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ENVIRONMENTAL MONITORING REPORT Semestral Report October 2019

Project 41444-024

Loan 3317-VIE: Second Northern Greater Mekong Subregion

Transport Network Improvement Project (Additional Financing)

Prepared by Thang Long PMU, Ministry of Transport

for the Asian Development Bank (ADB)

Environmental Monitoring Report No. 3

Semi-annual Report

January-June 2019

Second Northern Greater Mekong Subregion Transport Network

Improvement Project (Additional Financing)

ADB Loan No. 3317 VIE (SF)

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.

ABBREVIATIONS

ADB Asian Development Bank

BOD5, Biological Oxygen Demand, five days

BTNMT Ministry of Natural Resources and Environment

CO Carbon Monoxide

Cu Copper

CEMP Contractor’s Environmental Management Plan

COD Chemical Oxygen Demand

DO Dissolved Oxygen

DONRE Department of Natural Resources and Environment

EMP Environmental Management Plan

SEMR Semi-annual Environmental Monitoring Report

ES Environmental Specialist

GCC General Conditions of Contract

GOV Government of Vietnam

GRM Grievance Redress Mechanism

Hg Mercury

MMP Materials Management Plan

PDCV Project Design Consultant

PMU-TL Project Management Unit (Thang Long)

PSC Project Supervision Consultant

IEE Initial Environmental Examination

IES International Environmental Specialist

MOT Ministry of Transportation

NES National Environmental Specialist

NO2 Nitrogen dioxide

Pb Lead

PCC Particular Conditions of Contract

PMU-TL (Thang Long) Project Management Unit

PPE Personal Protection Equipment

PSC Project Supervision Consultant

QCVN Vietnam Standard

REMDP Resettlement and Ethnic Minority Development Plan

RoW Right-of-Way

SO2 Sulfur Dioxide

SPS Safeguard Policy Statement

SWMP Spoil and Waste Management Plan

TSD Technical and Scientific Division (in PMU-TL)

TSP Total Suspended Particulates

Zn Zinc

TABLE OF CONTENTS

1 INTRODUCTION ............................................................................................................... 1

1.1 Background .................................................................................................................................... 1

1.2 Scope and Purpose of Report ...................................................................................................... 1

1.3 Progress of Project Implementation ............................................................................................ 1

2 COMPLIANCE WITH ADB LOAN COVENANTS AND APPLICABLE GOVERNMENT LAWS,

REGULATIONS AND REQUIREMENTS .............................................................................. 2

2.1 Status of Compliance with ADB Loan Covenants ...................................................................... 2

2.2 Status of Compliance with Government Environmental Requirements .................................. 6

3 CHANGES IN PROJECT SCOPE ....................................................................................... 9

4 INCORPORATION OF ENVIRONMENTAL REQUIREMENTS INTO THE PROJECT

CONTRACTUAL ARRANGEMENTS ................................................................................... 9

5 SUMMARY OF ENVIRONMENTAL MONITORING ............................................................... 9

5.1 Compliance inspections ................................................................................................................ 9

5.1.1. Summary of inspection activities ............................................................................................... 9 5.1.2. Status of Compliance with the IEE-EMP during the Pre-construction Stage .......................... 10 5.1.3. Status of the EMP/CEMP Implementation during the Construction Stage .............................. 10

5.2 Environmental Effect Monitoring ............................................................................................... 26

5.1.4. Requirement ............................................................................................................................ 26 5.1.5. Results and Evaluation ............................................................................................................ 27

6 Key Environmental Issues .............................................................................................. 32

6.1 Key Issues Identified ................................................................................................................... 32

6.2 Issues from previous report(s) ................................................................................................... 33

6.3 Issues Identified by ADB’s Loan Review Mission (May and November 2018) ....................... 37

6.4 Issues identified by ADB’s Loan Mission Review in May 2019 ............................................... 39

6.5 Environmental and safety issues raised by local community during the consultation on the project income restoration program held on 05-10 June 2019 ............................................... 39

6.6 Highlights/Notable Environmental Management Practices ..................................................... 39

7 Complaints .................................................................................................................... 40

8 Conclusions................................................................................................................... 40

8.1 Overall Progress of Implementation of Environmental Management Measures ................... 40

8.2 Problems Identified and Actions Recommended ..................................................................... 41

Appendix 1: Assessment of Compliance with the EMP ......................................................... 42

Appendix 2: Contract with insurance company .................................................................... 62

LIST OF TABLES Table 1. Status of Civil Works by 30 June 2019 ...................................................................... 1 Table 2. Project loan covenants on environment and status of compliance ............................ 2 Table 3. The GOV environmental requirements and compliance levels .................................. 6 Table 4. List of PSC and Contractors’ Environmental Management Staff ................................ 9 Table 5. List of Material Sources............................................................................................12 Table 6. List of Disposal Sites ................................................................................................13 Table 7. Corrective Action Plan for Dust ................................................................................16 Table 8. Corrective Action Plan for Issues related to Flooding and Erosion ...........................18 Table 9. List of Contractors’ Camps .......................................................................................23 Table 10. Monitoring/Sampling Program ..............................................................................26 Table 11. Outstanding Environmental Issues and Action Plan .............................................33 Table 12. Issues Identified during the ADB Mission in May 2019 and Action Plan for Closure 37 Table 13. Notable Environmental Management Practices ....................................................39

LIST OF FIGURES Figure 1. Photos of Project’s quarries .....................................................................................12 Figure 2. Photos of disposal sites and spoils management ....................................................14 Figure 3. Photos of Construction Waste Management Practices ............................................15 Figure 4. Photos of hazardous waste management ................................................................15 Figure 5. Photo of Batching plant of Package 2.2 ...................................................................16 Figure 6. Photos of dust management ....................................................................................18 Figure 7. Erosion and run-off control measures ......................................................................20 Figure 8. Impacts of construction brought about by recent rains and open ditches .................22 Figure 9. River Protection and Water Quality Control .............................................................22 Figure 10. Photos of workers camps .....................................................................................23 Figure 11. Photos of Worksite Conditions .............................................................................24 Figure 12. Photos of Traffic Safety Conditions ......................................................................25 Figure 13. Results of TSP (dust) monitoring .........................................................................27 Figure 14. Results of Noise Level Monitoring ........................................................................28 Figure 15. Results of TSS Monitoring ...................................................................................28 Figure 16. Temperature Monitoring Results ..........................................................................29 Figure 17. pH Monitoring Results ..........................................................................................29 Figure 18. TSS Monitoring Results .......................................................................................30 Figure 19. BOD5 Monitoring Results.....................................................................................30 Figure 20. COD Monitoring Results ......................................................................................30 Figure 21. Oil and Grease Monitoring Results ......................................................................31 Figure 22. Coliform Monitoring Results .................................................................................31

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1 INTRODUCTION

1.1 Background

1. The Additional Financing for the Second Northern Greater Mekong Subregion Transport Network Improvement Project (the Project) aims to: (i) improve the section from Km 59+900 - Km 104+475 of the National Highway 217 (NH217); (ii) construct a railway flyover at Km 0 in Ha Trung; and (iii) improve the operation and maintenance of NH217 for the section from Km 59+900 – Km 104+475. The starting point of the Project is at Km 0 interchange with NH1A (Km 301+500 - NH1A) and North-South railway, Ha Trung District, Thanh Hoa Province. The ending point is at Km 104+475 at Dong Tam Intersection, Ba Thuoc District, Thanh Hoa Province.

2. In line with the ADB’s Safeguard Policy Statement (SPS) 2009, an Initial Environmental Examination (IEE) report1 including an Environmental Management Plan (EMP) was prepared and submitted to ADB by Thang Long Project Management Unit (PMU-TL) prior to conclusion of the loan agreement. The IEE-EMP contains the recommended environmental management measures and monitoring program to ensure that the identified negative environmental and social impacts during the Project implementation will be avoided or at least minimized to acceptable levels. In line with the recommendations in the IEE-EMP, civil works Contractors prepared their respective Contractor’s Environmental Management Plan (CEMP) that detail how the Contractors ensure compliance with the ADB’s SPS, the EMP and with the applicable laws and regulations of the GOV.

1.2 Scope and Purpose of Report

3. This report is the semi-annual environmental monitoring report (SEMR) of the period from January to June 2019 for the Project. It describes the environmental performance of the Project from January until end of June 2019. It explains the assessment of compliance by the Contractors with the IEE-EMP and with their respective CEMP. It also presents the assessment of the Project’s compliance with the loan covenants relevant to environment, the environmental laws, regulations and standards of the GOV as well as the Project’s compliance with the EMP during the detailed design and pre-construction stages.

1.3 Progress of Project Implementation

4. The Project was divided into three contract packages. All three packages have been awarded and

construction is ongoing by the end of June 2019, as shown in Table 1.

Table 1. Status of Civil Works by 30 June 2019 Contract Package

Scope Contractor Start Date Accomplishment by 30 June 2019

Planned Actual

Package 1.0 (PK-1.0)

Construction of Railway

Flyover

JV of Thang Long – Petro Infrastructure Investment

24 Jan 2018 77.08% 44.27%


Km59+900 to Km82+200 JV of Tan Thanh – Thong Nhat 16 Mar 2018 44.76% 39.66%


Section Km82+200 to Km 104+475

JV of Hoang Long – CENCO 1 21 Feb 2018 59.57% 39.31%

5. The construction activities implemented during this monitoring period is described as below for each package.

Package 1.0

6. Railway bridge construction: completed 02 piers, 01 pier is being carried out; casted 15/37 Super T girders and 18/36 plate girders; completed 42/59 bored piles. Pavement embankment: 2.0/2.32 km subbase and base; 0/2.32 km bamboo piles; 196,000/231,262 m pipe culverts: completed 5/7 locations, carrying out 02 locations; big box culverts: completed 1/5 locations, constructing 3/5 locations; 01 location of retaining wall: not yet constructed.

1 https://www.adb.org/sites/default/files/linked-documents/41444-024-ieeab_1.pdf

https://www.adb.org/sites/default/files/linked-documents/41444-024-ieeab_1.pdf

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Package 2.1

7. Common excavation: 175,944/270,208 m3 (65.11%); embankment works: 91,895/147,669 m3 (62.23%); completed 347/530 prefabricated component structures; aggregate base construction: 9 km/22.30 km; culverts: pipe culverts (10/33), box culvert 46/82); retaining wall (0%); bridge construction (1/1) ongoing; base course (0/22.3km); asphalting works (0/22.3km); finishing work – not yet started.

Package 2.2

8. Common excavation: 113,000/154,046m3 (73.37%); embankment works: 17/22.3 km (76.23%); prefabricated component structures: completed 3,100/9,850 segments, casting girder L=20m: 4/9 girders (Hon Nga bridge); aggregate base construction: 13/22.30 km (58.3%); culverts: pipe culverts (24/63), retaining wall on-going 02/07; bridge construction (2/2) ongoing; base course (7/22.3km); asphalting works (7/22.3km); finishing work – not yet started.

2 COMPLIANCE WITH ADB LOAN COVENANTS AND APPLICABLE GOVERNMENT LAWS, REGULATIONS AND REQUIREMENTS

2.1 Status of Compliance with ADB Loan Covenants

9. The list of Project loan covenants2 on environment and the status of compliance by the Project is

presented in Table 2.

Table 2. Project loan covenants on environment and status of compliance ADB Environmental loan covenants Status of compliance

Schedule 5, Para 2. The Borrower shall ensure, or cause the Project Executing Agency to ensure, that the preparation, design, construction, implementation, operation and decommissioning of the Project and all Project facilities comply with (a) all applicable laws and regulations of the Borrower relating to environment, health and safety; (b) the Environmental Safeguards; and (c) all measures and requirements set forth in the IEE, the EMP, and any corrective or preventative actions set forth in a Safeguards Monitoring Report. Should there be any discrepancy between the Borrowers laws and regulations and ADBs policy, ADBs policy shall prevail. In the case of any discrepancy or inconsistency among the Borrowers laws, regulations and procedures relating to the environment, health and safety and the SPS, the SPS shall prevail.

Not complied. During the construction stage, the Contractors’ compliance with the environmental safeguard requirements, health and safety regulations, and all measures specified in the IEE-EMP is regularly monitored by the PMU-TL with support from the PSC. Some mitigation measures have not been implemented properly and complaints regarding environmental issues have been received. Environmental Corrective Action Plan (ECAP) is under preparation.

Schedule 5, Para 3. The Borrower shall ensure that: (a) all bidding documents and Works contracts include the EMP and require contractors to comply with its provisions; (b) portions of the Project, regardless of the source of funding, will adopt the provisions of the EMP and will comply with the Environmental Safeguards; (c) the Project Executing Agency (i) adequately supervises the Works carried out by

Not complied. Section 4.18 of the General Conditions of Contract (GCC) stipulates the requirement to comply with environmental protection measures while Section 6.7 specifies the requirements on health and safety. Compliance with these conditions is highlighted in the Particular Conditions of Contract. (a) The EMP has been included as Annex 04 of the

bidding documents issued for all the civil works packages

2 https://www.adb.org/sites/default/files/project-document/181176/41444-024-sfj.pdf

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ADB Environmental loan covenants Status of compliance

contractors to ensure compliance with the monitoring and mitigation measures set forth in the EMP, (ii) ensures that consultants engaged for construction supervision closely monitor the contractors compliance with the EMP, and (iii) the construction contractors develop a CEMP based on the EMP; and (d) semiannual reports on implementation of the EMP are submitted to ADB on a timely basis.

(b) All contractors prepared their CEMPs consistent with the EMP. The CEMPs have been approved by the PMU-TL and submitted to ADB. Environmental supervision/monitoring has not been conducted since before March 2019, when the national environmental consultant (NEC) abandoned his assignment without notice. As of 30 June 2019, only 2.4 person-months (PM) inputs are left for the NEC position, while the project construction is expected to continue until March 2020. Only 12 PMs were allocated for the NEC, although the Project Administration Manual requires 24 PMs3.

(c) SEMR are being prepared for submission to ADB, but with significant delay.

Schedule 5, Para 4. In the event that the Borrower and ADB agree during implementation to include improvement of any access roads under the Project, the Borrower shall ensure that: (a) the Project Executing Agency conducts an environmental assessment of such access roads proposed to be financed under the Project based on the EARF and SPS; and (b) such access roads (i) used for logging and or mining, or (ii) that pass through ecologically sensitive areas such as national biodiversity conservation areas and similarly protected sites, in each case, shall not be selected and financed under the Project.

Fully complied. (a) All items related to the Project such as access roads

to quarry sites have been identified during the detailed design stage and environmental management measures were incorporated in the EMP of the EIA report which was approved by Ministry of Transportation (MOT) in 2015 (hereinafter called as “Vietnamese EIA”).

(b) The project and its access roads do not pass through ecologically sensitive areas such as national biodiversity conservation areas and similarly protected sites.

Schedule 5, Para 5. In the event that there are additional components or major changes in the Project such as the location and/or design, that are not within the scope of the IEE and are expected to result in adverse environmental impacts, a new or supplementary environmental assessment report shall be prepared in compliance with the EARF and SPS and submitted to ADB for clearance prior to the implementation of the additional component or changes.

Not applicable currently There are no additional components or major changes in the Project currently. In the future, if there will be additional component or major changes in Project such as the location and/or design which were not covered by the Project IEE and expected to result in adverse environmental impact, a new or supplementary environmental assessment report shall be prepared in compliance with the EARF and SPS and submitted to ADB for clearance prior to implementation.

Schedule 5, Para 12. Safeguards - Related Provisions in Bidding Documents and Works Contracts. The Borrower shall ensure, or cause the Project Executing Agency to ensure, that all bidding documents and contracts for Works contain provisions that require contractors to: (a) comply with the measures relevant to the contractor set forth in the IEE, the EMP, the REMDP (to the extent they concern impacts

Fully complied. The bidding documents and contracts for all three packages contain the provisions (a) – (e). (a) The EMP has been incorporated in the bidding

documents as Annex 4. Section 4.18 of the GCC stipulates the requirement to comply with environmental protection measures while Section 6.7 specifies the requirements on health and safety. Compliance with these conditions is highlighted in the Particular Conditions of Contract, Part B -

2 The Loan Agreement (Schedule 5, para 2) states that “The Borrower, through the Project Executing Agency, shall

ensure that the Project is implemented in accordance with the detailed arrangements set forth in the PAM.”

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on Affected Persons during construction), and any corrective or preventative actions set forth in a Safeguards Monitoring Report; (b) make available a budget for all such environmental and social measures; (c) provide the Borrower and the Project Executing Agency with a written notice of any unanticipated environmental, resettlement or indigenous peoples risks or impacts that arise during construction, implementation or operation of the Project that were not considered in the IEE, the EMP, or the REMDP; (d) adequately record the condition of roads, agricultural land and other infrastructure prior to starting to transport materials and construction; and (e) reinstate pathways, other local infrastructure, and agricultural land to at least their pre-Project condition upon the completion of construction.

Specific Provisions, which state that Sub-clause 4.18 of the GCC shall be read as follows:

“The Contractor shall (i) comply with the provisions of the Environmental Management Plan (“EMP”); (ii) ensure that the construction and operation of the Project shall be carried out in accordance with the EMP; and (iii) construction contractors shall develop a CEMP based on the EMP;

The Contractor shall take all necessary measures and precautions to ensure that the execution of the Works and all associated operations are carried out in conformity with statutory and regulatory environmental requirements of the Government of Viet Nam, as well as the environmental mitigation measures in the environmental management plan (EMP) and CEMPs. Employer reserves the right to withhold payments for progress billing and/or stop construction in the event of violations with the environmental requirements and mitigation measures mentioned above; and

In the event the contractor fails to implement the required environmental mitigation measures within the completion dates set by Employer, Employer shall engage a third party to undertake such measures and the associated costs shall be deducted from the contractor’s payment. “

CEMP is included in the Contractors’ Technical Bid. CEMPs have been prepared by the Contractor and approved by the PMU-TL.

(b) Annex 04 - CEMP Report that forms part of the Bidding Documents issued to bidders states under ‘A - Contents to be Included in the Bid’, that: “the Contractor’s bid are advised to clearly state that all necessary costs for implementation of EMP [are] included in the bid price, which is already made into details in the Bidding documents and in compliance with the Environmental Measures Statement of the Project. In Section C.1 (v) of the EMP - Environmental Management System Requirement - General Responsibility of the Contractor, it is specified that it is the responsibility of the Contractor to update EMP provided by the Detailed Design Consultant and prepare necessary resources to implement proposed mitigation measures to Employer/PSC before work commence.

(c) Annex 04 – EMP report that forms part of the Bidding Documents issued to bidders, states under C.1 (iv) Environmental Management System Requirement - General Responsibility of the Contractor that the Contractor shall “provide and inform Employer on activities and operation that can directly affect or continuously have noticeable adverse impacts on environment”.

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(d) The requirements to record existing conditions of roads, agricultural lands and other infrastructure project construction are specified in different sections of the technical specifications. In Section 101-17, Investigation of Related Submerged and Non-Submerged Structures, Contractors are required to carefully survey to identify exact locations of submerged and non-submerged public structures related to the construction of the whole works. Section 103- Construction Organization and Traffic Control, Item 3.1.2.2 - General requirements specify that the Contractor shall be responsible for carrying out the necessary investigations and information requirements for traffic control and safety. In Section 105-Site Engineering and Shop Drawing, Section 105-3 specifies horizontal profiling of the road and identification of drainage structures. Section 105-4 specifies the requirement for old road surface volume survey and Section 105-7 specifies the requirement for topographic survey for potentially unstable areas including drainage characteristics (such as ditches, ponds, waterways and rice fields).

(e) Specification Section 108.3 - Final Cleanup, states that Contractors also have to restore to the original condition all areas that are not required to be modified.

Schedule 5, Para 13. The Borrower shall, or cause the Project Executing Agency to, do the following: (a) submit semi-annual Safeguards Monitoring Reports to ADB and disclose relevant information from such reports to Affected Persons promptly upon submission; (b) if any unanticipated environmental and/or social risks and impacts arise during construction, implementation or operation of the Project that were not considered in the IEE, the EMP, or the REMDP, promptly inform ADB of the occurrence of such risks or impacts, with detailed description of the event and proposed corrective action plan; (c) no later than the conduct of the detailed measurement survey, engage a qualified and experienced external expert(s) or qualified NGO(s) under a selection process and terms of reference acceptable to ADB, to monitor resettlement activities and land acquisition. facilitate the carrying out of any verification activities by such external expert(s) or qualified NGO(s), and report on a semi-annual basis to the Borrower and ADB, as applicable; and (d) report any actual or potential breach of

Partially complied. (a) SEMR are being prepared for submission to ADB,

but with significant delay. For example, the previous SEMR for Jul-Dec 2018 could not be finalized/disclosed until May 2019. all semi-annual environmental monitoring reports for this Project, immediately after they are uploaded on the ADB website, the PMU-TL will, with the assistance of PSC, translate the whole report into Vietnamese language, prepare the summary report in Vietnamese, and submit them to the Provincial People’s Committee of Thanh Hoa Province. Furthermore, PMU-TL will request PSC to (i) post these reports at their commune offices within the project impact areas; and (ii) disseminate the disclosure (posting) information to the local people through district people’s committees’ radio.

(b) During this report period, there are no records or reports received by the PMU-TL or the PSC of any complaint or information on unanticipated environmental issues or impacts that were not considered in the IEE or EMP.

(c) N/A (not relevant to environment) (d) Issues relating to dust, hazardous waste

management, cleanliness and traffic safety were noted by the PSC during the project inspections. The PSC requires the Contractors to correct such

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compliance with the measures and requirements set forth in the EMP or the REMDP promptly after becoming aware of the breach.

issues through site instruction and letters immediately after such issues are observed.

2.2 Status of Compliance with Government Environmental Requirements

10. The status of compliance with the GOV environmental requirements is presented in Table 3.

Table 3. The GOV environmental requirements and compliance levels No. Government Environmental Requirements Compliance Status

Laws on environment protection

1 Environmental Protection Law No.55/2014/QH13 of the 13th National Assembly, the 7th Session, passed on 23 Jun 2014 and put into force from 1 Jan 2015.

Not complied with.

All environmental protection requirements are

fulfilled, such as preparation of Vietnamese EIA and

EMP, however, protection and mitigation measures

are not implemented properly and caused some

environmental problems and complaints from the

local people.

PMU-TL prepared Vietnamese EIA for the project,

which was approved by the MOT in 2015.

The Vietnamese EIA includes:

1. Origin of the project, project owners, and the

competent authority's approval of the project;

method of the environmental impact

assessment.

2. Evaluation of technological choice, work items

and any activity relating to the project which can

cause bad effects on the environment.

3. Assessment of current status of natural and

socio-economic environment carried out at areas

where the project is located, adjacent areas and

demonstration of the suitability of the selected

project site.

4. Assessment and forecast of waste sources, and

the impact of the project on the environment and

community health.

5. Assessment forecast and determination of

measures for managing the risks of the project

posed to the environment and community health.

6. Waste disposal measures.

7. Measures for minimizing the impact of the project

on the environment and community health.

8. Consultation result.

9. Environmental management and supervision

programs.

10. Budget estimate for the construction of

environmental protection facilities and measures

to be taken to minimize the environmental

impact.

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No. Government Environmental Requirements Compliance Status

11. Alternatives to the application of measures for

the environment protection.

2 Decree No. 18/2015/ND-CP dated 14 Feb 2015 of the Government on Regulating Strategic Environmental Assessment, Environmental Impact Assessment and Environmental Protection Commitment;

Fully complied

Vietnamese EIA has been prepared for this project in

accordance with the government regulation. (See

item 1 above)

3 Decree No.38/2015/ND-CP dated 24 Apr 2015 issued by the GOV on waste and waste materials management.

Partially Complied Housekeeping has improved compared to the last reporting period, but not good enough. Contractor will be continually reminded to maintain good housekeeping. Recycling and segregation of wastes will be a topic of workers’ environmental training to be carried out in July 2019 by the Contractors and follow-on training by the PSC also in July 2019.

4 Circular No.36/2015/TT-BTNMT dated 30 June 2015 issued by the MONRE regarding the hazardous waste’s management.

Partially Complied The contractors have not signed contract with hazardous waste collection company for collection and treatment of hazardous solid and liquid wastes. The contractors are collecting solid and liquid hazardous wastes in separate containers but have not constructed a storage area for proper storage of hazardous wastes prior to collection by licensed company. Hazardous waste management will be included in the follow-on training to be conducted by the Consultant in July 2019.

5 Circular No.27/2015/TT-BTNMT dated on 29 May 2015 on strategic environmental assessment, environmental impact assessment, and environmental protection plan.

Fully complied

Vietnamese EIA has been prepared and circulated to

Contractors before start of construction.

Other relevant decrees or ordinances:

1 Decree No. 45/2013/ND-CP dated 10 May 2013 of the GOV regarding the detailed regulation on some articles of the Labor Code on working hours, rest hours, occupational safety and occupational hygiene.

Partially complied The Contractors are complying with the required working hours, rest hours, occupational hygiene but they must improve on occupational safety in construction sites.

2 Circular No.22/2010/TT-BXD dated 2 Dec 2010 issued by the Ministry of Construction (MOC) regarding the regulation on labor safety during the project construction process.

Partially complied Most workers do not wear PPE on site. Safety training for workers should be strengthened. The PSC had a meeting with the Contractors on 08 July 2019 to discuss about worker training topics and schedules. Package 1.0 has scheduled the training for 23 July 2019. PK-2.1 and PK-2.2 have not confirmed their training schedule.

3 Decision No.3733/2002/QD-BYT issued by the Ministry of Health dated 10 Oct 2002 regarding the promulgation of 21 labor hygiene standards, 5 principles and 7 labor hygiene measurements.

Fully Complied All worker camps are provided with safe drinking and domestic water supply, sanitary latrine with septic tank, kitchen and dining areas. Camps are maintained in sanitary condition.

Environmental Standards and Regulations

1 QCVN 03-MT: 2015/BTNMT – National Not Applicable The Vietnamese EIA does not

http://thuvienphapluat.vn/van-ban/EN/Lao-dong-Tien-luong/Decree-No-45-2013-ND-CP-elaborating-a-number-of-articles-of-the-labor-code-on/188515/tieng-anh.aspx






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No. Government Environmental Requirements Compliance Status

technical regulation on permitted limits of some heavy metals in soil

require soil survey for heavy metals.

2 QCVN 15:2008/BTNMT – National technical regulation on residues of plant protection chemicals in soil

Not Applicable The Vietnamese EIA does not specify the need to carry out survey for chemical constituents in soil.

3 QCVN 05-MT: 2013/ BTNMT – National technical regulation on ambient air quality

Complied. Air quality monitoring was carried out on 27-29 May 2019. The results indicated that the dust in the project sites was within the regulatory limit of 300 µg/m3. Detailed information could be found in Section 5.2 of this report.

4 QCVN 06: 2009/BTNMT – National technical regulation on some certain hazardous substances in the ambient air

Complied. Equipment used in the project are in good condition and have certificate. Equipment on site are quite new and do not emit visible smoke.

5 QCVN 07: 2009/BTNMT – National technical regulation on hazardous waste thresholds

Not Applicable The Project is not expected to produce excessive quantity of hazardous waste. The Vietnamese EIA does not specify the need to carry out laboratory analyses of hazardous wastes.

6 QCVN 08-MT: 2015/BTNMT – National technical regulation on surface water quality

Complied. Surface water quality monitoring was carried out on 27-29 May 2019 for suspended solids (SS). The results indicated that the concentration of SS in the three (3) sampling locations was lower than the regulatory limit of 50mg/l for water intended for agricultural uses. Detailed information could be found in Chapter 5.2 of this report.

7 QCVN 09-MT: 2015/BTNMT – National technical regulation on groundwater

Not Applicable The Vietnamese EIA does not specify the need to carry out groundwater quality monitoring

8 QCNV 10-MT: 2015/BTNMT – National technical regulation on sea water quality

Not Applicable The project site is far from the sea. The Vietnamese EIA does not specify the need to carry out survey on sea water quality

9 QCVN 14-MT:2008/BTNMT - National technical regulation on domestic wastewater

Not Applicable The Vietnamese EIA does not specify the need to carry out survey of domestic wastewater quality.

10 QCVN 40:2011/BTNMT – National technical regulation on industrial wastewater quality

Not Applicable The Vietnamese EIA does not specify the need to carry out survey of industrial wastewater quality.

11 QCVN 43: 2012/BTNMT – National technical regulation on sediment quality

Not Applicable The Vietnamese EIA does not specify the need to carry out survey of sediment quality

12 QCVN 26: 2010/BTNMT – National technical regulation on noise

Complied. Noise monitoring was carried out on 27-29 May 2019. The results indicated that the noise levels in the project area from 6:00am to 6:00pm are mostly below the daytime standard levels of QCVN 26: 2010/BTNMT, which is 70 dBA for non-sensitive areas. Detailed information could be found in Section 5.2 of this report.

13 QCVN 27: 2010/BTNMT – National technical regulation on vibration

Not Applicable The Vietnamese EIA does specify the need to conduct vibration survey however project insurance to cover for damage or cracks on houses/buildings due to vibration caused by the Project construction activities have been considered in the Project. Copies of the contract with insurance company for PK-1.0 and PK-2.1 are shown in

Appendix 2.

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3 CHANGES IN PROJECT SCOPE

11. There are no changes in project scope from the scope described in the approved IEE: (i) carrying out improvements to approximately 45 km of QL217 from km 59+900 to Km 104+475; (ii) create a new flyover in Ha Trung; and (ii) improve the operations and maintenance of QL217.

4 INCORPORATION OF ENVIRONMENTAL REQUIREMENTS INTO THE PROJECT CONTRACTUAL ARRANGEMENTS

12. The environmental considerations have been incorporated into the documents such as the EMP/IEE, the bidding and contract documents of project and respective CEMP. In the bidding and contract documents, the content of the environmental impact and proposed mitigation measures for construction period in the EMP section in the disclosed IEE is included.

5 SUMMARY OF ENVIRONMENTAL MONITORING

5.1 Compliance inspections

5.1.1. Summary of inspection activities

13. The loan agreement provides for the engagement of an International Environmental Specialist (IES)

and a National Environmental Specialist (NES) under the PSC4 to supervise and monitor the implementation of the environmental management measures recommended in the IEE-EMP.

14. An IES was mobilized early in the construction stage, but due to health problems, he was unable to continue the assignment. The IES was replaced and the replacement IES was mobilized in mid-September 2018 for intermittent deployment of about 4.0 months until project completion. The NES is carrying out the environmental monitoring tasks for the Project also on intermittent assignment.

15. Monitoring of compliance by the contractors with the IEE-EMP and with their approved CEMP is done by the PSC-ES once or twice a month through site inspections. Inspections are carried out together with the counterpart staff of the contractors. Monitoring is aided by the monitoring checklist which was prepared by the PSC based on the environmental requirements specified in the Project’s EMP. The effectiveness of a contractor’s environmental management of a particular impact item is evaluated qualitatively using the following rating criteria:

FC – Fully complied: all management measures in the EMP are carried out PC – Partially complied: few measures are carried out or measures are generally not satisfactory NC – Not complied: None of main measures is carried out, the level of adverse impact is not mitigated N/a – Not applicable: recommended measures are not applicable during the monitoring period

16. Conditions at sites visited are photo documented. Non-compliances noted during each site visit and instructions to correct within a specific timeframe are relayed to the concerned contractor during the site visits. The findings and instructions to correct the non-compliances are also formally documented through a letter issued to the Contractor after the site visit, as necessary.

17. PMU-TL has designated an environmental officer to take overall responsibility in ensuring that the EMP recommendations are fully complied with. In line with the consulting service agreement, the PSC has designated an IES and a NES to supervise and monitor the Contractors’ implementation of the CEMP on intermittent deployment. The Contractors have also designated their respective staff to take charge of the implementation of their environmental compliance commitments as specified in their respective CEMP.

18. Table 4 shows the deployment status of the environmental management staff of the PSC and those of the contractors by end of June 2019.

Table 4. List of PSC and Contractors’ Environmental Management Staff Contract Package

Designation Total MM

Name Status (30 June 2019)

Remarks

PSC International 4.0 Apolo Jucaban Mobilized 25/04/2018 Replaced

4 The Project Administration Manual requires 4 person-months (PMs) of IES and 24 PMs of NES.

10

Environment Specialist (IES)

Demobilized 08/05/2018

Elsie Monsanto Mobilized 16/09/2018 Demobilized 05/10/2018

Active

Mobilized 06/01/2019 Demobilized 19/01/2019


National Environmental Specialist (NES)

12

Phan Anh Tuan Mobilized 20/12/2017 Demobilized 06/04/2018

Replaced

Bui Nguyen Pho


To be replaced

PK-1.0 Environmental specialist

Lu Hong Duong Active

PK-2.1 Environmental specialist

Le Thanh Hai Replaced

Nguyen Thanh Duy

Active

PK-2.2 Environmental Specialist

Huang Quoc Nam

Replaced

Tao Van Son Active

19. The assessment of compliance with the EMP recommendations during the detailed design and preconstruction stages as well as during the construction stage from the start of construction activities until

30 June 2019 is shown in Appendix 1. The assessment is explained below.

5.1.2. Status of Compliance with the IEE-EMP during the Pre-construction Stage

20. The IEE-EMP contained several recommendations to be carried out during the detailed design and pre-construction stages of the Project to set the tone for the implementation of necessary environmental management measures during project construction, recognizing that significant negative impacts of Project implementation will mostly occur during the construction stage.

21. The PMU-TL has complied with those recommendations. The detailed design was reviewed prior to construction. The EMP recommendation to avoid graves, cemeteries, sensitive receptors, and cutting of trees of significant ecological value was considered in the choice of alignment and construction methodology. The recommended environmental management plans, i.e., the waste management and spoils disposal plan, materials management plan, drainage management plan, erosion control plan, traffic management plan, noise and dust control plan, utilities re-provisioning and tree replacement plan have all been incorporated in the CEMP of all the three road contract packages, although they were not prepared/finalized prior to the commencement of the construction works. The PMU-TL has designated an environmental officer within the PMU-TL to oversee the implementation of the EMP during the construction stage. The PMU-TL continually coordinates with the local authorities at the provincial, district and commune levels to disclose information or provide updates about the project, obtain support, agree on measures to minimize negative project impacts, and establish coordination mechanism to address issues and grievances. Consistent with the concept of environmentally responsible procurement, the PMU-TL ensured that the requirement for the contractors to fully comply with the EMP is incorporated in the contract conditions. “Protection of the Environment” is specified in Section 4.18 of the GCC and reiterated further in Part B-Specific Provisions of the PCC of each contract package.

5.1.3. Status of the EMP/CEMP Implementation during the Construction Stage

22. Generally, the Contractors’ implementation of their respective CEMP and compliance with the mitigation measures recommended in the EMP is not satisfactory. The level of compliance varies from site to site. The Contractors improvement in implementing EMP.

23. The status of compliance by the Project to the environmental management or mitigating measures specified in the EMP from 01 January to 30 June 2019 is explained below.

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1) Activate management plans and obtain permits / licenses

24. Fully complied. The Contractors of all three contract packages have completed and submitted their respective CEMP in July 2018. The specific plans recommended in the EMP, i.e., the Waste Management Plan, Materials Management Plan, Drainage Management Plan, Erosion and Sedimentation Control Plan, Plan for Replanting and Restoration, Temporary Traffic Management Plan, Dust and Noise Management Plan, and Health Management and Public Relations Plan have been integrated into and form part of the CEMPs.

25. By end of June 2019, the project construction activities are in full swing, thus the Contractors are simultaneously implementing the environmental management measures specified in the approved CEMP.

26. The Contractors have applied for and obtained the permits and licenses for their soil, sand and aggregate quarry sites, spoils disposal sites, and facilities for concrete and asphalt batching plants. In some instances, the Contractors source their sand, quarry and concrete mix requirements from licensed suppliers that hold the necessary permit to operate. Copies of the permits for the material sources was included in Annex 2 of the First Semi-Annual Report 2018.

2) Orientation for Contractors, Workers on Environmental and Social management

27. Fully Complied. The PSC conducted an environmental awareness training for the Contractors, Consultants and PMU-TL in March 2019. Follow-on training to cover specific topics including roles/responsibilities in environmental management, wastewater management, solid waste management, air quality/noise/vibration, housekeeping, erosion control, and public safety is planned by the PSC in July 2019. The PSC-ES had a meeting with the Contractors on 08/07/2019 to discuss the required environmental orientation/training for workers. Suggested topics include worker induction/orientation or project environmental requirements; solid waste management; noise, emissions, dust and water quality management; worker, public safety and traffic safety and communication procedures. The Contractors have scheduled the worker trainings on the following dates:

• Package 1.0 – 23 July 2019

• Package 2.1 – 26 July 2019

• Package 2.2 – 29 July 2019

3) Loss of Trees, Vegetation and Aesthetics

28. Fully complied. No trees or vegetation of significant ecological value were removed during the clearing activities. The removal of trees and vegetation was confined within the Project’s right-of-way. No areas outside of the Project RoW were cleared of vegetation. Workers are prohibited from cutting trees for firewood. There has been no report or complaint relating to tree-cutting due to the Project activities.

4) Drainage and Hydrological Impacts

29. Fully complied. The Project designs were reviewed prior to construction activities and no major variations were required. The drainage management plan has been incorporated in the CEMP and the Contractors are implementing on site. Drainage works are in progress.

5) Utilities

30. Fully complied. Coordination with the utility service providers to confirm areas where utilities must be relocated has been undertaken. By 30 June 2019, the handed-over land for PK-2.1 and PK-2.2 still have some outstanding obstructions such as drainage ditches, electrical posts, and electrical and communication cables which the utility companies have not yet removed. There has been no reported interruption of the electrical, water and telecommunication supplies in the project areas attributable to project activities, however. Likewise, the outstanding obstructions are not affecting the current progress of the Contractors’ construction activities.

6) Materials exploitation and management of quarry and borrow areas

31. Fully complied. The MMP has been incorporated into the Contractors’ CEMP. The quarries and

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material sources of all contractors have necessary approval from the PSC and local authorities. Copy of the permits may be found in Annex 2 of the 1st SEMR 2018. All materials for the Project are sourced from licensed companies. No issues relating to management of quarry sites were reported this period. The

Contractors’ approved material sources are listed in Table 5.

Table 5. List of Material Sources Package Quarry

Type Location Distance

from Site Remarks

PK-1.0 Rock Vinh Minh commune, Vinh Loc, Thanh Hoa

12km Owned by Thanh Joint Stock Company

Sand Quy Loc commune, Yen Dinh, Thanh Hoa (12)

12km Owned by Duc Loc JSC

Sand Xuan Thanh, Hanh Phuc Commune, Tho Xuan, Thanh Hoa

2km Owned Hai Lam Private Company

Soil Ha Ninh commune, Ha Trung, Thanh Hoa 2km Duc Cuong JSC

PK-2.1 Rock Cam Thanh Commune, Cam Thuy, Thanh Hoa)

8km Owned by Tan Thanh 2 MTV Join Stock Company

Soil Km76 (right side) – Lang En Quarry/ Cam Thanh, Cam Thuy; on the right.

On site Owned by Thung Moong

PK-2.2 Rock Dien Lu Commune, Ba Thuoc District, Thanh Hoa

3km

Sand Sand/ Thiet Ong and Thiet Ke Commune, Ba Thuoc, Thanh Hoa

2km

Soil Km92+400 (right side) - Lam Xa commune, Ba Thuoc, Thanh Hoa

On site

Photo 1. Rock quarry Tan Hai

Photo 2. Soil quarry at Km76, Package 2.1

Photo 3. Soil quarry at Km92+400, Package 2.2

Photo 4. Soil quarry at Ha Ninh Commune, Package 1.0

Figure 1. Photos of Project’s quarries

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7) Spoils Disposal

32. Fully Complied. The Spoils Disposal Plan has been incorporated into the Contractors’ respective CEMP. Package 1.0 has four spoil disposal sites. These were approved by the PSC on 04 May 2018 in letter Ref. B.046-Package HW27-1. The spoils sites have a combined capacity of 34,500 m3. Package 2.1 has three disposal sites with a combined capacity of 30,800 m3. All sites have approval of Thanh Hoa Province. Package 2.2 has five disposal sites with a capacity of 20,000 m3 each. The sites were approved by the PSC on 17 April 2018 in letter Ref. D.034-Package HW217-1. All disposal sites have approval from the district PCs (Refer to Annex 2 of the first SEMR). The Contractors’ approved disposal sites are listed in

Table 6. The sites are at various stages of utilization and are generally well-managed. Notable is the good practice by the Contractors of removing and hauling out of spoils as soon as generated from the clearing or excavation works such that no high stockpile of spoils is visible along the roads or embankments. Spoils disposed outside of the approved disposal sites were not observed.

Table 6. List of Disposal Sites Package Site No. Location Capacity

(m3) Status

(30 June 2019)

PK-1.0 1 Phu Nham Cultural House, Ha Ninh Commune, Ha Trung District, Thanh Hoa Province

2,500 Active

2 Da Qua 1 Cultural House, Ha Ninh Commune, Ha Trung District, Thanh Hoa Province

2,000 Active

3 Da Qua 2 Cultural House, Ha Ninh Commune, Ha Trung District, Thanh Hoa Province

15,000 Active

4 Nghe Do Cultural House, Ha Ninh Commune, Ha Trung District, Thanh Hoa Province

15,000 Active

Total 34,500

PK-2.1 1 Km 59+900, Cam Binh Commune, Cam Thuy District, Thanh Hoa Province

6,000 Active

2 Km 70+900 Cam Thach Commune, Cam Thuy District, Thanh Hoa Province

4,800 Active

3 Km 73+600 Cam Thach Commune, Cam Thuy District, Thanh Hoa Province

20,000 Active

4 Km61+100 Cam Thach Commune, Cam Thuy District, Thanh Hoa

7,800 Active


4,500 Not yet used


12,000 Active


15,000 Completely used

Total 70,100

PK-2.2 6 Km85+000-Km85+500, Luyen Village, Dien Quang Commune, Ba Thuoc District, Thanh Hoa Province

20,000 Active

7 Km88+550-Km88+750, Bai Tom Village, Ai Thuong Commune, Ba Thuoc District, Thanh Hoa Province

20,000 Active

8a Km90+900, Khuon Vien Cong Xo Village, Ai Thuong Commune, Ba Thuoc District, Thanh Hoa Province

20,000 Active

8b Km91+450-Km91+600, Doi Village, Ai Thuong Commune, Ba Thuoc District, Thanh Hoa Province

6,000 Active

9 Km99+700-Km101+000, Suoi Village, Thiet Ong Commune, Ba Thuoc District, Thanh Hoa Province

20,000 Active

Total 86,000

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Photo 1. 01/03/2019. No stockpile of spoils along the road during embankment excavation. Spoils are hauled out immediately to disposal site, Km96+000-Km96+100, HW217-2.2

Photo 2. Disposal Site at Km78+200, HW217-2.1 has been filled and handed over to the owner

Photo 3. 12/05/2019. Embankment has been cleared of spoils before asphalting at Km81+550-Km81+700, HW217-2.1

Photo 4. Spoils disposal site at Km72+300, HW217- 2.1

Photo 5. 02/07/2019. No stockpile of uncollected spoils from the slopes and embankment excavation at Km70+250, Package 2.1

Photo 6. 27/05/2019. Embankment has been cleared of spoils before asphalting works at Km 98, Package 2.2

Figure 2. Photos of disposal sites and spoils management

8) General Construction Waste Disposal

33. Partially complied. Domestic solid wastes are regularly collected by the garbage collectors in the community. Contractors need to improve the management of construction wastes at the fabrication yards (collecting empty fuel drums, cement bags - Package 1; making cement foundation, surrounding bank for fuel and roofing - PK-2.1; garbage collection, scrap metal in casting yard area - package 2.2). Housekeeping will be a topic of environmental awareness training for workers to be carried out by the Contractors in July 2019.

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Photo 1. Housekeeping needs improvement, HW217- 1.0

Photo 2. Relatively clean worker’s camp at HW217-1.0

Photo 3. Housekeeping at Contractor’s campsite and storage area needs improvement, HW217- 2.2

Photo 4. Housekeeping needs improvement at fabrication yard of HW217- 2.2

Figure 3. Photos of Construction Waste Management Practices

9) Use of hazardous substances and hazardous waste disposal

34. Not Complied. The Contractors still haven’t entered into agreement with a licensed company for the collection of hazardous wastes. In September 2018, the PSC gave instructions to the Contractors to provide proper storage area for oil and other hazardous materials and wastes. Follow-on letters were issued in November 2018 and January 2019 but until now, the Contractors have not complied with the PSC instructions. The leaking oil tank at Km 97+400 has not been repaired or removed by the Contractor. The PSC required the Contractor to either replace or remove the tank. The PSC will recommend to PMU-TL the imposition of sanction to the Contractors for disregard of environmental requirements in accordance with the Contract conditions.

Photo 1. 28/12/18. Empty oil drum on the ground at the fabrication yard, HW217-2.1

Photo 2. 28/12/18. Improperly installed fuel tank that leaks oil has not been replaced or removed, HW217-2.2

Figure 4. Photos of hazardous waste management

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10) Asphalt plant rock crushers, bitumen usage and soil contamination

35. Partially complied. Asphalt paving works has started and the asphalt batching plant of the HW217-2.2 has started operating. The batching plant site is on flat terrain in a good location far from residential areas and water bodies. Wastewater treatment has been put in place. This asphalt batching plant is located in Thung Moong stone quarry, the quarry has been approved for environmental impact assessment reports (No. 2132 / QD-UBND dated June 21, 2016 of Thanh Hoa Provincial People's Committee).

Figure 5. Photo of Batching plant of Package 2.2

11) Noise and dust nuisances

36. Partially complied. There were no issues relating to noise during this period. Vehicles and equipment were maintained in good condition and works were not carried out at night near sensitive receptor areas. Batching plants and fabrication areas that produce noise were far from residential clusters.

37. Excessive dust is among the issues raised by the local people during the consultation on the project income restoration program held on 05-10 June 2019. Although the Contractors carry out regular watering, dust persists during very dry days as the watered areas dry up within 30 minutes after watering. The Contractors have difficulty meeting the PCS’s instructions to increase watering to 5x-6x per day because of the length of exposed construction areas. Excessive dust arise whenever speeding cars pass. Although the speed of construction vehicles is controlled, that of private vehicles is not.

38. Table 7 is the proposed CAP relative to excessive dust based on findings during the consultation

with the local authorities between 28 June 2019 and 03 July 2019.

Table 7. Corrective Action Plan for Dust Environmental

Issue Status (11/07/2019) Follow-on Action Milestone

Dust In PK-1.0, the chairperson of Ha Ninh commune and the head of Environment of Ha Trung town both confirmed that dust is not a major issue. The Contractor carries out watering regularly (5x to 6x daily) and the local people also understand that dust could not be totally prevented or eliminated. They fully support the project and have very close coordination with PMU-TL. The Contractor immediately resolves issues relayed by the PCs.

In PK-2.1, the chairperson of Cam

Binh commune said they are happy because 7km of road in the commune has been asphalt-paved and it is now comfortable to travel. Dust in not an issue anymore and suggests that if project can be fast-tracked, dust will be minimized. Other commune PCs

Contractors to carry out the following measures:

• increase watering of project sites and public roads affected by project to 5x to 6x a day during very dry days

• ensure trucks transporting materials are fully covered when passing through public roads

• immediately clean up soil spills from trucks or mud from wheels left on public roads

• ensure that trucks are not overloaded

• sprinkle water on dry soil or sand temporarily stockpiled near the roads or cover the stockpiles

Contractor should provide sufficient and efficient watering trucks before start Construction. PSC will not allow works to proceed if watering trucks are not provided.

Daily Daily for PSC. ES to monitor every 2nd and 4th week each month

17

requested to fast-track road construction to minimize dust. In PK-2.2, residents have complaint about dust. Although the Contractor carries out watering several times with two trucks, roads dry up immediately because these days it is too hot. The PCs suggested that if road construction is faster, dust will be minimized. In a meeting with the Contractors on 08/07/2019 the PSC-ES advised the Contractors to observe preventive measures such as increase watering to 5x to 6x a day on very dry days, ensure trucks are covered when using public roads, avoid overloading of trucks, and observe speed limit of less than 15km/hr. when passing through residential areas.

PSC will recommend withholding of payment of IPC for repeated violation by the Contractor.

PSC-ES will strictly monitor the contractor’s compliance and require correction when necessary.

Status update to be included in monthly and quarterly reports of the PSC and in SEMR.

Photo 1. Watering system of HW217-1.0. A more efficient watering truck could ensure that a larger area can be watered in a shorter period.

Photo 2. 28/05/2019. Newly watered section at HW217- 2.1

Photo 3. 12/05/2019. Paved and compacted unpaved embankment does not generate excessive dust, Km81+550-Km81+700, HW217-2.1

Photo 4. 03/07/2018. Newly watered embankment from Km0+100 to Km0+300, HW217-1.0

18

Photo 5. 03/07/2018. Newly watered embankment, HW217-1.0

Photo 6. Excessive dust is generated by a vehicle travelling at high speed, HW217-2.1

Figure 6. Photos of dust management

12) Blasting

39. Not applicable. Blasting is not required for the project.

13) Erosion control/run-off control

40. Partially complied. At selected locations, the Contractors are carrying out erosion and runoff control measures in preparation for the coming rainy season (Figure 7).

41. During the consultation on project income restoration program held between 5 and 10 June 2019, PMU-TL received some verbal complaints from project affected people. The complaints mostly relate to impacts of construction brought about by recent rains. These include: (1) influx of eroded soil and sand into farmlands; (2) flooding of farmlands due to newly constructed irrigation/drainage system as part of utilities work relocation; (3) impeded access to farmlands due to open irrigation/drainage system; and (4) community risks caused by the open ditches.

42. On 24 June 2019, the ADB requested the PMU-TL to consult with the local people and satisfactorily address their complaints. In response to ADB’s request, the PMU-TL together with the PSC and Contractors carried out consultation meetings and site surveys with the PCs of Canh Nang and Ha Trung towns; Ba Thuoc and Ha Trung Districts; and Ha Ninh, Cam Binh, Cam Thach, Cam Thanh, Dien Trung, and Lam Xa Commune from 28 June to 03 July 2019. The findings/status and corrective action plan for the issues related to erosion and flooding, including those specified in letter dated 18 June 2019 of Cam Thuy District PC to the PMU-TL, are summarized in Table 8. Figure 7 shows the impacts of construction brought about by recent rains.

Table 8. Corrective Action Plan for Issues related to Flooding and Erosion Environmental

Topic/Issue Status (11/07/2019) Follow-on Action Milestone

Influx of eroded soil and sand into farmlands

During the recent heavy rains, soil and stones had fallen into farmlands, ponds and drainage system affecting production at Km76+450 to Km76+550,

PK-2.1 (Photo 1- Figure 8). Cam Thanh

commune requested to provide erosion protection for the sloping sections.

The Contractor has completed the soil embankment at this location. Based on design, the slopes will be grassed. Contractor should provide temporary system for rainwater conveyance, sump and ditches along toe of slopes as temporary measures to catch soil/sand/silt during heavy rains.

July-August 2019

19

Environmental Topic/Issue

Status (11/07/2019) Follow-on Action Milestone

Flooding of farmlands due to newly constructed agricultural irrigation/drainage system as part of utilities works relocation in the project

At. Package 1.0, few houses got flooded in June 2019 from Km0+480 up to Km1+220 because there were no ditches and the residential areas were lower than the height of new road. The Contractor has cleared the affected areas and has provided temporary drainages ditches along the road. The Contractor also cleared and maintained the drainage channels around the area. The solution is acceptable to local people. (Photo 2 – Figure 8)

Contractor is required to ensure that temporary drainage ditches are provided and maintained as the road construction progresses.

PSC-ES will regularly check the site conditions and require contractor to improve conditions as necessary.

July-September 2019 Every 2nd and 4th week each month up to the end of rainy season.

At Package 2.1, there was flooding in March 2019 at Km67+530 affecting 3.5ha of rice fields in Mui Village, Cam Thach commune. This was caused by water overflowing from project’s drainage because the irrigation authority blocked the flow of floodwater from the Project’s drainage culvert during the construction of irrigation canals. The irrigation authority did not allow the Contractor to release water (Photo 3 - Figure 8). The farmers lost one cropping season. The head of PC did not mention if local people asked for compensation. Currently, there is no flooding. Construction of the irrigation canals is underway and may be completed soon.

The PSC-ES will regularly check the condition of drainage and progress of irrigation channels in this area, coordinate with commune PC and report to PSC engineers and PMU-TL if there is a need for further or immediate action.

Every 2nd and 4th week each month up to the end of rainy season.

Water coming from sloping areas of construction sites at Km71+680, Km72+017 and Km76+276 caused flooding in Cam Thanh Commune in May 2019. The affected areas included the Cam Thanh commune office and 12 houses along Thanh Long hamlet (Photo 4 - Figure 8). The chairperson suggested that fast-tracking of construction works will minimize impacts. He also suggested removal or relocation of the ditches from Km71+680 and Km72+017. For the culvert at Km76+276, the PC asked for review of design. The District PC has sent a letter to PMU-TL regarding their concerns.

PMU-TL and the PSC will review the design and construction method and discuss with the PC regarding the request.

July 2019

At Package 2.2, flooding temporarily affected nearby houses in May 2019 due to water overflow from the drainage culvert excavation area at Km87+111. The water subsided after the flood (Photo 5 – Figure 8). The issue has been resolved as the Contractor finished the culvert construction by end of May 2019.

The PSC required the Contractors to provide temporary drainage ditches and sumps in culvert locations near residences so that similar problems will not happen again. PSC will monitor the location of open ditches and assess areas vulnerable to flooding for the Contractor’s correction.

July-August 2019

Impeded access to farmlands due to open irrigation/drainage system

As temporary measure to ensure access by local people to their houses and farmlands, the Contractors provided temporary crossway at several open ditches (Photo 6 – Figure 8). However, the PSC has given

Contractors to fast track completion of drainage ditches and to implement PSC instructions to provide temporary cover on open ditches.

PSC monitor in a daily basis. ES to

Daily for PSC, ES to monitor up to the end of rainy

20

Environmental Topic/Issue

Status (11/07/2019) Follow-on Action Milestone

and open ditches and community risks caused by open ditches

instructions to the Contractors to provide temporary cover for all unfinished ditches/ditch excavation areas. By 30/06/19, drainage ditch locations that have been completed and fully covered: PK-1.0 – 636 l.m.; PK-2.1 – 9,160l.m; PK-2.2 – 9,850 l.m. Drainage ditches not yet covered: PK-2.1 – 6,194 l.m.; PK-2.2 – 13,767 l.m.

monitor every 2nd and 4th week each month up to the end of rainy season.

season.

Other concerns

Cam Thach PC requested for construction of new side ditches at the following sections as the existing ones have been damaged and not usable:

• Km 69+650 - Km 69+770 (RS)

• Km 69+610 - Km 69+770 (LS)

• Km 69+050 - Km 69+250 (LS)

PMU-TL to review the request and coordinate with the PC on the matter

July 2019

Photo 1. Contractor provided steel sheet piles along the stream bank to protect a house from potential stream rise where a pipe culvert is being constructed, HW217-1.0

Photo 2 Contractor provided steel sheet and soil bags along the stream bank to protect it from erosion during construction of flyover bridge foundation, HW217-1.0

Photo 3. Ongoing benching works with runoff trough to convey water downslope, HW217.2.1

Photo 4. Excavated ditch along the toe of erodible slope to convey runoff and help catch eroding soil, HW217-2.2

Photo 5. Ditches along sloping section will help minimize erosion and facilitate runoff conveyance, Km95 HW217-2.2

Photo 6. Lateral drainage to carry the rainwater toward the existing drainage channel to prevent ponding, HW217-2.1

Figure 7. Erosion and run-off control measures

Photo 1. Sand and rocks eroded from the slopes at Km76+450 to Km76+550

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Photo 2. 03/07/2019. Completed cross drain culvert, temporary ditches and existing drainage channel being maintained Contractor of Package 1.0

Photo 3. Flow of water from the completed culvert (right) was blocked while the irrigation channels (left) were being constructed by the irrigation authority during a heavy rain in March 2019.

Pipe culvert at Km72+017, building in front is Cam Thanh Commune Office

Houses that had been flooded at Km71+680

Photo 4. Areas in Cam Thanh Commune affected by waterflow in June 2019

Photo 5. Water that collected in the excavated area of ongoing culvert construction overflowed in front of the adjacent house in May 2019.

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Photo 6. Contractors provide temporary access for people at selected locations where culvert covers are not yet complete.

Figure 8. Impacts of construction brought about by recent rains and open ditches

14) River protection and bridge repair

43. Fully complied. No issues relating to improper disposal or placement of materials in rivers near the project sites were observed during this period. No issues relating to contamination or damage to riverine areas have been reported or have been observed.

15) Water quality

44. Fully complied. The Contractors’ storage areas for materials, lubricants and fuels are more than 50m from existing water bodies. Camps are mostly rented houses provided with sanitary toilets with septic tanks for primary treatment of wastewater and these camps are located away from rivers or creeks. No solid wastes, including spoils are disposed in drainage, creeks or rivers. There were no stockpiles of soil or borrow sites near water bodies. Washing of machinery and vehicles in rivers is prohibited. There were no reports or complaints related to impacts of the project on any water body during this period. There were no observed impacts on water quality in the rivers this period.

16) Water resources

45. Fully complied. The Contractors have rented houses for camps and erected their fabrication yards away from existing creeks or rivers. The site of the cement batching plant and asphalt plant of Package 2.2 is far from any water body. No stockpiles of sand, aggregates or rock materials were stored near a river or any water body. No trash, solid wastes, spoils or liquid wastes were reported to have been disposed on any water body and there are no visible signs of contamination of water bodies near the project sites due to project construction activities. No complaint related to water resource contamination or unauthorized use was received during this period.

The construction activities at Km99, HW217-2.2 have no visible impact on the river adjoining the project site.

The Contractor maintains the irrigation channel near the railway flyover bridge site, HW217-1.0

The Contractor controls the excavation activities for the flyover bridge foundation to ensure that the irrigation channel nearby will not be affected, HW217-1.0

Figure 9. River Protection and Water Quality Control

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17) Site Agent /Supervisor /Worker Camp canteen and facilities

46. Fully Complied. The Contractors generally rent local peoples’ houses for their laboratories, field offices and worker’s camps. Most workers come from the communes within the project sites, thus the requirement for accommodation is limited to engineers, heavy equipment operators, and other skilled workers who live in far cities or provinces.

47. All the field offices, laboratories and camps are in good condition and provided with basic facilities such as drinking water, domestic water supply, latrine with two-chamber septic tanks, bunk beds, and kitchen/dining areas. Some camps are provided with first aid kits. Sanitation around the camps is good. Housekeeping around the camp of Package 2.2 at Km97+900 has been improved. The PSC continually advises the Contractors to maintain good housekeeping in and around the camps.

Table 9. List of Contractors’ Camps Package Location Status (30 June 2019)

Package 1.0 Ha Ninh Commune, Ha Trung District In good condition; good maintenance; basic facilities provided

Package 2.1 Km62+800 In good condition; good maintenance; basic facilities provided Km72+200 In good condition; good maintenance; basic facilities provided Km77+400 In good condition; good maintenance; basic facilities provided

Package 2.2 Km82+200 In good condition; good maintenance; basic facilities provided

Km87+900 In good condition; good maintenance; basic facilities provided

Km97+900 In good condition; housekeeping has been improved.

Km104+043 In good condition; good maintenance; basic facilities provided

Photo 1. Site office of Package 2.2 at Lam Xa Commune, Ba Thuoc, Thanh Hoa Province

Photo 2. Contractor rented local people’s houses for workers camp, Km72+200, Package 2.1

Photo 3. Contractor rented local people’s house as camp, Km72+200, HW217-2.1

Photo 4. Worker camp of Package 1.0

Figure 10. Photos of workers camps

24

18) Sanitation and Diseases

48. Partially Complied. All offices, laboratories and camps are in good, sanitary condition during this period. Again, housekeeping at the fabrication yards of Package 1.0 and Package 2.2 should be improved (collecting empty fuel drums, cement bags - Package 1; making cement foundation, surrounding bank for fuel and roofing - PK-2.1; garbage collection, scrap metal in casting yard area - package 2.2). The Contractors have not provided portable toilets as required in letters B.09-Package HW217-1, C081.1 Package HW217-2-1 and D.100-Package HW217-2-2 issued by the PSC.

49. The PSC has engaged a Health and Gender Specialist as well as an HIV Awareness/Anti-human Trafficking Specialist for the Project. The specialists prepare a separate report on this subject matter.

19) Safety Precautions for Workers

50. Not complied. The Contractors have not assigned full-time safety officers to ensure worker and public safety. Despite earlier verbal and written instructions, the Contractors have not improved the management of fuel and hazardous wastes. First aid supplies are still not sufficient. Most workers do not wear PPE.

51. Proper use of PPE and safe acts are among the topics of the environmental awareness training scheduled to be carried out by the Contractors towards the latter part of July 2019.

Photo 1. 03/07/2019. Poor housekeeping pose hazard to workers, HW217-1.0

Photo 2. Fuel tank leaks oil; storage not improved; proper drip pan not provided, Km97+900, HW217-2.2

Photo 3. 11/03/2019. Workers do not wear proper PPE during concrete pouring at Km77+705, HW217- 2.1

Photo 4. Leaking oil tank and hazardous waste containers on the ground, HW217-2.2

Photo 5. Unsafe conditions at the fabrication area of Package 1.0. Acetylene tanks on the ground and unprotected electrical cables on the ground.

Photo 6. Unsafe conditions at the fabrication area of Package 1.0. Live electrical cables on water.

Figure 11. Photos of Worksite Conditions

25

20) Traffic and Public safety

52. Partially complied. Traffic safety and traffic conditions are managed by the Safety Specialist. At PK-2.1 and PK-2.2, some construction sites no warning signs are at some positions for construction of culvert, surface road, cut areas adjoining roadway or mechanical construction; do not install fences, pile targets for excavation of vertical culverts, open concrete trenches, intersections as showed in Figure 12. The PSC conducted traffic management training for the Contractor’s management staff in June 2018.

53. In January 2019, the PSC-ES advised the Contractors to strengthen safety measures at some critical areas such as Km76+300; Km104; cut areas at Km70+358, Km79+100, Km84+000, Km 92+250, Km92+400 and Km99+777. Furthermore, the Contractors were advised to provide warning signs (e.g., construction area 50m ahead, no entry, watch out-heavy equipment crossing) at the intersection of diversion road and existing road at Km81. Cut areas adjoining the roadway should be provided with temporary drainage ditches to convey runoff and to catch sliding soil that makes the road slippery when wet. The contractors need to:

✓ Coordinate with local traffic authorities and implement appropriate traffic diversion schemes to avoid inconvenience due to project operations to road users, ensure smooth traffic flow and avoid or minimize accidents, traffic delays and congestion

✓ Install bold diversion signs that would be clearly visible even at night, provide flag persons to warn of dangerous conditions and designate traffic officers in construction sites.

54. Traffic safety and public safety are among the issues mentioned in the letter of Cam Thuy District PC to PMU-TL date 18 June 2019. The District PC recommends that coordination with the Transport Department of Thanh Hoa Province (Transport Project Management Unit III) to come up with an agreement regarding traffic management at the T-junction in Cam Thach commune from Km69+403 to Km 60+540.

Photo 1. Hard barricade with reflector for night visibility and highly visible early warning sign boards should be provided at appropriate distance from worksite, Km99+777, HW217- 2.2.

Photo 2. Warning sign board and signal man should be provided where heavy equipment could block public road, HW217- 2.2

Photo 3. Open ditches pose public safety hazard

Photo 4. Warning sign boards (watch out: heavy equipment crossing, and construction area 50 m ahead, no entry) should be provided along the existing road intersection to warn motorists of potential hazard, Km81, HW217-2.1

Figure 12. Photos of Traffic Safety Conditions

21) Vibration

55. Partially Complied. In HW217- PK-2.1, there are 20 complainants regarding cracks on houses. In

26

HW217-2.2, there are 84 complainants. The Contractors have entered into agreement with insurance company to cover for damages to structures within 100m on both sides of the road. According to some local people interviewed on 28 June 2019 and 02 July 2019, a team from the insurance company have visited and checked the damages to their houses but no assessment of damage and compensation has been agreed. The Contractors said that the insurance company has formed teams to carry out the assessment in the following months, but a firmed-up schedule could not be provided yet.

22) Archaeological and cultural artifacts

56. Not applicable. No archaeological and cultural artifacts were found during excavation or construction activities this report period. If such archaeological or cultural relics were found in the future, it will be reported to the People’s Committee for proper disposition.

23) Enhancements

57. Not applicable. Construction activities are still ongoing; thus, enhancement works such as grassing or tree planting are not yet undertaken. Enhancements will be carried out when some areas are ready for such enhancements.

5.2 Environmental Effect Monitoring

5.1.4. Requirement

58. The IEE recommended to carry out baseline and environmental monitoring of noise (LAeq, LAmax, LA50), air quality (TSP) and water quality (for parameters pH, DO, TSS, COD, BOD5, Pb, Cu, Zn, Hg, Phenol) to be implemented by the PSC. Budget for the environmental quality monitoring has been included in the PSC cost.

59. Following MOT’s approval of the TOR and cost estimate of the environmental monitoring project (Decision No. 417/QĐ-BGTVT dated 05 March 2019), the contractor, Viet A Construction Design and Investment Consultancy (VITA E&C JSC), carried out the first environmental monitoring activities on 27-29 May 2019. The sampling and laboratory methods were in accordance with Vietnamese regulations and standards. The results are described below:

Table 10. Monitoring/Sampling Program

Monitoring

Parameter

Project

Package

Sampling Location

(Commune/District/Provin

ce)

Sampling Position Number

of

Samples

Sampling

Date/Time Sample ID

Longitude Latitude

I. Air Quality:

Total

Suspended

Particulate

(TSP)/ dust

HW217-

1.0

Ha Ninh - Ha Trung -

Thanh Hoa

105o50’45” 19o59’42” 18 27/05/2019

6h-22h

HW217-AQ1


Thanh Hoa

105o50’59” 20o00’06” HW217-AQ2

HW217-

2.1

Cam Thanh - Cam Thuy

- Thanh Hoa

105o21’43” 20o14’28” 18 28/05/2019

6h-22h

HW217-AQ3

Dien Trung - Ba Thuoc -

Thanh Hoa

105o19’27” 20o16’43” HW217-AQ4

HW217-

2.2

Lam Xa - Ba Thuoc -

Thanh Hoa

105o12’29” 20o19’56” 18 29/05/2019

6h-22h

HW217-AQ5

Thiet Ong - Ba Thuoc -

Thanh Hoa

105o12’42” 20o18’39” HW217-AQ6

II. Air Quality:

Noise (LeqA)

HW217-

1.0


Thanh Hoa

105o50’45” 19o59’42” 24 27/05/2019

6h-22h

HW217-AQ1


Thanh Hoa

105o50’59” 20o00’06” HW217-AQ2

HW217-

2.1

Cam Thanh - Cam Thuy

- Thanh Hoa

105o21’43” 20o14’28” 24 28/05/2019

6h-22h

HW217-AQ3

Dien Trung - Ba Thuoc -

Thanh Hoa

105o19’27” 20o16’43” HW217-AQ4

27

Monitoring

Parameter

Project

Package

Sampling Location

(Commune/District/Provin

ce)

Sampling Position Number

of

Samples

Sampling

Date/Time Sample ID

Longitude Latitude

HW217-

2.2

Lam Xa - Ba Thuoc -

Thanh Hoa

105o12’29” 20o19’56” 24 29/05/2019

6h-22h

HW217-AQ5

Thiet Ong - Ba Thuoc -

Thanh Hoa

105o12’42” 20o18’39” HW217-AQ6

III Surface

Water:

Suspended

Solids (SS)

HW217-

1.0

Ha Ninh - Ha Trung - Thanh Hoa

105o50’59” 22o00’07” 1 27/05/2019 HW217-WS1

HW217-

2.1

Cam Binh - Cam Thuy - Thanh Hoa

105o21’43” 20o14’28” 1 28/05/2019 HW217-WS2

HW217-

2.2

Thiet Ong - Ba Thuoc - Thanh Hoa

105o10’46” 20o17’34” 1 29/05/2019 HW217-WS3

IV. Wastewater

(temperature,

pH, TSS, COD,

BOD5, oil and

grease,

coliform, and

waste flow)

HW217-

1.0


105o50’59” 20o00’06” 1 27/05/2019 HW217-WW1


104o50’45” 19o59’41” 1 HW217-WW2

HW217-

2.1

Cam Binh - Cam Thuy - Thanh Hoa

105o26’22” 20o12’46” 1 28/05/2019 HW217-WW3

Dien Trung - Ba Thuoc - Thanh Hoa

105o19’33” 20o16’41” 1 HW217-WW4

Dien Trung - Ba Thuoc - Thanh Hoa

105o19’59” 20o16’08” 1 HW217-WW5

HW217-

2.2

Lam Xa - Ba Thuoc - Thanh Hoa

105o12’17” 20o20’23” 1 29/05/2019 HW217-WW6

Lam Xa - Ba Thuoc - Thanh Hoa

105o12’28” 20o19’37” 1 HW217-WW7

Canh Nang - Ba Thuoc - Thanh Hoa

105o13’15” 20o21’09” 1 HW217-WW8

5.1.5. Results and Evaluation

1) Air Quality: TSP or Dust

60. The dust content measured from all monitoring positions were lower than 300 µg/m3, the permissible level for dust as specified in QCVN 05: 2013/BTNMT. The results are summarized in Figure 12-1. At positions: AQ1, AQ2, AQ3 where there were many traffic vehicles, the concentrations of TSP or dust were higher than at the construction locations with less traffic vehicles, AQ4, AQ5, AQ6. The dust levels during the peak traffic hours from 10:00 am to 6:00 pm were also higher compared to early morning and nighttime. The results indicate that more dust is dispersed by passing vehicles than by construction equipment. However, although the measured dust levels were still within the QCVN limits, it is recommended for the Contractors to carry out more frequent watering particularly along the residential and/or commercial and sensitive areas such as schools, clinics or hospitals. On very dry days, watering should be increased to 5x to 6x per day.

Figure 13. Results of TSP (dust) monitoring

0

100

200

300

400

TSP

(m

g/m

3)

28

2) Noise Levels

61. The measurement of noise levels was conducted at the same locations as the TSP monitoring. The monitoring was carried out at daytime from 6:00a.m. to 6:00p.m. The results are presented in Figure 12-2.

62. The results show that the noise levels in the project area from 6:00am to 6:00pm are mostly below the daytime standard levels of QCVN 26: 2010/BTNMT, which is 70 dBA for non-sensitive areas. The daytime noise levels fluctuate relatively evenly at the monitoring positions of the 03 packages. At QA1 of Package HW217-P1, the noise levels are relatively higher compared to the other locations and even exceeded the QCVN 26: 2010/BTNMT standard between 7:00-10:00am. This location is near the railway thus the passing trains could be contributing to noise level. The high noise levels also coincide with the rush hours of traffic flow at HW1. Construction trucks transporting materials and other construction equipment and machineries at these locations may be contributing to noise levels as well.

63. To ensure that construction activities will not cause unacceptable noise levels and cause nuisance to the nearby residents, Contractors should implement preventive measures. These include avoiding unnecessary use of horn, limiting the speed of transport trucks to less than 15km/hr. when passing through residential areas, avoiding noisy activities during the noontime rest hours of people, prohibiting the queuing of equipment along the road and avoiding simultaneous noise-producing activities.

Figure 14. Results of Noise Level Monitoring

3) Surface Water: Suspended Solids (SS)

64. Sampling for SS was conducted from May 27 to May 29, 2019 at the three positions indicated in the monitoring program above. For each package, one sample was taken.

65. As shown in Figure 12-3, the concentration of SS at all the surface water monitored was lower than the limits specified in QCVN 08-MT:2015/BTNMT (B1) - water intended for agricultural uses. The QCVN limit is 50mg/l while the measured concentrations ranged from 27mg/l to 36mg/l. This connotes that the construction works, particularly the earthmoving activities, did not cause the SS to increase beyond the allowable concentrations.

Figure 15. Results of TSS Monitoring

4) Wastewater Quality

66. Wastewater quality sampling was carried out from May 27 to May 29, 2019 at eight locations (worker camps) as indicated in Table 10. The samples were tested for temperature, pH, TSS, COD, BOD5,

0.0

50.0

100.0

6-7

h

7-8

h

8-9

h

9-1

0h

10

-11

h

11

-12

h

12

-13

h

13

-14

h

14

-15

h

15

-16

h

16

-17

h

17

-18

h

Leq - HW217

AQ1 AQ2 AQ3 AQ4AQ5 AQ6 QCVN

Leq

HW217-WS1 HW217-WS2 HW217-WS3

P1 P2.1 P2.2

TSS 27.0 35.0 36.0

QCVN 50 50 50

0.0

10.0

20.0

30.0

40.0

50.0

60.0

TSS

(mg/

l)

29

lubricant and grease, coliform and waste flow. The samples were taken at ditch locations before the wastewater discharges into a surface water. The test results were compared to the limits of QCVN 20:2008/BTNMT Column B, the standard for wastewater for discharge into water sources not used for domestic water supply. The results are summarized below:

a) Temperature

67. The sampling period was summer thus the measured temperatures of the wastewater sample were quite high, ranging from 27.1oC to 28.6oC, as shown in Figure 12-4. There is no regulatory limit for temperature.

Figure 16. Temperature Monitoring Results

b) pH

68. All the samples were within the pH range specified in QCVN 14:2008/BTNMT between 5.5 and 9.0 as shown in Figure 12-5. This indicates that there were no discharges that drastically caused the water to be highly acidic or highly alkaline.

Figure 17. pH Monitoring Results

c) TSS

69. Figure 17 illustrates the results of TSS measurements. TSS ranged from 23-45mg/l and all samples were below the 50mg/l QCVN:2008/BTNMT maximum allowable concentration of TSS. The wastewater sample WW1 taken from the campsite of Package HW217-P1.0 has the highest TSS concentration at 45mg/l while the sample from WW4 from the campsite of Package 2.1 has the lowest TSS concentration of 23 mg/l.

WW1

WW2

WW3

WW4

WW5

WW6

WW7

WW8

P1 P2.1. P2.2

T(oC) 27.4 28.3 27.1 27.8 28.6 28.4 27.6 28.3

0.05.0

10.015.020.025.030.035.040.0

Temperature

Tem

p(o

C)

WW1

WW2

WW3

WW4

WW5

WW6

WW7

WW8

P1 P2.1. P2.2

pH (mg/l) 7.8 7.9 7.6 7.6 7.2 8.2 7.9 7.6

QCVN 5.0 5.0 5.0 5.0 5.0 5.0 5.0 5.0

QCVN 9.0 9.0 9.0 9.0 9.0 9.0 9.0 9.0

0.0

5.0

10.0

15.0

20.0

pH

30

Figure 18. TSS Monitoring Results

d) Biochemical Oxygen Demand (BOD5)

Figure 19. BOD5 Monitoring Results

70. Figure 12-7 shows the results of BOD5 laboratory tests. The BOD5 concentrations ranged from 13.1mg/l to 19.5mg/l, which were much lower the than the allowable concentration of 30mg/L.

e) Chemical Oxygen Demand (COD)

Figure 20. COD Monitoring Results

71. Figure 12-8 shows the results of COD laboratory tests. The COD concentrations ranged from 27.5mg/l to 41.0 mg/l. There is no specified limit for COD in QCVN 14:2018/BMNT. This indicates that COD is not regulated for wastewater to be discharged into water sources which are not intended for domestic uses. However, even comparing with the limits specified in QCVN 14-MT: 2015/BTNMT for wastewater to be discharged into water sources intended for domestic uses, the COD concentrations were much lower.

f) Oil and grease

72. Figure 12-9 illustrates the measured concentrations of oil and grease in the wastewater samples.

WW1

WW2

WW3

WW4

WW5

WW6

WW7

WW8

P1 P2.1. P2.2

TSS (mg/l) 45 43 37 33 38 36 39 37

QCVN 50 50 50 50 50 50 50 50

01020304050607080

TSS

(mg/

l)

WW1

WW2

WW3

WW4

WW5

WW6

WW7

WW8

P1 P2.1. P2.2

BOD5 (mg/l) 19.5 16.3 14.8 13.1 15.7 14.6 15.9 14.4

QCVN 30 30 30 30 30 30 30 30

0.05.0

10.015.020.025.030.035.040.0

BO

D(m

g/l)

WW1

WW2

WW3

WW4

WW5

WW6

WW7

WW8

P1 P2.1. P2.2

COD (mg/l) 41.0 34.2 31.1 27.5 33.0 30.7 33.4 30.2

QCVN 75 75 75 75 75 75 75 75

0.05.0

10.015.020.025.030.035.040.045.050.055.060.0

CO

D(m

g/l)

31

The concentrations ranged from 4.7mg/l to 6.7mg/l. All samples were within the QCVN 14: 2008/BTNMT limit for oil and grease.

Figure 21. Oil and Grease Monitoring Results

g) Coliform

73. Figure 12-10 illustrates the measured concentrations of coliform in the wastewater samples. The concentrations ranged from 600MPN/100ml to 1100MPN/100ml. All wastewater samples have lower concentration of coliform than the QCVN 14: 2008/BTNMT limit which is 3000MPN/100ml.

Figure 22. Coliform Monitoring Results

h) Conclusion

The wastewater test results indicate that the concentration pollutants in the wastewater were within the allowable limit of QCVN14:2008/BTNMT, therefore the wastewater can be discharged into surface water sources that are not intended for domestic water uses without needing further treatment.

5) Recommendations

74. Although the results of the air quality, noise and water quality monitoring indicate that the standards of Vietnam were not exceeded, few recommendations are proposed to prevent or at least minimize the negative impacts of construction activities:

- During the construction phase, the use of noise-causing construction equipment working should be regulated, especially in densely populated areas or in the areas near schools or hospitals particularly during noon break, early morning or evening and at the beginning, middle and end of the classes;

- Maintain and even strengthen implementation of measures to minimize dust such as watering, dampening soil and loose materials during transportation, and proper storage and covering at the construction sites to reduce dust emissions during dry days in the locations near schools and residential areas;

WW1

WW2

WW3

WW4

WW5

WW6

WW7

WW8

P1 P2.1. P2.2

Dầu mỡ (mg/l) 6.20 6.10 6.70 6.50 4.70 5.20 6.20 5.70

QCVN 10 10 10 10 10 10 10 10

0.001.002.003.004.005.006.007.008.009.00

10.00

Oil

and

Gre

ase

(mg/

l)

WW1

WW2

WW3

WW4

WW5

WW6

WW7

WW8

P1 P2.1. P2.2

Coliform(MPN/100ml)

800 650 900 700 1100 600 850 900

QCVN 3000 3000 3000 3000 3000 3000 3000 3000

0150300450600750900

1,0501,2001,3501,5001,6501,8001,9502,1002,2502,4002,5502,7002,8503,000

Co

lifo

rm(M

PN

/100

ml)

32

- Avoid unnecessary use of horn and regulate speed limit of trucks and construction equipment that pass through the public roads;

- Immediately sweep roads whenever stones or soil fell from vehicles or from wheels of vehicles;

- Vehicles transporting loose materials must be covered with canvas to avoid spillage; and

- Collect domestic wastewater and waste during construction or take measures to minimize lubricant, oil spillage and microorganisms before discharging wastewater into the environment.

6 Key Environmental Issues

6.1 Key Issues Identified

75. The main issues identified during this monitoring period are as follows:

- Poor management of hazardous wastes: The Contractors still haven’t entered into agreement with a licensed company for the collection of hazardous wastes. In September 2018, the PSC gave instructions to the Contractors to provide proper storage area for oil and other hazardous materials and wastes. Follow-up letters were issued in November 2018 and January 2019 but until now, the Contractors have not complied with the PSC instructions. The leaking oil tank at Km 97+400 has not been repaired or removed by the Contractor. The PSC required the Contractor to either replace or remove the tank. The PSC will recommend to PMU-TL the imposition of sanction to the Contractors for disregard of environmental requirements in accordance with the Contract conditions. (para.32)

- Excessive dust. Excessive dust is among the issues raised by the local people during the consultation on the project income restoration program held on 05-10 June 2019. Although the Contractors carry out regular watering, dust persists during very dry days as the watered areas dry up within 30 minutes after watering. The Contractors have difficulty meeting the PCS’s instructions to increase watering to 5x-6x per day because of the length of exposed construction areas. Excessive dust arise whenever speeding cars pass. Although the speed of construction vehicles is controlled, that of private vehicles is not. (para.37, Table 7)

- Soil Erosion and Flooding. During the consultation on project income restoration program held between 5 and 10 June 2019, PMU-TL received some verbal complaints from project affected people. The complaints mostly relate to impacts of construction brought about by recent rains. These include: (1) influx of eroded soil and sand into farmlands; (2) flooding of farmlands due to newly constructed irrigation/drainage system as part of utilities work relocation; (3) impeded access to farmlands due to open irrigation/drainage system; and (4) community risks caused by the open ditches. (para 40, Table 8)

- Poor Sanitation. Housekeeping at the fabrication yards of Package 1.0 and Package 2.2 should be improved. The Contractors have not provided portable toilets as required in letters B.09-Package HW217-1, C081.1 Package HW217-2-1 and D.100-Package HW217-2-2 issued by the PSC. (para 46)

- Worker Safety. First aid supplies are still not sufficient. Most workers do not wear PPE. (para. 50)

- Traffic and Public Safety. In January 2019, the PSC advised the Contractors to strengthen safety measures at Km76+300, Km104, and cut areas at Km70+358, Km79+100, Km84+000, Km 92+250, Km92+400 and Km99+777. Furthermore, the Contractor need to provide safety signs (e.g., construction area 50m ahead, no entry, watch out-heavy equipment crossing) at the intersection of diversion road and existing road at Km81. Cut areas adjoining the roadway should be provided with temporary drainage ditches to convey runoff and to catch sliding soil that makes the road slippery when wet. (para. 51).

- The contractors (PK2.1 and PK2.2) need to continue:

✓ In coordination with local traffic authorities, implement appropriate traffic diversion schemes to avoid inconvenience due to project operations to road users, ensure smooth traffic flow and avoid or minimize accidents, traffic hold ups and congestion

✓ Install bold diversion signs that would be clearly visible even at night, provide flag persons to warn of dangerous conditions and designate traffic officers in construction sites.

- Traffic safety and public safety are among the issues mentioned in the letter of Cam Thuy District PC to PMU-TL date 18 June 2019. The District PC recommends that coordination with the Transport Department of Thanh Hoa Province (Transport Project Management Unit III) to come up with an

33

agreement regarding traffic management at the T-junction in Cam Thach commune from Km69+403 to Km 60+540. (para. 52)

- Vibration Impact. In HW217-P2.1, there are 20 complainants regarding cracks on houses. In HW217-2.2, there are 84 complainants. The Contractors have entered into agreement with insurance company to cover for damages to structures. According to some claimants who were interviewed on 28 June 2019 and 02 July 2019, a team from the insurance company have visited and checked the damages to their houses but no assessment of damage and compensation has been agreed. The Contractors said that the insurance company has formed teams to carry out the assessment in the following months, but a firmed-up schedule could not be provided yet.

6.2 Issues from previous report(s)

76. Table 11 lists the outstanding environmental issues that were identified in the 1st and 2nd Semi-

annual Monitoring Reports and the proposed measures for their resolution:

Table 11. Outstanding Environmental Issues and Action Plan No Key Issues Corrective actions Status of implementation of the

actions up to June 2019

1 Hazardous waste ▪ The contractors have not signed

contract with hazardous waste collection company for collection and treatment of hazardous solid and liquid wastes.

▪ The contractors have not constructed a storage area for proper storage of hazardous wastes prior to collection by licensed company.

▪ oil tanks and oil containers are not installed properly and do not have concrete base (bunds) or protection from spills. Oil spills are noticeable in some sites.

▪ Inappropriate storage of hazardous waste

▪ PSC will provide guidance on proper construction of hazardous materials and waste storage to the Contractors

▪ PSC to re-issue reminder letter to the Contractors to enter into contract with licensed company for regular collection of hazardous wastes

Done in Sep 2019

▪ Fuel or gasoline is stored far from water bodies; however, some fuel tanks are located near the camps Package 2.2 at Km97+900). They should be installed away from camps or houses.

▪ The fuel containers should be checked for leaks. Leaking drums or containers should not be used.

▪ Fuels storage should be in covered areas with bund to prevent seepage or leak into the ground with proper sign boards.

▪ The Contractors should provide proper storage area for fuel and fuel drums. Storage areas should be covered, provided with bund to prevent leaks from seeping into the ground, and provided with appropriate warning signs such as no smoking and no unauthorized entry.

▪ Contractors should immediately enter into agreement with a licensed company for regular collection of hazardous wastes.

▪ All Contractors should maintain a record of the hazardous wastes produced for reporting to DONRE once a year

Not Done Yet In September 2018, the PSC gave instructions to the Contractors to provide proper storage area for oil and other hazardous materials and wastes. Follow-up letters were issued in November 2018 and January 2019 but until now, the Contractors have not complied with the PSC instructions. The leaking oil tank at Km 97+400 has not been repaired or removed by the Contractor. The PSC required the Contractor to either replace or remove the tank.

The PSC will recommend to PMU-TL the imposition of sanction to the Contractors for disregard of environmental requirements, in accordance with the Contract conditions.

34

No Key Issues Corrective actions Status of implementation of the actions up to June 2019

2 Lack of personal protective equipment (PPE) ▪ Most workers do not wear PPE

on site. The Contractors must improve on occupational safety in construction sites.

▪ lack of PPE

PSC will require the Contractors to provide necessary PPE to workers and strictly require workers to wear PPE.

Daily monitoring

Contractors must provide adequate PPE to workers.

Not Done Yet Most workers do not wear PPE.

Workers’ safety The Contractors have not assigned full-time safety officers to ensure worker and public safety. Unsafe conditions such as lack of proper storage area for fuel, electric wires on the ground, and unsafe electrical cables have been observed in some sites, particularly at the fabrication areas of Package 1.0 and Package 2.2. First aid supplies in most camps are either lacking or insufficient. Most workers do not wear PPE. Safety training for workers should be strengthened.

▪ Contractor will assign at least a full-time safety officer to ensure worker and public safety

▪ Contractors must re-arrange the construction site to ensure safety

▪ Contractors to purchase full first aid tools and PPE and provide trainings for workers how to use PPE before working.

Not Done Yet The Contractors have not assigned full-time safety officers to ensure worker and public safety. Despite earlier verbal and written instructions, the Contractors have not improved the management of fuel and hazardous wastes

3 Lack of warning signs at landslide/slip positions

Warning signs should be provided at critical areas where landslide or slip has occurred or has high probability of occurrence

Partially Done

The PSC conducted traffic management training for the Contractor’s management staff in June 2018.

During this report period, the contractors continued the implementation of measures to ensure traffic safety and maintain good traffic flow where construction works are being implemented. However, the Contractors need to strengthen safety measures at Km76+300, and Km104, and cut areas at Km70+358, Km79+100, Km84+000, Km 92+250, Km92+400 and Km99+777. Furthermore, the Contractors need to provide warning signs (e.g., construction area 50m ahead, no entry, watch out-heavy equipment crossing) at the intersection of diversion road and existing road at Km81. Cut areas adjoining the roadway should be provided with temporary drainage ditches to convey runoff and to catch sliding soil that makes the road slippery when wet

4 Training ▪ Safety training for workers

should be strengthened. ▪ The PSC has not yet conducted

the environmental awareness

The PSC had a meeting with the Contractors on 09/07/2019 to discuss and agree on the schedule for worker’s training. Contents, objectives and examples of

Partially Done The PSC carried out environmental training for the Contractors in March 2019. Follow-on training is scheduled for July

35


training for the Contractor. ▪ The Contractors also have not

yet carried out orientation on environmental and social management for their workers.

training materials per topic were explained to the Contractors in detail: (1) Worker induction/ orientation on Project CEMP and Project’s environmental requirements to include prohibited acts, wearing of PPE and safe work practices, community relationship, and weekly tool box meetings; (2) Solid Waste Management to include waste segregation, litter control, daily housekeeping, and hazardous waste management; (3) Noise, emission, water quality , and vibration control to include site watering, proper use of horn, truck cover and load control, avoidance of idling of equipment, and avoidance of disposal of litter and wastewater in drainage and streams; (4) Worker, Public and Traffic Safety to include proper use of PPE, buddy system, maintenance of warning sign boards and barriers, smoking, HIV/AIDS, communicable disease control; and (5) Reporting Procedure in case of UXO chance find, archaeological relic chance find and incident/accident.

2019. The Contractors will carry out environmental training for workers on: 23/07/2019 - Package 1.0 30/07/2019 - Package 2.1 26/07/2019 - Package 2.2

5 Public safety ▪ “Advance Warning Signs” are not

equipped at each section of the construction site. No bamboo posts and tape ribbon around obstructions, culverts, working areas

▪ Lack of warning signs and barricades at critical road sections where Works are being carried out

Traffic Safety ▪ There are critical areas where

traffic management measures should be strengthened such as at the borrow areas at Km76+300, Km92+400 and Km104, and cut areas at Km70+358, Km79+100 and Km84+000. The excavation works at Km84+000 is immediately after a bend and is partly hidden from view. Reflectorized warning sign boards indicating heavy equipment crossing, that construction works are ongoing, and that there is hazard of falling materials, should be placed at

The Contractors should provide early warning signs at critical road sections and at locations where work is on-going. Warning signs should be placed at strategic locations and should be highly visible (not too low on the ground that driver of heavy equipment could not see)

Done Partially

Site conditions have improved at Km76+300, Km70+358 and Km79+100. The Contractor still needs to provide warning signs (e.g., construction area 50m ahead, no entry, watch out-heavy equipment crossing) at the intersection of diversion road and existing road at Km81, Km84+000, Km 92+250, Km92+400 and Km99+777.

Cut areas adjoining the roadway should be provided with temporary drainage ditches to convey runoff and to catch sliding soil that makes the road slippery when wet

36


strategic locations at least 20m before the sites to forewarn the motorists and pedestrians of the potential hazards. Cut areas adjoining the roadway should also be provided with temporary drainage ditches to convey runoff and to catch sliding soil that makes the road slippery when wet.

6 Absence of environmental effect monitoring

▪ Environmental monitoring contractor should be mobilized by PSC as soon as possible

▪ Environmental monitoring (noise, air, water…) should be implemented as soon as possible.

Done Following MOT’s approval of the TOR and cost estimate of the environmental monitoring project (Decision No. 417/QĐ-BGTVT dated 05 March 2019), the contractor, Viet A Construction Design and Investment Consultancy (VITA E&C JSC), carried out the first environmental monitoring activities on 27-29 May 2019.

7 No toilets available on site for workers (separate for male and female), all packages

▪ In separate letters to the Contractors dated 07 November 2018, the PSC required the Contractors to improve the situation and apply the measures committed in the environmental management plan of the Contractor.

Done Partially Contractors’ site offices and rented houses for workers have built-in toilets. Contractors have not provided portable toilets in construction areas outside of site offices and rented houses. Contractors have not provided separate toilet for male and female at fabrication areas and bunkhouses or at resting areas of workers.

8 Burning of waste (HW217-1.0) ▪ The PSC advised the Contractor that burning of waste is prohibited.

▪ Prohibited acts such as burning of waste is among the topics of workers’ training to be carried out on 23/07/2019 for HW217-1.0

Done. The Contractor has stopped burning of waste

9 Waste oil not collected (HW217-1.0)

▪ The PSC advised the Contractor to have the waste oil collected

Done The waste oil has been collected.

10 Contractors of HW217-2.1 and HW217-2.2 have not installed warning barrier at starting point of drainage culvert construction

▪ In separate letters to the Contractors dated 07 November 2018 and follow-up letter in January 2019, the PSC required the Contractors to improve the situation and apply the measures committed in the environmental management plan of the Contractor.

Done Partially Safety tapes and warning signs have been provided in some culvert location, but most barriers are not stable, safety tapes are not maintained, and warning sign boards are not of good quality and do not meet the standards for warning sign boards.

11 The alert light, guideposts, warning line have not been placed at intersections with ramp along the route (HW217-2.1 and HW217-2.2)

▪ In separate letters to the Contractors dated 07 November 2018 and follow-up letter in January 2019, the PSC required the Contractors to improve the situation and apply the measures committed in the environmental

Not Done The Contractors have not provided yet.

37


management plan of the Contractor.

12 Prevention and compensation measures to be implemented immediately whenever construction machines cause crack or settlement or structures along the route (HW217-2.1 and HW217-2.2)

▪ The Contractors to enter into Contract with insurance companies to cover for claims against cracks and pay local people for damages

Done Partially In HW217-P2.1, there are 20 complainants regarding cracks on houses. In HW217-2.2, there are 84 complainants. The Contractors have entered into agreement with insurance company to cover for damages to structures. According to some claimants who were interviewed on 28 June 2019 and 02 July 2019, a team from the insurance company have visited and checked the damages to their houses but no assessment of damage and compensation has been agreed. The Contractors said that the insurance company has formed teams to carry out the assessment in the following months, but a firmed-up schedule could not be provided yet.

13 At Chieng Tam Bridge: no barrier, soil bag at the foot of slope of material discharge area to prevent slippage and erosion into the river

▪ In letter Ref. C.081.1-Package HW217-2-1 dated 07 November 2018, the PSC required the Contractor to improve the situation and apply the measures committed in the environmental management plan of the Contractor.

Done The Contractor has provided barrier and sandbags at the foot of slope of Chieng Tam bridge

6.3 Issues Identified by ADB’s Loan Review Mission (May and November 2018)

77. Issues identified during the ADB mission in May 2018 which are still pending are (a) inappropriate storage of hazardous waste, (b) insufficient dust control at construction sites, and (c) lack of personal protective equipment (PPE). Issues that were identified during the ADB mission in November 2019 that are still pending are (a) no toilets available on site for workers, separate for male and female, (b) alert light, guide posts, warning lines have not been placed at intersections with ramp along the route at HW217-2.1 and HW217-2.2, (c) warning barrier at starting point of drainage culvert construction have not been installed (HW217-2.1 and HW217-2.2). These issues, the proposed action plan and target date of resolution have

been specified in Table 11. New issues that were observed during the site visit of the ADB loan review

mission in May 2019 are listed in Table 12.

Table 12. Issues Identified during the ADB Mission in May 2019 and Action Plan for Closure

Identified Environmental Issue

Status 30 June 2019

Action Plan for Closure of Issue

Milestone

Community safety risk

As temporary measure to ensure access by local people to their houses and farmlands, the Contractors provided temporary crossway at several open ditches.

The PSC instructed the Contractors to provide temporary cover for all unfinished ditches/ditch excavation areas. Contractors to fast track completion of drainage ditches and to implement

From July 2019

38

PSC instructions to provide temporary cover on open ditches.

Absence of traffic safety management/control

Cam Thach PC requested PMU-TL to coordinate with the Transport Department of Thanh Hoa Province to ensure traffic safety for road users and vehicles.

PMU-TL, PSC and Contractor will review the TMP and coordinate with the Transport Department of Thanh Hoa regarding the traffic safety plan.

July-August 2019

Improper solid waste management

Fabrication yards and temporary resting areas of workers are still disorderly and unkempt. Waste segregation and proper waste disposal is not carried out. Cigarette butts, soft drink cans and other trash are thrown everywhere.

Contractors’ and workers awareness on proper solid waste management will be strengthened through trainings to be held by the PSC for the Contractor and engineers and by the Contractors for their workers. Solid waste management topic to focus on waste segregation, litter control, daily housekeeping, and hazardous waste management

PK-1.0 – 23 July 2019 PK-2.1 - 30 July 2019 PK-2.2 - 26 July 2019 PSC – 17 July 2019

Poor condition of workers’ camp

No improvement Contractors to improve housekeeping, carry out litter control, proper domestic waste management

From July 2019

Lack of Personal Protective Equipment

No improvement despite follow-up letters to the Contractors. Many workers still do not wear PPE. Welders do not have face protection, Workers doing works at height do not have sufficient fall protection.

The PSC had a meeting with the Contractors on 09/07/2019 to discuss and agree on the schedule for worker’s training. Wearing of PPE and safe work practices will be among the topics of workers’ training.

PSC will require the Contractors to provide necessary PPE to workers and strictly require workers to wear PPE. Workers not wearing proper PPE will not be allowed at worksites.

Workers’ training to include lectures on requirement to wear PPE on site, safe work practices and safe acts will be carried out by the Contractors

Daily PK-1.0 – 23 July 2019 PK-2.1 - 30 July 2019 PK-2.2 - 26 July 2019

Absence of information disclosure on grievance redress mechanism

During the consultation meetings with the PCs, the PCs confirmed that they are aware of the GRM procedures and they are closely coordinating with the PMU-TL and vice versa for resolution of any issue relating to the project.

PSC-ES and PMU-TL to continue coordination with PCs to document complaints and discuss solutions.

Every month Meetings to be held as necessary to resolve issues

39

6.4 Issues identified by ADB’s Loan Mission Review in May 2019

78. Some remained environmental problems were discovered during the inspection and supervision of ADB Mission in May 2019:

- PMU-TL received many verbal complaints on environmental issues from the participants (project affected

people) during consultations on the project income restoration program held between 5 and 10 June

2019. The complaints are (i) in flux of eroded soil and sand into farmland; (ii) flooding of farmlands due

to newly constructed agricultural irrigation/drainage system as part of utilities works relocation in the

project; (iii) impeded access to farmlands due to the open irrigation/drainage system; (iv) community risk

caused by the open ditches; (v) crack on their structures; and (vi) dust. Some claimed that they missed

harvest for two seasons already, due to the disturbance caused by the project. An accident of a child,

who accidentally fell into an open ditch during the nighttime and could not get out by himself.

- ADB’s Review Mission in May 2019 found that environmental supervision/monitoring has not been

conducted since before March 2019 (the national environmental consultant (NEC) abandoned his

assignment). The mission also noticed that only 12 PMs were allocated for NEC, although the Project

Administration Manual required 24 PMs. The mission also found environmental problems at the project

sites, some of which remain unresolved from the previous missions in May-June and November 2018.

6.5 Environmental and safety issues raised by local community during the consultation on the project income restoration program held on 05-10 June 2019

79. Some shortcomings have been seen during the construction of the pipelines along the road across households such as: (i) The construction contractor has not paid attention to making barriers carefully, and (ii) the contractor has not made temporary cross bridges to facilitate movement of households.

80. Through the surveys in the districts and the communes, the Consultant has received reflection of households and local authorities about the status of subsidence and cracking of houses caused by construction. The total number of affected households whose houses are cracked and settled by the construction in 03 districts includes 290 households; In Ha Trung district, there are 03 households having house subsidence and cracking (Dang Thi Sam, Tran Thi Tuyet, Tong Thi Mun), outside the site clearance demarcation. In Ba Thuoc district, there are about 286 affected households, of which Ai Thuong commune has 85 households, Dien Quang commune has 65 households, Lam Xa commune has 60 households, Thiet Ong commune has 61 households, and Dien Trung commune has 15 households. For Cam Thuy district in Ha Son village, Cam Binh commune, 1 household reflects that the construction contractor cracks their house.

6.6 Highlights/Notable Environmental Management Practices

81. Table 13 summarizes the good environmental management practices noted by the ES during the construction site visits.

Table 13. Notable Environmental Management Practices Road

Package Notable Environmental Management Practices

Package 1.0 Good management of spoil sites, removal of spoils immediately from construction sites, good maintenance of equipment and vehicles, maintenance of existing drainage channels, provision of slope protection at critical to prevent erosion, supply of clean water at camps, good erosion control at some sites; good condition of quarry sites; hauling trucks are covered and not overloaded, building materials are neatly gathered at the temporary storage areas in the project area.

Package 2.1 Good management of spoil sites, immediate removal of spoils from construction sites, supply of clean water at camps, good maintenance of equipment and vehicles; good condition of quarry sites; good erosion control at some sites; hauling trucks are covered and not overloaded

Package 2.2 Good management of spoil sites, good selection of location of cement and asphalt batching plant, maintenance of existing drainage systems at side, prevention of erosion into local people’s fields, supply

40

of clean water at camps; good condition of quarry sites; hauling trucks are covered and not overloaded

7 Complaints

82. In the past few months, issues relating to impacts of flooding, soil erosion, cracks on houses, public safety and dust have arisen. Some local people have been affected and relayed their complaints verbally to the commune PCs which in turn relayed the complaints to the district PCs. The District PC of Cam Thuy sent an official letter to PMU-TL regarding the issues on 18 June 2019.

83. Complaints were also raised during the consultations on the project income restoration program on 05-10 June 2019. The complaints are (i) influx of eroded soil and sand into farmlands; (ii) flooding of farmlands due to newly constructed agricultural irrigation/drainage system as a part of utilities works relocation in the project; (iii) impeded access to farmlands due to the open irrigation/drainage system; (iv) community risks caused by the open ditches; (v) cracks on their structures; and (vi) dust. According to the complainants, some of them had filed complaints 4-6 months ago, but no feedback has been received.5 Some claimed that they missed harvest for two seasons already, due to the disturbance caused by the project. An incident of a child, who accidentally fell into an open ditch during the nighttime and could not get out by himself, was also reported. In a letter dated 24 June 2019, ADB requested the MOT and PMU-TL to

- (continue to) implement corrective actions;6 and in parallel,

- mobilize a national environmental consultant with sufficient person-months;

- consult with the affected people and satisfactorily address their complaints;

- provide (refresher) environmental safeguards training to the workers with the assistance of international and national environmental consultants;

- prepare a corrective action plan (CAP) and submit to ADB by 30 June 2019; and

- report CAP implementation to ADB through the SEMR for the period between January and June 2019 (which is due by 15 July 2019, as agreed during the Mission) and succeeding SEMRs as appropriate.

84. Through the consultation with the affected people and site inspection, PMU-TL needs to (i) identify and understand the complaints attributed to the project, (ii) agree corrective actions, and (iii) disseminate information about the grievance redress mechanism (GRM). The consultation should continue throughout project implementation as necessary.

85. The CAP should; (i) include and reflect the outcome of the consultation with the affected people; (ii) cover the complaints relevant to the project as well as environmental issues identified by internal monitoring and ADB missions; and (iii) explain the corrective actions taken and to be taken, with implementation timeline and milestones.

86. As of 31 July 2019, Consultants Supervision submitted a CAP to PMU-TL for submission to ADB.

87. Consultation/coordination meetings and site visits with the commune, town, and district PCs were carried out jointly by the PMU-TL, PSC and Contractors on 27 June 2019 and 02-03 July 2019. The findings and recommendations to resolve the issues are explained in the relevant sections of this report.

88. Land acquisition issues are being monitored and continually being resolved by PMU-TL Thang Long in close coordination and consultation with the relevant People’s Committees. The status of land acquisition is covered in separate reports by the PMU-TL.

8 Conclusions

8.1 Overall Progress of Implementation of Environmental Management Measures

5 The Project construction started in January 2018, and two semi-annual environmental monitoring reports (SEMRs)

have been submitted so far. Both reports state that “There are no pending or outstanding environmental complaints as of 30 June 2018/31 December 2018 (the last day of the respective monitoring period)”.

4 PMU-TL explained to ADB, in the meeting held on 13 June 2019, that they have been implementing some corrective actions, although they have never directly communicated with the complainants.

41

89. While many of the recommendations in the IEE-EMP are being implemented by the Contractors, compliance with some environmental management measures still need to be strengthened.

90. To force the Contractors to comply with their commitments in the CEMP and for the Project to be fully complying with the environmental laws and regulations of Vietnam and the ADB Safeguards Policies (2009), as a last recourse, the PSC is strongly considering to recommend to PMU-TL the withholding of payments for progress billings and/or stop construction or deduct payments to the Contractor for the associated

cost of corrective measures to be contracted to a third party, in accordance with the Particular Conditions of Contract, Section B.

8.2 Problems Identified and Actions Recommended

91. The following environmental issues are a summary of environmental aspects where improvement is needed to improve compliance with the EMP. The PSC has regularly sent letters to all contractors to request contractors to improve environmental condition, and the recommended timeframe for compliance:

42

Appendix 1: Assessment of Compliance with the EMP

Environmental Concern

Objective Proposed Mitigating Measures in the EMP

Assessment of Compliance with the

EMP7 Remarks

PK-1 PK-2.1

PK-2.2

A PRE-CONSTRUCTION STAGE

1

Design update and project disclosure

Update designs.

Compliance with VIE statutory environmental assessment process.

Establishment of Grievance Redress Mechanism (GRM)

1. Secure the services of the Project Design Consultants (PDCV) to update designs to address design requirements.

2. Notify Project to DONRE and identify environmental permits / certificates under statutory environmental assessment process.

3. Implement plan for Grievance Redress Mechanism and inform Than Hoa Province

FC FC FC Designs were updated by PDCV during the detailed design stage. Necessary permits for quarry, spoils disposal sites were obtained prior to construction and incorporated in the Contractors’ CEMPS. GRM plan has been disclosed.

2

Subproject boundaries change.

EMP can control impacts and compliance required for environmental laws.

1. Ensure the road is as described in IEE and RRP (Report and Recommendations to the President) with same land acquisition.

2. Design bypasses and QL217 upgrading works within RoW, to avoid graves, cemeteries and other sensitive receiver/receptors

3. Detailed ddesign alignment to avoid sensitive receivers, loss of vegetation and trees.

4. Detailed ddesign to provide for enhancement where practicable.

5. Make plan for tree replacement with forest and local authorities DFO.

6. Review and update IEE and EMP & include in bidding

FC FC FC Recommendations were implemented during the detailed design stage.

7 FC = Full Compliance

GC = Good Compliance PC = Poor Compliance NC = Not Complying NA = Not Applicable Pa.C = Partial Compliance

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EMP7 Remarks

PK-1 PK-2.1

PK-2.2

documents and resubmit in line with ADB SPS 2009.

3

Environmental capacity development

Ensure TSD and PMU-TL can develop management capacity to implement the EMP so PMU-TL-TSD to supervise implementation EMP and environmental mitigation measures

1. Deliver revised environmental assessment and EMP.

2. IEEs and EMPs are checked by TSD and included in bidding documents to prepare contractors for environmental responsibilities.

2. Training to TSD (PMU-TL) on all matters required in IEE; using workshops and on-the-job training techniques and case studies.

4. Capacity building activities. Consolidate environmental specialists in TSD and PMU-TL.

5. Develop strengthening plan for the environmental management by TSD and PMU-TL and retain staff for project duration.

FC FC FC Recommendations were implemented during the detailed design stage. Environmental trainings will also be carried out during the construction stage.

4

Plan Spoil and Waste Disposal

Minimize waste; avoid fly-tipping and pollution.

1. Re-use of waste materials & spoil disposal locations included in contracts.

2. PDCV prepares draft WASTE MANAGEMENT PLAN and SPOIL DISPOSAL PLAN as part of updated EMP (update by contractor later).

FC FC FC Spoil sites have been identified and disposal plans were incorporated in the Contractors’ respective CEMP.

5 Plan construction materials management

Avoid stockpiling of rock-based materials and erosion runoff.

1. Schedule construction materials to avoid stockpiling. 2. Designs to balance cut and fill where possible and avoid borrow areas in agricultural land. 3. Draft MATERIALS MANAGEMENT PLAN for selected contractor to include in CEMP.

FC FC FC Design recommendations were implemented during the detailed design stage. MMP is included in the Contractors’ respective CEMP.

6

Drainage and Hydrological Impacts

To minimize hydrological impacts flooding and erosion of riverbanks.

1. Designs for bridges and culverts sufficient to control flooding with appropriate drainage structures to cater for worst case flow and rainfall from 100-year return storm and to dissipate energy of flow to reduce erosion.

2. Designs for drainage to avoid disposal of outflow on steep slopes >30% and non- vegetated areas. Protect slopes below.

3. Draft DRAINAGE MANAGEMENT PLAN for selected contractor to update in CEMP.

FC FC FC Design recommendations were implemented during the detailed design stage.

44




EMP7 Remarks

PK-1 PK-2.1

PK-2.2

7

Erosion Control and Flooding

To minimize hydrological impacts, flooding damage to the works and erosion of riverbanks.

1. Incorporate erosion control and slope stabilization measures in the engineering design such as side ditches and berms, rock lining and slope walls, and provision of vegetation cover on slopes, where appropriate. 2. Temporary drainage works are to be designed based on the historical flood data and flood forecasting. 3. Ensure design includes prevention of flooding in adjacent areas during rehabilitation or construction of bridges. 4. Incorporate in the design side drainage structures to divert the stream water at construction sites. 5. Design incorporates sufficient sizes of drains to take design flows. 6. Draft EROSION CONTROL PLAN for selected contractor to update in CEMP.

FC FC FC Design recommendations were implemented during the detailed design stage and Erosion Control Plan is described in the Contractors’ respective CEMP.

8

Traffic Condition

Minimize disturbance of traffic and traffic congestion.

1. Contact all relevant local authorities and local village groups to plan traffic management.

2 Draft TEMPORARY TRAFFIC MANAGEMENT plan in revised EMP for selected contractor to update in CEMP.

FC FC FC TMP is incorporated in the Contractors’ respective CEMP.

9

Protect and deprovision irrigation, utilities and trees

Minimize interruption to power, water supply telecoms and irrigation system and tree cutting

1. Identify all power, water supply, telecommunications and irrigation systems likely to be interrupted by the works and trees to be cut. 2. Contact all relevant local authorities for utilities, forestry authority and local village groups to plan deprovisioning of power, water supply, telecommunications and irrigation systems and tree replanting.

3. Draft UTILITIES and IRRIGATION REPROVISIONING PLAN and TREE REPLACEMENT PLAN for selected contractor to update in CEMP.

FC FC FC Recommendations were implemented during the detailed design stage. Plans are described in the Contractors’ respective CEMP.

10 Noise and dust management

Minimize noise and dust

1. Reconfirm all noise and dust sensitive receivers likely to be affected.

FC FC FC Noise and Dust Control Plan is described in the Contractors’ respective CEMP.

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PK-2.2

2. Contact local village groups to plan mitigation in advance.

3. Draft NOISE and DUST CONTROL PLAN for selected contractor to update in CEMP.

11

Environ-mentally responsible procurement

Opportunity enhance design/avoid pollution.

1. Awareness workshop with candidate contractors before bids are accepted. 2. Include in bid document that Contractor shall engage capable and trained staff or site agent(s) to take responsibility for the environmental management and safety issues at the working level and to monitor the effectiveness and review mitigation measures as the project proceeds 3. Non-polluting or enhancing methods. 4. Contractors submit MS of mitigation measures and enhancements with tender with dedicated named staff; environmental and erosion control managers. 5. Recruit qualified staff to oversee implementation of environmental and safety measures specified in the EMP

FC FC FC Each Contractor has appointment an Environmental Officer for the Project

12

Unexploded

Ordinance

Contact independent and international mines advisory groups and agencies at the design stage to identify if UXO is a potential threat to works

FC FC FC The PMU-TL Thang Long signed with 319 Company to check (unexploded ordinance) whole construction land of this project at the design stage to identify if UXO is a potential threat to works. 319 Company finished the UXO verification and clearance in June 2017 and found none of UXO within entire project area. (see Annex No.9- Agreement Minutes of the completion of package No 5B “UXO clearance”)

13 Water quality

baseline

Conduct water quality analysis two weeks before opening up construction activities within 50m at three bridges in each district.

NC NC NC Baseline was not collected (see Chapter 5.2)

14 Noise

baseline

Conduct noise and air quality monitoring and analysis two weeks before opening up construction activities within 50m at all bridges

NC NC NC Baseline was not collected (see Chapter 5.2)

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PK-2.2

B. CONSTRUCTION STAGE

1 Activate management plans and obtain permits / licenses

Avoid impacts from unplanned activities

1. PSC shall conduct contractor environmental awareness training

2. Update and activate management plans for spoil and waste, materials, drainage, erosion control, traffic, utilities, noise and dust control and worker and public safety included in CEMP

3, Contractor(s) and their suppliers comply with all statutory requirements for permits from DONRE with regard to use of mechanical equipment, establishment and operation of construction plants such as concrete batching plant, rock crusher, etc.

FC FC FC • PSC carried out training in March 2019.

• The Contractors have started implementing the environmental management measures specified in the CEMP while finalizing in the CEMP for approval.

• Contractors have secured the necessary permits for disposal sites and quarries. The permits will be incorporated in the CEMP

2 Orientation for Contractor, Workers on environmental and social management.

Contractor & workers trained to implement mitigation measures and better implementation of EMP.

1. Contractor/TSD training by PSC on all aspect of EMP, CEMP and all management issues for waste, noise etc.

2. Contractors clearly separate resources applied to mitigation measures. Tenders identify named staff to supervise management’s plans 3. Implement malaria controls and HIV-AIDS education in line with social plans 4, HIV/AIDS awareness and prevention program shall be implemented under the Project

FC FC FC • The PSC conducted the environmental awareness training for the Contractors in March 2019. Follow-on training scheduled for July 2019.

• Contractors have scheduled worker training on the 4th week of July 2019

• HIV/AIDS awareness training was carried out on 25 June 2019. Other HIV/AIDS program activities are being carried out according to approved plan.

3 Loss of trees, vegetation & aesthetics

Avoid removing trees and prevent deforestation

1. Tree-cutting and replanting plan will be prepared before vegetation clearing is undertaken as part of CEMP. 2. Monitor and marking of vegetation that will not be removed agreed with forest authority prior to commencement of construction. 3. Forest authority to approve replacement of cut trees to be undertaken based on the tree cutting and replanting plan. 4. Cut slopes designed not to undercut or destabilize adjacent tree lined slopes. 5. Ensure ban on use of forest timber for fuel is in

FC FC FC • The tree-cutting and replanting plan is incorporated in the CEMP. No trees of ecological importance were removed during clearing activities for the project. Clearing is confined within the Project RoW.

• Workers are prohibited from cutting trees for firewood. Camps are provided with electric stove or LPG stove for cooking.

• The Contractor will be required to submit a detailed replanting plan before completion of construction activities and the PSC will ensure that the plan will specify the prohibition on

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PK-2.2

CEMP and Workers shall be prohibited from cutting trees for firewood. 6. Clearing of trees minimized in CEMP. 7. During replanting/revegetation works, new alien plant species (i.e., species not currently established in the country or region of the project) shall not be used unless carried out with the existing regulatory framework for such introduction. Invasive species shall not be introduced into new environments.

introduction of new or invasive species

4

Drainage and Hydrological Impacts

To minimize hydrological impacts flooding and erosion of riverbanks.

1. Review detailed designs for cross-drainage structures, assess and agree with PMU-TL (PSCV/PMU-TL) if redesign is required or if new structures would be constructed or existing ones would be repaired. 2. Update DRAINAGE MANAGEMENT PLAN in CEMP. 3. Implement agreed designs for bridges and culverts sufficient to control flooding as designed and to dissipate energy of flow to reduce erosion. 4 Protect or deprovision irrigation channels that cross the works areas. 5. Protect natural streams may become silted by construction runoff, workshops and equipment washing yards. 6. Minimize alterations in the project corridor’s surface drainage patterns as far as possible: 7. Drains to be constructed so that the outfalls of the surface run-off from the carriageway are diverted away from the sensitive receiver/receptors. 8 Ensure that storm drains and highway drainage systems are periodically cleared to maintain storm water flow during construction.

FC FC FC • Design plans were reviewed before the start of construction works. There were no major deviations from the original design.

• The drainage management plan is part of the CEMP

• Implementation of bridges and culverts are in accordance with the approved plans

• All recommendations have been considered in the final design of projects

5

Utilities

Prevent interruption of services such as electricity and

1. Update UTILITIES and IRRIGATION REPROVISIONING PLAN 1. Reconfirm power, water supply, telecommunications and irrigation systems likely to be interrupted by the

FC FC FC • All utilities that will be affected have been identified during the detailed design stage and have been coordinated with the relevant service providers.

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PK-2.2

water during relocation of the utility’s line /connections.

works and trees to be cut. 2. Contact all relevant local authorities for utilities and local village groups to plan provisioning of power, water supply, telecommunications and irrigation systems. 3. Utilities shall be relocated and reconnected well ahead of commencement of construction works and contractor shall coordinate with utility company for relocation and reconnection well before works commence. 4. Affected communities shall be properly informed in advance. 5. Reconnection of utilities shall be done at the shortest practicable time before construction commences. 5. Utilities damaged during construction shall be reported to the PSCV and utility authority and repairs arranged immediately.

• There are some utilities that have not been transferred but ongoing construction activities are not affecting the services to local communities and current works are not affected by the utilities that have yet to be transferred.

6

Materials exploitation and management of quarry and borrow areas

Minimize impacts from materials extraction, transportation and storage with MMP.

1. Update draft MATERIALS MANAGEMENT PLAN (MMP) in CEMP 2. Balance cut and fill requirements to minimization impacts from extraction of aggregates. 3. Prioritize use of existing quarry sites with suitable materials and update the list of quarries and borrow pits monthly in MMP and report to PMU-TL1/TSD and minimize impacts on other local resources. 4. Procure materials only from DONRE authorized quarries. 5. If the contractor shall operate the quarry site, required environmental permits shall be secured prior to operation of quarry/borrow areas. 5. Follow compensatory planting plan if trees must be removed 6. Stockpile topsoil for later use and fence and re-contour borrow pits after use. Topsoil, overburden, and low-quality materials shall be properly removed, stockpiled near the site, and preserved for

FC FC FC • MMP is incorporated in the Contractors’ CEMPs.

• Existing quarry sites are used as appropriate

• All quarry sites have necessary permits from authorities

• There are no quarries located in riverbeds

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rehabilitation. 7. Use quarry with highest ratio between extractive capacity (both in terms of quality) and loss of natural state; 8. Use quarry sites lying close to the alignment, with a high level of accessibility and with a low hill gradient; 9. Do not use quarries in areas of natural woodland or near rivers which provide food and shelters for birds and other animals. 10. It is preferable to avoid or reduce the sections of quarry sites located on riverbed. If it is not possible to locate quarries out of riverbeds, quarry sites lying on small rivers and streams shall be avoided. Alluvial terraces or alluvial deposits which lie on the riverbeds but not covered by water in normal hydrological conditions, are preferred; 11. In quarries in the mountainous or hilly areas, or wherever slopes are important, cut terraces after extraction and implement a drainage system and vegetation cover for rehabilitation. 12. Ensure borrow pits are left in a tidy state with stable side slopes and proper drainage to avoid creation of water bodies favorable for mosquito breeding

7

Spoil Disposal

Control spoil and construction waste disposal, oily and hazardous wastes.

1. Update Spoil Disposal section in SPOIL & WASTE MANAGEMENT PLAN (SWMP) updated by Contractor one month before construction (in CEMP) to cover all aspects of spoil removal, storage, disposal and monitoring to be approved in writing by PSC one month prior to starting works.

2. Areas for disposal to be agreed with landowner and DONRE checked and recorded by the PSC/PMU-TL1 and monitored

3. Spoil disposal areas to be rehabilitated monitored, catalogued, and marked.

FC FC FC • The SWMP is part of the Contractors’ respective CEMP

• Disposal sites have approval from local authorities

• Disposal sites are approved by the PSC Project Manager

• Use of disposal sites is being monitored by the PSC ES regularly

• Spoils disposal sites are well-managed

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8

General Construction Waste Disposal

Reduce, reuse and recycle waste and contamination due to poor waste disposal practices.

1. Update Waste Management section of SWMP, updated by Contractor one month before construction (in CEMP) to cover all aspects of waste storage, disposal and accidental spills to be approved in writing one month prior to starting works.

2. Areas for disposal to be agreed with landowner and DONRE checked and recorded by the PSCV/PMU-TL1 and monitored

3. Waste disposal areas to be rehabilitated monitored, catalogued, and marked.

4. Segregation of wastes shall be observed. Cleared foliage, shrubs and grasses can be given to local farmers for fodder and fuel. Organic (biodegradables) shall be collected and disposed of on site by composting (no burning on site). 4. Recyclables shall be recovered and sold to recyclers.

5. Residual and hazardous wastes shall be disposed of in disposal sites approved by local authorities.

PC PC PC • Domestic solid wastes are regularly collected by the garbage collectors in the community however general construction wastes at fabrication yards are poorly managed.

• Housekeeping is poor, and segregation of construction wastes is not carried out daily. The Contractors have not provided for waste bins or containers for the different waste types at fabrication yards.

• During site visits, PSC reminds the Contractors to improve on housekeeping, but housekeeping practice has not improved. Housekeeping will be a focus of the follow-on environmental management training by the PSC in July 2019.

9

Use of hazardous substances and hazardous waste disposal

Minimize contamination due to use and storage of hazardous substances

1. Update Hazardous Waste section of SWMP, one month before construction (in CEMP). Include in CEMP requirements for: safe storage of fuel and bulk materials; from sites with permit under provincial laws and agreed by TSD and DONRE 2. Hydrocarbon, toxic material and (explosives --- if blasting will be involved) will be stored in adequately protected sites to prevent soil and water contamination 3. Vehicle maintenance and refueling will be confined to areas in construction sites designed to contain spilled lubricants and fuels. 4. Fuel depot shall be provided with impervious flooring and bund/containment wall to keep spilled fuel/lubricant within the depot; 5. Used oil and other toxic and hazardous materials shall be disposed of in an authorized facility off-site.

NC NC NC • The Contractors still haven’t entered into agreement with a licensed company for the collection of hazardous wastes. During this period, minimal amount of toxic wastes was generated as construction activities were limited. Toxic or hazardous wastes generated are mainly used oil and contaminated rags used in the repair of equipment. Oil wastes arising after each work shift are collected in small containers.

• In September 2018, the PSC gave instructions to the Contractors to provide proper storage area for oil and other hazardous materials and wastes. Follow-up letters were issued in November 2018 and January 2019 but by end of June 2019, the Contractors still have not

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6. Adequate precautions will be taken to prevent oil/lubricant/ hydrocarbon contamination of channel beds. Spillage, if any, will be immediately cleared with utmost caution to leave no traces. 7. Spillage waste will be disposed at disposal sites approved by local authorities and approved by PSCV. 8. All areas intended for storage of hazardous materials will be segregated and provided with adequate facilities to combat emergency situations complying with all the applicable statutory requirements. 9. The Contractor shall identify named personnel in the CEMP in-charge of these sites and ensure they are properly trained to control access to these areas and entry will be allowed only under authorization.

complied with this requirement. The leaking oil tank at Km 97+400 has not been repaired or removed by the Contractor.

• The PSC required the Contractor to either replace or remove the tank. Proper storage and management of hazardous substances and hazardous waste disposal will be a focus of the follow-on environmental management training by the PSC in July 2019.

10

Asphalt plant rock crushers, bitumen usage and soil contamination

Avoid air pollution, nuisances, traffic obstacles and contamination

1. Locate asphalt plant, rock crushers and bitumen supply off road and (wherever practicable) at least 500m from nearest sensitive receivers and rivers.

2. Locate asphalt plant rock crushers and bitumen supply on sealed surfaces to prevent soil contamination, off road and (wherever practicable at least 500m from nearest sensitive receivers) and install and maintain dust suppression equipment.

3. Bitumen should not be used as fuel. Fuel wood not for bitumen heating. Bitumen drums stored in dedicated area not scattered along 2NGMSTNIP road.

4. Bitumen will not be allowed to enter either running or dry streambeds and nor will be disposed of in ditches or small waste disposal sites prepared by the contractor. 5. Bitumen storage and mixing areas shall be protected against spills and all contaminated soil must be properly handled according to applicable national and local laws and regulation. As a minimum, these areas

FC FC PC • The Contractor of Package 2.2 has installed an asphalt plant and the location is far from water bodies, on level ground and far from residential areas.

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must be contained, such that any spills can be immediately contained and cleaned up. Any petroleum products used in the preparation of the bitumen mixture must also be carefully managed to avoid spills and contamination of the local water table. 6. Fuel wood shall not be used for heating bitumen and bitumen shall be not used as fuel. 7. Bitumen drums shall be stored in a dedicated area, not scattered along the works 8. All accidental spills of bitumen or chemicals should be cleaned up immediately with the top 2cm of any contaminated soil underneath and disposed of as chemical waste to a site approved by the local authority. 9. Prevent soil contamination requiring contractors to instruct and train their workforce on storage and handling of materials and chemicals that can potentially cause soil contamination. 10. Recycle debris generated by dismantling of existing pavement subject to the suitability of the material. 11. Solid waste generated during construction and at campsites to be treated and safely disposed only in demarcated waste disposal sites identified and agreed with PSCV/PMU-TL and the local community.

11

Noise and dust nuisances

To minimize air impacts effectively and avoid complaints due to the airborne dust.

1. Update the Noise and Dust control plan NDCP before construction (in CEMP). Include requirements for CONTOL NOISE and ALL DUSTY MATERIALS AT SOURCE. 2. Restrict works to daylight hours within 500m of residential settlements and hospitals. 3. PME and Vehicle emissions to meet national TCVN standards. 4. Monitor & investigate complaints; propose alternative mitigation measures. 5. Keep stockpiles moist and cover vehicles to prevent

PC PC PC • Noise and Dust Control are included in the approved CEMP of contractors.

• Contractors work only in the day. No works are being carried out at night.

• Contractors vehicles have certificate.

• The PSC carried out investigation of complaints against dust and cracks on houses from 28 June to 03 July 2019. A corrective action plan (CAP) was prepared to resolve the issues

• There were no stockpiles of spoils along the road. Excavated materials are removed from

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spillage, 6. Clean up road surfaces after work. 7. Ensure regular maintenance of equipment and provision of muffler silencers for all vehicles and equipment. 8. Temporary noise barriers shall be used, as necessary, in sites where sensitive receptors are present, such as residential areas, schools, hospitals, temples, etc. 9. To protect buildings and structures from vibration, non-vibrating roller shall be used in construction sites near buildings and structures. 10. Structures which are damaged due to vibration caused by the Project shall be repaired immediately as directed by PSCV. 11. Machinery shall be turned off when not in use. 12. Pile driving during to be schedule for daytime if construction site is near sensitive receptors or approved by DONRE, local authority and PSCV. 12. PSCV shall undertake monitoring of TSP and noise at the locations of justifiable complaints and compare to stations which were sampled during pre-construction phase to validate complaints.

sites immediately. Contractors cover their trucks when passing through residential areas

• Some residents complained about excessive dust. Contractors carry out watering but not sufficient during the very hot days.

• In Package 2.1, there are 24 claimants against cracks on houses, in Package 2.2, there are 83 claimants. The Contractors have entered into agreement with Insurance Companies to cover for the claims against damages. The insurance companies have formed teams to assess the damages and some houses have been visited but there is no official report and agreement with house owners on compensation yet.

• Machineries are turned off when not in use

• Construction of foundations are done in daytime.

• The PSCV carried our monitoring of TSP and noise on 27-29 May 2019. The results indicated that the Vietnamese regulations on noise and TSP are not exceeded in any sampling site.

12

Blasting (if required)

Perform safe blasting and prevent damage and nuisances from blasting

1. PDCV will be reviewed requirements for blasting at the detailed design

If required

2. Contractor to review requirements for blasting in CEMP.

3. Blasting will be carried out as per Vietnamese statutory requirements with notification to DONRE and local police.

4. Blasting plan will be included in CEMP.

NA NA NA Blasting is not required

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5. No blasting will take place without condition survey of the buildings within 500m and permission and monitoring by the PSCV.

6. People living near blasting sites will be informed of blasting times prior to the blasting.

7. Warning sirens will be sounded before blasting.

8. Pre-splitting should be undertaken.

9. Blast blankets will be laid over the blast area to reduce flying rock

10. Where the vibration from blasting is exceeding the maximum permissible level, or damage occurs to local property information from the blasting should be used to modify blasting patterns and calculate a reduced charge for future blasts

11. Blasting will not be undertaken at night.

12. Workers at blasting sites will be trained prior to blast operations and provided with safety equipment and earplugs.

13

Erosion control / run-off

Protect established works.

1. Update the draft Erosion Control Plan (ECP) produced by the PDCV and implement slope stabilization measures in the detailed designs and maintained during construction to protect the works. 2. Establish vegetation & erosion protection immediately after completion of works in each stretch / sector. 3. Check weather forecasts and minimize work in wet weather and. 4. Stockpile topsoil for immediate replanting after cutting. 5. Minimize damage and cutting of surrounding vegetation during slope formation. 6. Protect the cut slope with planted vegetation, bioengineering or conventional civil engineering structures as soon as practicable after cutting.

PC PC PC • In May and June 2019, several houses and 3.5ha of rice fields have been flooded or affected by soil/stones sliding from slopes of completed embankments in some road sections, particularly at Package 1.0 and Package 2.1. The issue in Package 1.0 has been resolved and the affected communities are satisfied with the mitigating measures carried out by the Contractor. In Package 2.1, the affected commune PCs requested the PMU-TL to relocate some drainage ditches and construct culverts in other locations. The PMU-TL and PSCV are reviewing and studying the requests.

• Some good practices to control erosion such as benching or terracing and immediate transport

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7. Include and implement appropriate measures for slope protection, i.e. vegetation cover and stone pitching, as required in the detailed construction drawings. 8. Prevent erosion and protect the cut slope with temporary or permanent drainage as soon as practicable after cutting. 9. If new erosion occurs accidentally, back fill immediately to restore original contours. 10 Low embankments will be protected from erosion by seeding and planting indigenous grasses that can flourish under local conditions. 11. High embankments, i.e. 2m high and above, will be considered for protection by constructing stone pitching or a riprap across the embankment immediately after the works are completed. This practice will also be applied along cross-drainage structures where embankments are more susceptible to erosion by water runoff. 12. Payments will be linked to the completion of the works as indicated by the installation of erosion control measures to protect the works to the satisfaction of PSCV/PMU-TL.

of soil materials from excavation area were noted in some sites.

14

River protection and bridge repair

Protect rivers and maintain river flow

In sections along and near rivers and streams: 1. Rocks and stones will be disposed not to block rivers and streams. 2. In bridge repair and demolition sites, the bridge structure will not be dropped into the river, but alternative means will be used to avoid "dropping the bridge" into rivers/streams. This will be done by "sawing" appropriate sections of the bridge and using cranes to lift these sections away or alternatively by construction of a platform onto which the bridge could be lowered. 3. Cofferdams, silt fences, sediment barriers or other

FC FC FC • No issues relating to improper disposal or placement of materials in rivers near the project sites were observed during this period.

• No issues relating to contamination or damage to riverine areas have been reported.

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devices will be used as appropriate based on the design to prevent migration of silt during excavation and boring operations within streams. If cofferdams are used, these will be dewatered and cleaned to prevent siltation by pumping from cofferdams to a settling basin or a containment unit. 4. Other erosion control measures above and covering open surfaces with grasses and creepers to reduce runoff will be implemented as early as possible in construction.

15

Water quality

Prevent water quality impacts due to negligence and ensure unavoidable impacts managed effectively.

1. Store of lubricants, fuels in dedicated enclosures >50 m from water bodies. 2. Dispose solid waste from construction activities (NO BURNING) in line with SWMP in CEMP. 3. Covering materials to reduce run-off. 4. No stockpiling or borrow sites < 50m of water body. 5. Monitor and investigate water quality if complaints occur. 6. Work in rivers will be scheduled during dry season and work duration shall be as short as possible. 7. Immediate stabilization of bare slopes shall be undertaken. 8. Construction storage/stockpiles shall be provided with bunds to prevent silted run-off. 9. Stockpile areas and storage areas for hazardous substances shall be located away from water bodies. 10. Washing of machinery and vehicles in surface waters shall be prohibited. 11. In response to complaints water quality measurements will be taken (by PSCVL/TSD) 50m before (upstream) and 50m after (downstream) the bridges at in line with the methodology used in for baseline sampling and impacts determined by reference to the baseline results.

FC FC FC • The Contractors’ storage areas for materials, lubricants and fuels are more than 50m from existing water bodies.

• Camps are mostly rented houses provided with sanitary toilets with septic tanks for primary treatment of wastewater and these camps are located away from rivers or creeks.

• No solid wastes, including spoils are disposed in drainage, creeks or rivers.

• There were no stockpiles of soil or borrow sites near water bodies.

• Washing of machinery and vehicles in rivers is prohibited. There were no reports or complaints related to impacts of the project on any water body during this period.

• There were no observed impacts on water quality in the rivers this period.

• There were no complaints related to water quality this period

16 Water Reduce damage 1. Use water without depleting local village supplies FC FC FC • The Contractors have rented houses for camps

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resources to riverbed and irrigation network.

assess water availability and evaluate the impact on community resources. 2. Bring in project water by tanker as necessary. 3. Worker camps will be located >500m from the nearest settlement to prevent the contamination of community-owned water resources. 4. Maintain close liaison with local communities to ensure that any potential conflicts related to common resource utilization for project purposes are resolved quickly. 5. Guidelines will be established to minimize the wastage of water during construction operations and at campsites. 6. Avoid and minimize use of riverbed for construction materials. 7. Confine winning river materials to 20% of river width in any location and keep away from riverbanks. 8. Reinstate riverbanks if necessary. 9. Re-provision irrigation channels affected by works two weeks before commencement of works to satisfaction of TSD and local community. 10. All irrigation canals along the alignment shall be clearly marked on the ground to prevent accidental dumping of fill materials into these canals. 11. In case of accidental obstruction or damage, irrigation ditches and ponds shall be cleaned or repaired immediately.

and erected their fabrication yards away from existing creeks or rivers.

• The site of the cement batching plant and asphalt plant of Package 2.2 is far from any water body.

• No stockpiles of sand, aggregates or rock materials were stored near a river or any water.

• No trash, solid wastes, spoils or liquid wastes were reported to have been disposed on any water body and there are no visible signs of contamination of water bodies near the project sites due to project construction activities.

• No complaint related to water resource contamination or unauthorized use was received during this period.

17

Site Agent / Supervisor /Worker Camp canteen and facilities.

Worker facilities not to cause nuisance or exploit forest of wildlife resources.

1. Worker camp location and facilities located >500m from settlements and agreed with local communities and facilities approved by PSCV and TSD and managed to minimize impacts. 2. Construction camps will be established in areas with adequate natural drainage channels to facilitate flow of the treated effluents. 3. Hire and train as many local workers as possible

FC FC FC • The Contractors generally rent local peoples’

houses for their laboratories, field offices and workers camps.

• Most workers come from the communes within the project sites, thus the requirement for accommodation is limited to engineers, heavy equipment operators, and other skilled workers

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4. Portable lavatories (or at least pit latrines in remote areas) shall be installed and open defecation shall be discouraged and prevented by cleaning lavatories daily and by keeping lavatory facilities always clean. 5 Wastewater effluents from contractors’ workshops and equipment washing yards will be passed through gravel/sand beds and all oil/grease contaminants will be removed discharging it into natural streams. Oil and grease residues shall be stored in drums awaiting disposal in line with the agreed Waste Management Plan. 6. Predictable wastewater effluent discharges from construction works shall have the necessary permits from DONRE and local authorities before the works commence. 7. Borrow pits and natural depressions with pre-laid impervious liners will be used to dispose of scarified/scraped asphalt, and then covered with soil. This will check potential groundwater contamination. 8. Options for completely or partially recycling scraped scarified materials will also be considered. 9. Food shall be provided from farms nearby and bush meat supplies will be banned to discourage poaching. 10 Ban use of guns and hunting equipment by workers and dismiss workers taking or using green timber or hunting or in possession of wildlife. 11. Camp site will be cleaned up to the satisfaction of TSD and local community after use. 12. Solid and liquid waste will be managed in line with Waste Management Plan. 13 All waste materials shall be removed and disposed to disposal sites approved by local authorities 14. Land used for campsites shall be restored to the original condition as far as practicable and the area shall be planted with appropriate trees / shrubs as soon

who live in far cities or provinces.

• All the field offices, laboratories and camps are in good condition and provided with basic facilities such as drinking water, domestic water supply, latrine with two-chamber septic tanks, bunk beds, and kitchen/dining areas.

It was observed that the Contractors have not provided portable toilets at places where works are being carried out. In letters (B.09-Package HW217-1, C081.1 Package HW217-2-1 and D.100-Package HW217-2-2) the PSC required the Contractors to provide portable toilets (separate for male and female workers) where works are being carried out, especially where there is concentration of workers. The Contractors have not provided portable toilets.

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as practicable after it is vacated and cleaned.

18

Sanitation and Diseases

Control of infectious diseases.

1. Standing water will not be allowed to accumulate in the temporary drainage facilities or along the roadside to discourage mosquitoes. 2. Temporary and permanent drainage facilities will be designed to facilitate the rapid removal of surface water from all areas and prevent the accumulation of surface water ponds. 3. Malaria controls and HIV-AIDS education will be Implemented in line with social plans for the project. 4. HIV/AIDS awareness and prevention program shall be implemented in line with social plans under the Project

PC PC PC • All offices, laboratories and camps are in good, sanitary condition during this period. Housekeeping at the camp and fabrication yard of Package 2.2 at Km97+900 has improved compared to the past months. Housekeeping at the fabrication yard of Package 1.0 has also improved although burning of waste has been observed in this site.

• The HIV/AIDS awareness and program has been approved and activities are being carried out in accordance with the approved plan. HIV/AIDS training was conducted on 25 June 2019. Surveys and data gathering activities have started from March 2019.

19

Safety Precautions for the Workers and first aid.

Ensure worker safety.

1. Contractor updates Worker and Public Safety Plan (WPSP) and instructs workers in health and safety matters. 2. Establish safety measures as required by law and by good engineering practice and provide first aid facilities (CEMP). 3. Fencing on all excavation, borrow pits and sides of temporary bridges 4. Workers shall be provided with appropriate personal protective equipment (PPE) such as safety shoes, hard hats, safety glasses, ear plugs, gloves, etc. at no cost to the employee. 5. The contractor shall orient workers on health and safety issues related to their activities as well as on the proper use of PPE. 6. Where worker exposure to traffic cannot be eliminated, protective barriers shall be provided to shield workers from traffic vehicles. Another measure is to install channeling devices (e.g., traffic cones and

NC NC NC • The Contractors have not assigned full-time

safety officers to ensure worker and public safety.

• Unsafe conditions such as lack of proper storage area for fuel, electric wires on the ground, and unsafe electrical cables have been observed in some sites, particularly at the fabrication areas of Package 1.0 and Package 2.2.

• First aid supplies in most camps are either lacking or insufficient. Most workers have not worn PPE. Safety training for workers should be strengthened.

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barrels) to delineate the work zone. 7. Workers shall be provided with potable water supply. 8. Construction camps shall be provided with adequate drainage to avoid accumulation of stagnant water. 9. Construction camps shall be provided with toilets/sanitation facilities in accordance with local regulations to prevent any hazard to public health or contamination of land, surface or groundwater. These facilities shall be well maintained to allow effective operation.

20

Traffic and Public safety

Prevent accident with public in local community

1. Include in WPSP for barriers (e.g., temporary fence), shall be installed at construction areas to deter pedestrian access to the roadway except at designated crossing points. 2. The public/residents shall not be allowed in high-risk areas, e.g., excavation sites and areas where heavy equipment is in operation and such sites have a watchman to keep public out. 3. Speed restrictions shall be imposed on Project vehicles and equipment when traveling within 50m of sensitive receptors (e.g. residential, schools, temples, etc.). 4. Upon completion of construction works, borrow areas will be backfilled or fenced.

PC PC PC • All contractors have set up bold diversion signs that would be clearly visible even at night and provide flag persons to warn of dangerous conditions (along the construction sites).

• “Advance Warning Signs” are not equipped at each section of the construction site. No bamboo posts and tape ribbon around obstructions, culverts, working areas.

• There are critical areas where traffic management measures should be strengthened such as at the borrow areas at, Km92+400 and Km104, and cut areas at Km79+100 and Km84+000.

• The excavation works at Km84+000 is immediately after a bend and is partly hidden from view. Reflectorized warning sign boards indicating heavy equipment crossing, that construction works are ongoing, and that there is hazard of falling materials, should be placed at strategic locations at least 20m before the sites to forewarn the motorists and pedestrians of the potential hazards.

• Cut areas adjoining the roadway should also be provided with temporary drainage ditches to convey runoff and to catch sliding soil that makes the road

slippery when wet.

21 Archaeological Preservation of 1. Site agents instructed to keep a watching brief for NA NA NA • There were no archaeological and cultural

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and cultural artifacts.

chance finds of cultural and archaeological relics. identified during construction

relics 2. Should any potential items be located, the site PSCV will immediately be contacted and work will be temporarily stopped in that area. 3.. If the site supervisor determines that the item is of potential significance, an officer from the Department of Culture and Information (DCI) will be invited to inspect the site and work will be stopped. 4. Until DCI has responded to this invitation work will not re-commence in this location until agreement has been reached between DCI and DOR as to any required mitigation measures, which may include excavation.

artifacts found during excavation or construction activities during this report period. If such archaeological or cultural relics are found in the future, this will be reported to with the People’s Committee for proper disposition.

22

Enhancements

Provide environmental enhancement of the project

Contractor to reconfirm and implement enhancements identified at the detailed design stage and included in the updated EMP.

NA NA NA Construction activities are still ongoing; thus, enhancement works such as grassing or tree planting are not yet undertaken. Enhancements will be carried out when some areas are ready for such enhancements.

62

Appendix 2: Contract with insurance company

1) Construction risk insurance contract of bidding package 1.0

66

2) Construction risk insurance contract of bidding package 2.2

77

3) Certificate of compulsory insurance in construction investment activities of package 2.1