrete batching plant has obtained Environmental Permit but it is located in a distance less than 300 m from

In Binh Chanh, Nha Be districts of Ho Chi Minh City it is very difficult to find a place over 300 m from


173

Project activities

(1)


Impacts (2)


Location (4)


EEMC (5)


(6) residential areas. However, no complaints from local residents on dust, noise and offensive smells pollution. Compliance

residential sites to locate a batching plant. Therefore, guideline of 300 m should be reconsidered..


Construction site

This measure was

implemented Compliance

36. Impose speed limits on construction vehicles to minimize noise emission along areas where sensitive receptors are located (houses, schools, hospitals

Project site

No speed limit warning signs at the access road and construction area Minor infringement

Before 30th June 2016 Contractor should install speed limit warning signs at sensitive receptors and ask drivers to follow the speed guideline


Construction site

This measure was implemented and the construction site is over 200 m from residential areas, noise impact is not evident.


174

Project activities

(1)


Impacts (2)


Location (4)


EEMC (5)


(6) Compliance

38. Install noise control walls (3.0-4.5m high, thick materials) at high noise sources that affect sensitive receptors (temples, pagodas, churches, schools

Construction site

Noise control wall is lower than 3.0 m, but no noise impact to sensitive receptors occurred. Compliance


Project commun

es

Truck movement cause high noise pollution Minor Infringement

Contractor should implement a proper plan for truck operation to avoid serious noise pollution during night-time.


Construction site

This measure is



Construction site

This measure is


Air pollution (dust, NOx, SO2, CO, Pb, VOC) caused by earth works and other construction

42. On rainless day undertake watering, at least twice per day, on dusty and exposed areas at construction yards, materials stockpile, within and in the vicinity of concrete mixing stations, construction sites and access roads where residential areas and other sensitive receptors (e.g., schools,

Construction site, concrete batching

plant, materials storage

and

At access roads watering is done but dust pollution is not well controlled.

At roads near by residential areas watering should be done many times in dry


175

Project activities

(1)


Impacts (2)


Location (4)


EEMC (5)


(6) activities populated areas adjacent to National

Road 1A and Provincial Road 50 in districts of Binh Chanh, Nha Be and Long Thanh, etc.) are located nearby. At each construction site, contractors shall ensure availability of a tanker truck for this purpose. Higher watering frequency (e.g., 4 to 6 times per day) shall be implemented by the contractor as the need to arises to ensure that impacts to sensitive receptors are minimized.

service road.

Minor infringement

days. This measure should be implemented immediately.

53. In addition to watering the zones in front of and inside concrete mixing stations, the following measures shall also be implemented to reduce impacts due to dust emissions: i) Concrete mixers and asphalt stations shall be located at least 300 m from residential areas, hospitals, schools, and other sensitive receptors. ii) ditches of 4 x 10 x 0.3 m (L x W x D) would be made by contractors in order to wash vehicles before they go out of the stations. This measure is necessary for concrete mixing stations where the dust content is very high as it keeps down soil and sand adhering to vehicle wheels. These are highly feasible measures. The best measure is to wash truck body and tires before moving out of the construction to urban areas. iii) Provide enclosing walls (3.0 – 4.0 m in high) around the construction sites that are near sensitive receptors (schools, populated areas, churches, pagodas, etc).

Concrete batching plant and asphalt stations, construction site

- Location of batching plant is less than 300 m from residential site. - This type of ditch is not installed. However, nose and dust impacts to the residential sites are low (no observation of high noise and dust at residential site and no complaint from locla residents) Minor infringement

- Contractor should install a ditch for washing vehicles. This measure should be completed before 30th June 2016 - In Binh Chanh, Nha Be districts of Ho Chi Minh City it is very difficult to find a place over 300 m from residential sites to locate a batching plant. Therefore, guideline of 300 m should be reconsidered

44. Tightly cover construction materials Access This measure


176

Project activities

(1)


Impacts (2)


Location (4)


EEMC (5)


(6) (sand, soil, cement, gravel, etc.) during transport with tarpaulins or similar sheet materials.

roads is implemented. Compliance


Spoils disposal

site

Due to spoil store area is responsible by other agency. The Contractor is not responsible for implementation of this measure.


Construction site

and access roads

This measure is implemented. Compliance



Construction site

and surrounding area

No expanding activity to outside the project’s ROW. In this package there is not a mangrove forest area Compliance


Construction site


No Cutting trees outside the project area. Compliance

49. Prior to commencement of construction activities on site identify

Construction site

This measure is not


177

Project activities

(1)


Impacts (2)


Location (4)


EEMC (5)


(6) and mark with suitable visual reminders the areas of mangroves that are not to be disturbed during the works. This measure is recommended for the construction site at the banks of Soai Rap, Long Tau and Thi Vai rivers where belts of mangrove trees occur.


necessary because Package A2-2 is not in the mangroves area.


Construction site




Construction site





Project site



Project site

Safety equipment/devices were provided but at monitoring time some workers (under 10% of number of workers) did not use. Minor infringement

Strictly require worker to use safety equipment

54. Strictly impose speed limits on construction vehicles along residential areas and where other sensitive receptors such as schools, hospitals,

Project site and access roads

No speed limit signs at residential

areas

Contractor should install speed limit signs along


178

Project activities

(1)


Impacts (2)


Location (4)


EEMC (5)


(6) and other populated areas are located. Educate drivers on safe driving practices to minimize accidents and to prevent spill of hazardous substances and other construction materials during transport.

Minor

infringement

residential areas and require drivers to follow the speed regulation. This measure should be completed before 30th June 2016

55. Barriers (e.g., temporary fence) shall be installed at construction areas to deter pedestrian access to these areas except at designated crossing points. Sufficient lighting at night as well as warning signs shall be provided in the periphery of the construction site

Project site

No barriers at construction area to deter pedestrian access. Lighting at night is sufficient. Minor infringement

Contractor should install barrier or fences to avoid local people accessing to construction sites or danger sites. This measure should be completed before 30th June 2016


Project site

This measure is


5.Specific issues: Dredging, filling, cutting activities during road

Acidification of soil and water caused by earth filling/cutting activities at acid sulfate

57. Install temporary shallow ponds (ground for containing dredged materials) and settlement pond at the construction sites which are highly affected by acidic water, to receive run-off water containing acidic materials, neutralize acidic water if its pH <5 or

Project site

This measure is



179

Project activities

(1)


Impacts (2)


Location (4)


EEMC (5)


(6) construction at ASS areas

soil (ASS) area. Consequently, aquaculture and aquatic organisms in the acidified canals, ponds could be affected.

lower than pH value of surrounding water prior to discharge into fields or canals. 58. Use lime to neutralize acidic storm water and run-off from construction site with pH<5 (if this acidity is created by the project activities) at places close to water intake site for domestic use, agricultural land, aquaculture pond and in other areas where acidic water is generated by project activities

Project site

In March 2016 no soil acidity occurred, therefore, this measure is not used.

This measure should be used in the rainy months


Project site

In March 2016 no soil acidity occurred, therefore, this measure is not used.

This measure should be used in the rainny months


Project site

In March 2016 no soil acidity and no transfer of acidic water to surrounding areas. Therefore, this measure is not used.

This measure should be used in the rainy months


Project site

No any cutting activity of trees outside the project area found.

62. Any construction contractor who causes soil or water acidification that kills fish, shrimp or other aquaculture species or damages crops shall be

Project site

No complaints from local residents

about water


180

Project activities

(1)


Impacts (2)


Location (4)


EEMC (5)


(6) subject to fines and payment of compensation under Vietnam laws.

acidification

Compliance

6. Use of hazardous substances (fuel, oil, etc.), generation of construction and domestic wastes

- Surface water, groundwater, air, land pollution caused by spills and construction wastes and excavation spoils - Adverse impacts on cultivated areas and aquaculture - Aesthetic issues


Project site

Watering is not done but no dust dispersion from spoil storage areas to residential sites Minor infringement

Contractor should carry our watering if dust dispersion will impact to residential sites.

64. Arrange different kinds of rubbish bins for collection and segregation of domestic waste, hazardous waste around construction, and workers’ camp sites

Workers camp and

construction sites,

No segregation of domestic waste, hazardous waste Major infringement

Contractor should provide different kinds of bins for collection and segregation of domestic waste, hazardous waste classification of domestic solid waste and hazardous waste. This measure should be completed before 30th June 2016

65. In cases when construction sites that last for more than 6 months (for building bridges), construction contractors can build pits for receiving and disposing of

Worker’s camp and

construct

This measure is not necessary due to all


181

Project activities

(1)


Impacts (2)


Location (4)


EEMC (5)


(6) domestic solid wastes. The pit should be located over 100m from boundary of the nearest residential area

ion site domestic waste are collected and transported by a local environmental service unit.


Workers camp and

construction sites,

This measure is

implemented Compliance

67. Implement the following measures for handling hazardous substances and wastes: (i) Store fuel and hazardous substances in paved areas with roof and embankment. If spills or leaks do occur, undertake immediate clean up. (ii) Ensure availability of spill clean up materials (e.g., absorbent pads, etc.) specifically designed for petroleum products and other hazardous substances where such materials are being stored. (iii) Segregate hazardous wastes (oily wastes, used batteries, fuel drums) and ensure that storage, transport and disposal shall not cause pollution and shall be undertaken consistent with national and local regulations. (iv) Ensure all storage containers are in good condition with proper labeling. (v) Regularly check containers for leakage and undertake necessary repair or replacement. (vi) Store hazardous materials above flood level. (vii) Equipment maintenance areas shall be provided with drainage leading to an oil-water separator that will be regularly skimmed of oil and maintained

Workers camp sites

Some fuel tanks are not stored in fuel storage area Spill clean up materials are not available. No proper hazardous waste segregation and storation. Major infringement

Contractor should properly manage oily and hazardous wastes, included oily wastes following the MONRE regulation. This measure should be implemented immediately.


182

Project activities

(1)


Impacts (2)


Location (4)


EEMC (5)


(6) to ensure efficiency. Discharge of oil contaminated water shall be prohibited. 68. Provide information on waste management in training program for workers, including how to manage hazardous wastes. Train relevant construction personnel in handling of fuels and spill control procedures

Workers camp

conduct and

construction sites

This measure was implemented but not for all workers Minor infringement

Contractor should conduct training program on hazardous waste management for all engineers and workers This program should be done in 2016.

69. All excavation spoils that will be re-used shall be collected and stored with adequate protection for dust control and erosion. The spoils shall be temporarily stored in areas close to the construction site but more than 200 from residential, commercial, cultural sites and other sensitive receptors.

Project site

On road construction side, the dredged soil is used to make road embankment. Compliance


Project site

No disposal of construction waste into fields, ponds, rivers and canals. Compliance

71. Where significant amount of oily wastewater or spill/leakage of oil and grease may occur (e.g., equipment maintenance areas), oil/water separators shall be provided for treatment of wastewater

Project site

No significant amount of oily wastewater or spill/leakage of oil and grease may occurred. This measure was


183

Project activities

(1)


Impacts (2)


Location (4)


EEMC (5)


(6) not used.


Project site

Contractors has sign contract with environmental service enterprises of districts for safe disposal of wastes Compliance

73.Burning wastes at the construction site is prohibited. Except for burning cut trees with following conditions: only a small volume (<100kg/time); far from camps, fuel storage, residential sites (over 500m); with availability of fire control facilities and manpower.

Project site

No burning wastes at the construction and worker camp areas Compliance

74. Properly plan a spoils disposal area at each construction site. This area shall be approved by the local authority and shall be located 300m from residential sites and well protected by fences or walls.

Project site

The spoil disposal site complied with the requirements Compliance


Project site and

surrounding area

This measure is implemented . Compliance

- Increased river/canal/pond siltation affecting local


Project site

Construction wastes are collected but not well segregated by

Construction waste segregation should be done strictly


184

Project activities

(1)


Impacts (2)


Location (4)


EEMC (5)


(6) aquaculture, aquatic ecosystem.

the sanitation team Minor infringement


Project site

Segregation of construction wastes into non-hazardous and hazardous wastes were not well implemented. Major infringement

Contractor should properly collect and segregate construction wastes into non-hazardous and hazardous wastes. This measure should be done immediately.

78. Sign a contract with district or provincial environmental service unit, (for example HCMC URENCO, Dong Nai URENCO, or Long An URENCO), to weekly transport all amount of hazardous solid wastes to the provincial/ district treatment sites

Project site



Project site

This measure was

implemented

Compliance


Project site

Due to spoil disposal site is under management of other agency so the contractor is not responsible


185

Project activities

(1)


Impacts (2)


Location (4)


EEMC (5)


(6) for this measure.


Reduction of vegetation cover, affecting local biological resource, creating increased soil erosion


Project site

No cutting trees outside the project ROW Compliance


Project site

This measure is not necessary because in Package A2-2 there is not mangroves area.


- Damage to access roads and increased traffic congestion provincial Road 50 and other roads. - Traffic accidents


Project commun

es



Project commun

es

Traffic signal boards and traffic advisory signs at the roads are installed but at some residential sites they are not so clear. Lighting at night at construction sites is sufficient. Minor infringement

Contractor should install more traffic signal boards and traffic advisory signs. This measure should be implemented before 30th June 2016

85. Access roads damaged during Project Road


186

Project activities

(1)


Impacts (2)


Location (4)


EEMC (5)


(6) transport of construction materials and other project-related activities shall be reinstated upon completion of construction works at each section.

communes

damaged by truck movement is not repaired because construction is not completed.

.

Noise, dust pollution


Project commun

es

This measure is

implemented

Compliance


Project commun

es

Watering of access roads during dry days is done but dust pollution still occurs Minor infringement

Contractor should increase watering. This measure should be done immediately.


Road embankment could obstruct water flow, causing inundation of surrounding areas

88. Design and construct appropriate cross drainage systems with suitable dimensions and appropriate location to avoid flooding on areas alongside the road embankment,

Project commun

es

This measure was implemented. This was checked by CSC. Compliance


Project commun

es

No filling up canals and creeks at the construction site Compliance


187

Project activities

(1)


Impacts (2)


Location (4)


EEMC (5)


(6)

10. Specific issue: Construction of bridges In this package 4 bridges (Ong Thin: 711 m; Viaduct over NH50; Viaduct over interchange with NH50; Ong Nam bridge) are under construction.

Construction worker camps: causing impacts similar with those at road construction


Bridge construction site

The bridges are constructed at the same time by the same contractor with road construction. Construction worker camps: cause impacts similar with those at road construction. Therefore, assessment of the compliance of the contractor with each measure required in the EMP is the same as one in items 19-37 above.

Increased noise and vibration causing impacts similar with those at road construction



Noise and vibration cause impacts similar with those at road construction. Therefore, assessment of the compliance of the contractor with each measure


188

Project activities

(1)


Impacts (2)


Location (4)


EEMC (5)


(6) required in the EMP is the same as one in items 40-45 above.

Domestic and construction waste generation causing the impacts similar to those at road construction



Domestic and construction waste generation cause the impacts similar to those at road construction. Therefore, assessment of the compliance of the contractor with each measure required in the EMP is the same as one in items 74-85.

Air pollution caused by earth works and material transport



Air pollution generated by earth works and material transport cause the impacts similar to those at road construction. Therefore, assessment of the compliance of the contractor with each


189

Project activities

(1)


Impacts (2)


Location (4)


EEMC (5)


(6) measure required in the EMP is the same as one in items 52-56 above.




Vegetation clearing within the bridge construction areas was done before construction.

95. Firmly consolidate river banks using stones, concrete and other suitable retaining measures at each bridge construction site and ensure that water courses (rivers, canals, etc.) shall be kept free of excavation spoil and construction debris, floating and submerged. Spoil and construction materials stockpile area shall be located away from water bodies and under no circumstances will these materials be dumped into watercourses.





At the proposed sites for bridge construction no mangrove trees (only very few Nipa palm trees grown). Mangrove replanting plan is not necessary.

Operation of barges for

97. Discharge of untreated waste water and release of rubbish from barges shall

Bridge construct

At the field visit (March


190

Project activities

(1)


Impacts (2)


Location (4)


EEMC (5)


(6) material transport, causing water pollution by wastes, fuel leakage

be prohibited. Solid wastes shall be periodically collected and transported to disposal sites approved/licensed by local authorities.

ion site 2016) no construction at the river banks implemented. No operation of barges for material transport











102. The contractor shall ensure that barge owners involved in bridge construction shall have an oil spill prevention and response plan and relevant technical facilities for its implementation. In case of spills of oil and other hazardous substances, the contractor shall implement the following measures: (i) Immediately inform the Saigon Port Authority, who is responsible for waterway transport in Ho Chi Minh City and surrounding region. (ii) Engage oil spill removal companies and local authorities to immediately respond to oil spill incidents caused by the Project. (iii) Immediately inform communes which may be affected by oil the spill. (iv) After the oil spill has been controlled/removed, the contractor will coordinate with the relevant local communes to address land and water pollution caused by the spill, and to provide compensation for



191

Project activities

(1)


Impacts (2)


Location (4)


EEMC (5)


(6) environmental and economic damages, following the relevant Vietnamese laws and guidelines.


Social impacts (employment/livelihood, health risks)


Project site

Almost all workers come

from other place.

Minor infringement

When volume of construction will be increased contractor should employ more local people, especially young people of the affected and vulnerable affected households.


Project site

Contractor cooperated with the local PCs to minimize the adverse effects of the planned construction force and unplanned migrants. Compliance


Project site

Implementation is ongoing together with A1-A4 contractors. Minor infringement

Contractor should conduct training programs on prevention of HIV/AIDs, epidemic


192

Project activities

(1)


Impacts (2)


Location (4)


EEMC (5)


(6) diseases and

other related diseases. for workers. This measure should be implemented in 2016.




Project site


Compliance


From the detailed assessment on the contractor's compliance (JO of SMCC-CIENCO 4) with EMP, can be concluded that, at the present time, the contractor has implemented various measures to prevent pollution and waste management. Most of the measures are complied with EMP. However, in the total of over 100 evaluated measures 24 measures were not complied, of which 22 measures as minor infringement and 2 measures as major infringement are evaluated. The main major infringement relates with improper management of hazardous wastes. They must be properly corrected immediately.


193

Figures on the state of environmental management at Packages A2-2, March 2016

Conduction of external environmental monitoring with representatives of contractor and construction supervision consultants

Fuel is stored without roof, fuel leakage and fire control facilities.

Fuel leakage: without oil spill control measure A batching plant: no complaints about noise and

dust pollution from local residents

This is not an equipment suitable for waste collection and segregation.

First aid box is provided at a worker camp but nothing inside.


194

Toilets areas are not separated for male and female workers

Construction waste was not properly managed.

A settlement pond at batching plant No.1 Some workers work at height do not use protective

wire

Gas tankers are stored in a separate site. Activities of a bored pile: poor spoil management


195

No fence and warning signs at a deep pond Signboard at the entrance area of concrete batching

plant No. 1, 2


196

APPENDIX 4: ASSESSMENT OF THE COMPLIANCE OF PACKAGE A3 WITH THE EMP REQUIREMENTS

Project activities

(1)

Potential Environmenta

l Negative Impacts

(2)

Proposed Mitigation Measures in the EMP cleared

by ADB (3)

Location

(4)

Level of Compliance Evaluated by

EEMC (6)

Correction Measure

Proposed by EMC

1. Preparation of CEMP- Contractual Requirement

2. Prior to commencement of any site works, each contractor shall prepare a site-specific or construction EMP (CEMP) which specifies the responsibilities, location associated costs, schedule/timeframe and other relevant information for implementing its provisions which will include the following: (i) selection of sites for material exploitation and storing, as well as sites for concrete, crushing and asphalt plants, (ii) plans for material transportation routes and timing, (iii) identification of specific disposal sites for unsuitable soils, (iv) soil erosion control measures including soil stabilization measures at disposal sites, (v) treatment of acid sulfate soils and resulting run-off, (vi) wastewater collection and treatment, (vii) construction camp management, (viii) quarry/aggregate/borrow site management and restoration, (ix) traffic management, (x) noise reduction measures including construction of temporary noise barriers, (xi) dust suppression measures, (xii) handling and storage of hazardous substances such as fuel, etc. (xiii) solid waste collection and disposal, (xiv)

Site office of the contractor

CEMP has been prepared by the Contractor and reviewed and temporarily approved on July 31st 2015 and, after revision and update, finally approved on August 17th 2015 by JV OF DASAN – KUNHWA – ICT with no objection against their proposed plan. Furthermore, the contractor already has a disposal site for unsuitable soils, which was approved by the local Environmental Management Authority (Nha Be ONRE) on September 8th 2015 and subsequently approved by


197

Project activities

(1)


l Negative Impacts

(2)


by ADB (3)

Location

(4)


EEMC (6)

Correction Measure

Proposed by EMC

replanting measures, (xv) occupational and community health and safety, (xiv) repair of damaged community facilities such as irrigation canals, etc. (xvii) emergency response plan in case of spills and other accidents involving workers and the community, (xviii) chance-find procedures measures and other applicable mitigation measures indicated in the Project EMP included in the EIA approved by ADB. The CEMP should be fully consistent with the Project EMP. Before civil works begin, the CEMP shall be reviewed by the Project Supervision Consultant and endorsed to ADB.

the construction supervision consultant on November 27th 2015 Compliance

2. Vegetation clearance

Disposal of biological waste may pollute the air and water environment, obstruct waterway transport, cause adverse aesthetic impact


Project site

All measures from 3 to 5 were followed by the contractor. Compliance


5. Burn the cut trees in accordance with national and local regulations, and only in limited cases with strict conditions (less than 100 kg at a time; more than 500m from residential areas and other sensitive receptors such as schools, hospital, culturally significant sites, etc. and fuel storage sites, 200 m from worker camps; with available and sufficient fire prevention devices and manpower for fire extinguishing and ensuring that


198

Project activities

(1)


l Negative Impacts

(2)


by ADB (3)

Location

(4)


EEMC (6)

Correction Measure

Proposed by EMC

surrounding vegetation are protected from fire; will not cause nuisance and safety risks to sensitive receptors (houses, schools, etc.) and road users in the surrounding areas.)

2. Vegetation clearance (as above)

Reduced vegetation area, causing damage to local wetland ecosystem


Outside the project site

No clearance of vegetation outside the project’s ROW Compliance


Out of the Western and Eastern banks of the concerning rivers.

Viaduct 1 was designed to go over Le Van Luong and Long Thoi – Nhon Duc roads. No mangrove in this area. Compliance

10. Implement a Mangrove Reforestation Plan (MRF) to replant mangroves for compensation of the lost mangrove area at river, canal banks due to site clearance (mainly at river, canal banks in Nha Be, Can Gio, Nhon Trach, Long Thanh districts). Detailed MRF is found in Section V.B.2 of the EIA Report.

Ba Lao Bridge crossing Can Giuoc River in Nha ba District

Not necessary because no mangrove in this area, but only some scattered Nipa palm of not high biodiversity value. Compliance


199

Project activities

(1)


l Negative Impacts

(2)


by ADB (3)

Location

(4)


EEMC (6)

Correction Measure

Proposed by EMC

3. Establishment of Construction Worker camp site


18. Implement proper solid waste management through implementation of the following measures: (i) Prohibit burning of construction and domestic waste. (ii) Do not permit disposal of solid waste into canals, rivers, other watercourses, agricultural field and public areas. Disposal shall only be to areas approved/licensed by local authorities. (iii) Properly collect and segregate domestic waste at worker camps and offices. Use rubbish bins for containing domestic solid waste (iv) Sign contract with local environmental service units for regular transport (weekly) of solid waste to disposal sites. (iv) Ensure that wastes are disposed to sites approved by local authority. (iv) Use of pits with proper lining for disposal of domestic solid waste. Location of the pits shall be over 200m from residential sites and over 100m from workers’ eating area. Before the team moves to a new construction site, trash pits shall be disinfected with lime or hypochlorite solution, then firmly covered with a 20 – 30 cm layer of soil.

Worker camp site

- There are only two 200-L steel drums used for collecting solid waste. Furthermore, they may not be suitable during rainy seasons. - Solid waste is found around on the ground and on the bank of the nearby water body. - Some solid waste was burnt just near the housing camp. - Solid waste is collected regularly by, and payable to, the local service company, without a contract. Minor infringement

- Contractor to provide a sufficient amount of suitable lidded bins for solid waste. → The contractor has already taken a corrective action by collecting the solid waste improperly disposed of on the ground on April 11th 2016. - The contractor is to sign a contract with local service company for regular transport of solid waste to approved disposal sites

Sanitary wastes (sewage) from

19. Provide efficient and clean mobile toilets for each construction site (separate

Project site

- Mobile toilets provided at


200

Project activities

(1)


l Negative Impacts

(2)


by ADB (3)

Location

(4)


EEMC (6)

Correction Measure

Proposed by EMC

workers, causing water, air, land pollution, and diseases.

facilities shall be provided for male and female workers).

construction sites. - Toilets with septic tanks are provided at worker camp. - Clean water for hand washing at toilet and sufficient water for bathing and sanitation purposes is provided. - Separationof toilets/bathing areas for male and female. Compliance


Project site


Worker camp site


Worker camp site


Worker camp site

No rubbish bins were provided at the toilet area. Minor infringement

→ The contractor has already taken a corrective action by providing a rubbish bin at the toilet area on April 11th 2016.

Conflict between workers and

24. Employ, as much as possible, local people as construction workers and

Communes where

- No information on employing


201

Project activities

(1)


l Negative Impacts

(2)


by ADB (3)

Location

(4)


EEMC (6)

Correction Measure

Proposed by EMC

local residents and community disturbance

prioritize opportunities for the PAHs. Implement suitable training programs for local workers.

the project is located in

local people. - So far no conflicts between workers and local residents nor community disturbance were reported Compliance


Project site and communes where the project is located in

Similar content is included in the regular monthly OHS training. compliance

26. Establish a grievance redress mechanism (GRM), well guide local residents to apply GRM; provide local communities information on the upcoming construction activities; record any complaints received and respond to them based on the GRM, properly cooperate with local PCs, DONREs, social associations to properly solve claims of the PAHs and problems related to environmental issues related to the project.

Communes where the project is located in

- As reported by the contractor, a project information blackboard is under preparation - No hotline provided for local residents for directly receiving complaints from local residents. Minor

The contractor is to establish a grievance redress mechanism and provide a hotline for receiving complaints from local residents. This measure must be completed before 30th June 2016


202

Project activities

(1)


l Negative Impacts

(2)


by ADB (3)

Location

(4)


EEMC (6)

Correction Measure

Proposed by EMC

infringement.



Before commencement, the contractor had informed Nha Be PC (in written) about the project area and implementation plan. Compliance



- As reported by the contractor, regular meetings are held with officers of both commune and district PCs regarding the project implementation. Compliance

Transmission of infectious diseases from local people to workers and vice versa and other health and safety


Project site and communes where the project is

- A Baseline Survey for HIV Prevention Activities was submitted by the contractor on December

- The contractor to have the HIV Prevention Program for Construction Workers approved


203

Project activities

(1)


l Negative Impacts

(2)


by ADB (3)

Location

(4)


EEMC (6)

Correction Measure

Proposed by EMC

issues.

located in

14th 2015. There is however no proof of such orientation, nor evidence that workers were specifically trained in prevention of HIV/AIDS and other related diseases. - No leaflets at project site or worker camp site. Minor infringement.

and subsequently to implement the program as soon as possible.


Worker camp site

Workers are provided with clean and safe food and potable water in sufficient amount. Compliance


Project site and worker camp site

- Insufficient amount of rubbish bins (currently 200-L steel drums) at both project site and worker camp.

- The contractor to provide more (lidded) rubbish bins at both worker camp and project site.


204

Project activities

(1)


l Negative Impacts

(2)


by ADB (3)

Location

(4)


EEMC (6)

Correction Measure

Proposed by EMC

- Rubbish is collected regularly by the local service company, though without a contract. Minor infringement

- The contractor is to sign a contract with local service company for weekly transport of rubbish to district's treatment sites. The above measures should be finished before 30th June 2016


Construction and worker camp site

Measures 32 are implemented. Compliance





Worker camp site


Project


205

Project activities

(1)


l Negative Impacts

(2)


by ADB (3)

Location

(4)


EEMC (6)

Correction Measure

Proposed by EMC

35. Install sign boards, lighting system at the construction sites, borrow pits, or places which may cause accidents for people and workers

site Measures 35 are implemented. Compliance





Workercamp site

Measure 37 was implemented. Compliance


Storm water from construction sites, improper stockpiling of spoils and construction materials, haphazard spoils disposal, soil erosion and land slide at construction sites, causing damage to roads, polluting of canals, rivers and pond; and obstruction of flow of water courses.


Project site

The contractor reported that design is good for erosion and storm water control. This was confirmed by CSC. Compliance


Project site

Not necessary because there are no mangrove at the project area


206

Project activities

(1)


l Negative Impacts

(2)


by ADB (3)

Location

(4)


EEMC (6)

Correction Measure

Proposed by EMC

40. (viii) Provide grass cover and other suitable slope stabilization measures on road embankment slopes and on long term stockpile of spoils (ix) Spoil disposal shall not cause sedimentation and obstruction of flow of watercourses, damage to agricultural land and densely vegetated areas. (x) The spoils disposal site shall be located at least 50m from surface water courses and shall be protected from erosion by avoiding formation of steep slopes and grassing. (xi) Spoils shall only be disposed to areas approved by local authority. (xii) Water courses (rivers, canals, etc.) shall be kept free of excavation spoil and construction debris, floating and submerged. (xiii) Spoil and construction materials stockpile area shall be located away from waterbodies and under no circumstances will these materials be dumped into watercourses. (xiv) Dredged and excavated materials shall be reused or provided to local residents as soon as possible, if they require such materials, for land reclamation. The remaining spoils can be disposed into low elevation sites for road construction. (xv) Provide temporary sediment traps (ditches and

Project site

- Waste soil generated from bored pileshas partly been used for leveling onsite and currently reaches a Nipa palm water body nearby, without being isolated by an embankment. The situation could be worse during the coming rainy season. - Part of excavated materials is still around. Minor infringement

- The contractor is to provide an embankment to isolate the leveling waste soil from the nearby water body. - The contractor is to reuse or give the remainingexcavated materials to local residents as soon as possible.


207

Project activities

(1)


l Negative Impacts

(2)


by ADB (3)

Location

(4)


EEMC (6)

Correction Measure

Proposed by EMC

ponds) if high sediment laden runoff are observed. 41. Design and install culverts and drainage systems to avoid flooding

Project site



42. (i) Select proper places for setting up borrow pits to avoid areas of serious acid sulfate and saline soils and to avoid encroachment into forest, cultivation, commercial and residential areas. Borrow sites shall be covered by necessary environmental permits/licenses and shall be located over 300m away from residential, commercial, cultural sites and other sensitive receptors (schools, hospital, etc.). (ii) Proper soil erosion control during borrow pits construction and operation by proper design and installation of adequate drainage system. (iii) Proper control of storm water at borrow sites in the rainy season by using sediment traps, treatment of turbidity, strong acidic water (by lime) and oil separation water if high turbidity, high acidity or high oil content were found. (iv) Proper dust control during dredging, excavation at borrow sites and earth transport. (v) Topsoil (about 15 cm) will be kept and refilled after excavation is over,

Borrow areas

- A3 Package will not directly explore any borrow pits for construction materials. Instead, sub-contractor have been selected for supplying all raw materials for construction. - All planned construction material suppliers have been agreed by the CSC and submitted to EPMU for consideration and approval (PDF copies are available) Compliance


208

Project activities

(1)


l Negative Impacts

(2)


by ADB (3)

Location

(4)


EEMC (6)

Correction Measure

Proposed by EMC

(vi) Long – term material stockpiles will be covered to prevent wind erosion, (vii) Upon completion of extraction activities, re-contour borrow/quarry pit wall or fill-up when there are available and suitable materials such as excavation spoils, replace topsoil, and re-vegetate with native species such as grasses and fast-growing shrubs, (viii) Quarries and borrow pits will not be established in national, provincial, district and village conservation forests and other protected sites, (ix) Operation of existing quarry/borrow sites shall be preferred over establishment of new sites, as much as possible, (x) In case the Project will involve new quarry/borrow sites, necessary approvals from environmental authorities shall be obtained prior to operation of such sites, (xi) During borrow site operation, provide adequate drainage to avoid accumulation of stagnant water, (xii) Borrow/quarry sites shall not be located in productive land and forested areas, (xiii) Upon completion of extraction activities, borrow pits shall be dewatered and fences shall be installed, as appropriate, to minimize health and safety risks. (xiv) Borrow pits will be left in a tidy state with stable side slopes and proper drainage in


209

Project activities

(1)


l Negative Impacts

(2)


by ADB (3)

Location

(4)


EEMC (6)

Correction Measure

Proposed by EMC

order to avoid erosion (xv) To avoid drowning when pits become water-filled, measures such as fencing, providing flotation devices such as a buoy tied to a rope, etc. shall be implemented. (xvi) It is possible that villagers may request borrow pits to be excavated so that they may be used as water reservoirs or fishponds. If this were to be agreed between the contractors and the villagers, all the full safety measures detailed above must be observed. Such agreements would be formalized in writing between the contractors and the villagers after full discussion with all concerned parties.



Construction site

- The construction-related activities, as observed on site and through experiences from other packages, seemingly cause certain noise. The actual situation is, however, not available from local residents since no public consultation was held.

- The contractor is to monitor noise at households nearby high noise sources (i.e. batching plant) and implement countermeasures If the noise actually exceeds the allowable levels.


210

Project activities

(1)


l Negative Impacts

(2)


by ADB (3)

Location

(4)


EEMC (6)

Correction Measure

Proposed by EMC

- As reported by the contractor, loud noise generating machines work only during 06:00-11:30 and 13:30-18:00. Compliance


- Concrete mixers and batching plants, through experiences from other packages, seemingly generate a reasonable amount of dust. - Since batching plant No.2 does not meet the 300m distance requirement, a 6m height steel blinding fence and net fence has been instanlled by the contractor to minimize

- The contractor is to monitor dust and noise at the nearby residential area and implement countermeasures If the dust and noise actually exceed the allowable levels. This measure should be implemented before 30th June 2016


211

Project activities

(1)


l Negative Impacts

(2)


by ADB (3)

Location

(4)


EEMC (6)

Correction Measure

Proposed by EMC

both noise and dust generation to the neiboghhood. This has been checked by the CSC and submitted to EPMU on April 25th 2016 for consideration. Minor infringement


Construction site

Measure 45 was done Compliance

46. Impose speed limits on construction vehicles to minimize noise emission along areas where sensitive receptors are located (houses, schools, hospitals)

Measure 46 was done. Compliance


Construction site

Loud noise generating machines work only during 06:00-11:30 and 13:30-18:00. Compliance

48. Install noise control walls (3.0-4.5m high, thick materials) at high noise sources that affect

Construction site

There are no sensitive receptors in


212

Project activities

(1)


l Negative Impacts

(2)


by ADB (3)

Location

(4)


EEMC (6)

Correction Measure

Proposed by EMC

sensitive receptors (temples, pagodas, churches, schools)

the vicinity.


Project communes



Construction site

Measure 50 was done (through interviews with the drivers and construction machines operators) Compliance


Construction site

There was no loud noise during the field visit. No workers were therefore found to use such kind of PPE.

Air pollution (dust, NOx, SO2, CO, Pb, VOC) caused by earth works and other construction activities

52. On rainless day undertake watering, at least twice per day, on dusty and exposed areas at construction yards, materials stockpile, within and in the vicinity of concrete mixing stations, construction sites and access roads where residential

Construction site, concrete mixing stations, materials

- It was not too dusty during the field survey. - Measure 52 is implemented


213

Project activities

(1)


l Negative Impacts

(2)


by ADB (3)

Location

(4)


EEMC (6)

Correction Measure

Proposed by EMC

areas and other sensitive receptors

stockpile areas, and access roads

Compliance

53. In addition to watering the zones in front of and inside concrete mixing stations, the following measures shall also be implemented to reduce impacts due to dust emissions: i) Concrete mixers and asphalt stations shall be located at least 300m from residential areas, hospitals, schools, and other sensitive receptors. ii) Ditches of 4 x 10 x 0.3 m (L x W x D) would be made by contractors in order to wash vehicles before they go out of the stations. This measure is necessary for concrete mixing stations where the dust content is very high as it keeps down soil and sand adhering to vehicle wheels. These are highly feasible measures. The best measure is to wash truck body and tires before moving out of the construction to urban areas. iii) Provide enclosing walls (3.0 – 4.0 m in high) around the construction sites that are near sensitive receptors (schools, populated areas, churches, pagodas, etc.).

Concrete mixing plants, construction sites

- Since batching plant No.2 does not meet the 300m distance requirement, a 6m height steel blinding fence has been to minimize the noise. This has been checked by the CSC and submitted to EPMU on April25th 2016 for consideration. Minor infringement

- The contractor is to monitor dust and noise at the nearby residential area and implement countermeasures If the dust and noise actually exceed the allowable levels. This measure should be implemented before 30th June 2016


Access roads

Measure 54 is applied. Compliance


214

Project activities

(1)


l Negative Impacts

(2)


by ADB (3)

Location

(4)


EEMC (6)

Correction Measure

Proposed by EMC



Dredged spoil was not compacted. The surface of dredged spoil sites was not covered by dense plastic sheets to prevent dust dispersion. Minor infringement

- The contractor is to compact the dredged soil and cover the spoil storage sites dense plastic sheets as soon as possible.



Measure 54 is applied. PDF copies of all licenses and registration certificates are available. Compliance



Construction site and surrounding area

- No expanding the project ROW - There are no wetland nor mangrove forest in the project area.


Construction site and surroun

No cutting trees outside the project area


215

Project activities

(1)


l Negative Impacts

(2)


by ADB (3)

Location

(4)


EEMC (6)

Correction Measure

Proposed by EMC

ding area

Compliance

59. Prior to commencement of construction activities on site identify and mark with suitable visual reminders the areas of mangroves that are not to be disturbed during the works. This measure is recommended for the construction site at the banks of Soai Rap, Long Tau and Thi Vai rivers where belts of mangrove trees occur.


- There are no mangroves in the project area.

60. Do not dispose dredging spoils and all types of waste onto mangrove forest areas, agricultural land, densely vegetated areas, and water courses.





Measure 61 is implemented Compliance


62. Provide firefighting equipment at the work areas, as appropriate, and at construction camps.

Project site

Firefighting equipment at the work areas, as appropriate, and at construction camps is provided. Compliance

63. Provide workers with appropriate safety equipment/devices (such as

Project site

Measure 63 is implemented


216

Project activities

(1)


l Negative Impacts

(2)


by ADB (3)

Location

(4)


EEMC (6)

Correction Measure

Proposed by EMC

dust mask, hard hats, safety shoes, goggles, ear plugs, etc.) and strictly require them to use these as necessary.

Compliance





Project site

Measure 65 is implemented. Compliance

66. The general public/local residents shall not be allowed in high – risk areas, e.g. excavation sites and areas where heavy equipment is in operation.

Project site


5. Specific issues: Dredging, filling, cutting

Acidification of soil and water caused by earth filling/cutting

67. Install temporary shallow ponds (ground for containing dredged materials) and settlement pond at the construction sites which are

Project site

At present, no run –off water nor high acidity water generated at


217

Project activities

(1)


l Negative Impacts

(2)


by ADB (3)

Location

(4)


EEMC (6)

Correction Measure

Proposed by EMC

activities during road construction at ASS areas

activities at acid sulfate soil (ASS) area. Consequently, aquaculture and aquatic organisms in the acidified canals, ponds could be affected.

highly affected by acidic water, to receive run-off water containing acidic materials, neutralize acidic water if its pH <5 or lower than pH value of surrounding water prior to discharge into fields or canals.

the construction area. This measure is therefore not needed.

68. Use lime to neutralize acidic storm-water and run-off from construction site with pH<5 (if this acidity is created by the project activities) at places close to water intake site for domestic use, agricultural land, aquaculture pond and in other areas where acidic water is generated by project activities

Project site

At present, no run –off water nor high acidity water generated at the construction area. This measure is therefore not needed.


Project site

At present, no run –off water nor high acidity water generated at the construction area.This measure is therefore not needed.

70. In case that ASS spoil is heaped up along the road, in order to avoid of the transfer of sulfate water to agriculture and aquaculture land, construction contractors shall design and utilize storing grounds with enclosure of suitable width and height. The capacity of a storing

Project site

At present, no run–off water nor high acidity water generated at the construction area.This measure is


218

Project activities

(1)


l Negative Impacts

(2)


by ADB (3)

Location

(4)


EEMC (6)

Correction Measure

Proposed by EMC

ground is determined on a case by case basis to adequately accommodate spoils and shall be compacted to avoid erosion and percolation.

therefore not needed.


Project site

At present, no run–off water nor high acidity water generated at the construction area.This measure is therefore not needed.


Project site

So far no report on nor complaints about the project impacts on fish and shrimp. Compliance

6. Use of hazardous substances (fuel, oil, etc.), generation of construction and domestic waste

- Surface water, groundwater, air, land pollution caused by spills and construction wastes and excavation spoils - Adverse


Project site

Dredged soil storage sites are not close to residential areas. This measure is therefore not needed.

74. Arrange different kinds of rubbish bins for collection and

Worker camp

- Insufficient amount of

- The contractor to


219

Project activities

(1)


l Negative Impacts

(2)


by ADB (3)

Location

(4)


EEMC (6)

Correction Measure

Proposed by EMC

impacts on cultivated areas and aquaculture - Aesthetic issues

segregation of domestic waste, hazardous waste around construction, and workers’ camp site.

and construction sites,

rubbish bins (currently 200-L steel drums and half 200-L plastic drums) at project site and worker camp. - Poor segregation leads to mixing up oil rags with general waste. Major infringement

provide a sufficient amount of rubbish bins with name plate at both project sites and worker camp - The contractor is to train workers be able to segregate the two main types of waste properly. The above measures must be implemented before 30th Jue 2016

75. In cases when construction sites that last for more than 6 months (for building bridges), construction contractors can build pits for receiving and disposing of domestic solid waste. The pit should be located over 100m from boundary of the nearest residential area

Domestic solid waste is collected and transported by a local service company. Measure 75 is therefore not needed.

76. Make drainage ditches at worker camp site and construction sites to prevent flow of storm water to cultivated land and aquaculture areas.

Worker camp and construction

Waste soil generated from bored piles currently reaches a

- The contractor is to make a drainage ditch or


220

Project activities

(1)


l Negative Impacts

(2)


by ADB (3)

Location

(4)


EEMC (6)

Correction Measure

Proposed by EMC

sites, Nipa palm water body nearby, without any prevention measures. Major infringement

embankment to prevent storm water. This measure should be implemented as soon as posible.

77. Implement the following measures for handling hazardous substances and wastes: (viii) Store fuel and hazardous substances in paved areas with roof and embankment. If spills or leaks do occur, undertake immediate clean up. (ix) Ensure availability of spill cleanup materials (e.g., absorbent pads, etc.) specifically designed for petroleum products and other hazardous substances where such materials are being stored. (x) Segregate hazardous wastes (oily wastes, used batteries, fuel drums) and ensure that storage, transport and disposal shall not cause pollution and shall be undertaken consistent with national and local regulations. (xi) Ensure all storage containers are in good condition with proper labeling. (xii) Regularly check containers for leakage and undertake necessary repair or replacement. (xiii) Store hazardous

Construction sites

- 200-L steel drums and 30-L plastic cans (supposedly containing oil and/or lubricant, but with no labeling) are laying around, even just above surface water. - Spill cleanup materials are not available. - Poor segregation leads to mixing up oil rags with general waste - No labeling for (oil and/or lubricant) storage containers. - Equipment maintenance

The contractor has already removed the used oil cans from the final discharge point and cleaned up some oil polluted sites on April 11th 2016. The contractor has already constructed a concrete floor with a spill collection embankment for placing oil and lubricant drums on April 11th 2016. - The contractor is to immediately clean up the oil polluted


221

Project activities

(1)


l Negative Impacts

(2)


by ADB (3)

Location

(4)


EEMC (6)

Correction Measure

Proposed by EMC

materials above flood level. (xiv) Equipment maintenance areas shall be provided with drainage leading to an oil-water separator that will be regularly skimmed of oil and maintained to ensure efficiency. Discharge of oil contaminated water shall be prohibited.

is carried out here and there, even nearby the water, without any prevention measures (i.e. liners, pads, oil separators etc.), causing oil pollution to both soil and possibly water. - No embankment sourrounding the concrete additive tanks. - No storage for hazardous waste Major infringment

soil at the equipment maintenance sites. - The contractor is to urgently organize an appropriate storage for hazardous waste. - The contractor is to urgently provide prevention measures (e.g. liners, absorption pads etc.) and have them applied at the equipment maintenance sites. - The contractor is to immediately provide embankments sourrounding the concrete additive tanks. - The contractor is to immediately provide more containers/bi


222

Project activities

(1)


l Negative Impacts

(2)


by ADB (3)

Location

(4)


EEMC (6)

Correction Measure

Proposed by EMC

ns for colletingboth hazardous and domestic waste. - The contractor is to (re)train workers in segregation and handling of hazardous waste.

78. Provide information on waste management in training program for workers, including how to manage hazardous wastes. Train relevant construction personnel in handling of fuels and spill control procedures

Worker camp and construction sites

Specific training for management of hazardous wastes was not implemented. Minor infringement

The contractor to provide training in waste management for workers, including hazardous waste management, especially in handling of fuels and spill control procedures

79. All excavation spoils that will be re-used shall be collected and stored with adequate protection for dust control and erosion. The spoils shall be temporarily stored in areas close to the construction site but more than 200m from residential, commercial, cultural sites and other sensitive

Project site

Excavation spoils are partly re-used for leveling onsite and currently reach a Nipa palm water body nearby, without

- The contractor is to provide an embankment to isolate the excavation spoils from the nearby water body.


223

Project activities

(1)


l Negative Impacts

(2)


by ADB (3)

Location

(4)


EEMC (6)

Correction Measure

Proposed by EMC

receptors.

adequate protection for dust control and erosion. The situation could be worse during the coming rainy season. Minor infringement

- The contractor is to implement appropriate protection measures or give the remaining spoils to local residents as soon as possible.


Project site

No disposal of construction waste into fields, ponds, rivers and canals. Compliance


Project site

There is evidence of waste oil on surface water near the project site, but oil/water separators are not provided for treatment of wastewater Major infringement

- An oil/water separator could be installed before final discharge of wastewater into the river. - It is however important that the contractor provide absorption pads or mats and/or plastic


224

Project activities

(1)


l Negative Impacts

(2)


by ADB (3)

Location

(4)


EEMC (6)

Correction Measure

Proposed by EMC

sheets to collect waste oil at equipment maintenance sites. This measure should be implemented as soon as possible.


Project site

Wastes are collected and transported from the sites regularly by a local service company, but no contracts have been signed. Minor infringement

The contractor is to sign a contract with the local waste collection service company. This measure should be implemented as soon as possible.


Project site

No burning of wastes at the construction site. Compliance

84. Properly plan a spoils disposal area at each

Project site

Measure 84 is implemented.


225

Project activities

(1)


l Negative Impacts

(2)


by ADB (3)

Location

(4)


EEMC (6)

Correction Measure

Proposed by EMC

construction site. This area shall be approved by the local authority and shall be located 300m from residential sites and well protected by fences or walls.

Compliance


Project site and surrounding area

Part of dredged spoils not re-used for leveling onsite currently stills remains at project site. Minor infringement

The contractor is to allow local people or companies to take it away for soil reclamation as soon as possible.



Project site



Project site

- There is insufficient amount of waste containers at the project site. - Hazardous waste is often found mixed with non-hazardous waste. Major

- The contractor to provide more waste containers - The contractor to train workers better in segregation, collection and handling of hazardous waste. This


226

Project activities

(1)


l Negative Impacts

(2)


by ADB (3)

Location

(4)


EEMC (6)

Correction Measure

Proposed by EMC

infringement

measure should be implemented as soon as possible.

88. Sign a contract with district or provincial environmental service unit, (for example HCMC URENCO, Dong Nai URENCO, or Long An URENCO), to weekly transport all amount of hazardous solid waste to the provincial/ district treatment sites

Project site

So far no contracts with a local environmental service company to transport hazardous solid waste. Minor infringement

The contractor is to sign a contract with a local service company to transport all hazardous solid waste to the approved treatment sites. This measure should be implemented as soon as possible.


Project site

- Dredged spoils are partly re-used for leveling onsite and currently reach a Nipa palm water body nearby, without adequate protection for dust control and erosion. The situation could be

- The contractor is to implement appropriate protection measures or give the remaining spoils to local residents as soon as possible.


227

Project activities

(1)


l Negative Impacts

(2)


by ADB (3)

Location

(4)


EEMC (6)

Correction Measure

Proposed by EMC

worse during the coming rainy season. Minor infringement


Project site

Growing grasson excavated soil storage site is not necessary because duration for excavated soil storage is short.


Reduction of vegetation cover, affecting local biological resource, creating increased soil erosion


Project site



Project site

No cutting trees outside the project ROW and Package A3 is not located at Thi vai river banks. This measure is therefore not needed.

8. Transport of construction

- Damage to access roads and increased

93. In cooperation with provincial Department of Transport (DOT) and Transport

Project communes



228

Project activities

(1)


l Negative Impacts

(2)


by ADB (3)

Location

(4)


EEMC (6)

Correction Measure

Proposed by EMC

materials

traffic congestion provincial Road 50 and other roads. - Traffic accidents

Police to properly organize transport of materials for the project. As much as possible, schedule delivery of construction materials and equipment during non-peak hours.

Compliance


Project communes



Project communes

Not yet implemented because the project is still under construction now.

- Noise, dust pollution


Project communes


97. Watering of access roads during dry days shall be undertaken along densely populated areas and where

Project communes



229

Project activities

(1)


l Negative Impacts

(2)


by ADB (3)

Location

(4)


EEMC (6)

Correction Measure

Proposed by EMC

there other sensitive receptors are found such as schools, temples, hospital, etc.



98. Design and construct appropriate cross drainage systems with suitable dimensions and appropriate location to avoid flooding on areas alongside the road embankment

Project communes



Project communes


10. Specific issue: Construction of bridges




Construction of bridges has not yet been implemented





Domestic and construction

102. Similar mitigation measures suggested in items

Bridge construc

Construction of bridges has


230

Project activities

(1)


l Negative Impacts

(2)


by ADB (3)

Location

(4)


EEMC (6)

Correction Measure

Proposed by EMC

waste generation causing the impacts similar to those at road construction

74-85 tion site

not yet been implemented












106. Plant mangrove trees along the river/canal banks close to the bridge construction sites. Width and length of mangrove area to be planted are about 5m*100m (each site




231

Project activities

(1)


l Negative Impacts

(2)


by ADB (3)

Location

(4)


EEMC (6)

Correction Measure

Proposed by EMC

at each river bank), depending on each location.

Operation of barges for material transport, causing water pollution by wastes, fuel leakage

107. Discharge of untreated waste water and release of rubbish from barges shall be prohibited. Solid waste shall be periodically collected and transported to disposal sites approved/licensed by local authorities.
















112. The contractor shall ensure that barge owners involved in bridge construction shall have an oil spill prevention and response plan and relevant technical facilities for its




232

Project activities

(1)


l Negative Impacts

(2)


by ADB (3)

Location

(4)


EEMC (6)

Correction Measure

Proposed by EMC

implementation. In case of spills of oil and other hazardous substances, the contractor shall implement the following measures: (i) Immediately inform the Saigon Port Authority, who is responsible for waterway transport in Ho Chi Minh City and surrounding region. (ii) Engage oil spill removal companies and local authorities to immediately respond to oil spill incidents caused by the Project. (iii) Immediately inform communes which may be affected by oil the spill. (iv) After the oil spill has been controlled/removed, the contractor will coordinate with the relevant local communes to address land and water pollution caused by the spill, and to provide compensation for environmental and economic damages, following the relevant Vietnamese laws and guidelines.


- Social impacts (employment/livelihood, health risks)

113. - Implementation of proper measures to maximize local employment to minimize the numbers of non-local workers employed at the project site. - Severely affected and vulnerable affected persons will be prioritized in gaining employment in the works. As a minimum, in each severely affected household, one person of working age will be prioritized in gaining employment during

Project site

- Currently no exact data are available regarding this issue. Though all supportive works (cooks, cleaners etc.) met are local. - This issue may best be addressed when a large


233

Project activities

(1)


l Negative Impacts

(2)


by ADB (3)

Location

(4)


EEMC (6)

Correction Measure

Proposed by EMC

the construction phase, if he/she is qualified.

number of workers will be employed.


Project site

This measure may best be addressed when a large number of (unplanned non-local) workers will be employed.

115. Conduct orientation for construction workers on prevention of HIV/AIDs, epidemic diseases such as water-borne and vector-borne diseases and other related diseases.

Project site

- A Baseline Survey for HIV Prevention Activities was submitted by the contractor on December 14th 2015. There is however no proof of such orientation, nor evidence that workers were trained in prevention of HIV/AIDS and other related diseases. - No leaflets at project site or worker camp site.

- The contractor to have the HIV Prevention Program for Construction Workers approved and subsequently to implement the program as soon as possible.


234

Project activities

(1)


l Negative Impacts

(2)


by ADB (3)

Location

(4)


EEMC (6)

Correction Measure

Proposed by EMC

Minor infringement.




Project site

- No cultural heritage at ROW of Package A3. - No physical historical objectives found at A3 section. - Though the contractor is aware of the procedure if these happen Compliance


From the above evaluation on compliance of the A3 Package’s contractor (Joint Venture of Halla Corp – Vinaconex Eng.Cons. & Invest.JSC) with the EMP it may conclude that at present the contractor has implemented various measures for impact mitigation, pollution prevention and waste management. Most of the implemented measures comply with the EMP. However, in the total of over 100 evaluated measures 21 measures were not complied, of which 16 measures as minor infringement and 5 measures as major infringement are evaluated. The main major infringement relates with improper management of hazardous wastes. They must be properly corrected immediately.


235

Figures on the present state of environmental management at Packages A3, March 2016

Used oil cans are not well managed. A drum full with used lubricant is placed in a dangerous position and can easily cause spillage

Used oil and/or lubricant drums are not well managed


236

Oil and/or lubricant drums, without labelling, laying around here and there at the construction site

No embankments sourrounding the concrete additive tanks

Poor pipeline connection causes water leakage at the water cooling tower

Equipment maitenance conducted just above the surface water receiving body without any oil pollution prevention measures


237

Equipment maitenance conducted here and there at the project construction sites without any oil pollution prevention measures

Dredged soil is partly re-used on-site, currently reaches a Nipa palm water body nearby, without being isolated by an embankment,not compacted


238

Due to the lack of sufficient amount of containers/bins and poor handling, waste is around at the construction site and hazardous rcations (mainly oil gloves and rags) are often found mixed up with domestic solid waste

One of the very few solid waste containers (drums) existing at the worker camp site (but also at construction sites). Due to the lack of sufficient amount of containers/bins and poor awareness, solid waste is found here and there around on the ground at the worker camp site but also at the construction sites


239

APPENDIX 5: ASSESSMENT OF THE COMPLIANCE OF PACKAGE A4 WITH THE EMP REQUIREMENTS, APRIL 2016

No. Item Situation Level of Compliance,

Evaluated by EEMC

1 CEMP - Submitted on March 21st 2016 with Letter BLLT/A4/C/16-040 - Approved by the construction supervision consultants (JV of DASAN – KUNHWA – ICT) on April 12th 2016 by Letter BLLT/CSC/A4/16-035

Compliance

2 Health Assurance and Safety Plan

- Submitted on February 22nd 2016 with Letter BLLT/A4/16-005 - Approved by the construction supervision consultants (JV of DASAN – KUNHWA – ICT) on March 22nd 2016 by Letter BLLT/CSC/A4/16-024

Compliance

3 Background environmental monitoring plan

- Submitted in March 2016 with Letter BLLT/CSC/A4/16-005 - Under review by the construction supervision consultants (JV of DASAN – KUNHWA – ICT)

Compliance

4 Monthly and quarterly environmental monitoring reports

Will be started from May 2016 Compliance

5 HIV Prevention Program for Construction Workers

As reported by the contractor’s environmental engineer, the contractor has worked with both the EPMU and CSC on the implementation of a HIV Prevention Program for Construction Workers and currently is waiting for directions from the EPMU

Minor infringement

6 Environmental protection proposal for fabrication yard and two batching plants

Approved by Nha Be District Office of Natural Resources and Environment by Letter 563/UBND-PTNMT on March 30th 2016

Compliance

7 Disposal site - Proposal was submitted on April11th2016 with Letter 02/A4/BLLT to and verified by Nhon Duc Commune People’s Committee - The document is currently under assessment and consideration of the construction supervision consultants (JV of Dasan – KUNHWA – ICT) for approval

Compliance

8 Management of vegetation wastes

- About 280,000 m2 of Nipa palm has been cleared. Of which about 20% (55,000 m2) is currently stored at the construction site - This amount of waste will be transported to the disposal site once the site has been approved by the CSC

Minor infringement


240

9 Transport of excavated and/or dredged spoils

Principal Contract 06/A4/HDNT/BL-LT was signed on April 8th 2016 with Dai Phuc Loc Trade & Construction Co. Ltd. Compliance

10 Solid waste management

- Domestic solid waste is collected by a local collection team in Nhon Duc Commune - No contracts have been signed yet

Minor infringement

11 Hazardous waste management

- Not yet generated, as reported by the contractor’s environmental engineer - No contracts have been signed yet

Minor infringement

12 License for vehicles and construction machines used for the project

- Currently some main construction machines (three hydraulic drilling rigs and three wick drain machines) have got inspection certificate for use (PDF copies are available) - The contractor is currently completing the preparation of all necessary licenses and environmental certificates for the remaining vehicles and equipment and will soon submit to the CSC for approval before putting into use at the project

Compliance

13 Training workers on health, safety and environment

As reported by the contractor’s environmental engineer, a training program on health, safety and environment for workers is under preparation

Minor infringement

Figures on the present environmental management at Package A4

Construction of access road has just been started


241

Excavated/dredged soil is is to be stogared and removed

Vegetation waste is urgently be given or transported out

The only two containers for solid waste at the construction site


242

APPENDIX 6: ASSESSMENT OF THE COMPLIANCE OF PACKAGE J2 WITH THE EMP REQUIREMENTS

Project activities

(1)

Potential Environmental

Negative Impacts

(2)

Proposed Mitigation Measures in the EMP

cleared by ADB

(3)

Location (4)


EEMC (6)



1. Prior to commencement of any site works, each contractor shall prepare a site-specific or construction EMP (CEMP) which specifies the responsibilities, location associated costs, schedule/timeframe and other relevant information for implementing its provisions which will include the following: (i) selection of sites for material exploitation and storing, as well as sites for concrete, crushing and asphalt plants, (ii) plans for material transportation routes and timing, (iii) identification of specific disposal sites for unsuitable soils, (iv) soil erosion control measures including soil stabilization measures at disposal sites, (v) treatment of acid sulfate soils and resulting run-off, (vi) wastewater collection and treatment, (vii) construction camp management, (viii) quarry/aggregate/borrow site management and restoration, (ix) traffic management, (x) noise reduction measures including construction of temporary noise barriers, (xi) dust suppression measures, (xii) handling and storage of hazardous substances such


CEMP has been prepared by the Contractor and reviewed and approved by KEI-NE-OC-TEDI JV with no objection against their proposed plan. The contractor already submitted Environmental Certification of disposal areas to the Consultants. The CEMP is now under consideration by ADB. Compliance


243

Project activities

(1)


Negative Impacts

(2)


cleared by ADB

(3)

Location (4)


EEMC (6)


as fuel, etc. (xiii) solid waste collection and disposal, (xiv) replanting measures, (xv) occupational and community health and safety, (xiv) repair of damaged community facilities such as irrigation canals, etc. (xvii) emergency response plan in case of spills and other accidents involving workers and the community, (xviii) chance-find procedures measures and other applicable mitigation measures indicated in the Project EMP included in the EIA approved by ADB. The CEMP should be fully consistent with the Project EMP. Before civil works begin, the CEMP shall be reviewed by the Project Supervision Consultant and endorsed to ADB.




Project site All measures in column 3 were followed by J2 contractor. Compliance


4. Burn the cut trees in accordance with national and local regulations, and only in limited cases with strict conditions (less than 100 kg at a time; more than 500m from residential areas and other sensitive receptors such


244

Project activities

(1)


Negative Impacts

(2)


cleared by ADB

(3)

Location (4)


EEMC (6)


as schools, hospital, culturally significant sites, etc. and fuel storage sites, 200 m from worker camps; with available and sufficient fire prevention devices and manpower for fire extinguishing and ensuring that surrounding vegetation are protected from fire; will not cause nuisance and safety risks to sensitive receptors (houses, schools, etc.) and road users in the surrounding areas.)







Western approach bridge and Eastern approach bridge of Cha River Bridge

Design viaducts to go over the mangrove areas were done. Compliance

7. Implement a Mangrove Reforestation Plan (MRF) to replant mangroves for compensation of the lost mangrove area at river, canal banks due to site clearance (mainly at river, canal banks

River bank close to the ROW

It is not necessary because of impact only on the area of Nipa palm which does not have a high


245

Project activities

(1)


Negative Impacts

(2)


cleared by ADB

(3)

Location (4)


EEMC (6)


in Nha Be, Can Gio, Nhon Trach, Long Thanh districts). Detailed MRF is found in Section V.B.2 of the EIA Report.

biodiversity value.

3. Establishment of Construction workers’ camps


8. Implement proper solid waste management through implementation of the following measures: (i) Prohibit burning of construction and domestic waste. (ii) Do not permit disposal of solid waste into canals, rivers, other watercourses, agricultural field and public areas. Disposal shall only be to areas approved/licensed by local authorities. (iii) Properly collect and segregate domestic waste at worker camps and offices. Use rubbish bins for containing domestic solid waste (iv) Sign contract with local environmental service units for regular transport (weekly) of solid waste to disposal sites. (iv) Ensure that wastes are disposed to sites approved by local authority. (iv) Use of pits with proper lining for disposal of domestic solid waste. Location of the pits shall be over 200m from residential sites and over 100m from workers’ eating area. Before the team moves

Workers’ camps

- Hazardous waste in domestic solid waste bin (fabrication yard No. 1) - No name plates in some waste bins. - Contract for collecting and treating solid waste was invalid by December 2015. Minor infringement

- Contractor implements waste separation at source - Name plates must be mounted on every rubbish bin. - The contractor must prepare a new contract for treating domestic solid waste from the project. The above measures should be implemented before 30th June 2016


246

Project activities

(1)


Negative Impacts

(2)


cleared by ADB

(3)

Location (4)


EEMC (6)


to a new construction site, trash pits shall be disinfected with lime or hypochlorite solution, then firmly covered with a 20 – 30 cm layer of soil.

Sanitary wastes (sewage) from workers, causing water, air, land pollution, and diseases.


Project site

- Using of sanitary 2-chamber septic tanks instead. - Clean water for hand washing at each toilet area is provided. - Sufficient water for bathing and sanitation purposes is provided. Compliance


Project site


Worker camp sites


Worker camp sites


Worker camp sites

Toilet paper was discarded indiscriminately in the toilet on

- Provide 01 rubbish bin for every toilet room and ask


247

Project activities

(1)


Negative Impacts

(2)


cleared by ADB

(3)

Location (4)


EEMC (6)


site Minor infringement

workers to keep sanitation. This measure should be implemented before 30th June 2016



Communes where the project located in

No information on employing local people. No conflict between workers and local residents and no community disturbance Compliance



The training program has been prepared and approved by the Consultants. It was submitted to PMU for consideration. Compliance

16. Establish a grievance redress mechanism (GRM), well guide local residents to apply GRM; provide local communities information on the upcoming construction


- Although the Contractor already set up along temporary bridge and culvert with

- A hotline should be provided for local residents through Binh


248

Project activities

(1)


Negative Impacts

(2)


cleared by ADB

(3)

Location (4)


EEMC (6)


activities; record any complaints received and respond to them based on the GRM, properly cooperate with local PCs, DONREs, social associations to properly solve claims of the PAHs and problems related to environmental issues related to the project.

hotline number (+84) 0983343547 and contact person (Mr. Xuan - Safety Officer), some local residents still complain about this. - Late in solving complaints from local residents (comments in the public consultation with Binh Khanh PC and local residents). Minor infringement

Khanh PC and along the project ROW as soon as posible. - The EPMU and the contractors should pay more attention to complaints from local residents and governments and deal with them as soon as possible.



Measures 27 were done Compliance

18. Undertake regular meetings (e.g., twice a month) between contractor and Commune PCs on matters that may affect local residents such as presence of workers, construction


Comments atthe public consultation with Binh Khanh PC and local residents:

The EPMU and the contractors should pay more attention to


249

Project activities

(1)


Negative Impacts

(2)


cleared by ADB

(3)

Location (4)


EEMC (6)


activities and schedule, etc.

- Late in solving complaints from local residents. Minor infringement

complaints from local residents and deal with them as soon as possible.






Worker camp sites

Clean and safe food supply and potable water supply in sufficient amount are provided for workers Compliance


Project site and Worker camp sites

- Weekly transport (by local environmental service unit) to district's treatment site is implemented. - No name plates for some rubbish bins.

Name plates must be mounted on every rubbish bin.


250

Project activities

(1)


Negative Impacts

(2)


cleared by ADB

(3)

Location (4)


EEMC (6)


Minor infringement



Toilet paper was discarded indiscriminately in the toilet on site Minor infringement

- Provide 01 rubbish bin for every toilet room and ask workers to keep sanitation.





Worker camp sites


25. Install sign boards, lighting system at the construction sites, borrow pits, or places which may cause accidents for people and workers

Project site

Sign boards, lighting system at the construction sites, places which may cause accidents for people and workers were installed. Compliance

Taps in the toilet - The


251

Project activities

(1)


Negative Impacts

(2)


cleared by ADB

(3)

Location (4)


EEMC (6)




have not been closed after use. Minor infringement

contractor should ask workers to close taps after use.


Workers’ camp sites



Storm water from construction sites, improper stockpiling of spoils and construction materials, haphazard spoils disposal, soil erosion and land slide at construction sites, causing damage to roads, polluting of canals, rivers and pond; and obstruction of flow of water courses.


Project site

The contractor informed that design is good for erosion and storm water control. Through field survey, EEMC found that road embankment at the project site was well constructed. No erosion and landslide observed Compliance


Project site

Not yet implemented because no erosion occurred.

30. (xvi) Provide grass cover

Project site

Measure 37 was


252

Project activities

(1)


Negative Impacts

(2)


cleared by ADB

(3)

Location (4)


EEMC (6)


and other suitable slope stabilization measures on road embankment slopes and on long term stockpile of spoils (xvii) Spoil disposal shall not cause sedimentation and obstruction of flow of watercourses, damage to agricultural land and densely vegetated areas. (xviii) The spoils disposal site shall be located at least 50m from surface water courses and shall be protected from erosion by avoiding formation of steep slopes and grassing. (xix) Spoils shall only be disposed to areas approved by local authority. (xx) Water courses (rivers, canals, etc.) shall be kept free of excavation spoil and construction debris, floating and submerged. (xxi) Spoil and construction materials stockpile area shall be located away from water bodies and under no circumstances will these materials be dumped into watercourses. (xxii) Dredged and excavated materials shall be reused or provided to local residents as soon as possible, if they require such materials, for land reclamation. The remaining spoils can be disposed into



253

Project activities

(1)


Negative Impacts

(2)


cleared by ADB

(3)

Location (4)


EEMC (6)


low elevation sites for road construction. (xxiii) Provide temporary sediment traps (ditches and ponds) if high sediment laden runoff are observed. 31. Design and install culverts and drainage systems to avoid flooding

Project site

Culverts and drainage systems were installed. Compliance


32. (xvii) Select proper places for setting up borrow pits to avoid areas of serious acid sulfate and saline soils and to avoid encroachment into forest, cultivation, commercial and residential areas. Borrow sites shall be covered by necessary environmental permits/licenses and shall be located over 300m away from residential, commercial, cultural sites and other sensitive receptors (schools, hospital, etc.). (xviii) Proper soil erosion control during borrow pits construction and operation by proper design and installation of adequate drainage system. (xix) Proper control of storm water at borrow sites in the rainy season by using sediment traps, treatment of turbidity, strong acidic water (by lime) and oil separation water if high turbidity, high

Borrow areas

So far, at J2 borrow pits are not operated, so evaluation on compliance with the EMP is not made.


254

Project activities

(1)


Negative Impacts

(2)


cleared by ADB

(3)

Location (4)


EEMC (6)


acidity or high oil content were found. (xx) Proper dust control during dredging, excavation at borrow sites and earth transport. (xxi) Topsoil (about 15 cm) will be kept and refilled after excavation is over, (xxii) Long – term material stockpiles will be covered to prevent wind erosion, (xxiii) Upon completion of extraction activities, re-contour borrow/quarry pit wall or fill-up when there are available and suitable materials such as excavation spoils , replace topsoil, and re-vegetate with native species such as grasses and fast-growing shrubs, (xxiv) Quarries and borrow pits will not be established in national, provincial, district and village conservation forests and other protected sites, (xxv) Operation of existing quarry/borrow sites shall be preferred over establishment of new sites, as much as possible, (xxvi) In case the Project will involve new quarry/borrow sites, necessary approvals from environmental authorities shall be obtained prior to operation of such sites, (xxvii) During borrow site operation, provide adequate


255

Project activities

(1)


Negative Impacts

(2)


cleared by ADB

(3)

Location (4)


EEMC (6)


drainage to avoid accumulation of stagnant water, (xxviii) Borrow/quarry sites shall not be located in productive land and forested areas, (xxix) Upon completion of extraction activities, borrow pits shall be dewatered and fences shall be installed, as appropriate, to minimize health and safety risks. (xxx) Borrow pits will be left in a tidy state with stable side slopes and proper drainage in order to avoid erosion (xxxi) To avoid drowning when pits become water-filled, measures such as fencing, providing flotation devices such as a buoy tied to a rope, etc. shall be implemented. (xxxii) It is possible that villagers may request borrow pits to be excavated so that they may be used as water reservoirs or fishponds. If this were to be agreed between the contractors and the villagers, all the full safety measures detailed above must be observed. Such agreements would be formalized in writing between the contractors and the villagers after full discussion with all concerned parties. .

33. No noisy construction-

Construction

- No source of


256

Project activities

(1)


Negative Impacts

(2)


cleared by ADB

(3)

Location (4)


EEMC (6)



related activities (e.g., construction works, piling, use of jackhammer, transport of materials along residential areas and other sensitive receptors, piling, etc.) will be carried out during night-time (10PM-6AM) near sensitive receptors (residences, hospital, etc.). As much as possible, locate high vibration generation sources over 50m from residential sites, offices, buildings, etc.

site noise was found at the survey and no complaints from local residents about noise. No dust emission and noise was observed from the household who cultivated shrimp near the project site. Compliance


- Concrete mixers and batching plants generated dust all day and night long (at different levels), affecting the living activities of some households within the proximity (around 100m) (complaints from local residents) - Batching plants were not operating during the site survey of EEMC Minor infringement

- Contractor will conduct additional dust monitoring for households that is near dust sources (such as: batching plant) to determine the actual level of dust. If the construction dust is actually over the allowable range, Contractor will prepare countermeasures and acquire the


257

Project activities

(1)


Negative Impacts

(2)


cleared by ADB

(3)

Location (4)


EEMC (6)


concurrent from local resident. - The contractor should immediately implements suitable mitigation measures to reduce impact of dust to living activities of local residents.


Construction site



Measure 46 was done. Level of compliance: Compliance


Construction site

- No source of noise was found at the survey and no complaints from local residents about noise. No dust emission and noise was observed from


258

Project activities

(1)


Negative Impacts

(2)


cleared by ADB

(3)

Location (4)


EEMC (6)


the household who cultivated shrimp near the project site. Compliance

38. Install noise control walls (3.0-4.5m high, thick materials) at high noise sources that affect sensitive receptors (temples, pagodas, churches, schools)

Construction site

- Enclosing walls around the construction sites is just 2.0 m high. There is no receptors in the vicinity of the construction site. Control walls with 2 m high are acceptable. Compliance


Project communes



Measure 40 was done (by direct interviews with the drivers and construction machines operators. Maintenance was found at the project site during the time of inspection.


259

Project activities

(1)


Negative Impacts

(2)


cleared by ADB

(3)

Location (4)


EEMC (6)


Compliance


Construction site

There was no source of loud noise at the moment of field survey


42. On rainless day undertake watering, at least twice per day, on dusty and exposed areas at construction yards, materials stockpile, within and in the vicinity of concrete mixing stations, construction sites and access roads where residential areas and other sensitive receptors

Construction site, concrete mixing stations, materials stockpile areas, and access roads

Not too dusty at the project site at the moment of field survey

43. In addition to watering the zones in front of and inside concrete mixing stations, the following measures shall also be implemented to reduce impacts due to dust emissions: i) Concrete mixers and asphalt stations shall be located at least 300m from residential areas, hospitals, schools, and other sensitive receptors. ii) Ditches of 4 x 10 x 0.3 m (L x W x D) would be made by contractors in order to wash vehicles before they go out of the stations. This measure is

Concrete mixing plants and asphalt stations, construction sites

- Enclosing walls around the construction sites is just 2.0 m high. There is no receptors in the vicinity of the construction site. Control walls with 2 m high are acceptable. Compliance


260

Project activities

(1)


Negative Impacts

(2)


cleared by ADB

(3)

Location (4)


EEMC (6)


necessary for concrete mixing stations where the dust content is very high as it keeps down soil and sand adhering to vehicle wheels. These are highly feasible measures. The best measure is to wash truck body and tires before moving out of the construction to urban areas. iii) Provide enclosing walls (3.0 – 4.0 m in high) around the construction sites that are near sensitive receptors (schools, populated areas, churches, pagodas, etc). 44. Tightly cover construction materials (sand, soil, cement, gravel, etc.) during transport with tarpaulins or similar sheet materials.

Access roads




Construction of bored piles was finished. So amount of dredged spoil generated is negligible. Compliance

46. All vehicles, construction machines used for the project

Construction site and

The contractor must provide the


261

Project activities

(1)


Negative Impacts

(2)


cleared by ADB

(3)

Location (4)


EEMC (6)


should have license of the Vietnam Register or Police approving compliance to Vietnam Standard on vehicle emission.

access roads licenses for demonstration – The Consultant supervision already checked and approved before mobilization drivers and equipment. Compliance




- No expanding the project ROW to the wetland and mangrove forest area. - J2 Package is not located at Thi Vai Bank Compliance



No cutting trees outside the project area Compliance

49. Prior to commencement of construction activities on site identify and mark with suitable visual reminders the areas of mangroves that are not to be disturbed during the works. This measure is recommended for the construction site at the banks of Soai Rap, Long Tau and


Section J2 is not located in mangrove forest.


262

Project activities

(1)


Negative Impacts

(2)


cleared by ADB

(3)

Location (4)


EEMC (6)


Thi Vai rivers where belts of mangrove trees occur. 50. Do not dispose dredging spoils and all types of waste onto mangrove forest areas, agricultural land, densely vegetated areas, and water courses.


No disposal of dredging spoils and all types of waste onto mangrove forest areas, agricultural land, densely vegetated areas, and water courses. Compliance.



Measure 61 is well implemented Compliance


52. Provide firefighting equipment at the work areas, as appropriate, and at construction camps.

Project site

Firefighting equipment at the work areas, as appropriate, and at construction camps is provided. Compliance

53. Provide workers with appropriate safety equipment/devices (such as dust mask, hard hats, safety shoes, goggles, ear plugs, etc.) and strictly require them

Project site



263

Project activities

(1)


Negative Impacts

(2)


cleared by ADB

(3)

Location (4)


EEMC (6)


to use these as necessary. 54. Strictly impose speed limits on construction vehicles along residential areas and where other sensitive receptors such as schools, hospitals, and other populated areas are located. Educate drivers on safe driving practices to minimize accidents and to prevent spill of hazardous substances and other construction materials during transport.




Project site



Project site


5. Specific issues: Dredging, filling,

Acidification of soil and water caused by earth

57. Install temporary shallow ponds (ground for containing dredged materials) and settlement pond at the

Project site

At present, no run –off water and no high acidity water


264

Project activities

(1)


Negative Impacts

(2)


cleared by ADB

(3)

Location (4)


EEMC (6)


cutting activities during road construction at ASS areas

filling/cutting activities at acid sulfate soil (ASS) area. Consequently, aquaculture and aquatic organisms in the acidified canals, ponds could be affected.

construction sites which are highly affected by acidic water, to receive run-off water containing acidic materials, neutralize acidic water if its pH <5 or lower than pH value of surrounding water prior to discharge into fields or canals.

generated at road construction area, so this measure is not needed.


Project site

At present, no high acidity water generated at road construction area, so this measure is not needed. (there was actually no run-off during the field visit as it was at the mid of dry season)


Project site

At present, no high acidity water generated at road construction area, so this measure is not needed.

60. In case that ASS spoil is heaped up along the road, in order to avoid of the transfer of sulfate water to agriculture and aquaculture land, construction contractors shall design and utilize storing

Project site



265

Project activities

(1)


Negative Impacts

(2)


cleared by ADB

(3)

Location (4)


EEMC (6)


grounds with enclosure of suitable width and height. The capacity of a storing ground is determined on a case by case basis to adequately accommodate spoils and shall be compacted to avoid erosion and percolation.

61. The enclosure shall preferably include settling or sedimentation reservoirs to reduce turbidity and suspended solid and to treat leach ate of acidic water (including neutralization with lime if pH of water in the reservoir is lower than that of the surrounding environment).

Project site

At present, no run – off water and no high acidity water generated at road construction area, so this measure is not needed.


Project site

Local residents and local authorities in Binh Khanh commune complained in the public consultation meetings that there are still some households affected by the activities of the project but have not been addressed. Minor infringement

Contractors should hold meetings with PAHs and local authorities to resolve these issues as soon as possible.


266

Project activities

(1)


Negative Impacts

(2)


cleared by ADB

(3)

Location (4)


EEMC (6)



- Surface water, groundwater, air, land pollution caused by spills and construction wastes and excavation spoils - Adverse impacts on cultivated areas and aquaculture - Aesthetic issues


Project site

Dredged soil storage sites are not close to residential areas. Therefore, this measure is not needed.

64. Arrange different kinds of rubbish bins for collection and segregation of domestic waste, hazardous waste around construction, and workers’ camp sites.

Workers’ camp and construction sites,

- Hazardous waste in domestic solid waste bin (fabrication yard No. 1) - No name plates in some waste bins. Major infringement

- Contractor implements waste separation at source - Name plates must be mounted on every rubbish bin.


Domestic solid waste is transported and treated properly by a sub-contractor. And bridge is not constructed. Therefore, measure 75 is not needed.

66. Make drainage ditches at worker camp sites and construction sites to prevent flow of storm water to




267

Project activities

(1)


Negative Impacts

(2)


cleared by ADB

(3)

Location (4)


EEMC (6)


cultivated land and aquaculture areas. 67. Implement the following measures for handling hazardous substances and wastes: (xv) Store fuel and hazardous substances in paved areas with roof and embankment. If spills or leaks do occur, undertake immediate clean up. (xvi) Ensure availability of spill cleanup materials (e.g., absorbent pads, etc.) specifically designed for petroleum products and other hazardous substances where such materials are being stored. (xvii) Segregate hazardous wastes (oily wastes, used batteries, fuel drums) and ensure that storage, transport and disposal shall not cause pollution and shall be undertaken consistent with national and local regulations. (xviii) Ensure all storage containers are in good condition with proper labeling. (xix) Regularly check containers for leakage and undertake necessary repair or replacement. (xx) Store hazardous materials above flood level. (xxi) Equipment maintenance areas shall be provided with drainage


- There is no embankment sourrounding the chemical tank (concrete additives). - No measures for preventing waste oil spillage during vehicle/equipment maintenance on site. - Hazardous waste was not collected and stored in compliance with the law. Major infringment

- Embankments sourrounding the chemical tanks (concrete additives) must be built immediately. - Applying mitigation measures for preventing waste oil spillage during vehicle/equipment maintenance on site. - Hazardous waste must be collected and stored according to circular 36/2015/TT-BTNMT.


268

Project activities

(1)


Negative Impacts

(2)


cleared by ADB

(3)

Location (4)


EEMC (6)


leading to an oil-water separator that will be regularly skimmed of oil and maintained to ensure efficiency. Discharge of oil contaminated water shall be prohibited. 68. Provide information on waste management in training program for workers, including how to manage hazardous wastes. Train relevant construction personnel in handling of fuels and spill control procedures

Workers’ camp and construction sites

Measure 78 is well implemented. Compliance


Project site

Spoils are temporarily stored in areas close to the construction site but more than 200m from residential, commercial, cultural sites. Compliance


Project site

Disposal of construction waste into fields, ponds, rivers and canals was not observed Compliance


269

Project activities

(1)


Negative Impacts

(2)


cleared by ADB

(3)

Location (4)


EEMC (6)



Project site

- No measures for preventing waste oil spillage during vehicle/equipment maintenance on site. - Hazardous waste was not collected and stored in compliance with the law. Major infringment

- Applying mitigation measures for preventing waste oil spillage during vehicle/equipment maintenance on site. - Hazardous waste must be collected and stored according to circular 36/2015/TT-BTNMT of MONRE.


Project site


73. Burning wastes at the construction site is prohibited. Except for burning cut trees

Project site

Measure 83 is well implemented.


270

Project activities

(1)


Negative Impacts

(2)


cleared by ADB

(3)

Location (4)


EEMC (6)


with following conditions: only a small volume (<100kg/time); far from camps, fuel storage, residential sites (over 500m); with availability of fire control facilities and manpower.

Compliance


Project site



Project site and surrounding area




Project site


77. Properly collect and segregate construction

Project site

Measure 87 is well implemented.


271

Project activities

(1)


Negative Impacts

(2)


cleared by ADB

(3)

Location (4)


EEMC (6)


wastes into non-hazardous and hazardous wastes.

Compliance


Project site

A contract with a local environmental company was signed. Compliance


Project site

There are 2 available disposal areas (No.1 and No.2) for non-hazardous waste soil disposal. Compliance


Project site

Growing grasson excavated soil storage site is not necessary because time for excavated soil storage is only 1-2 weeks.

7. Cutting trees within and outside the project

Reduction of vegetation cover, affecting local biological


Project site

No cutting trees outside the project ROW


272

Project activities

(1)


Negative Impacts

(2)


cleared by ADB

(3)

Location (4)


EEMC (6)


ROW

resource, creating increased soil erosion

Compliance


Project site

No cutting trees outside the project ROW and Package J2 is not located at Thi vai river banks. Therefore, this measure is not needed.




Project communes



Project communes

Measure94 is implemented. Compliance

85. Access roads damaged during transport of construction materials and other project-related activities

Project communes

Not yet implemented because the project is still


273

Project activities

(1)


Negative Impacts

(2)


cleared by ADB

(3)

Location (4)


EEMC (6)


shall be reinstated upon completion of construction works at each section.

under construction now.



Project communes



Project communes





Project communes


89. Do not fill up canals and creeks at the construction site. In case filling of local drainage system is extremely necessary, consultation with local authorities shall be undertaken and their

Project communes



274

Project activities

(1)


Negative Impacts

(2)


cleared by ADB

(3)

Location (4)


EEMC (6)


permission obtained beforehand. An alternative drainage shall be established before the existing canal is filled-up.





Assessment are as the same as items 19-37













Land erosion and land slide

94. Confine vegetation clearing within the areas

Bridge construction



275

Project activities

(1)


Negative Impacts

(2)


cleared by ADB

(3)

Location (4)


EEMC (6)


at bridge construction site. Obstruction of waterways.

required for construction.

site

Compliance






No erosion, landslides at the place of bridge construction, so it is not necessary to take this measure. Compliance

Operation of barges for material transport, causing water pollution by wastes, fuel

97. Discharge of untreated waste water and release of rubbish from barges shall be prohibited. Solid waste shall be periodically collected and transported to disposal sites approved/licensed by local




276

Project activities

(1)


Negative Impacts

(2)


cleared by ADB

(3)

Location (4)


EEMC (6)


leakage authorities. 98. Each barge shall have rubbish bins for solid waste collection, oil separator for proper collection of oily wastewater and fire control facilities.













102. The contractor shall ensure that barge owners involved in bridge construction shall have an oil spill prevention and response plan and relevant technical facilities for its implementation. In case of spills of oil and other hazardous substances, the contractor shall implement the following measures: (i) Immediately inform the


There is no proof that The barge owner does not have an oil spill prevention and response plan and relevant technical facilities for its implementation. Minor infringement

The barge owner must get approval for their oil spill prevention and response plan and they have to equip all relevant technical facilities for


277

Project activities

(1)


Negative Impacts

(2)


cleared by ADB

(3)

Location (4)


EEMC (6)


Saigon Port Authority, who is responsible for waterway transport in Ho Chi Minh City and surrounding region. (ii) Engage oil spill removal companies and local authorities to immediately respond to oil spill incidents caused by the Project. (iii) Immediately inform communes which may be affected by oil the spill. (iv) After the oil spill has been controlled/removed, the contractor will coordinate with the relevant local communes to address land and water pollution caused by the spill, and to provide compensation for environmental and economic damages, following the relevant Vietnamese laws and guidelines.

its implementation




Project site

This measure will be implemented when the contractor will require a big number of workers

104. In recognition of the fact


278

Project activities

(1)


Negative Impacts

(2)


cleared by ADB

(3)

Location (4)


EEMC (6)


that despite implementation of the above measures, large numbers of non-local workers will still be required, construction contractors will work with the local authorities to develop a range of measures to minimize the adverse effects of the planned construction force and unplanned migrants.

Project site This measure will be implemented when the contractor will require a big number of non-local workers


Project site





Project site

No cultural heritage at ROW of Package J2


No physical historic objectives found at J2

From the detailed assessment on the contractor's (JO of Sumitomo Mitsui – Cienco4) compliance with EMP, can be concluded that, at the present time, the contractor has implemented various measures to prevent pollution and waste management. Most of the measures are complied with EMP. However, in the


279

total of over 100 evaluated measures 12 measures were not complied, of which 9 measures as minor infringement and 3 measures as major infringement are evaluated. The main major infringement relates with improper management of hazardous wastes. They must be properly corrected immediately. In comparison with other packages (A1, A2-1, A2-2, A3, A4), environmental management of Package J2 (JO of Sumitomo Mitsui – Cienco4) is likely better. Some pictures on the present state of the environmental management at Package J2

Meeting with representatives of EPMU, the Consultants and contractors

Reports on safety and health prepared by the contractor

Having a talk with a household closed to the project site

Some activities of the project


280

Hazardous waste was stored improperply Oil spillage during vehicle maintenance

Protection walls for chemical tanks were broken No waste separation at source

Batching plant was not operating during EEMC’s survey

Toilet paper in a toilet on site


281

APPENDIX 7: ASSESSMENT OF THE COMPLIANCE OF PACKAGE J3 WITH THE EMP REQUIREMENTS

Project activities

(1)


Impacts

(2)


by ADB

(3)

Location (4)


EEMC (6)



1. Prior to commencement of any site works, each contractor shall prepare a site-specific or construction EMP (CEMP) which specifies the responsibilities, location associated costs, schedule/timeframe and other relevant information for implementing its provisions which will include the following: (i) selection of sites for material exploitation and storing, as well as sites for concrete, crushing and asphalt plants, (ii) plans for material transportation routes and timing, (iii) identification of specific disposal sites for unsuitable soils, (iv) soil erosion control measures including soil stabilization measures at disposal sites, (v) treatment of acid sulfate soils and resulting run-off, (vi) wastewater collection and treatment, (vii) construction camp management, (viii) quarry/aggregate/borrow site management and restoration, (ix) traffic management, (x) noise reduction measures including construction of temporary noise barriers, (xi) dust suppression measures, (xii) handling and storage of hazardous substances such as fuel, etc. (xiii) solid waste collection and disposal, (xiv)


CEMP has been prepared by the Contractor and reviewed and approved by KEI-NE-OC-TEDI JV with no objection against their proposed plan. The contractor already submitted Environmental Certification of disposal areas to the Consultants. The CEMP is approved by ADB. Compliance


282

Project activities

(1)


Impacts

(2)


by ADB

(3)

Location (4)


EEMC (6)


replanting measures, (xv) occupational and community health and safety, (xiv) repair of damaged community facilities such as irrigation canals, etc. (xvii) emergency response plan in case of spills and other accidents involving workers and the community, (xviii) chance-find procedures measures and other applicable mitigation measures indicated in the Project EMP included in the EIA approved by ADB. The CEMP should be fully consistent with the Project EMP. Before civil works begin, the CEMP shall be reviewed by the Project Supervision Consultant and endorsed to ADB.




Project site

All measures in column 3 were followed by J3 contractor. Compliance


4. Burn the cut trees in accordance with national and local regulations, and only in limited cases with strict conditions (less than 100 kg at a time; more than 500m from residential areas and other sensitive receptors such as schools, hospital, culturally significant sites, etc. and fuel


283

Project activities

(1)


Impacts

(2)


by ADB

(3)

Location (4)


EEMC (6)


storage sites, 200 m from worker camps; with available and sufficient fire prevention devices and manpower for fire extinguishing and ensuring that surrounding vegetation are protected from fire; will not cause nuisance and safety risks to sensitive receptors (houses, schools, etc.) and road users in the surrounding areas.)







Western approach bridge and Eastern approach bridge of Cha River Bridge

Design viaducts to go over the mangrove areas were done. Compliance

7. Implement a Mangrove Reforestation Plan (MRF) to replant mangroves for compensation of the lost mangrove area at river, canal banks due to site clearance (mainly at river, canal banks in Nha Be, Can Gio, Nhon Trach, Long Thanh districts). Detailed MRF is found in Section V.B.2 of the EIA Report.

River bank close to the ROW

Mangrove Reforesting Plan (MRF) was prepared. Mangrove reforestation will be conducted in a different bid package.


284

Project activities

(1)


Impacts

(2)


by ADB

(3)

Location (4)


EEMC (6)


3. Establishment of Construction workers’ camps


8. Implement proper solid waste management through implementation of the following measures: (i) Prohibit burning of construction and domestic waste. (ii) Do not permit disposal of solid waste into canals, rivers, other watercourses, agricultural field and public areas. Disposal shall only be to areas approved/licensed by local authorities. (iii) Properly collect and segregate domestic waste at worker camps and offices. Use rubbish bins for containing domestic solid waste (iv) Sign contract with local environmental service units for regular transport (weekly) of solid waste to disposal sites. (iv) Ensure that wastes are disposed to sites approved by local authority. (iv) Use of pits with proper lining for disposal of domestic solid waste. Location of the pits shall be over 200m from residential sites and over 100m from workers’ eating area. Before the team moves to a new construction site, trash pits shall be disinfected with lime or hypochlorite solution, then firmly covered with a 20 – 30 cm layer of soil.

Workers’ camps

- Open burning of domestic waste (the Western bank of Long Tau river) - No waste separation at source (the Western bank of Long Tau river) Minor infringement

- Contractor implements the strict control to Garbage and burning should be prohibited. - Contractor should implement waste segregation at source.


285

Project activities

(1)


Impacts

(2)


by ADB

(3)

Location (4)


EEMC (6)


Sanitary wastes (sewage) from workers, causing water, air, land pollution, and diseases.


Project site

- Using of sanitary 2-chamber septic tanks . - Clean water for hand washing at each toilet area is provided. - Sufficient water for bathing and sanitation purposes is provided. - There is one toilet for female. Compliance


Project site


Worker camp sites


Worker camp sites


Worker camp sites





Some local people were employed as sanitation workers, kitchen maid, etc.. No conflict


286

Project activities

(1)


Impacts

(2)


by ADB

(3)

Location (4)


EEMC (6)


between workers and local residents and no community disturbance Compliance



The training program has been prepared and approved by the Consultants. It was submitted to EPMU for consideration. Compliance

16. Establish a grievance redress mechanism (GRM), well guide local residents to apply GRM; provide local communities information on the upcoming construction activities; record any complaints received and respond to them based on the GRM, properly cooperate with local PCs, DONREs, social associations to properly solve claims of the PAHs and problems related to environmental issues related to the project.


Grievance redress mechanism (GRM) was not prepared, yet. Minor infringement

Contractor should prepare GRM and disclose to local PCs, and residents

17. Regularly inform in advance the local PCs and local residents on the location and schedule of construction


This measure was implemented.


287

Project activities

(1)


Impacts

(2)


by ADB

(3)

Location (4)


EEMC (6)


activities which may cause impacts on the environment and life of people (e.g., road sections to be constructed; roads used for transport, locations of worker camps etc.)

Compliance



There were some meetings with local PCs but not twice a month






Worker camp sites

- Clean and safe food supply and potable water supply in sufficient amount are provided for workers. - Storage of rice inside of unused toilet is not appropriate. Minor infringement

- Do not store rice inside of the unused toilet or the contractor should change function of this toilet room.

21. Provide large - sized

Project

- Weekly

- More


288

Project activities

(1)


Impacts

(2)


by ADB

(3)

Location (4)


EEMC (6)


rubbish bins at construction sites and worker camps and weekly transport (by local environmental service unit) to district's treatment sites.

site and Worker camp sites

transport (by local environmental service unit) to district's treatment site is implemented. - Insufficient amount of rubbish bins onsite (the western bank of Long Tau river) - No waste separation at source (the western bank of Long Tau river) Minor infringement

rubbish bins must be provided at worker camps. → The Contractor has already done 15th April 2016. - The contractor will implement waste separation at source at the western bank of Long Tau river → The Contractor has already done 15th April 2016.








289

Project activities

(1)


Impacts

(2)


by ADB

(3)

Location (4)


EEMC (6)



Worker camp sites


25. Install sign boards, lighting system at the construction sites, borrow pits, or places which may cause accidents for people and workers Project

site

Sign boards, lighting system at the construction sites, places which may cause accidents for people and workers were installed. Compliance



Measures 26 was implemented. Compliance




4. Construction

Storm water from

28. Ensure proper design of road embankment so that soil

Project site

The contractor informed that


290

Project activities

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Impacts

(2)


by ADB

(3)

Location (4)


EEMC (6)


of road embankment, access roads, borrow pits, and auxiliary facilities (excavating, filling cutting activities, material transport):

construction sites, improper stockpiling of spoils and construction materials, haphazard spoils disposal, soil erosion and land slide at construction sites, causing damage to roads, polluting of canals, rivers and pond; and obstruction of flow of water courses.

storm water could be well controlled; erosion and land slide could be minimized.

design is good for erosion and storm water control Compliance


Project site

Not yet implemented because no erosion occurred.

30. (xxiv) Provide grass cover and other suitable slope stabilization measures on road embankment slopes and on long term stockpile of spoils (xxv) Spoil disposal shall not cause sedimentation and obstruction of flow of watercourses, damage to agricultural land and densely vegetated areas. (xxvi) The spoils disposal site shall be located at least 50m from surface water courses and shall be protected from erosion by avoiding formation of steep slopes and grassing. (xxvii) Spoils shall only be disposed to areas approved by local authority. (xxviii) Water courses (rivers, canals, etc.) shall be kept free of excavation spoil and construction debris, floating and submerged. (xxix) Spoil and construction materials stockpile area shall be located away from

Project site

- The contractor is advised to transport all spoil to approved disposal area as soon as possible because the rainy season is coming soon. -Wastewater from cleaning construction equipment was not effectively collected. Wastewater discharged to Long Tau river. -Bentonite overflowed from the container. Minor infringement

- Contractor already got approval for Disposal Area and transported disposal soil to such Disposal Area - Contractor should make dike along the Long Tau River within project area to prevent construction wastewater flowing into Long Tau river. → The Contractor has already done 15th April 2016. - Settling tanks should


291

Project activities

(1)


Impacts

(2)


by ADB

(3)

Location (4)


EEMC (6)


waterbodies and under no circumstances will these materials be dumped into watercourses. (xxx) Dredged and excavated materials shall be reused or provided to local residents as soon as possible, if they require such materials, for land reclamation. The remaining spoils can be disposed into low elevation sites for road construction. (xxxi) Provide temporary sediment traps (ditches and ponds) if high sediment laden runoff are observed.

be built 30 cm higher to prevent rainwater runoff into the tank as well as the tank does not overflow. - All construction wastewater must be collected on the first settling tank.. - The contractor must check the operation of the tank bentonite, ensure no spillage occurs.


Project site

Culverts and drainage systems were installed. Compliance

Activities at borrow pits may cause environmental pollution, soil erosion, damage local natural habitats,

32. (xxxiii) Select proper places for setting up borrow pits to avoid areas of serious acid sulfate and saline soils and to avoid encroachment into forest, cultivation, commercial and residential areas. Borrow sites shall be covered by necessary environmental permits/licenses

Borrow areas

So far, at J3 borrow pits are not operated, so evaluation on compliance with the EMP is not made.


292

Project activities

(1)


Impacts

(2)


by ADB

(3)

Location (4)


EEMC (6)


agricultural production, residential, commercial, cultural sites, and safety problems.

and shall be located over 300m away from residential, commercial, cultural sites and other sensitive receptors (schools, hospital, etc.). (xxxiv) Proper soil erosion control during borrow pits construction and operation by proper design and installation of adequate drainage system. (xxxv) Proper control of storm water at borrow sites in the rainy season by using sediment traps, treatment of turbidity, strong acidic water (by lime) and oil separation water if high turbidity, high acidity or high oil content were found. (xxxvi) Proper dust control during dredging, excavation at borrow sites and earth transport. (xxxvii) Topsoil (about 15 cm) will be kept and refilled after excavation is over, (xxxviii) Long – term material stockpiles will be covered to prevent wind erosion, (xxxix) Upon completion of extraction activities, re-contour borrow/quarry pit wall or fill-up when there are available and suitable materials such as excavation spoils , replace topsoil, and re-vegetate with native species such as grasses and fast-growing shrubs, (xl) Quarries and borrow pits will not be established in national, provincial, district and village conservation forests and other protected sites,


293

Project activities

(1)


Impacts

(2)


by ADB

(3)

Location (4)


EEMC (6)


(xli) Operation of existing quarry/borrow sites shall be preferred over establishment of new sites, as much as possible, (xlii) In case the Project will involve new quarry/borrow sites, necessary approvals from environmental authorities shall be obtained prior to operation of such sites, (xliii) During borrow site operation, provide adequate drainage to avoid accumulation of stagnant water, (xliv) Borrow/quarry sites shall not be located in productive land and forested areas, (xlv) Upon completion of extraction activities, borrow pits shall be dewatered and fences shall be installed, as appropriate, to minimize health and safety risks. (xlvi) Borrow pits will be left in a tidy state with stable side slopes and proper drainage in order to avoid erosion (xlvii) To avoid drowning when pits become water-filled, measures such as fencing, providing flotation devices such as a buoy tied to a rope, etc. shall be implemented. (xlviii) It is possible that villagers may request borrow pits to be excavated so that they may be used as water reservoirs or fishponds. If this were to be agreed between the contractors and the villagers, all the full safety measures


294

Project activities

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Impacts

(2)


by ADB

(3)

Location (4)


EEMC (6)


detailed above must be observed. Such agreements would be formalized in writing between the contractors and the villagers after full discussion with all concerned parties. .



Construction site

Measure 33 was implemented (No complaint from the household next to the project site- Mr. Nguyen Thanh Phong and Ms. Dang Thi Kim Ha) Compliance


Concrete mixers are located about 200 m from residential areas. However, no complaint from the household next to the project site- Mr. Nguyen Thanh Phong and Ms. Dang Thi Kim Ha.

35. Inform in advance local

Constructi

Measure 45 was


295

Project activities

(1)


Impacts

(2)


by ADB

(3)

Location (4)


EEMC (6)


residents on time/schedule and plan of construction activities.

on site done. Compliance




Construction site

Measure 47 was implemented (No complaint from the household next to the project site- Mr. Nguyen Thanh Phong and Ms. Dang Thi Kim Ha) Compliance

38. Install noise control walls (3.0-4.5m high, thick materials) at high noise sources that affect sensitive receptors (temples, pagodas, churches, schools)

Construction site

- Enclosing walls around the construction sites is just 2.0 m high. There is no receptors in the vicinity of the construction site. Compliance

39. Ensure that operation of trucks and other construction equipment and vehicles do not create high noise levels during

Project communes



296

Project activities

(1)


Impacts

(2)


by ADB

(3)

Location (4)


EEMC (6)


movement through densely populated areas.


Measure 50 was done (by direct interviews with the drivers and construction machines operators) Compliance


Construction site

There was no source of loud noise at the moment of field survey


42. On rainless day undertake watering, at least twice per day, on dusty and exposed areas at construction yards, materials stockpile, within and in the vicinity of concrete mixing stations, construction sites and access roads where residential areas and other sensitive receptors

Construction site, concrete mixing stations, materials stockpile areas, and access roads

Not too dusty at the project site at the moment of field survey

43. In addition to watering the zones in front of and inside concrete mixing stations, the following measures shall also be implemented to reduce impacts due to dust emissions: i) Concrete mixers and asphalt stations shall be located at least 300m from residential areas,

Concrete mixing plants and asphalt stations, construction sites

Enclosing walls around the construction sites is just 2.0 m high. There is no receptors in the vicinity of the construction site Compliance

Note: There is no receptors in the vicinity of the construction site. Noise wall is not necessary.


297

Project activities

(1)


Impacts

(2)


by ADB

(3)

Location (4)


EEMC (6)


hospitals, schools, and other sensitive receptors. ii) Ditches of 4 x 10 x 0.3 m (L x W x D) would be made by contractors in order to wash vehicles before they go out of the stations. This measure is necessary for concrete mixing stations where the dust content is very high as it keeps down soil and sand adhering to vehicle wheels. These are highly feasible measures. The best measure is to wash truck body and tires before moving out of the construction to urban areas. iii) Provide enclosing walls (3.0 – 4.0 m in high) around the construction sites that are near sensitive receptors (schools, populated areas, churches, pagodas, etc).


Access roads


45. Dredged spoil shall be compacted to minimize dust dispersion to surrounding residential areas. The surface of dredged spoil storage sites may be covered by dense plastic sheets to prevent dust dispersion. This sheet is also good for soil erosion prevention in the rainy months. Dredged


- No dust dispersion at area of spoil storage. - Dredged spoils shall be disposed to sites approved as soon as possible because of coming rainy

Disposal soil shall be transported to Disposal Area by 31th May 2016 (conducting)


298

Project activities

(1)


Impacts

(2)


by ADB

(3)

Location (4)


EEMC (6)


spoils shall be disposed to sites approved by local authority.

season



The contractor informed that all vehicles, construction machines used for the project have licenses The Consultant supervision already checked and approved before mobilization drivers and equipment. Compliance




- No expanding the project ROW to the wetland and mangrove forest area. - J3 Package is not located at Thi Vai Bank Compliance



No cutting trees outside the project area Compliance


299

Project activities

(1)


Impacts

(2)


by ADB

(3)

Location (4)


EEMC (6)


49. Prior to commencement of construction activities on site identify and mark with suitable visual reminders the areas of mangroves that are not to be disturbed during the works. This measure is recommended for the construction site at the banks of Soai Rap, Long Tau and Thi Vai rivers where belts of mangrove trees occur.


Section J3 is not located in mangrove forest.

50. Do not dispose dredging spoils and all types of waste onto mangrove forest areas, agricultural land, densely vegetated areas, and water courses.


No disposal of dredging spoils and all types of waste onto mangrove forest areas, agricultural land, densely vegetated areas, and water courses. Compliance






Project site

Fire fighting equipment at the work areas, as appropriate, and at construction camps is provided. Compliance


300

Project activities

(1)


Impacts

(2)


by ADB

(3)

Location (4)


EEMC (6)



Project site






Project site

- Local residents have to pass through the project area due to their living activities and business. Minor infringement

Contractors have agreed to open some roads for local residents and implement safety measures so that people can go through project area safely This measure


301

Project activities

(1)


Impacts

(2)


by ADB

(3)

Location (4)


EEMC (6)


should be implemented as soon as possible.


Project site

Local residents have to pass through the project area due to their living activities and business. Minor infringement

Contractors have agreed to open some roads for local residents and implement safety measures so that people can go through project area safely This measure should be implemented as soon as possible.

5. Specific issues: Dredging, filling, cutting activities during road construction at ASS areas

Acidification of soil and water caused by earth filling/cutting activities at acid sulfate soil (ASS) area. Consequently, aquaculture and aquatic organisms in

57. Install temporary shallow ponds (ground for containing dredged materials) and settlement pond at the construction sites which are highly affected by acidic water, to receive run-off water containing acidic materials, neutralize acidic water if its pH <5 or lower than pH value of surrounding water prior to discharge into fields or canals.

Project site

At present, no run –off water and no high acidity water generated at road construction area, so this measure is not needed.


302

Project activities

(1)


Impacts

(2)


by ADB

(3)

Location (4)


EEMC (6)


the acidified canals, ponds could be affected.


Project site

At present, no high acidity water generated at road construction area, so this measure is not needed. (there was actually no run-off during the field visit as it was at the mid of dry season)


Project site



Project site


61. The enclosure shall preferably include settling or

Project

At present, no


303

Project activities

(1)


Impacts

(2)


by ADB

(3)

Location (4)


EEMC (6)


sedimentation reservoirs to reduce turbidity and suspended solid and to treat leach ate of acidic water (including neutralization with lime if pH of water in the reservoir is lower than that of the surrounding environment).

site run – off water and no high acidity water generated at road construction area, so this measure is not needed.


Project site

No information on this issue. No complaint from the household next to the project site who is farming shrimp- Mr. Nguyen Thanh Phong and Ms. Dang Thi Kim Ha Compliance


- Surface water, groundwater, air, land pollution caused by spills and construction wastes and excavation spoils - Adverse impacts on cultivated areas and aquaculture


Project site

Dredged soil storage sites are not close to residential areas, agricultural areas. Therefore, this measure is not needed.

64. Arrange different kinds of rubbish bins for collection and segregation of domestic waste, hazardous waste around construction, and workers’


- No waste separation at source at the western bank of Long Tau river.

The corrective actions have been done by the


304

Project activities

(1)


Impacts

(2)


by ADB

(3)

Location (4)


EEMC (6)


- Aesthetic issues

camp sites.

- Contractor should follow Circular 36/2015/TT-BTNMT to preprare hazardous waste storage area. Minor infringement

contractor by 15th April 2016.


Domestic solid waste is transported and treated properly by a sub-contractor. Therefore, measure 75 is not needed.




67. Implement the following measures for handling hazardous substances and wastes: (xxii) Store fuel and hazardous substances in paved areas with roof and embankment. If spills or leaks do occur, undertake immediate clean up. (xxiii) Ensure availability of


- There is no embankment sourrounding the chemical tank (concrete additives). Minor infringement

- Embankments sourrounding the chemical tanks (concrete additives) must be built immediately.


305

Project activities

(1)


Impacts

(2)


by ADB

(3)

Location (4)


EEMC (6)


spill cleanup materials (e.g., absorbent pads, etc.) specifically designed for petroleum products and other hazardous substances where such materials are being stored. (xxiv) Segregate hazardous wastes (oily wastes, used batteries, fuel drums) and ensure that storage, transport and disposal shall not cause pollution and shall be undertaken consistent with national and local regulations. (xxv) Ensure all storage containers are in good condition with proper labeling. (xxvi) Regularly check containers for leakage and undertake necessary repair or replacement. (xxvii) Store hazardous materials above flood level. (xxviii) Equipment maintenance areas shall be provided with drainage leading to an oil-water separator that will be regularly skimmed of oil and maintained to ensure efficiency. Discharge of oil contaminated water shall be prohibited.

68. Provide information on waste management in training program for workers, including how to manage hazardous wastes. Train relevant construction personnel in handling of fuels and spill

Workers’ camp and construction sites

Report on Procedure of Waste Management was prepared. But there was no information on

Specific training program for management of hazardous wastes must be


306

Project activities

(1)


Impacts

(2)


by ADB

(3)

Location (4)


EEMC (6)


control procedures

training program for management of hazardous wastes Minor infringement

implemented in 2016 or the contractor shall provide more information on implementation of this program


Project site

Spoils are temporarily stored in areas close to the construction site but more than 200m from residential, commercial, cultural sites, agricultural areas. Compliance


Project site

Disposal of construction waste into fields, ponds, rivers and canals was not observed Compliance

71. Where significant amount of oily wastewater or spill/leakage of oil and grease may occur

Project site

No oil wastewater was found at the project site.


307

Project activities

(1)


Impacts

(2)


by ADB

(3)

Location (4)


EEMC (6)


(e.g., equipment maintenance areas), oil/water separators shall be provided for treatment of wastewater

Compliance


Project site



Project site

Open burning of domestic waste was found (the western bank of Long Tau river) Minor infringement

Contractor should implement the strict control to garbage and burning should be prohibited


Project site

There was no fences, gates, signs, car wash at Can Gio disposal area

Minor infringement

Contractors should install fences, gates, signs, car wash at Can Gio disposal area

75. Contractors shall keep at an

Project

Measure 85 is


308

Project activities

(1)


Impacts

(2)


by ADB

(3)

Location (4)


EEMC (6)


appropriate place the volume of dredged spoil (with high contents of organic matters) that is not used for leveling, and allow local people or companies to take it away for soil reclamation or forestation (farmers in the project districts like to use this type of soil for field reclamation of filling low land area).

site and surrounding area




Project site



Project site

There is no containers for storing hazardous waste at the western bank of Long Tau river. Major infringement

The corrective actions have been done by 15th April 2016 .


Project site

Contract for collection and treatment of hazardous waste is under negotiation. The contractor expects to sign the contract by 20th May 2016

The contractor must sign the contract by 20th May 2016


309

Project activities

(1)


Impacts

(2)


by ADB

(3)

Location (4)


EEMC (6)


Minor infringement


Project site

There are 2 available approved disposal areas (Disposal area in Can Gio and Nhon Trach) for non-hazardous waste soil disposal. They meet the EMP requirements for disposal sites. Compliance


Project site

Growing grass on excavated soil storage site is not necessary because time for excavated soil storage is only 1-2 weeks. During this storage time, watering the excavated soil was implemented to keep it stable, if necessary.


Reduction of vegetation cover, affecting local biological


Project site



310

Project activities

(1)


Impacts

(2)


by ADB

(3)

Location (4)


EEMC (6)


resource, creating increased soil erosion


Project site

No cutting trees outside the project ROW and Package J3 is not located at Thi vai river banks. Therefore, this measure is not needed.




Project communes



Project communes


85. Access roads damaged during transport of construction materials and other project-related activities shall be reinstated upon completion of

Project communes

Not yet implemented because the project is still under


311

Project activities

(1)


Impacts

(2)


by ADB

(3)

Location (4)


EEMC (6)


construction works at each section.

construction now.



Project communes



Project communes


9. Specific issue: Establishment of roadembankment



Project communes


89. Do not fill up canals and creeks at the construction site. In case filling of local drainage system is extremely necessary, consultation with local authorities shall be undertaken and their permission obtained beforehand. An alternative drainage shall be established

Project communes



312

Project activities

(1)


Impacts

(2)


by ADB

(3)

Location (4)


EEMC (6)


before the existing canal is filled-up.





The same assessment as items 19-37













Land erosion and land slide at bridge construction





313

Project activities

(1)


Impacts

(2)


by ADB

(3)

Location (4)


EEMC (6)


site. Obstruction of waterways.






No erosion, landslides at the place of bridge construction, so it is not necessary to take this measure. In fact, this measure is not practical. If erosion, landslides occurs, technical measures will be applied instead.

Operation of barges for material transport, causing water

97. Discharge of untreated waste water and release of rubbish from barges shall be prohibited. Solid waste shall be periodically collected and




314

Project activities

(1)


Impacts

(2)


by ADB

(3)

Location (4)


EEMC (6)


pollution by wastes, fuel leakage

transported to disposal sites approved/licensed by local authorities.














102. The contractor shall ensure that barge owners involved in bridge construction shall have an oil spill prevention and response plan and relevant technical facilities for its implementation. In case of spills of oil and other hazardous substances, the contractor shall implement the following measures: (i) Immediately inform the Sai


The barge owner does not have an oil spill prevention and response plan and relevant technical facilities for its implementation. Major infringement

The barge owner must get approval for their oil spill prevention and response plan and they have to equip all relevant


315

Project activities

(1)


Impacts

(2)


by ADB

(3)

Location (4)


EEMC (6)


Gon Port Authority, who is responsible for waterway transport in Ho Chi Minh City and surrounding region. (ii) Engage oil spill removal companies and local authorities to immediately respond to oil spill incidents caused by the Project. (iii) Immediately inform communes which may be affected by oil the spill. (iv) After the oil spill has been controlled/removed, the contractor will coordinate with the relevant local communes to address land and water pollution caused by the spill, and to provide compensation for environmental and economic damages, following the relevant Vietnamese laws and guidelines.

technical facilities for its implementation




Project site

This measure will be implemented when the contractor will require a big number of workers

104. In recognition of the fact

Project

This measure will


316

Project activities

(1)


Impacts

(2)


by ADB

(3)

Location (4)


EEMC (6)


that despite implementation of the above measures, large numbers of non-local workers will still be required, construction contractors will work with the local authorities to develop a range of measures to minimize the adverse effects of the planned construction force and unplanned migrants.

site be implemented when the contractor will require a big number of non-local workers


Project site





Project site

No cultural heritage at ROW of Package J3


No physical historic objectives found at J3

From the detailed assessment on the contractor's (JO of Sumitomo Mitsui – Cienco4) compliance with EMP, can be concluded that, at the present time, the contractor has implemented various measures to


317

prevent pollution and waste management. Most of the measures are complied with EMP. However, in the total of over 100 evaluated measures 13 measures were not complied, of which 11 measures as minor infringement and 2 measures as major infringement are evaluated. The main major infringement relates with improper management of hazardous wastes. They must be properly corrected immediately.

Figures on the situation of environmental management at Packages J3, March 2016

Meeting of EEMC with representatives of EPMU, CSC and contractors

Monthly environmental monitoring reports prepared by the contractor

Interviewing by EEMC with a household closed to the construction site

Construction activities at Package J3


318

Rice stored in an unused toilet room First-aid facility and fire fighting facility at the project

site

Solid waste segregation at J3 package Betonite leakage from the tank

Spoil must be moved to disposal area before the rainy season

A training course on work safety, sanitation and social security


319

A Clean workers’ camp Toilet for female

Chemical tanks are not properly storaged. There is evidence of construction wastewater discharging into Longtau river

No waste segregation at the western bank of Longtau river

Open burning of domestic solid waste at the project site


320

PERSONS MET BY THE EEMC SPECIALISTS DURING IMPLEMENTATION OF EXTERNAL ENVIRONMENTAL MONITORING IN MARCH AND APRIL 2016

1. At EPMU Office 23rd March 2016 1. Mr. Ngo Anh Sang, Head of Construction Management and LA 2. Mr. Le Van Dung, Expert 3. Ms. Phan Anh Thy, Environmental officer

2. Meeting on 15th April 2016 at CSC (Dasan-Kunhwa-ITC JV) Office

- EPMU: Ms. Phan Anh Thy, Environmental officer

- Supervision Consultants:

Dasan-Kunhwa-ITC JV: Mr. Nguyen Tien Dung, Co-Team Leader, ADB Packages KEI-NE-OCG-TEDI JV: Mr. An Quoc Vinh, Co-Team Leader, JICA Packages Mr. Nguyen Quoc Luan, environmental specialist for both Dasan-Kunhwa-ITC and KEI-NE-OCG-TEDI JVs

3. At the construction packages a. At Package A1, 28th March 2016: (ii) Ms. Phan Anh Thy, EPMU environmental officer (iii) Mr. Nguyen Quoc Luan, environmental Specialist of Dasan-Kunhwa-ITC JV (iv) Mr. Do Minh Quang, Safety engineer, Halla-Vinaconek JV; Tel: 0918420086 (v) Mr. Tran Ngoc Chuyen, Environmental engineer, Halla-Vinaconec JV; Tel: 0948004635 (vi) Mr. Nguyen Quoc Dung, Safety Inspector, Halla-Vinaconex JV; Tel: 0943422129 b. At Package A2-1: (vii) Ms. Phan Anh Thy, EPMU environmental officer (viii) Mr. Nguyen Quoc Luan, environmental Specialist of Dasan-Kunhwa-ITC JV (ix) Mr. Nguyen Xuan Mau, Technical Engineer of the Management Board (x) Mr. Le Van Luong, Safery and Environmental engineer c. At Package A2-2: (xi) Ms. Phan Anh Thy, EPMU environmental officer (xii) Mr. Nguyen Quoc Luan, environmental Specialist of Dasan-Kunhwa-ITC JV d. At Package A3 (xiii) Ms. Phan Anh Thy, EPMU environmental officer (xiv) Mr. Nguyen Quoc Luan, environmental Specialist of Dasan-Kunhwa-ITC JV (xv) Mr. Tran Dai Nghia, Environmental Management (xvi) Mr. Tran Le Viet Hau, Safery Management e. At Package A4 (xvii) Ms. Phan Anh Thy, EPMU environmental officer (xviii) Mr. Nguyen Quoc Luan, environmental Specialist of Dasan-Kunhwa-ITC JV (xix) Ms. Tran Thi Bich, Environmental Management (xx) Mr. Tran Van Hoa, Safery Management f. At Package J2 (xxi) Ms. Phan Anh Thy, EPMU environmental officer (xxii) Mr. Nguyen Quoc Luan, environmental Specialist of KEI-NE-OCG-TEDI JV (xxiii) Mr. Kazumitsu Tahara, Project Management package J2 (xxiv) Mr. Phạm ThanhToan, Environmental Management (xxv) Mr. Le Ngoc Xuan, Safery Management g. At Package J3


321

(xxvi) Ms. Phan Anh Thy, EPMU environmental officer (xxvii) Mr. Bui Huu Dung, EPMU officer (xxviii) Mr. Nguyen Quoc Luan, environmental Specialist of KEI-NE-OCG-TEDI JV (xxix) Mr. Edwin Zipagan, Safery Management package J3 (xxx) Mr. Đang Van Dien, environmental officer (xxxi) Mr.Nguyen Minh Khoi, Safery engineer (xxxii) Mr. Nguyen Ngọc Trung, supervisor 4. At communes: List of commune officers, representatives of NGOs and affected people at 3 communes met in the public consultation meetings are given in Part Five. Completion of English version: 30 April 2016 Completion of Vietnamese version: 30 May 2016 Completion of revised English and Vietnamese versions and resubmission to EPMU: 20th June 2016 Receiving comments from ADB: 18th September 2016 Final revision following ADB comments and resubmission to EPMU: 3rd October 2016. EEMC: Institute for Environmental Science and Development (VESDEC).