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E2100
V1
b
Preparation for PCB Management
and Disposal Demonstration Project
in Vietnam – CS6 “Environmental
Impact Assessment”
Environmental and Social
Framework Report
Vietnam Electricity (EVN)
11/004382
Final Report
Vietnam Electricity September 2008
18 Tran Nguyen Han Street
Hanoi
VIETNAM
Project funded by:
ARCADIS Belgium Content
11/004382 - EIA PCB Management Demonstration Project Vietnam
CONTENT
CONTENT .................................................................................................................................... I
LIST OF FIGURES .................................................................................................................... III
LIST OF TABLES .........................................................................................................................V
EXECUTIVE SUMMARY ............................................................................................................... I
1 CONTEXT, SCOPE AND OBJECTIVES ................................................................................. 1
2 POLICY ASSESSMENT WITH RESPECT TO PCB MANAGEMENT AND DISPOSAL ............... 3
3 IMPACT ASSESSMENT PROCEDURE ................................................................................ 11
4 PROJECT DESCRIPTION ................................................................................................. 29
5 ANALYSIS OF POTENTIAL IMPACTS (SCOPING) ............................................................ 49
6 ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT METHODOLOGY ....................... 57
7 COMPARISON OF ALTERNATIVES................................................................................... 79
8 ENVIRONMENTAL AND SOCIAL MANAGEMENT AND MONITORING PLAN ..................... 81
9 RESULTS PUBLIC CONSULTATION MEETINGS .............................................................103
10 KNOWLEDGE GAPS AND UNCERTAINTIES IN ASSESSMENT ........................................113
11 REFERENCES .................................................................................................................115
APPENDICES ..........................................................................................................................117
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ARCADIS Belgium List of figures
11/004382 - EIA PCB Management Demonstration Project Vietnam
LIST OF FIGURES
Figure 2-1: Flow chart public stakeholders involved directly in PCB management at local and national
levels (source: ECD, 2008) .................................................................................................................. 5
Figure 3-1 World Bank Environmental Assessment requirements versus project cycle ........................... 13
Figure 3-2: Selection of Social Analysis Study Methods and Tools ........................................................ 16
Figure 3-3: Presentation of EIA approval procedure ............................................................................ 22
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ARCADIS Belgium List of tables
11/004382 - EIA PCB Management Demonstration Project Vietnam
LIST OF TABLES
Table 2-1: Overview of authorities involved in the different aspects of the PCB lifecycle .......................... 4
Table 3-1: Guidance on screening procedure and disciplines covered in site specific impact assessments
on PCB management, disposal and remediation .................................................................................. 25
Table 4-1: Matrix of pre-treatment and treatment techniques .............................................................. 37
Table 5-1: Scoping for potential impacts related to presence, management, transportation and storage of
PCB containing materials ................................................................................................................... 50
Table 5-2: Scoping for potential impacts related to treatment, disposal and site remediation. ................ 52
Table 6-1: Standards and guidelines for air quality (WHO, 2000, TCVN 5937,2005) .............................. 63
Table 6-2: Guideline values for community noise in specific environments (WHO, 1995) ....................... 63
Table 6-3: Emission factors for PCB emissions (Annema et al, 1995) .................................................... 66
Table 6-4: Emission factors for traffic and construction activities (g/km) (USEPA, 1995) ........................ 66
Table 6-5: Sound power levels LW for different noise sounds .............................................................. 67
Table 6-6: Assessment criteria relevant for soil ................................................................................... 71
Table 6-7: Assessment criteria relevant for groundwater ..................................................................... 71
Table 6-8: Water quality standards and guidelines .............................................................................. 73
Table 6-9: Industrial waste water: Vietnamese limits of Parameters and Maximum Allowable
Concentrations of Pollutants .............................................................................................................. 74
Table 6-10: Geometric mean values for the 50 % effect concentration (L(E)C50), for the lowest observed
effect concentration (LOEC) for the No Observed effect concentration (NOEC) for PCBs in the aquatic
environment (Callebaut and Vanhaecke, 2000) ................................................................................... 77
Table 6-11: PCB standards and guidelines related to human health .... Error! Bookmark not defined.86
Table 8-1: Overview of typical mitigation measures and monitoring for activities related to PCB
management .................................................................................................................................... 87
Table 8-2 Overview of typical mitigation measures and monitoring related to PCB treatment and disposal
....................................................................................................................................................... 97
Table 9-1: Public Consultation During The EA Process ....................................................................... 104
Table 11-1: Policy Needs Assessment - Summary Table (Breeze and Associates, 2007a) ..................... 139
v
ARCADIS Belgium List of abbreviations
11/004382 - EIA PCB Management Demonstration Project Vietnam
LIST OF ABREVIATIONS
BCD Base catalysed decomposition process
BOD Biological Oxigen Demand
CO Carbon Monoxide
CO2 Carbon Dioxide
COD Chemical Oxigen Demand
CV Civil servant in charge of environmental protection
DIONRE Division of Natural Resources and Environment
DoC Department of Construction
DOH Department of Health
DOIT Department of Industry and Trade
DOLISA Department of Labor, Invalid and Social
DoNRE Departments of Natural Resources and Environment
DOPS Department of Public and Security
DOST Department of Science and Technology
DTPW Department of Transportation and Public Works
EA Environmental Assessment
EF Emission Factor
EIA Environmental Impact Assessment
EMP Environmental management plan
EPC Environmental Protection Commitment
EPD Environment Police Department
ESMP Environmental and Social Management Plan
EVN Vietnam Electricity
GEF Global Environmental Facility
GDOC General Department of Customs
GPCR Gas Phase Chemical Reduction
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ARCADIS Belgium List of abbreviations
11/004382 - EIA PCB Management Demonstration Project Vietnam
HW hazardous waste
IA Impact Assessment
KOC Partition coefficient octanol-water
LEC50 50% effect concentration
LEP Law on Environmental Protection
LOEC Lowest observed effect concentration
LTTD Low temperature thermal desorption
LW Sound power level
MoC Ministry of Construction
MoH Ministry of Health
MOIT Ministry of Industry and Trade
MOLISA Ministry of Labor, Invalid and Social
MoNRE Ministry of Natural Resources and Environment
MOPS Ministry of Public and Security
MoST Ministry of Science and Technology
MoSTE Ministry of Science, Technology and Environment
MoTr Ministry of Transportation
N Nitrogen
NIP National Implementation Plan Stockholm Convention
NOEC No observed effect concentration
NOx Nitrogen oxides
NSEP National Strategy for Environmental Protection
P Phosphor
PCB Polychlorinated Biphenyl
PCDD Polychlorinated Dibenzodioxins
PCDF Polychlorinated Dibenzofurans
PCE Perchloroethylene
PEL Permissible exposure limit
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ARCADIS Belgium List of abbreviations
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PM10 Particulate Matter of 10 Microns in diameter or smaller
POP Persistent Organic Pollutant
PPC Provincial People’s Committee
SA Social Assessment
SO2 Sulfur dioxide
SS Suspended Solids
SVE Soil Vapour Extraction
SW Solubility coefficient in water
TCB Trichlorobenzene
TEF Toxic Equivalent Factor
TEQ Toxicity Equivalent
TiO2 Titanium Dioxide
TLV Tolerance Limit Value
TSP Total Suspended Particles
VEA Vietnam Environment Administration
WAO Wet air oxidation
WB World Bank
WHO World Health Organisation
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ARCADIS Belgium Executive summary
11/004382 - EIA PCB Management Demonstration Project Vietnam
EXECUTIVE SUMMARY
The last decades Vietnam has experienced a rapid industrialisation and a very important economic
development. This has resulted in the generation of an increasing amount of industrial waste including
hazardous and toxic waste. In particular POPs, including PCBs, create a hazard for human health and for
environmental safety.
In Vietnam, the presence of PCBs in the environment is resulting from the import of dielectric fluids
contained in transformers, capacitors and other electrical equipment. Being aware of the risks to human
health and ecosystems, Vietnam ratified the Stockholm Convention in July 2002, committing to reduce
and eventually eliminate 12 POPs, including PCBs. Under this convention, Vietnam is bound to phase out
the use of equipment containing PCBs by 2020 and to treat the contained PCBs by 2028. The Ministry of
Natural Resources and Environment (MONRE) is the leading agency overseeing the preparation and the
implementation of the countries National Implementation Plan for the Stockholm Convention. Within
MONRE, Vietnam Environment Administration (VEA) has been designated as the agency to implement
POP activities.
At present Vietnam does not have a functioning system to safely transport and store PCB containing
materials. Neither is there adequate treatment and disposal potential. Major progress has to be made to
achieve the goals set forward by the Stockholm Convention and as such to minimize the risks for human
health and environment.
Within this framework the PCB management demonstration project has been developed, supported by
the World Bank and the Global Environment Facility. The project aims to assist Vietnam to establish a
sound PCB management system that would minimize potential environmental and health risks from
unmanaged PCB oils and equipment. This would entail significant investment in PCB management
infrastructure and strengthening of limited technical and management capacity of all key stakeholders
including the public and private sectors in Vietnam. The project will develop a National Action Plan for
Sound PCB Management and initiate implementation of the first phase of the Action Plan. It is obvious
that this project, aiming at better PCB management of PCB equipment and wastes, will ultimately
generate positive environmental and social impacts. Improper management of PCBs could however lead
to negative environmental and social impacts and therefore is subject to an environmental and social
impact assessment.
The objective of this EA and SA framework report is to prepare an environmental and social assessment
framework to assess all potential environmental and social impacts associated with the activities of the
PCB project on the one hand and to identify proper measures to mitigate such impacts on the other
hand; this framework covers the full spectrum of PCB management and disposal issues including
transportation and storage, treatment, disposal or recycling and site remediation. It is intended to allow
a better management of PCBs taking into account all environmental and social/human health issues.
Next to this it should be a reliable framework for the preparation of project EIAs necessary for specific
PCB management projects in Vietnam.
PCB management activities with potential environmental and social impacts are diverse and include:
identification of PCB-containing products and equipment;
testing PCB content of products and oils;
labelling of PCB-free and PCB-containing equipment and waste;
packaging and collection of PCB-waste;
transportation of PCB-waste;
temporary storage of PCB-waste;
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recycling.
A scoping of potential impacts related to PCB management is summarised in the table below.
Table 1: Potential impacts related to PCB management
Impact Presence Testing Handling oils, Replacement, Temporary Transpor-
of PCB equipment materials and retro filling, (final) tation
containing waste recycling storage
materials (packaging,
labelling)
Water and aquatic resources
Groundwater X (X) X X X (X)
contamination
Surface water X (X) (X) X X (X)
contamination
Soil and waste
Soil contamination X (X) X X X (X)
Waste production X X x
Climate, air and noise
Air emissions of X X (X)
POPs
Dust formation (X) (X)
Noise production (X)
Ecosystems
Loss of ecological X (X)
valuable areas
Ecotoxicity to X X X X
terrestrial life
Ecotoxicity to X (X) X X
aquatic life
Land use
Land use change X
Losses of sites X
with
archaeological,
historical and
cultural value
Man and his social economic living environment
Direct health risks X (X) X X X (X)
(direct exposure)
Indirect health risk X X X X
Nuisance (dust, (X)
noise)
Social effects X X X
(resettlement)
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Impact Presence Testing Handling oils, Replacement, Temporary Transpor-
of PCB equipment materials and retro filling, (final) tation
containing waste recycling storage
materials (packaging,
labelling)
Social effects X (X)
(employment)
X Potential environmental impact
(X) Potential environmental impact not likely to occur
PCB treatment and disposal activities have potential environmental and social impacts as well. Only
treatment techniques likely to be applied in Vietnam are described in this framework report. Other
techniques will not be subject to EIA in Vietnam. The following techniques are covered:
pre-treatment techniques:
- dewatering,
- electrical equipment disassembly,
- shredding,
- screening,
- oil/water separation,
- pH adjustment,
- low temperature thermal desorption,
- solvent washing,
- adsorption/absorption;
alkali reduction including sodium;
base catalysed decomposition process;
gas phase chemical reduction;
cement kiln co-processing;
plasma arc decomposition;
wet air oxidation;
site remediation techniques:
- soil washing,
- thermally enhanced soil vapour extraction,
- soil flushing,
- in situ vitrification,
- TiO2 enhanced photocatalysis.
A scoping of potential impacts related to PCB management is summarised in Table 2.
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Table 2: Potential impacts of PCB treatment and site remediation
Impact Reduction Oxidation Combustion/ Site
destruction treatment incineration Remediation
method
Water and aquatic resources
Groundwater contamination X (X) X
(ground)water use X X X
Surface water contamination X X X X
Soil and waste
Soil contamination, X (X) X
Waste production (X) X X (X)
Climate air and noise
Air emissions X X X X
Dust formation (X) (X) X (X)
Noise production X X X (X)
Smell (X) X X
Ecosystems
Loss of ecol. valuable areas X (X) X
Ecotoxicity to terrestrial life X X X (X)
Ecotoxicity to aquatic life X X X X
Land use
Land use change X (X) X (X)
Landscape alteration X X X
Losses of sites with archaeological, (X) (X) X
historical and cultural value
Man and his social economic living
environment
Direct health risks (direct exposure) X X X (X)
Indirect health risk X X X (X)
Nuisance (noise, visual effects, X X X (X)
traffic,…)
Social effects (resettlement) (X) (X) X
Social effects (economic/employment) (X) X X
Social effects (transport) X X X
Social effects (use of resources) (X) X X (X)
X Potential environmental impact
(X) Potential environmental impact not likely to occur
Several projects, planned and implemented in the framework of the overall PCB management program,
will be subject to environmental and social impact assessment. Methodology and an overview of
information needed to prepare an EIA are discussed below.
A profound project description is the first essential part of an EIA. It comprises the following
components:
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General description of the project in the study area:
- A geographical map (at least 1/10 000) showing the exact location of the project and the
exact project area,
- A general description of the surroundings of the project,
- A description and map of the topography of the surroundings,
- The administrative situation (owner, available permits),
- The on-site infrastructure proposed;
Description of the pre-construction and construction phase:
- An overview of the different phases and the timing for the project,
- A description of the consecutive activities during construction:
preparation works i.e. excavation, pumping of groundwater, removal of soil,
building activities,
transport needs for the construction,
development of temporary settlements,
- The use of resources and waste production to be expected;
Description of the operational phase including the actual performance of the plant:
- Description of the PCB containing equipment to be managed or treated (kind of
equipment, volume of PCB content, type and concentration of PCB’s),
- Description of historic experiences concerning the PCB equipment: leakages, other
accidents,
- Description of the operations and handling foreseen on the location (i.e. sampling,
labelling, packaging, recycling, retro filling) and description of the way the operations will
be carried out,,
- Description of the (preventive) measures already foreseen to prevent pollution
- Description of the way transport will be carried out: type of trucks, packaging, preventive
measures foreseen, quantity to be transported,
- Description of the storage facilities: type of construction, storage conditions, preventive
measures foreseen, quantity to be stored, packaging,
- Description of the pre treatment techniques used: process description, capacity foreseen
per day and per year, operation time schedule, acceptation procedure for PCB
equipment,
- Description of the treatment and/or disposal techniques: process description,
treatment/disposal capacity, regime (continuous flow versus batch), operation time,
acceptance procedure,
- Presence of groundwater extraction on site and in the immediate surroundings (number
of wells, depth of extraction well, results regarding water quality, capacity, …),
- Kind of surface covering, presences of impermeable paving, …,
- Existing procedures in the case of the occurrence of accidents, spill procedures,
- Transport activities linked to (pre) treatment and disposal: transportation needs
(quantities) and mode, numbers of vehicles per day and per year,
- Utilities linked to treatment and disposal units: description of energy supply, description
of equipment or measures to prevent/treat possible environmental pollution: water
treatment unit, air purification equipment,
- The sound power level and the use pattern of equipment and utilities to be used for (pre)
treatment,
- Description of the storage needs associated with the treatment and disposal units:
storage capacities needed for each type of product; storage quantities per year;
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description of the storage facilities: size, measures foreseen to prevent pollution, storage
conditions,
- Quantification and description of the origin and use of resources: water supply
(groundwater, surface water, …) energy supply (including energy carrier: gas, coal, …),
- Quantification of the use of materials and chemicals,
- Estimation of the waste production: description of the quantities of different types of
waste expected to be produced, description of the storage facilities for waste, the waste
management and the final fate of each of the different types of waste,
- Description of the different sources for emissions and waste water production: expected
and maximum allowed flow rate, temperature and composition of the off gasses;
characteristics of the emission point (stack) i.e. height, diameter; flow rate and
characteristics of the waste water (i.e. temp, COD, BOD, N, P, SS, …).
Once this project description has been completed, environmental and social impacts can be described
and assessed. Impact description and assessment is divided into several disciplines:
Air, climate and noise;
Soil and groundwater;
Water and aquatic resources;
Fauna and flora;
Land-use, landscape and archeological, historical and cultural values;
Man and his socio-economic living conditions.
For each discipline the following aspects are described:
Data and information needed:
Emission data:
Identification of emission sources
Quantification of emissions (measurements, emission factors)
…
Data on baseline situation:
Actual air, water, soil, … quality;
Climatological, geological, hydrological, … conditions
…
Assessment criteria
Standards and guidelines
Background values
…
Information sources:
Vietnamese legislation and agencies
Monitoring data
Field information
Sampling
…
Assessment methodology and criteria, e.g.:
Determining relevant impacts
Comparing impacts to available standards, guidelines, …
Evaluating impacts
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A well structured EIA follows a fixed structure throughout each discipline:
Description of the baseline situation;
Evaluation of the actual situation in relation to the assessment criteria;
Determination of the contribution of the project to the environmental quality;
Prediction and description of the environmental situation to be expected in the presence of the
project;
Evaluation of the importance of the environmental impact to be expected.
In an environmental and social impact assessment, the possible alternatives have to be evaluated. The
following types of alternatives should be considered:
the zero alternative: this is the evolution of the present situation without the PCB project being
implemented;
the alternative with the planned situation if the project is carried out.
For the latter several alternatives or scenarios may be studied i.e.:
location alternatives: comparison of different possible locations for the project to be carried out;
technical alternatives: comparison of different techniques/processes/methodologies to carry out
the project.
In order to be able to compare the different alternatives studied the principles of multi-criteria analysis
have to be applied. To that aim – for standardisation and comparison reasons - all impacts are classified
according to the following schedule:
0 No effect
+ Slight positive effect: this is an improvement of the existing situation for a specific impact
with limited magnitude, extent and significance
++ Moderate positive effect: this is a significant improvement of the existing situation for a
specific impact leading to surpassing the criteria used and characterised by a clear
magnitude or extent
+++ Highly positive effect: this is a significant effect with an important magnitude and extent
- Slight negative effect: this is a deterioration of the situation for a specific impact without
surpassing the criteria set; the impact can generally by mitigated and is reversible or
limited in extent and magnitude
-- Moderate negative effect: this is a deterioration of the situation for a specific impact giving
raise to surpassing the criteria used: it is characterised by a clear magnitude or extent,
however mitigation may lower the effect
--- Highly significant negative effect: this is a significant deterioration of the situation for a
specific impact characterised by a large magnitude and extent
---- Very important negative effect: this is a significant deterioration of the situation for a
specific impact characterised by a large magnitude and extent and irreversible in nature
without mitigation possibilities
In that way the impacts from different nature are brought into one scale which will allow mutual
comparison. In order to evaluate the relative importance given to the different environmental issues,
valuation factors are proposed. This may be agreed upon between the group of experts involved in
carrying out the EIA. It is to be advised however that the major stakeholders are involved in valuating
the environmental issues since they are supposed to be well aware of the project and local sensitivities.
In the particular case of the PCB project it is proposed that EVN, DONRE, VEA and one NGO are involved
in the evaluation and identification of the valuation factors.
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Once the valuation factors have been attributed, the impact assessment score has to be multiplied by the
valuation factor for each impact. The valuated scores obtained in this way are to be added up to come
to a total environmental score. The alternative with the lowest (negative) score is then ranked to be the
alternative having the smallest environmental effect. However, the comparison also has to be subject of a
qualitative discussion and interpretation.
Next to the project description, assessment of potential impacts, and comparison of alternatives, an EIA
also contains an environmental management and monitoring plan. This plan consists of a set of
mitigation, monitoring, and institutional measures to be taken during implementation and operation of
the project. The aim is to eliminate adverse environmental and social impacts, offset them, or reduce
them to acceptable levels. The plan also includes the actions needed to implement these measures.
The environmental management and monitoring plan identifies feasible and cost-effective measures that
may reduce potentially significant adverse environmental impacts to acceptable levels. The plan includes
compensatory measures if mitigation measures are not feasible, cost-effective, or sufficient. The plan
includes following activities:
identifying and summarizing all anticipated significant adverse environmental impacts;
describing each mitigation measure, including the type of impact to which it relates and the
conditions under which it is required (e.g. continuously, in the event of contingencies), together
with designs, equipment descriptions, and operating procedures;
estimating any potential environmental impacts of these measures; and
providing linkage with any other mitigation plans if required for the project.
Environmental monitoring during project implementation provides information about key environmental
aspects of the project, particularly the environmental impacts of the project and the effectiveness of
mitigation measures. Such information allows corrective action to be taken when needed. Therefore, the
EMP identifies monitoring objectives and specifies the type of monitoring, with linkages to the impacts
assessed in the EIA report and the mitigation measures described in the EMP. The monitoring section of
the EMP provides:
a specific description and technical details of monitoring measures including:
the parameters to be measured;
methods to be used;
sampling locations;
frequency of measurements;
detection limits (where appropriate);
definition of thresholds that will signal the need for corrective actions; and
monitoring and reporting procedures to ensure early detection of conditions that necessitate
particular mitigation measures, and furnish information on the progress and results of mitigation.
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1 CONTEXT, SCOPE AND OBJECTIVES
The last decades Vietnam has experienced a rapid industrialisation and a very important economic
development. This has resulted in the generation of an increasing amount of industrial waste including
hazardous and toxic waste. In particular POPs, including PCBs, create a hazard for human health and for
environmental safety.
The presence of PCBs in Vietnam and its environment is resulting from the import of dielectric fluids
contained in transformers, capacitors and other electrical equipment. Based upon initial inventories it has
been extrapolated that the quantity of PCB contaminated oil amounts up to at least 13,000 tonnes
contained in about 18,600 transformers and 3,350 capacitors. PCB contaminated soil or small electrical
equipment is not included (SNC Lavalin 2007).
Being aware of the risks to human health and ecosystems, Vietnam ratified the Stockholm Convention in
July 2002, committing to reduce and eventually eliminate 12 POPs, including PCBs. Under this
convention, Vietnam is bound to phase out the use of equipment containing PCBs by 2020 and to treat
the contained PCBs by 2028. The Ministry of Natural Resources and Environment (MONRE) is the lead
agency overseeing the preparation and the implementation of the countries National Implementation Plan
for the Stockholm Convention.
Within MONRE, Vietnam Environment Administration (VEA) has been designated as the agency to
implement POP activities.
At present Vietnam does not have a functioning system to safely transport and store PCB containing
materials. Neither is there adequate treatment and disposal potential. Major progress has to be made to
achieve the goals set forward by the Stockholm Convention and as such to minimize the risks for human
health and environment.
Within this framework the PCB project has been developed, supported by the World Bank and the Global
Environment Facility. This project aims to assist Vietnam to establish a sound PCB management system
that would minimize potential environmental and health risks form unmanaged PCB oils and equipment.
It consists of five components:
PCB management framework and action plan,
PCB management demonstration;
Institutional strengthening;
Monitoring, Enforcement and Evaluation;
Project Management.
This implies the development of a management framework followed by demonstration activities to further
refine the PCB management system.
The project will be dealing with the whole range of PCB management issues from import, handling,
servicing and decommissioning to disposal.
It is obvious that this project, aiming at better PCB management and disposal of PCB equipment and
wastes, will ultimately generate positive environmental and social impacts. Nevertheless as a
World Bank funded project, it is subject to the World Bank Environmental and Social Safeguard Policies,
implying to carry out an Environmental Impact Assessment. Improper management of PCBs could indeed
lead to negative environmental and social impacts.
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Taking into account this need for the EIA procedure to be followed for PCB related activities, the
objective of the present project is:
To prepare an environmental assessment framework to assess all potential environmental and social
impacts associated with the activities of the PCB project on the one hand and to identify proper
measures to mitigate such impacts on the other hand; this framework will cover the full spectrum of
PCB management and disposal issues including transportation and storage, treatment, disposal or
recycling and site remediation. The framework will be discussed with the different in country
stakeholders. It is intended to allow a better management of PCBs taking into account all
environmental and social/human health issues. Next to this it should be a reliable framework for the
preparation of project EIAs to be prepared in association with specific PCB management projects in
Vietnam.
The second objective of the contract will be the preparation of such a project EIA for the PCB
management project at the Pha Lai Thermal Power Plant, following the procedures and methodology
outlined in the EA framework. This also involves consultation with the project affected population.
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2 POLICY ASSESSMENT WITH RESPECT TO PCB MANAGEMENT
AND DISPOSAL
2.1 ROLES AND RESPONSIBILITIES
Breeze and Associates Inc. (2007b) summarizes the roles and responsibilities of Ministries and Agencies
at both the national and provincial levels. The following analysis is based on a comparison with the best
practices of leading jurisdictions identified in the Desk Top and Final Breeze and Associates Reports.
2.1.1 National level
The Ministry of Natural Resources and Environment (MONRE) has been given the responsibility to
exercise the uniform State management of hazardous wastes and to organize and direct hazardous waste
management activities. In addition, MONRE can develop and promulgate directives including sector
environmental standards for the selection of HW landfill sites and the technical norms for the design,
construction and operation of HW facilities. MONRE also has the responsibility to oversee and conduct
inspections and to monitor and report on progress for the management of hazardous wastes.
The Vietnam Environment Protection Administration (VEA) has been given the functions of
issuing generator registers and licenses for transportation and facilities and to coordinate these functions
with the provincial DONREs in accordance with national regulations. VEA can also direct provincial
DONREs on data collection and the preparation of annual inventories for hazardous wastes.
The Ministry of Construction (MOC) has been given responsibilities in two key areas. First, MOC sets
the sector standards for the construction of all HW transportation systems and facilities in Vietnam. They
are to collaborate with MOSTE (MONRE) in the development of these standards. Second, MOC can direct
PPCs in planning for the construction of hazardous waste facilities. Within this role, MOC can direct PPCs
to direct provincial DOCs to develop these plans.
The Ministry of Transportation (MOT) has responsibility for setting sector operating standards and
issuing general operating licenses for all general goods transporters, vehicle emissions and driver’s
licenses. Under Circular 12/2006, VEA and the provincial DONREs must ensure that these general
operating licenses from MOT have been issued before issuing any hazardous waste transportation
licenses. MOT does not have a direct role in the issuance of the hazardous waste licenses.
The Ministry of Science and Technology (MOST) has responsibility for coordinating the development
of national standards including the development of standards for hazardous waste treatment technologies
including obligated / regulated standards.
The Ministry of Industry and Trade (MOIT) – (the former Ministry of Industry (MOI)) has been
given key responsibilities for supervising, inspecting and applying measures to ensure that hazardous
waste generators in the industrial sector comply with the regulations. They are also responsible for
mobilizing capital for pollution abatement and for collecting statistics on HW management in the
industrial sector in cooperation with MONRE.
The Ministry of Health (MOH) has been given parallel responsibilities for overseeing the management
of medical wastes at health care facilities. MOH supervises, inspects and applies measures to ensure that
hospitals and health care facilities comply with its regulations. In addition, MOH has the prime
responsibility, in coordination with MOC and MONRE, for planning, selecting technologies and establishing
medical waste incinerators.
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The Ministry of Labor, Invalid and Social Affairs (MOLISA) is in charge of workers’ safety and
occupational health, including providing guidelines and PCB good practices for workers who may be
working with PCB equipment.
The Environmental Police Department with the Ministry of Public Security was formed in 2007. This
Agency is responsible for investigations and prosecutions under the environmental laws of Vietnam.
2.1.2 Provincial level
At provincial level, the Provincial People’s Committees (PPCs) have the principal responsibility for
ensuring that national directives are implemented in the provinces. In this respect, the PPCs direct the
DONREs, DOCs and DTPWs to undertake the responsibilities described below.
The Departments of Natural Resources and Environment (DONREs) have been given
responsibility to be the one door for all applications for generator registers and licenses. In this respect,
the DONREs issue registers and licenses as prescribed by Circular 12/2006, conduct inspections and take
enforcement action. These responsibilities are for transporters and facilities that manage wastes from
within their individual provinces. Transboundary transactions of wastes by transporters or by storage,
treatment and disposal facilities are the responsibility of VEA. The DONREs are also responsible for
developing a database and conducting inventories of HW information for submission to VEA.
The Departments of Construction (DOCs) are responsible for planning for HW facilities and ensuring
that they meet the standards set by the national MOC. The Departments of Transportation and
Public Works (DTPWs) prepare feasibility plans and organize the implementation of these plans for
hazardous waste management facilities. DTPWs are also responsible for issuing provincial general
operating licenses for vehicles.
Besides, other above mentioned ministries have their corresponding departments at the provincial level
such as DOIT, DOLISA, DOH, and which are responsible for implementing the repsonsibilities of their
ministries at the local provinces.
2.1.3 Overview of responsible parties involved in PCB management, disposal
and remediation
A substantial number of Ministries, departments and other agencies are involved in different aspects of
the lifecycle of PCBs. Table 2-1 summarizes these responsibilities.
Table 2-1: Overview of authorities involved in the different aspects of the PCB lifecycle
(Source: Vietnam NIP Stockholm Convention, 2006)
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Figure 2-1: Flow chart public stakeholders involved directly in PCB management at local and
national levels (source: ECD, 2008)
Government GOV
level
MOTr MOPS
MOLISA MOIT MoNRE MOC MOST MOH
(DOE) (VEPA) DOE DOE (DOSTE)
(
Provincial level PPC
DOTr DOPS DOH DOLISA DOIT DOST
DONRE DOC
Sub VEPA
District level
DPC
DIONRE SeC
Commune level
2.1.4 Need for improvement CPC
CV
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The Breeze and Associates Inc. (2007b) report identified following findings:
As found in the Breeze and Associates’ Desk Top Report for PCBs, there are no significant gaps in
Ministry and Department responsibilities for hazardous wastes. Significant responsibilities have been
assigned to MONRE, VEA and the provincial DONREs to ensure that hazardous waste efforts are
coordinated and focused on national level priorities. This division of responsibilities is appropriate and
will allow resources to be focused in those areas where they will have the most impact.
The Breeze and Associates’ Desk Top Report however found that there were areas of significant
overlap for PCBs. Breeze and Associates’ review has identified similar overlaps for hazardous wastes:
- MOI, MONRE, the Environmental Police Agency and the DONREs all have roles for inspecting
and directing HW generators for the industrial sector;
- Both MOH and MONRE have significant roles for the safe management of hazardous medical
wastes. This has led to separate sets of regulations for hazardous wastes for both the
industrial and medical sectors. This may result in a lack of understanding and, in the end,
poor compliance;
- MOC and MONRE / VEA have overlapping roles for the evaluation of transfer, treatment and
disposal facilities as part of the licensing functions;
There will be need for effective coordination between national Ministries and Agencies including MOH,
MONRE, MOC, MOST, the Environmental Police Agency and MOH if the hazardous waste provisions are
to be effectively implemented. One technique for achieving the required levels of cooperation would be
Memoranda of Understanding between key Ministries prescribing their respective roles and
responsibilities and methods for resolving potential conflicts.
2.2 POLICY FRAMEWORK
In 1998, the Vietnam National Environment Agency (NEA) with funding support from the Asian
Development Bank began the development of a national strategy for hazardous waste management. The
preparatory work was undertaken by Environmental Resources Management (ERM) from the UK. ERM
proposed a national strategy consisting of three elements: development of a regulatory framework,
building institutional capacity and the establishment of storage, treatment and disposal facilities.
Although the ERM strategy was never formally adopted, the report supported the first significant policy
steps by Vietnam to manage hazardous wastes. These included the development of the hazardous waste
elements of the Law on Environmental Protection passed by the National Assembly and the Prime
Minister’s Decision 155/1999. It provided overall direction and a focus for the countries hazardous waste
management program.
Breeze and Associates Inc. (2007b) summarizes the policies, regulations and legislation which have been
put in place for solid, hazardous and medical wastes at both the national and provincial levels. The
following sub-sections describe the policies which are of particular importance to the PCB policy
recommendations.
2.2.1 National framework
The Law on Environmental Protection (LEP), 2005 provides the foundation for environmental policy
in Vietnam. The LEP prescribes policies, measures and resources for environmental protection as well as
the rights and obligations of individuals and organizations. Among other policy directions, the LEP
includes environmental standards, environmental assessment requirements as well as sections dealing
with both municipal and hazardous waste management. The sections on hazardous waste management
prescribe requirements for licensing, monitoring, record keeping as well as basic standards for
transportation, storage, treatment and disposal.
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As found in the Desk Top Report of Breeze and Associates, Decision 155/ 1999, Decision 23/2006
and Circular 12/2006 build on the LEP policy requirements. These regulations provide a “cradle to
grave” management system that has the potential to ensure the safe management of hazardous wastes
including PCBs. These three regulations include definitions, requirements for waste generators,
transporters and receivers as well as implementation procedures and responsibilities for State
Management Agencies for the Environment (SMAEs).
Vietnam became a signatory to the Basel Convention on the Transboundary Movement of
Hazardous Wastes in 1995. The requirements to obtain Prior Informed Consent and licenses have been
built into Decisions 155 and Circular 12. MOI Circular 01/2006 also imposes restrictions on imports
and exports. These restrictions require that MOI issue a letter of consent before a provincial agency can
authorize any transboundary movement of PCBs and other prescribed materials.
The Law on Chemicals, 2007 regulates chemical activities, safety on chemical activities, rights and duties
of organizations, individual joined chemical activities and state management of chemical activities. The
Law includes 10 chapters with 71 articles: the general provisions, development of chemical industry,
manufacture and trade of chemicals; classification, labelling, packaging and Safety Chemical Note; the
use of chemicals, prevention and dealing with chemical problems; classification, registration and
providing information on chemicals; protecting the environment and safety for the community, state
management responsibility on chemical activities and the execution provision. Decree No. 108/2008/ND-
CP dated 07 Oct 2008 of Government provides guidelines and instructions for implementing some articles
of the Law on Chemicals.
In addition to regulatory and legislative provisions, Vietnam has produced several guidelines to promote
the environmentally sound management of hazardous wastes:
Decision 60/2002 from the former MOSTE prescribes technical guidelines for hazardous wastes
landfills. It includes principles, methodologies and criteria to prevent and mitigate the impacts of
hazardous waste landfills. It prescribes those HW acceptable for such landfills as well as requirements
for their location, design, construction, operation, monitoring and closure.
TCXDVN 230-2004 from MOC provides hazardous waste landfill design standards. These guidelines
complement the MOSTE guidelines.
Draft Guidelines for the Use of Wastes as Fuels and Materials in the Production of Cement
were prepared for MONRE with the assistance of the Vietnam Canada Environment Project (VCEP).
The guidelines prescribe waste selection criteria, pre-treatment, transportation, receiving, monitoring
and reporting as well as requirements for EIA approvals and licensing. They have not yet been formally
approved by MONRE; however they have been a useful resource in the licensing of the HOLCIM
cement kiln for hazardous waste.
A methodology to calculate treatment fees for waste water containing hazard constituent
was issued by NEA in 2001. This method calculates industrial and medical waste water treatment fees
for wastes containing heavy metals, acids and for textile and dying wastes.
A methodology to calculate solid waste treatment fees was issued by NEA in 2001 including
fees for treatment methods such as sedimentation, solidification, heat treatment and landfill. The
guidance also provides a methodology to calculate hazardous waste treatment fees. Based on this
methodology, the cost for solid hazardous waste transportation and treatment by secure landfill is
about 1,300,000 VND/tonne and the cost for hazardous medical waste treatment by secure landfill is
4,600,000 VND/m³.
In 2003, the Prime Minister approved the National Strategy for Environmental Protection (NSEP).
Hazardous wastes were identified as one of the 36 priority projects. In May 2006, VEA drafted a
hazardous waste management plan under the NSEP but it still has to be finalized and approved.
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The intention of the draft plan was to set up a management system including: the legal framework,
compliance and enforcement, support services and infrastructure for treatment and disposal. The
objectives for the hazardous waste plan were:
in the period of 2006-2010: 100 % HW to be controlled; 60 % HW to be treated; complete the legal
framework, macro planning and approval procedures;
in the period 2010-2020: all HW to be managed, treated, reduced, recycled, reused and safely
disposed of with a minimal quantity going to landfill.
Six priority projects were defined for HW over the four year period:
Investigate and assess the status of HW and set up an information system;
Develop and complete the legal framework;
Develop and implement treatment models and develop a collection, transportation, treatment and
disposal network;
Develop and implement demo-projects for recycling, reuse and recovery;
Set up a project to establish HW treatment facilities in the Southern, Northern and Central regions;
Develop national macro planning for HW collection, treatment and disposal.
Although this plan was not formally adopted, several nationally funded projects were undertaken in 2005
and 2006 to assess the performance of the current program and to make recommendations for further
development. These two projects are described in more detail in the Breeze and Associates Inc. (2007b)
report.
2.2.2 Provincial frameworks
Decision 155/1999, Decision 23/2006 and Circular 12/2006 define specific responsibilities for
provincial PCs, DONREs and other departments for the safe management of hazardous wastes. These
responsibilities have been described in the previous chapter. To implement these responsibilities, nine
provinces have developed policies and have started to put these into action.
Hanoi has passed Decision 152 to meet its obligations under the national regulations. Decision 152
builds on national Decision 155 but is restricted to industrial hazardous wastes. In addition to the national
requirements, the Hanoi directive further clarifies the responsibilities of DONRE and other departments,
introduces additional city standards and defines Nam Son Commune as the location for the central
disposal site.
HCMC and Long An have each developed two guidelines. The first guideline reproduces Decision 155
while the second reproduces MOSTE Decision 60/2002 on HW landfills. In addition, HCMC has
passed Directive 09/2003 aimed at improving the management of medical wastes along the lines
described by MOH Decision No. 2575/1999.
Dong Nai Decision 2582 is based on Decision 155 but prescribes more detailed requirements for the
hazardous waste management system of that province. It also clarifies the responsibilities of the DONRE
and other departments.
Long An, Hai Phong and Hai Duong have all developed provincial regulations based on Decision 155,
however these regulations have not yet been approved by the provincial PCs.
Phu Tho Decision 2777/2002 is based on national Decision 155 and requires all industrial and
hazardous waste generators and transporters to follow specified hazardous waste requirements. The
regulation also appointed the Viet Tri Environmental and Urban Service Company to be responsible for
hazardous waste management at a provincially licensed treatment plant.
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Nam Dinh PPC adopted their Hazardous Waste Strategy in 2006 to guide regulatory development,
capacity building efforts and the establishment of facilities. Nam Dinh has also drafted a regulation but
the PPC has decided to rely instead on the new national requirements found in Decision 23 and Circular
12.
2.2.3 Need for improvement
Breeze and Associates Inc. (2007b) report identified following findings:
Vietnam does not have a formally adopted hazardous waste management strategy or plan. The draft
VEA hazardous waste component of the National Environmental Protection Strategy is a sound first
step but it will need to address, more effectively, two essential components defined by ERM – capacity
building at the national, provincial and local levels and the establishment of cost effective treatment
and disposal facilities.
As found in the Desk Top Report, Decision 155/1999, Decision 23/2006 and Circular 12/2006 provide
the foundation for a basic “cradle to grave” hazardous waste system for the country. The report also
concluded that there are a number of inconsistencies between the 1999 and the 2006 policies. These
include differences in manifesting requirements and prescribed timelines for issuing generator registers
and licenses. These inconsistencies will need to be resolved if significant levels of compliance are to be
achieved.
Nine provinces have started to develop policy frameworks to implement their HW responsibilities.
Breeze and Associates’ review of the provincial requirements has shown that the provinces have begun
to diverge from the national provisions. This divergence will make it difficult for the regulated
community which is managing hazardous wastes across provincial borders to understand the
requirements. This lack of understanding will inevitably lead to a lack of compliance.
In Breeze and Associates’ discussions with selected provincial officials, they found that the provinces
and cities now implementing the hazardous waste management regulations are struggling to
understand how to achieve compliance. They need additional technical support in the form of
guidelines for generators, transporters as well as storage and treatment facilities. They also require
inspection and enforcement protocols for government inspectors monitoring facilities and protocols for
review engineers preparing licenses for these facilities.
2.2.4 Overall PCB policy needs and options assessment
Breeze and Associates (2007a) identified and assessed policy needs and options based on international
best practices and made recommendations for a policy, regulatory and legislative framework for Vietnam.
Their throughout analysis has been summarised in the table presented in appendix 0 including a needs
assessment in following fields:
PCB Policy Framework for Vietnam;
Thresholds and Timelines;
In-Service PCB Equipment and Materials;
PCB Waste Management;
Contaminated Sites;
Policy Compliance;
Environmental Monitoring;
National Inventories;
Public Awareness / Involvement;
Capacity Building and Training;
Cost Recovery Mechanisms;
Roles and Responsibilities.
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As a base of comparison, Breeze and Associates (2007a) analysed the requirements under the Stockholm
Convention and four best practice jurisdictions: Australia, the Philippines, Canada and the European
Union.
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3 IMPACT ASSESSMENT PROCEDURE
Environmental impact assessment is the process in which environmental factors are integrated into
project planning and decision-making so as to achieve ecologically sustainable development.
In this chapter, a guideline is provided on the EA procedure to be followed by the project initiator when
doing a project in the scope of the PCB management, disposal and remediation.
Being a World Bank funded project, the environmental and social impact assessment procedures as
defined in the World Bank Safeguard rules should be followed in the scope of this PCB Management
Demonstration Project. Besides this, EIAs should comply with the current Vietnamese legislation in this
field. Both are briefly described in following chapters. As this Framework is not limited to PCB
management aspects, EIA rules and legislation to be followed in PCB disposal and remediation projects
are also described.
Taking into account above described legislation and rules, a decision tree is provided for site specific EIAs
as a guidance tool to screen the proper EA procedures and content.
3.1 WORLD BANK SAFEGUARD RULES
The objective of the World Bank's environmental and social safeguard policies is to prevent and mitigate
undue harm to people and their environment in the development process. They are a cornerstone of its
support to sustainable poverty reduction.
The effectiveness and development impact of projects and programs supported by the Bank has
substantially increased as a result of attention to these policies. Safeguard policies have often provided a
platform for the participation of stakeholders in project design, and have been an important instrument
for building ownership among local populations.
3.1.1 Environmental assessment
The objectives of this item are to provide an overview of the World Bank EIA process.
In World Bank operations, the purpose of Environmental Assessment is to improve decision making, to
ensure that subproject options under consideration are sound and sustainable, and that potentially
affected people have been properly consulted. To meet this objective, the World Bank policy defines
procedures to: (a) identify the level of environmental risk (screening) associated with a project, (b)
assess the potential environmental impacts associated with the risk and how they should be reduced to
acceptable levels (environmental assessment and management), (c) ensure the views of local groups that
may be affected by the project are properly reflected in identifying the environmental risk and managing
any impacts (public consultation), (d) make certain that the procedures followed in the environmental
assessment process are adequately disclosed and transparent to the general public (disclosure) and (e)
includes measures for implementation and supervision of commitments relating to findings and
recommendations of the environmental assessment (environmental management plan).
An environmental assessment should be carried out early in the project cycle during project conception
and design stage in order to identify its direct and indirect impacts on physical and social environment
and establish linkages. The various steps to be followed during identification, preparation, appraisal,
negotiation, implementation, and evaluation of the project, as recommended in the World Bank
guidelines, are given in Figure 3-1.
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Screening and scoping, the most important parts of EIA, need to be certainly and effectively carried out
to identify the environmental parameters that will be affected by development projects, and initiate
dialogues with affected people for appraising the positive and negative features of the projects for
effective public participation. The World Bank undertakes environmental screening of each proposed
project to determine the appropriate extent and type of EA. The Bank classifies the proposed project into
one of four categories, depending on the type, location, sensitivity, and scale of the project and the
nature and magnitude of its potential environmental impacts.
(a) Category A: A proposed project is classified as Category A if it is likely to have
significant adverse environmental impacts that are sensitive 1 diverse, or
unprecedented. These impacts may affect an area broader than the sites or facilities
subject to physical works. EA for a Category A project examines the project’s
potential negative and positive environmental impacts, compares them with those of
feasible alternatives (including the “without project” situation), and recommends any
measures needed to prevent, minimize, mitigate, or compensate for adverse impacts
and improve environmental performance. For a Category A project, the borrower is
responsible for preparing a report, normally an EIA (or a suitably comprehensive
regional or sectoral EA) that includes, as necessary, elements of other instruments
such as an environmental audit, hazard or risk assessment, and environmental
management plan (EMP).
(b) Category B: A proposed project is classified as Category B if its potential adverse
environmental impacts on human populations or environmentally important areas —
including wetlands, forests, grasslands, and other natural habitats — are less adverse
than those of Category A projects. These impacts are site-specific; few if any of them are
irreversible; and in most cases mitigation measures can be designed more readily than
for Category A projects. The scope of EA for a Category B project may vary from project
to project, but it is narrower than that of Category A EA. Like Category A EA, it examines
the project’s potential negative and positive environmental impacts and recommends any
measures needed to prevent, minimize, mitigate, or compensate for adverse impacts and
improve environmental performance. When the screening process determines, or national
legislation requires, that any of the environmental issues identified warrant special
attention, the findings and results of Category B EA may be set out in a separate report.
Depending on the type of project and the nature and magnitude of the impacts, this
report may include, for example, a limited environmental impact assessment, an
environmental mitigation or management plan, an environmental audit, or a hazard
assessment. For Category B projects that are not in environmentally sensitive areas and
that present well-defined and well-understood issues of narrow scope, the World Bank
may accept alternative approaches for meeting EA requirements: for example,
environmentally sound design criteria, siting criteria, or pollution standards for small-scale
industrial plants or rural works; environmentally sound siting criteria, construction
standards, or inspection procedures for housing projects; or environmentally sound
operating procedures for road rehabilitation projects.
1
A potential impact is considered “sensitive” if it may be irreversible (e.g., lead to loss of a major natural habitat) or
raise issues covered by OP 4.10, Indigenous Peoples; OP 4.04, Natural Habitats; OP 4.11, Physical Cultural
Resources; or OP 4.12, Involuntary Resettlement.
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Figure 3-1 World Bank Environmental Assessment requirements versus project cycle
(c) Category C: A proposed project is classified as Category C if it is likely to have
minimal or no adverse environmental impacts. Beyond screening, no further EA action is
required for a Category C project.
(d) Category FI: A proposed project is classified as Category FI if it involves investment
of Bank funds through a financial intermediary, in subprojects that may result in adverse
environmental impacts.
Bank staff “screen” each proposed project to determine which safeguard policies may be triggered. The
Project owner is then informed of the actions needed for compliance. The screening criteria applied by
the World Bank to determine whether OP 4.01 has been triggered plus other specific requirements of the
World Bank are summarized again in the following table:
Project stage The World Bank
Legal Operational Policy 4.01 on Environmental Assessment and
references associated BP 4.01.
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Screening Project Bank “screens” the project and determines whether it falls into
Identification 1 of 3 Categories:
A- Likely to have significant adverse impacts that are sensitive,
diverse or unprecedented and may affect a broad area:
Detailed EIA and environmental management plan (EMP)
Required
B- Potential impacts are less adverse than for Category A, they
are site specific, few if any are irreversible and in most cases,
mitigatory measures can be designed more readily than for
Category A projects. Less detailed EIA Required.
C- Minimal or no adverse environmental impacts. No further
requirements.
Scoping During Pre- For Category A projects, scoping requires the proponent/Project
Feasibility or owner to organize:
Feasibility Field visit by an environmental specialist to prepare
studies scope, procedures, schedule and outline for EA study.
Project affected people and NGOs should be
consulted before ToR for detailed EA study is finalized.
Bank must approve resulting scope and ToR for
detailed EA study.
The Bank will assist the Project owner / proponent to
do this as needed.
For Category B projects, Project owner must discuss and
agree EIA scope and ToR with Bank.
Preparation Detailed Design For Category A projects, the Project owner/proponent must
of report (Prep. Of EIA) retain a independent EA expert(s) not affiliated with the
project to carry out EA. For high risk/multi-dimensional
Category A projects, the Project owner must also engage
an advisory panel of independent, internationally
recognized environmental specialists to advise on
aspects of the project relevant to the EIA.
Components of an EIA report according to the World Bank safeguard policies Category A include:
Executive summary: a concise discussion of significant findings of the EIA and recommended
actions in the project;
A policy, legal, and administrative framework;
Project description: description of the project's geographic, ecological, social and temporal
context, including any off-site investments that may be required by the project, such as dedicated
pipelines, access roads, power plants, water supply, housing and raw material and product
storage materials;
Baseline data: an assessment of the study areas dimensions and a description of relevant
physical, biological, and socio-economic conditions, including any changes anticipated before the
project begins, and current and proposed development activities within the project area, even if
not directly connected to the project;
Impact assessment: identification and assessment of the positive and negative impacts likely to
result from the proposed project. Mitigation measures, and any residual negative impacts that
cannot be mitigated, should be identified. Opportunities for environmental enhancement should
be explored. The extent and quality of available data, key data gaps, and uncertainties associated
with predictions should be identified/estimated. Topics that do not require further attention should
be specified;
Analysis of alternatives: assess investment alternatives from an environmental perspective.
This is the more proactive side of EA -enhancing the design of a project through consideration of
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alternatives, as opposed to the more defensive task of reducing adverse impacts of a given
design;
A mitigation or management plan: consists of the set of measures to be taken during
implementation and operation to eliminate, offset, or reduce adverse environmental impacts to
acceptable levels. The plan identifies feasible and cost-effective measures and estimates their
potential environmental impacts, capital and recurrent costs and institutional, training and
monitoring requirements. The plan should provide details on proposed work programs and
schedules to help ensure that the proposed environmental actions are in phase with construction
and other project activities throughout implementation. The plan should consider compensatory
measures if mitigation measures are not feasible or cost-effective;
An environmental monitoring plan: specifies the type of monitoring, who will do it, how much
it will cost, and what other inputs, such as training, are necessary;
Public consultation: Consultation with affected communities is recognised as key to identifying
environmental impacts and designing mitigation measures. The World Bank's policy requires
consultation with affected groups and local NGOs during at least two stages of the EA process: (1)
at the scoping stage, shortly after the EA category has been assigned, and (2) once a draft EA
report has been prepared.
3.1.2 Social assessment
Social assessment is the instrument used most frequently to analyze social issues and solicit stakeholder
views. Social assessment helps make the project responsive to social development concerns, including
seeking to enhance benefits for poor and vulnerable people while minimizing or mitigating risk and
adverse impacts. It analyzes distributional impacts of intended project benefits on different stakeholder
groups, and identifies differences in assets and capabilities to access the project benefits.
A social assessment is made up of analytical, process, and operational elements, combining
the analysis of context and social issues
with a participatory process of stakeholder consultations and involvement,
to provide operational guidance on developing a project design, implementation, and
monitoring and evaluation (M&E) framework.
The scope and depth of the social assessment should be determined by the complexity and importance of
the issues studied, taking into account the skills and resources available. To the extent possible, the
project social assessment should build on existing data and analysis relevant to the sector and project.
Gender, ethnicity, social impacts, and institutional capacity are among the social factors that need to be
taken into account in development operations. In the past these factors have been analyzed separately
with the result that some issues received attention whereas others were overlooked. Social assessment
was developed by the Bank's Social Policy Thematic Team to provide a comprehensive, participatory
framework for deciding what issues have priority for attention and how operationally useful information
can be gathered and used. Because this method was developed by Bank staff, the steps in SA are
consistent with Bank procedures and existing operational directives.
The choice of tools and methods (see Figure 3.2) for a specific social assessment will depend on several
factors, such as the project area and the quality of previous social development information specific to
the project, region and sector. Resource constraints, the time frame for the social assessment, the
availability of capable human resources and the information gaps that the social assessment needs to fill
will also affect the choice of methodology.
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Figure 3-2: Selection of Social Analysis Study Methods and Tools
Review of area-specific data
Bank activities
Review of qualitative and
quantitative country specific data
Decision for Social Assessement
Need to launch more comprehensive data Need to evaluate stakeholders and launch
gathering and analyses participation activities
Evaluate appropriateness of tools for participation
and stakeholders analysis
Selection Factors Media campaigns, seminars, workshops, etc.
Financial Recources
Types of Analyses
Timeframe
Selection of scope of Qualitative Analysis
data collection
Human Recources
Quantitative and qualitative
Analysis
Diversity of project area
Social Assessement Report
Participatory Monitoring and Evaluation
3.2 ENVIRONMENTAL IMPACT ASSESSMENT AND ENVIRONMENTAL
PROTECTION COMMITMENT RULES IN VIETNAM
In Vietnam the Law on Environmental Protection (LEP) went into effect on January 10, 1994. It aims to
preserve a healthy, clean, and beautiful environment, achieve environmental improvements, ensure
ecological balance, prevent and overcome adverse impacts on people, on environment (including nature),
on the rational and economical exploitation, and utilization of natural resources.
The EIA was mentioned in the LEP. Article 18 stipulates that organizations and individuals must submit
EIA reports to be appraised by the state management agency for environmental protection. The result of
the appraisal should constitute of one of the bases for the competent authorities to approve the projects
or authorize their implementation (SIDA, 2004).
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The Ministry of Natural Resources and Environment (MoNRE) was created and replaced the Ministry of
Science, Technology and Environment (MoSTE) at the end of 2002. Today, MoNRE performs the
functions of state management over land, water, and mineral resources, environment, hydro-
meteorology, survey, and mapping for the whole country. It works on various tasks, including EIA with
ministerial and provincial agencies, as well as with the National Assembly offices, and finally with the
prime minister.
The provincial Departments of Natural Resources and Environment (DoNREs) are delegated to make
decisions on numerous issues related to the use and management of local natural resources and
environment, combined with environmental and land planning. The Vietnam Environment Administration
(VEA) is included in the state management; its main task is to monitor environmental measures. VEA
primarily monitors the project owners’ mitigation actions as stipulated in the EIA report. Much of this
responsibility, however, is decentralized to the DoNRE (Severinsson, 2004).
Depending on the type and size of the planned project and the sensitivity of the natural and social
environment, a distinction is made between environmental impact assessment studies (EIA) and
environmental protection commitments (EPC). EIA and EPC legislation in Vietnam is stipulated by Decree
80/2006/ND-CP (issued 09/08/2006) detailing and guiding the implementation of a number of articles
of the law on environmental projection including EIA and EPC and Decree 21/2008/ND-CP (issued
28/02/2008), amending and supplementing a number of articles of Decree 80/2006/ND-CP on:
the list of projects subject to EIA, obligation related to public consultations and the appraisal and
approval process;
registration and certification aspects of EPCs.
Article 1.3. of the Government's Decree 21/2008/ND-CP, amends and supplements Clause l of Article 6 of
Decree 80/2006/ND-CP on the list of projects subject to the making of an environmental impact
assessment report. A detailed list of projects subject to EIA is presented in annex to Decree 21/2008/ND-
CP. In case environmental impacts are less significant than for those projects subject to EIA, an
environmental protection commitment should be drafted to ensure comprehensive development and
sustainability.
When elaborating EIA reports or project EPCs, it is required to apply Vietnam compulsory environmental
standards; environmental standards must be in accordance with the international treaties which were
signed by Vietnam.
Other important legal documents relevant for the scope of EIAs regarding PCB management and disposal
related projects, include:
The Environment Protection Laws approved by the National Assembly of the Socialist Republic of
Vietnam dated November 29, 2005, effected from July 01, 2006;
Decision number 23/2006/QĐ-BTNMT of the Ministry of Resource & Environment issued
December 26, 2006 on Hazardous waste List. (related with the Basel Convention on the
Transboundary Movement of Hazardous Wastes in 1995);
Decision number 12/2006/ QĐ-BTNMT of the Ministry of Resource & Environment issued
December 26, 2006 stipulating the conditions to set up and the procedures to register, to license,
to give a code to manage the harmful waste materials;
Decree number 68/2005/NĐ-CP issued December 20, 2005 of Government of Chemical Safety;
Notification number 12/2006/TT-BCN issued December 22, 2006 of Ministry of Industry of
Industrial Safety;
Decree No 13/2003/ND-CP issued February 19, 2003 to regulate the list of dangerous cargo
transported by road
Circular No 02/2004/TT-BCN of the Ministry of Industry issued December 21, 2004 to guide to
implement Decree No 13/2003/ND-CP
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Circular No 10/2008/TT-BKHCN issued August 8, 2008 to instruct to the procedures to give licence
for hazardous chemicals transportation by road
QCVN 03:2008 National technical regulation on the emission of health care solid waste
incinerators
QCVN 03:2008 National technical regulation on the allowable limits of heavy metals in the soils
TCVN 6706-2000 Classification of hazardous wastes;
TCVN 6706:2000 Warning and precautionary sign of hazardous wastes;
TCVN 7629:2007 Hazardous waste thresholds
TCXDVN 320:2004 Hazardous solid waste landfills – Design standard
Decision number 22/2006/QĐ-BTNMT issued December 18, 2006 of Ministry of Resource &
Environment to obligation to apply the Vietnamese standards of Environment as below:
1. TCVN 5937:2005 Air quality – Ambient air quality standards,
2. TCVN 5938:2005 Air quality – Maximum allowable concentration of hazardous
substances in ambient air,
3. TCVN 5939:2005 Air quality – Industrial emission standards – Inorganic substances
and dusts,
4. TCVN 5940:2005 Air quality – Industrial emission standards – Organic substances,
5. TCVN 5945:2005 Industrial wastewater – Discharge standards;
Decision number 07/2005/QĐ-BTNMT issued September 20, 2005 of Ministry of Resource &
Environment to obligation to apply the Vietnamese standards of Environment as below:
1. TCVN 7440:2005 Emission standards for thermal power industry;
The Vietnamese Environmental Standards issued in 1995 and the Vietnamese Standards of
Environment, which obligate to apply issues attaching to Decision number 35/2002/QĐ-BKHCNMT
dated June 25, 2002 (not abrogated by Decision number 22/2006/QĐ-BTNMT dated December
18, 2006):
Standards concerning air quality:
1. TCVN 6560:1999 Air quality – Emission standards for health care solid waste incinerators
– Permissible limits,
2. QCVN 02:2008 National technical regulation on the emission of incinerators for
health care solid waste;
3. TCVN 6438:2001 Road vehicles – Maximum permitted emission limits of exhaust gas,
4. TCVN 6991:2001 Air quality – Standards for inorganic substances from industrial
emissions discharged in industrial zones,
5. TCVN 6992:2001 Air quality – Standards for inorganic substances from industrial
emissions discharged in urban regions,
6. TCVN 6993:2001 Air quality – Standards for inorganic substances from industrial
emissions discharged in rural and mountainous regions,
7. TCVN 6994:2001 Air quality – Standards for organic substances from industrial
emissions discharged in industrial zones,
8. TCVN 6995:2001 Air quality – Standards for organic substances from industrial
emissions discharged in urban regions,
9. TCVN 6996:2001 Air quality – Standards for organic substances from industrial
emissions discharged in rural and mountainous regions;
standards concerning noise:
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1. TCVN 5948-1998 Acoustic – Noise emitted by accelerating road vehicles – Permitted
maximum noise level,
2. TCVN 5949-1998 Acoustics – Noise in public and residential areas - Maximum
permitted noise level;
standards concerning water quality:
1. TCVN 5942-1995 Water quality – Surface water quality standards,
2. TCVN 5943-1995 Water quality – Coastal water quality standards,
3. TCVN 5944-1995 Water quality – Ground water quality standards,
4. TCVN 6772:2000 Water quality – Domestic wastewater standards,
5. TCVN 6773:2000 Water quality – Water quality guidelines for irrigation,
6. TCVN 6774:2000 Water quality – Fresh-water quality guidelines for protection of
aquatic life,
7. TCVN 6980:2001 Water quality – Standards for industrial effluents discharged into
rivers used for domestic water supply,
8. TCVN 6981:2001 Water quality – Standards for industrial effluents discharged into
lakes used for domestic water supply,
9. TCVN 6982:2001 Water quality – Standards for industrial effluents discharged into
rivers used for water sport and recreation,
10. TCVN 6983:2001 Water quality – Standards for industrial effluents discharged into
lakes used for water sport and recreation,
11. TCVN 6984:2001 Water quality – Standards for industrial effluents discharged into
rivers: for protection of aquatic life,
12. TCVN 6985:2001 Water quality – Standards for industrial effluents discharged into
lakes: for protection of aquatic life,
13. TCVN 6986:2001 Water quality – Standards for industrial effluents discharged into
coastal water used for protection of aquatic life,
14. TCVN 6987:2001 Water quality – Standards for industrial effluents discharged into
coastal water: for water sport and recreation;
The standards concerning soil quality:
1. TCVN 7209- 2002 Soil quality – maximum allowable limits of pesticide residues in the
soil;
The standards concerning the vibration, labour sanitation:
1. TCVN 6962:2001 Vibration emitted by construction works and factories – Maximum
permitted levels in the environment of public and residential areas
Technical documents: Feasibility Study of the Project.
The standards concerning hazardous wastes
1. TCVN 6706-2000 Classification of hazardous wastes;
2. TCVN 6707: 2000 Warning and precautionary sign of hazardous wastes;
3. TCVN 7629:2007 Hazardous waste thresholds
4. TCXDVN 320:2004 Hazardous solid waste landfills - Design standard
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3.2.1 Environmental Impact Assessment: content and procedure
3.2.1.1 Reporting structure and content
The recommended EIA structure according to Vietnamese law includes:
INTRODUCTION
1. Project profile
2. Legal and technical basis for environmental impact assessment (EIA)
3. EIA Methodology
4. Organization of E.I.A. implementation
Chapter 1: BRIEF DESCRIPTION OF PROJECT
1.1. Name of project
1.2. Project owner
1.3. Location of project
1.4. Main contents of project
Chapter 2: NATURAL, ENVIRONMENTAL, ECONOMIC AND SOCIAL CONDITION
2.1. Natural and environmental condition:
- Geographical and geological condition
- Meteorological and hydrographical condition
- Current condition of natural environmental factors
2.2. Economic and social condition:
- Economic condition
- Social condition
Chapter 3: ASSESSMENT OF ENVIRONMENTAL IMPACTS
3.1 Assessment of impacts
- Impacts that relate to waste
- Impacts that do not relate to wastes
- Forecasting environmental risks that project may take
3.2. Evaluation on detail level and reliability of assessment
Chapter 4: SOLUTIONS AND MEASURES TO MINIMIZE NEGATIVE IMPACTS, TO PREVENT AND
COPE WITH ENVIRONMENTAL PROBELMS
4.1. For Negative impacts
4.2. For environmental problems
Chapter 5: ENVIRONMENTAL MANAGEMENT AND MONITORING PROGRAMS
51. Environmental management program
5.2. Environmental monitoring program
Chapter 6: COMMUNITY CONSULTATION
6.1. Consultation with communal level People’s Committees
6.2. Consultation with communal level National Father Front Committees
6.3. Responses and commitments of project owners to the opinions raised in consultation process
CONCLUSION, RECOMMENDATION, AND COMMITMENT
1. Conclusion
2. Recommendation
3. Commitment
ANNEXES
A detailed explanation about the content of each of the above indicated chapters is indicated in the
attachment of the Circular No. 05/2008/TT-BTNMT of the Ministry of Natural Resources and Environment
providing guidance on strategic environmental assessment, environmental impacts assessment and
environmental protection commitment.
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3.2.1.2 Consultation needs
As required in Article 6a (Decree 21/2008/ND-CP dated on February 28, 2008) consultation of commune,
ward or township, People’s Committees and community representatives should be organized in the
process of making environmental impact assessment reports.
Commune, ward or township Fatherland Front Committees shall represent communities in
contributing opinions in the process of making environmental impact assessment reports of
investment projects in their localities.
The project owner shall send a document on the project's major investment items, environmental
issues and environmental protection measures and request the commune-level People's
Committee and Fatherland Front Committee of the place where the project is to be executed to
give opinions.
Within fifteen (15) working days after receiving a written request for opinions, commune-level
People's Committee and Fatherland Front Committee shall give their opinions in writing and make
them public to local people.
Past this time limit, if they issue no written replies, the commune-level People's Committees and
community representatives shall considered having agreed with the project owner.
3.2.1.3 Approval procedure
According to Article 11 of Decree 21/2008/ND-CP on appraisal of EIA reports, heads or leaders of
agencies stipulated in Clause 7 of Article 17 of Law on Environmental Protection shall make decisions on
the establishment of Appraisal Councils for EIA reports of the projects.
Based on the technological, technical and environmental complexity of the projects, the heads or leaders
of agencies stipulated in Clause 7 of Article 17 of Law on Environmental Protection make decisions on the
selection of appraisal form through the Appraisal Council or Appraisal Service Providers. The Appraisal
Council or Appraisal Service Providers have the functions of providing consulting services for competent
agencies to consider and evaluate the quality of EIA reports as background for considering and approving
in accordance with the regulations. In necessary circumstances, before official meetings of the Appraisal
Council, the responsible agencies can exercise supporting appraisal modalities as follows:
Survey on the project implementation site and surrounding location;
Taking samples for reference analysis;
Collecting opinions of communities surrounding the project implementation site;
Collecting critical opinions from experts outside the Appraisal Council, relevant scientific and
technological agencies, social and vocational organizations, and non-governmental organizations;
Organizing appraisal meetings on specific topics.
The Appraisal Council and Appraisal Service Providers on EIA reports operate in accordance with
regulations issued by Minister of Natural Resources and Environment.
The duration for appraisal of projects under the competence authority of making decision and approval of
the National Assembly, the Government, the Prime Minister as well as inter-sectoral and inter-provincial
projects is 45 working days, starting on the date of receiving valid application dossiers. For projects that
are not in the scope of Clause 1 of article 12 of Decree 21/2008/ND-CP, duration for appraisal is 30
working days since the date of receiving valid application dossiers. In case EIA reports are not approved
and must be re-appraised, duration for re-appraising is determined in Clauses 1 and 2 of article 12.
The approval procedure in the scope of the EIA project including the different steps and responsible
parties throughout the different project phases is presented in Figure 3-2.
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Figure 3-3: Presentation of EIA approval procedure
Investor Ministry of Planning and Investment
Phase 1
Add information
Ministry of Natural Resources and Environment
Environmental Assessment
Submit EIA report
Board of Environmental Assessment
Board of specialist
Phase 2
45 days
Pass
Not approve/ require additional
information
Approve
Supervision Perform project
Construction and installation EP facilities
Report
Monitoring mitigation measures
Evaluate EA report
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3.2.2 Environmental Protection Commitment: content and procedure
3.2.2.1 Reporting structure and content
Proposed structure and requirements of an environmental protection commitment according to
Vietnamese law is as follows:
I. GENERAL INFORMATION
1.1. Project name: (exact name as in feasible study report or investment report)
1.2. Name of agency, project owner:
1.3. Contact address of agency, project owner:
1.4. Head of agency, company owned project:
1.5. Facilities for contact with agency, company owned project: (telephone number, Fax, E-mail...).
II. PROJECT EXECUTING SITE
III. SCALE OF PRODUCTION, BUSINESS
IV. DEMAND FOR ENERGY AND FUEL
V. ENVIRONMENTAL IMPACTS
5.1. Arisen wastes
5.2. Other impacts
VI. MEASURES FOR MINIMIZING NEGATIVE IMPACTS
6.1. Waste treatment
6.2. Minimizing other impacts
VII. ENVIRONMENTAL TREATMENT PLANS; ENVIRONMENTAL MONITORING PROGRAMS
VIII. IMPLEMENTATION COMMITMENT
Commitment on Implementation of wastes treatment, minimization of other impacts raised in
environmental impact assessment report; commitment of following current standards on environment;
commitment of implementing other environmental protection methods as regulated by Vietnamese law.
Further details on the content of an EPC is presented in annexes attached with Circular No.05/2008/TT-
BTNMT by Ministry of Natural Resources and Environment guiding on strategic environmental
assessment, environmental impact assessment and environmental protection commitment
3.2.2.2 Elaboration of environmental protection commitments
In case the preparation of an EPC is due, LEP 2005 specifies that after receiving valid EPC dossiers within
time duration as stipulated in Clause 2 of Article 26 of Law on Environmental Protection, the People’s
Committees at district or communal levels are authorized to issue certificates to those objects who
register environmental protection commitments.
According to the Circular 05/2008-TT-BTNMT of the Ministry of Natural Resources and Environment, the
project owners have responsibility to send the dossier registering for environmental protection
commitment (EPC) to the People’s Committee at the district level or authorized People Committee at
commune level where the project is executed.
In case the project is belonging to two or more districts, towns, cities … , the project owners choose one
People Committee at district level belonging to a province to send a dossier registering for environmental
protection commitment. The content and form of the dossier registering environmental protection
commitment are regulated as stipulated in Annnex 26 of the Circular 05/2008-TT-BTNMT- Guideline for
strategic environmental assessment, environmental impact assessment and environmental protection
committment.
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3.3 SCREENING PROCEDURE AND GUIDANCE ON CONTENT ACCORDING
TO WORLD BANK AND VIETNAMESE RULES ON ENVIRONMENTAL
IMPACT ASSESSMENTS
Based on the EIA rules defined in the Vietnamese legislation and the World Bank safeguard policies, a
guidance is provided on the appropriate EA procedures which need to be followed.
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Table 3-1 illustrating the procedure to be followed based on above described World Bank rules and
Vietnamese legislation.
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Table 3-1: Guidance on screening procedure and disciplines covered in site specific impact assessments on PCB management, disposal and
remediation
IMPACT ASSESSMENT SCREENING PROCEDURE FOR SITE SPECIFIC IMPACT ASSESSMENT PROJECTS
1. LOCATION
Projects using part or the whole land area represented by nature conservation zones, national parks, historical-cultural relic areas, world World Bank Vietnamese
heritages, biosphere reserves, and famous scenic places which are protected under decisions of provincial/municipal People’s Committees legislation
Cat A EIA
2. TYPE OF PROJECT
PCB Management Project or Sub-Project PCB Treatment and Disposal Project or Sub-project Site Remediation Project or Sub-project
Subtasks World Bank Vietnamese Subtasks World Bank Vietnamese Subtasks World Bank Vietnamese
legislation legislation legislation
Testing equipment Cat B EPC Treatment based on Cat A EIA Soil excavation and Cat A EIA
destruction by reduction transportation
Handling oils, materials and Cat B EPC Treatment based on Cat A EIA Soil washing (excavated Cat A EIA
waste including packaging, oxidation treatment contaminated soil)
labelling and transport
Replacement, retrofilling and Cat B EPC Treatment based on Cat A EIA Thermally enhanced soil Cat A EIA
recycling combustion/incineration vapour extraction
Construction of temporary Cat B EPC Construction of final Cat A EIA In-situ soil flushing Cat A EIA
storage place storage place or/and
disposal at landfills for HW
In situ vitrification Cat A EPC
TiO2 enhanced Cat A EPC
photocatalysis
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IMPACT DISCIPLINES TO BE COVERED IN SITE SPECIFIC IMPACT ASSESSMENT PROJECTS
In general following disciplines should be covered in an impact assessment, including both Cat A and B projects according to the World Bank Safeguard rules and EIA and EPCs
according to Vietnamese legislation.
Water and aquatic resources: Land use:
Ground water contamination Land use change
Surface water contamination Loss of sites with archaeological, historical and cultural value
Soil and waste: Man and his socio-economic living environment:
Soil contamination Direct health risks (direct exposure)
Waste production Indirect health risks
Climate, air and noise: Nuisance (dust, noise)
Air emissions of POPs Social effects (resettlement)
Dust formation Social effects (employment)
Noise production Social effects (other)
Ecosystems:
Loss of ecological valuable areas
Ecotoxicity to terrestrial life
Ecotoxicity to aquatic life
Depending on the type of project, some disciplines may be excluded from the impact assessment. Based on the scoping results, only those disciplines for
which potential environmental impacts “x” and potential environmental impact not likely to occur “(x)” are indicated should be included in an impact
assessment:
PCB Management Project or Sub-Project PCB Treatment and Disposal Project or Sub-project Site Remediation Project or Sub-project
For each of the specified subtask, see Table 5-1 For each of the specified subtask, seeTable 5-2
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3.4. SCREENING PROCEDURE FOR SITE SPECIFIC PROJECTS AND
INVOLVEMENT OF DIFFERENT PARTIES
WB VEA MOIT EVN People’s
Committee
(PC)
VEA PMU / EVN
PMU
Facility owner and Facility owner develop
independent consultant EPC to comply with the
develop EIA to comply with government’s
the WB’s requirement requirement
Submit to the WB Submit to the PC
PMUs
supervise all
Review of WB activities of Review of PC
the process
No No
Review satisfactory? Review satisfactory?
YES YES
Approved EIA Approved EPC
Disclosure by
facility owner
PMUs inform the WB WB issues No
the disclosure situation Objection
Figure 3-4: Screening procedure for site specific projects
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World Bank: As category B project, all site specific projects will require an EIA to meet with the bank
requirements. The facilities owner will need to prepare EIA in English and submit to the Bank for their
internal approval. The PMU is responsible for proposing scope and TOR of EIA, which must be agreed by
the WB later on. In the framework of the PCB Management Demonstration Project, this EIA will include
an EMP. When TOR is developed, the facilities owner may consider hiring an independent consultant to
develop an EIA based on this EA framework. If the EIA report is not acceptable to the WB, the bank will
send it back to the facilities owner for revision. In case that EIA is approved by the WB, the facilities will
be responsible for translating it into Vietnamese and for disclosing it on the location of the project and on
the website of VEA. The disclosure information will be sent to the WB, including where and when the EIA
report was disclosed.
Vietnam:
As mentioned in previous sections, all subprojects under current design would not fall into listed projects
which require EIA according to Vietnam regulations. Instead, the project owner needs to prepare an EPC
to meet with requirements of government regulations. All necessary steps to comply with requirements
specified in LEP 2005, Decree 80/2006/ND-CP, Decree 21/2008/ND-CP and the Circular 05/2008-TT-
BTNMT are described below:
The facilities owner will prepare an EPC dossier in Vietnamese and submit to the People’s Committee at
the district level or authorized People’s Committee at commune level where the project is executed. The
EPC dossier consists of:
01 copy of recommendation form for certifying EPC according to Annex 25 of the Circular
05/2008-TT-BTNMT
05 copies of EPC with the structure and content according to the Annex 24 and Annex 26 of the
Circular 05/2008-TT-BTNMT of the Ministry of Natural Resources and Environment. Since the
content of EPC can be made based on the information of EIA submitted to the bank. The PMU
will take the responsibility of translation and adapt to make the required EPC.
01 copy of project document.
The time for registration of EPC for certification is before applying for construction permits. In case it
does not require construction permits, it should be submitted before commencing the projects.
In case of a qualified dossier, the People’s Committee at district or commune level is authorized to
certify, register the environmental protection commitment of the project owner according to a structure
as stipulated in Annex 27 of Circular 05/2008-TT-BTNMT. In case of registering and certifying at district
level, the People Committee at district level sends one certified dossier of environmental protection
commitment together with the certificate document to the project owner for implementation.
When the EPC dossier is approved by the People’s Committee, the PMU is responsible for informing the
WB about the situation. It will help the bank in making decision to issue the No Objection for the project.
It should be noted that there are differences between projects implemented in EVN and non EVN – sites.
While in EVN sites, the PMU of EVN will take the responsibilities of helping facility owner in drafting and
submitting of EIA for the Bank requirements as well as EPC dossier for Vietnam government, the PMU of
VEA and MOIT will takes that responsibilities for project undertaken in non EVN sites.
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4 PROJECT DESCRIPTION
4.1 OVERALL PROJECT OVERVIEW: PCB MANAGEMENT DEMONSTRATION
PROJECT
The project aims to assist Vietnam to establish a sound PCB management system that would minimize
potential environmental and health risks from unmanaged PCB oils and equipment. In so doing, the
project is designed to establish a sound PCB management in the country. This would entail significant
investment in PCB management infrastructure and strengthening of limited technical and management
capacity of all key stakeholders including the public and private sectors in Vietnam. The project will
develop a National Action Plan for sound PCB management and initiate implementation of the first phase
of the Action Plan.
Recognizing the need for better understanding of PCB situation in Vietnam, the project will give priority
to the development of a comprehensive PCB inventory and reporting system, strengthening of PCB
regulatory, institutional framework, analytical capacity, good practices for operating, handling, labelling,
transporting, maintenance, and storage of PCB equipment and wastes. Site-specific PCB management
systems including a reporting framework consistent with the policies and regulations to be established as
part of this Project will be tested in selected facilities in 10 demonstration provinces. Experience and
lessons learned from these specific facilities would be used to refine the Vietnam sound PCB
management system before the system is applied nationwide on a mandatory basis.
One of the elements in the site-specific PCB management system includes development of a maintenance
and retirement schedule for PCB equipment. The maintenance and retirement schedule will take into
account Vietnam’s obligations under the Stockholm Convention and any PCB oil and equipment phase-out
policies to be recommended by this Project. This information would provide Vietnam with an estimate of
waste matrices and waste stream. This improved understanding of PCB equipment and wastes along
with the country’s overall plan for hazardous waste management, would enable Vietnam to determine
cost-effective and environmental friendly treatment and disposal options for the next phase of the sound
PCB Management Action Plan.
The Project consists of five components:
1. PCB Management Framework and Action Plan;
2. PCB Management Demonstration;
3. Institutional Strengthening;
4. Monitoring and Evaluation;
5. Project Management.
The project components with potential environmental and social impacts include:
Component 1: “Development of PCB management framework”: This assessment has been completed
satisfactorily under TF1 “Assessment of policy, regulatory and legal framework for PCB management”.
The executive summary of the policy assessment report is given in chapter 2.
Component 2: “Demonstration of PCB management”, which will support in the demonstration
provinces:
- physical improvement of existing storage facilities;
- identify, label, maintain, and service in-use PCB equipments;
- transport and storage of retired PCB equipment and oils, and wastes;
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Component 3, 4 and 5 also have an indirect impact on environmental and social conditions but are not
subject to environmental and social impact assessment according to Vietnamese and World Bank rules.
However, in case tasks as described in component 3, 4 and 5 appear in site specific PCB management
projects, they will be covered as one integrated part in the impact assessment.
The second component, “PCB Management Demonstration project”, proposes to conduct implementation
of PCB management activities from identification to safe storage of PCB oils, equipment, and wastes for
final disposal. Procedures for implementing these activities will strictly follow the regulations and
guidelines developed under the component 1 (PCB Management Framework and Action Plan) of this
project.
Pilot implementation of these PCB management activities would be conducted at 9 selected facilities
within the eleven demonstration provinces:
Ha Noi;
Hai Phong;
Hai Duong;
Quang Ninh;
Nam Dinh;
Ho Chi Minh City;
Dong Nai;
Ba Ria – Vung Tau;
Can Tho;
Lam Dong - Da Lat;
De Nang.
In the framework of the PCB management and disposal project, different activities may be carried out
that imply environmental impacts. It concerns all kinds of activities related to PCB management on the
one hand and activities related to (pre)treatment, disposal and remediation of PCBs on the other hand.
4.2 PROJECT ACTIVITIES RELATED TO PCB MANAGEMENT
PCB management activities with an environmental impact potential include all activities:
related to the identification and inventory of PCBs and PCB containing products or equipment, like
testing of equipment, sampling and analysing oils, proper labelling of PCB-free and PCB-containing
equipment,
related to the proper handling of PCBs, PCB-containing products or equipment and PCB-waste, like
packaging, collection and transportation, temporary storage at the place of origin of the waste
preceding collection, temporary storage preceding final disposal operations or final storage,
related to reuse and recycling of PCBs and/or equipment, including decontamination techniques,
recycling of equipment and of oils, retrofilling, maintenance on PCB-containing equipment.
Issues related to PCB treatment and disposal operations are described in chapter 4.3.
Up to date PCB management in Vietnam is in its initial phase. Through the Ministry of Natural Resources
and the Environment (MONRE) a “Vietnam National Implementation Plan for Stockholm Convention on
Persistent Organic Pollutants Toward 2020” has been developed, approved and submitted (NIP, 2006).
In this plan it is outlined how POPs will be managed, reduced and eventually eliminated.
Today an initial inventory has been conducted in Vietnam which indicated that approximately 1,800
capacitors and 10,000 transformers contain PCB’s. The quantity of estimated oil amounts up to
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7,000 tonnes. It should be stressed however that the inventory is not complete so that the PCB
contaminated oil will be substantially higher i.e. estimate of 13,000 tonnes (SNC-Lavalin, 2007).
In the framework of the “PCB management and disposal project” Venitco is actually further inventorizing
and analysing PCB containing equipment, in particular capacitors and transformers.
Other management practices are for the moment not developed in Vietnam. From site visits it indeed
appeared that storage conditions are far from ideal, transformers in some cases being stored on bare soil
without protection and being exposed to weather conditions.
Recycling activities are carried out without much care and sensibilisation of the works as such leading to
potential exposure.
4.2.1 Identification of PCB-containing products and equipment
An effective policy on PCB management and disposal starts with a thorough identification of PCB
containing equipment and wastes.
A distinction between PCB-containing and PCB-free materials can be difficult, for following main reasons:
PCBs can be present in waste from old ‘open’ applications, dating from a period where the use of
PCBs in specific applications was common practice, but for which the use has stopped or has been
forbidden for a longer time. E.g. PCBs have been used in paints and glues used between 1960 and
1980, and they will still be found occasionally in construction and demolition waste as it precipitated
into concrete. It is however very difficult to screen all construction and demolition waste on the
presence of PCBs.
PCBs can be found in recycled oil products, where non PCB-containing oils and PCB-containing oils
have been recycled together and a dilution of PCBs has been taken place.
When confronted with this problem on identification of PCB-containing waste, a choice can be made
based on a risk assessment between two approaches
The application of the precautionary principle, with the treatment of the whole waste fraction under a
worst case scenario, as if it contained PCBs. This can be advised for high risk waste streams for which
treatment under a worst case scenario could turn out more economically than testing all individual
wastes. It should be examined if this is an appropriate approach for waste oils.
A follow up with random spot checks to manage the probability and the risk of encountering PCB-
containing wastes. This might be an appropriate approach for wastes possibly contaminated by ‘open’
use of PCBs.
PCB can be mainly found in following ‘closed’ applications:
Electrical transformers, in which PCB containing oil is deliberately applied as a dielectric fluid. An
identification plate can sometimes identify these transformers. Well known mark names for PCB-
containing fluids are: askarel, pyraleen, chlophen, …;
Electrical transformers, in which no PCB containing oil is applied deliberately, but where the oil might
be contaminated with PCBs during maintenance works. An identification plate will not exclude the
presence of PCBs. Testing might be necessary;
Industrial electrical capacitors with more than 1 litre of PCB-containing oils;
Small scale capacitors in older electrical household equipment;
Other electrical components like fluorescent tube ballasts, voltage regulators, electromagnets,
switches, circuit breakers, rectifiers, vacuum pumps, liquid filled electrical cables,…;
Hydraulic systems and heat transfer systems.
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PCBs can also be found in ‘open’ applications like lubricants, plasticizer and flame retardants, paints,
printing inks, varnish, wax, glues, fill mortar, wood conservation agents, chlorine bleached paper … .
4.2.2 Testing PCB content of products and oils
When the PCB content cannot be derived from the age or nature of the waste or equipment, testing on
PCB content can be useful to determine the PCB content. The Stockholm Convention considers an upper
limit value of 0.005 % of PCBs in liquids (Stockholm Convention annex A points (d) and (e)). The USA
has not yet implemented the Convention. The European POPs Regulation 850/2004, implementing the
Convention, considers a waste as PCB-containing if it contains more than 15 µg/kg.
The limit is calculated as PCDD and PCDF according to the following toxic equivalency factors (TEFs):
TEF
PCDD
2,3,7,8-TeCDD 1
1,2,3,7,8-PeCDD 1
1,2,3,4,7,8-HxCDD 0.1
1,2,3,6,7,8-HxCDD 0.1
1,2,3,7,8,9-HxCDD 0.1
1,2,3,4,6,7,8-HpCDD 0.01
OCDD 0.0001
PCDF
2,3,7,8-TeCDF 0.1
1,2,3,7,8-PeCDF 0.05
2,3,4,7,8-PeCDF 0.5
1,2,3,4,7,8-HxCDF 0.1
1,2,3,6,7,8-HxCDF 0.1
1,2,3,7,8,9-HxCDF 0.1
2,3,4,6,7,8-HxCDF 0.1
1,2,3,4,6,7,8-HpCDF 0.01
1,2,3,4,7,8,9-HpCDF 0.01
OCDF 0.0001
4.2.2.1 Sampling
Usually sampling of PCB oils in transformers is a non destructive technique that can be combined with
maintenance of the equipment. Sampling on other electrical equipment can be combined with the
process of dismantling and decontamination. Sampling on PCBs from open applications usually includes
the collection of a representative amount of well chosen waste fractions.
4.2.2.2 Testing techniques
Following standards can be used for the testing of PCB content in oils:
For PCBs in insulating liquids in transformators, capacitors…: EN61619;
For PCBs in oil waste and petrochemical products: EN12766-1 and prEN12766-2.
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The total amount is the sum of all identifiable and quantifiable congeners. Oil samples are diluted in
hexane and analysed using gas chromatography with a mass spectrometric detector or an electron
capture detector ECD, after cleaning the sample using silica/H 2SO4 silica NaOH, or using silica/sulphate
silica/benzene sulphonic acid.
4.2.3 Labelling of PCB-free and PCB-containing equipment and waste
The labelling of PCB-containing equipment or tested PCB-free equipment needs to be reliable in order to
achieve a correct waste treatment chain. All actors involved, generators, collectors, waste sorting
facilities, waste pre-treatment- recycling- or disposal facilities should at every moment be able to make a
distinction between PCB-containing equipment and PCB-free equipment based on reliable labels. This will
be useful to avoid mixing the waste or the waste oils in the decontamination and treatment phases.
4.2.4 Packaging and collection of PCB-waste
Packaging of PCB-containing waste can serve two purposes. It can be useful to separate PCB-containing
waste from non PCB-containing waste, and it can be necessary to avoid leaching or dispersion of PCBs in
the environment during the waste storage and treatment chain.
Depending on the nature of the waste, different packaging strategies can be used. When liquid waste is
packed, reusable drums can be used. It should be guarded that they are not reused to pack non PCB-
containing materials except if they have gone through a proper decontamination operation, like solvent
washing with proper treatment of the PCB-containing solvents (see paragraph 4.3.1.8).
When non reusable packaging is used, it can be necessary to treat them as PCB-containing waste if they
have made contact with the PCB in the packed waste.
Collection of PCB-waste is preferable performed by professional companies or organisations experienced
in waste handling and handling of hazardous substances. A call system seems appropriate, because PCB-
containing waste is generated occasionally by taking equipment out of use. It is not a regular waste fit
for a periodical collection (weekly, monthly collection). Potentially PCB-containing waste from households
can be collected through a bring system e.g. for electrical equipment or for private construction and
demolition waste.
4.2.5 Transportation of PCB-waste
4.2.5.1 General conditions
Key elements that have to be taken into account when shipping hazardous substances relate to:
Requested or useful documentation and safety sheets that should accompany the transport;
Technical equipment of the transport means, avoiding or limiting damage by precipitation of the
hazardous substance in the environment and avoiding health risks for the driver and the society, in
case on normal use and in case of an accident;
Adequate packaging;
Labelling;
Safe and stable loading conditions;
Level of expertise and training of the driver and the loaders;
Transfrontier shipment.
As described in paragraph 4.3.8, transfrontier shipment, mainly to incineration plants in industrialised
countries, can be a valuable alternative for local waste treatment.
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Vietnam is member of the Basel Convention since 13.03.1995, but no export of hazardous waste has
been reported under the procedures of the Convention.
According to the Convention article 4.2: ”Each Party shall take the appropriate measures to (e) Not allow
the export of hazardous wastes or other wastes to a State or group of States belonging to an economic
and/or political integration organization that are Parties, particularly developing countries, which have
prohibited by their legislation all imports, or if it has reason to believe that the wastes in question will not
be managed in an environmentally sound manner, according to criteria to be decided on by the Parties at
their first meeting.” Export of hazardous waste, if acceptable, should always be accompanied by a
procedure of consent of the involved parties as regulated by the Basel convention.
Vietnam has not yet ratified the Ban-amendment, adopted at the Second Conference of the Parties to the
Basel Convention (COP2), 25 March 1994 in Geneva in which the parties decided:
to prohibit immediately all transboundary movements of hazardous wastes which are destined for
final disposal from OECD to non-OECD States;
to phase out by 31 December 1997, and prohibit as of that date, all transboundary movements of
hazardous wastes which are destined for recycling or recovery operations from OECD to non-OECD
States.
Transfrontier shipment of PCB-waste entering Vietnam from an OECD-country could be avoided, although
the Ban amendment has not yet entered into force.
Export of PCB-containing waste is legally allowed to all countries that under the Basel convention gave
permission on import, but sustainable waste management practices could, under application of article 4.2
and in line with the idea of the Basel-ban, limit this export to OECD-countries.
4.2.6 Temporary storage of PCB-waste
Temporary storage of PCB-containing waste takes place at two different moments in the waste treatment
chain. Before the waste is collected and after collection before the waste is properly treated.
4.2.6.1 Before collection
Temporary storage takes place at the premises and under the responsibility of the generator of the
waste. Decommissioned PCB-containing equipment, mainly transformers or industrial capacitors,
sometimes stay at the place where they were used, and will only be disposed of at the moment of
demolition. In Vietnam however, decommissioned transformers and capacitors are in general stored in
storage yards in various provinces (i.e. Nam Dinh, Ho Chi Minh City, Da Nang, …). Storage conditions
may however in some cases be quite poor. Other PCB-containing waste can be temporarily stored with
the other waste waiting for a periodical industrial waste collection or waiting for proper transport to a
waste treatment or disposal facility.
The quantities of stored waste will be rather limited and will only include the locally generated waste.
The quality of waste storage depends upon the management. In optimal conditions waste should be
stored in a sheltered and guarded place with an impermeable floor and equipped with technical measures
to remediate accidental spills or leakage of liquids. The temporary storage should be limited in time, and
should be managed in a way that avoids environmental damage and that avoids the mixing of waste.
4.2.6.2 Before disposal
Waste can be temporarily stored after collection when the waste treatment capacity is not able to
immediately treat an accidental higher supply of waste. Temporary storage is necessary for all processes
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where the waste is generated or collected in a discontinuous way, e.g. when equipment is deactivated or
when a collection campaign has taken place, and the waste treatment technique is a continuous process
treating smaller amounts at the time. A balance is needed between the temporary storage and the waste
treatment, avoiding that the temporary storage is growing above the yearly treatment capacity.
On the other hand temporary storage can be necessary to collect an amount of waste that makes
treatment technically feasible or economically acceptable. This is necessary when the waste generation
or collection is a continuous process where very regularly small amounts of waste are collected (e.g. from
a lot of different SMEs) and the treatment process is operating discontinuously, treating larger batches of
waste.
Temporary storage can take place under the responsibility of the waste collector or the waste treatment
centre. The same precautionary measures as described above will be necessary, but on a larger scale.
Waste streams from different producers will be combined in the temporary storage, which requires a well
managed supervision not to allow unfavourable mixtures of waste of a different nature.
When appropriate waste treatment capacity is not yet available, temporary storage can be a solution to
wait for planned investments in final disposal infrastructure to become operational. The European
Commission uses in its Landfill Directive 1999/31/EC a threshold value on three year allowable temporary
storage for non hazardous waste and one year temporary storage for hazardous waste. If the temporary
storage of waste is longer than these thresholds, the installation is considered to be a landfill and it has
to fulfil all more stringent exploitation conditions of a landfill. The US (Code of Federal Regulation: 40
CFR Parts 264 and 265, on http://www.ega.gov/osw/inforesources/pubs/orientat/rom35.pdf) defines
storage as “holding hazardous waste for a temporary period, after which the hazardous waste is treated,
disposed of, or stored elsewhere temporary. The temporary period is not limited in time. If transporter
storage at a transfer facility exceeds 10 days, the transfer facility becomes a storage facility. Temporary
storage is in both approaches only acceptable if a final disposal operation will be realised within a limited
timeframe. If final disposal is not foreseen or if final disposal will only be realised at an undefined
moment in future, solutions other than temporary storage (e.g. export) will have to be found in a
transitional period.
4.2.7 Recycling
4.2.7.1 Recycling PCBs as PCB
As the use of PCBs is forbidden under the Stockholm Convention (article 3: parties should prohibit and/or
take the legal and administrative measures necessary to eliminate the production and use of PCB ),
recycling of PCBs is not allowed. However this recycling prohibition is refined in part II (d) of Annex I (d)
of the Convention: “Except for maintenance and servicing operations, not to allow recovery for the
purpose of reuse in other equipment of liquids with polychlorinated biphenyls content above 0.005 per
cent”. Recycled PCB may be applied for the maintenance and servicing operations on equipment that
can operate until 2025.
Recycling of PCBs should therefore be very well regulated and limited to the quantities needed for the
purpose of maintenance and servicing.
4.2.7.2 Recycling materials contaminated with PCBs
PCBs can be fully removed from equipment;
by disassembly of electrical equipment (see paragraph 4.3.1.2);
by applying a preparatory activity based on media transfer technologies like thermal desorption,
solvent washing or adsorption/absorption techniques (see paragraphs 4.3.1.7, 4.3.1.8 and 4.3.1.9).
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Once these operations have been performed, the remaining metals or materials can be fit for reuse or
recycling. Also residues from a PCB disposal operation can be fit for recycling.
Because of the high value of metal scrap, shredding and recycling transformers and other electrical
equipment becomes economically attractive. Therefore is should be avoided that non decontaminated
equipment enters into the recycling circuit.
4.2.7.3 Retrofilling
Reuse on decontaminated transformers can be achieved by applying retrofilling techniques. Since the
production of PCB-containing fluids was discontinued, several dielectric fluid options have emerged.
Replacement fluids should perform well in the field of electrical properties, physical traits, use with
switching operations, maintenance and environmental fate. They need to have similar dielectric
properties, similar stability, similar fire safety and should be less toxic or persistent.
The four predominant synthetic and natural materials that lend themselves to fire-resistant dielectric
applications are organic polyol esters, silicone-based fluids, less flammable petroleum oils, and synthetic
hydrocarbons. Mineral oils and silicones are categorised as a ‘less flammable’ substitute and are widely
used in transformers. ‘Non-flammable’ substitutes are:
Perchloroethylene (PCE) which is the most common PCB substitute but which still has many of the
properties that caused PCBs to be banned.
Trichlorobenzene (TCB) which is slightly less popular than PCE and which can create dioxins under
arcing conditions.
Tetrachloroethylene under the trade mane of Wecosol. This product is used for over 50 years and
remains stable.
The basic steps in a retrofil operation are:
Perform electrical tests;
Check for any necessary gasket or bushing replacements;
Flush with new, PCB-free mineral oil dielectric fluid;
Fill with new PCB-free mineral oil dielectric fluid;
Test for residual PCBs.
The decision to retrofil can be based on following considerations:
Cost;
Equipment usage;
Effectiveness of retrofilling process;
Disposal options for PCB liquids;
Liability;
Public perception;
Equipment downtime;
Viability of the replacement fluid;
Availability of PCB substitutes.
4.3 PROJECT ACTIVITIES RELATED TO PCB TREATMENT AND DISPOSAL
PCB treatment and disposal activities with an environmental impact potential include activities likely to be
operated in Vietnam, as identified by SNC-Lavalin (2007), that can be performed on-site or more likely
off-site in specialised treatment facilities, disregarding the nature of the PCB-containing waste that has to
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be treated. The evaluation of SNC-Lavalin is recapitulated and added in this chapter. The
recommendations of SNC-Lavalin have been taken into consideration; only treatment techniques are
described that are likely to be applied for in Vietnam. Other techniques will not be subject of an EIA in
Vietnam.
4.3.1 Pre-treatment techniques
The treatment of hazardous waste usually can be described as a chain of different process steps, where
the waste is pre-treated to give it the appropriate physicochemical properties, (size, state of aggregation,
water content, concentration or solution, acidity, calorific value, …), next the waste is handed over for its
actual disposal operation and hereafter the disposal residues can be submitted to another waste
treatment installation. These subsequent treatment steps can take place either in one plant or in several
spatially separated installations.
The pre-treatment techniques described below can be combined with the disposal operations described
in the next paragraphs, depending on the nature of the waste.
Table 4-1: Matrix of pre-treatment and treatment techniques
catalysed
including
Chemical
process
Cement kiln co-processing
Plasma arc decomposition
reduction (GPCR)
Alkali reduction
Wet air oxidation
Phase
decomposition
sodium
(BCD)
Base
Gas
Dewatering X X X
Electrical equipment X X X X X X
disassembly
Shredding X X X X X
Screening X X X X X
Oil/water separation X X X
pH adjustment X X
Soil washing X X X X X
Thermal desorption X X X X
Solvent washing X X X X
Adsorption/absorption X X X
Depending on the size of the required installation and the complexity of the applied technique some pre-
treatment techniques can be applied on the spot where the PCB-containing waste or soils originate from,
while other techniques are strictly connected to or integrated with a treatment or recycling technique off-
site. Most techniques are fit for both an on-site or off-site configuration.
4.3.1.1 Dewatering
Dewatering is a pre-treatment approach that partially removes water from the wastes to be treated.
Dewatering can be employed for destruction technologies which are not suitable for aqueous wastes
(e.g. molten sodium), for which dewatering can serve to augment the calorific value, for which
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dewatering is an interesting technique to reduce size and quantity of the waste to be treated or to
change the state of aggregation (e.g. solid versus liquid).
Both resulting waste streams, the soil/solids and the water/liquids, will likely require treatment after
separation.
There is wide-variety of dewatering techniques that depend on the matrices being treated. Soil de-
watering techniques include plate-and-frame filter presses, drum filters, vacuum filters, centrifuges and
many other systems. Selecting the systems for remediation is dependent on the characteristics of the
waste to be treated (water content, particle size and distribution, through-put, end-point conditions,
etc.). Thermal systems commonly called driers can also be used for dewatering. These technologies are
well-developed and commercialized.
The most important potential source of pollution from dewatering is the waste water stream. Improper
removal of waste water might cause surface water contamination and as a consequence ecotoxicity to
aquatic life and indirect health risk to man.
4.3.1.2 Electrical equipment disassembly
Large and medium-sized liquid-filled transformers comprise steel vessels, containing the dielectric fluid,
windings and supports (lumber and paper). Once the oil has been drained, the transformers can be
broken down. Lumber and paper can be separated and contained for destruction. The cores have proven
resistant to solvent washing and also require a multi-stage pretreatment approach which includes
shredding, as well as the application of a direct destruction technology (i.e. incineration). The steel
vessels, often referred to as hulks or carcasses, can be solvent washed (see 4.3.1.8) or subject to a
destruction technology.
Other, smaller scale electrical equipment can contain PCBs in quantities less than 1 litre PCB-containing
oils. Mainly small sized capacitors in fridges, washing machines, fluorescent lighting ballasts, public
lighting armatures, industrial applications like power-current compensating capacitors for electrical
installations, UPS emergency power supply on batteries, small one-phase motors for pumps or fans with
a fixed capacitor, larger thyristor rectifiers (filter capacitors). Most small PCB containing household
equipment has an age of above 20 years as production ceased long time ago. However, hazardous
components, including PCB-containing capacitors, should be removed from electrical and electronic waste
before further treatment.
Small capacitors in fluorescent lighting ballasts can be broken down with the objective of size reduction.
Mobile trailers have been specifically designed for the disassembly of fluorescent lighting ballasts.
As long as electrical equipment disassembly is executed on an impermeable surface, no major pollution
sources are expected from this pre-treatment technique.
4.3.1.3 Shredding
Some technologies are only able to process wastes within a certain size limit. For example, some will
handle PCB contaminated solid wastes only if less than 200 microns in diameter. Shredding can be used
in these situations to reduce the waste components to a defined diameter. By reducing particle size,
shredding creates more surface area, increases exposure to treatment chemicals or systems (heat, light,
etc.). Small solid parts, such as capacitor pans from fluorescent lighting ballasts, are more accessible to
treatment after they have been shredded as the oil is no longer encased in metal.
Shredding can be a pre-treatment method for all solid PCB-containing waste. Next to the electrical
equipment and its components it can be applied to open applications. PCBs used to have a broad field of
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application, not only as an isolating fluid in capacitors and transformers, but also as a hydraulic oil,
coolant, lubricant, plasticizer in plastics, as a composing element in paints, inks, varnish, glue and
adhesives.
If shredding takes place on a hardened surface, no major pollution sources are expected. If not, this
technique can cause soil and groundwater pollution. In badly insulated conditions, noise production can
be relevant.
4.3.1.4 Screening
Screening as a pre-treatment step can be used to remove debris from the waste stream or for
technologies that may not be suitable for both soils and solid wastes. There are several screening
technologies commercially proven and developed including grizzly screens, drum screens and vibratory
screens amongst others. Such screening systems are widely available and commonly used in waste
management and remediation operations.
No major pollution sources are expected from this pre-treatment technique.
4.3.1.5 Oil/water separation
Oil/water separation is necessary for those treatment processes which are not suitable for aqueous
wastes (e.g. molten sodium) or which are not suitable for oily wastes. Both the water and the oily phase
may be contaminated after the separation and both may require a specific treatment.
PCBs are lipophylic/hydrophobic. They tend to partition to oils and fats and away from water, which
makes oil-water separation technology an interesting pre-treatment technique in the treatment chain to
concentrate the PCBs.
Oil/water separation is an old technology with many commercially proven and developed options. The
selection of specific systems depends on material and sizing characteristics. Common oil/water separation
systems include baffled gravity separators, skimmers and far more complicated systems such as
centrifuges. Chemical treatment may be required to remove soluble oils or disperse colloids.
The most important potential source of pollution from the oil/water separation pre-treatment technique is
improper removal of the water or oily phase. This might lead to surface water contamination, ecotoxicity
to aquatic life and even indirect health effects.
4.3.1.6 pH adjustment
Some treatment technologies are most effective in a defined pH range and in these situations, caustic,
acid or CO2 are often used to control pH levels. Some technologies may also require pH adjustment as a
post-treatment step. As PCBs are neither basic nor acidic, their presence does not influence the pH itself,
but other components in a wastewater stream may do so, particularly for such technologies as sodium
reduction.
No relevant pollution sources are expected from this pre-treatment technique.
4.3.1.7 Low temperature thermal desorption (LTTD)
Low-Temperature Thermal Desorption (LTTD) is a media transfer technology, also known as low-
temperature thermal volatilization, thermal stripping or soil roasting. It is used as an ex-situ remediation
technology that uses heat to physically separate volatile and semi-volatile compounds and elements
(most commonly petroleum hydrocarbons) from contaminated media (most commonly excavated soils).
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The same techniques can also be used for the decontamination of non-porous surfaces of electrical
equipment such as transformer carcasses that formerly housed PCB-containing dielectric fluids.
For soil, two common thermal desorption designs operating as continuous process are rotary dryers and
thermal screws. Rotary dryers are horizontal cylinders that can be indirectly or directly-fired and are
usually fuelled by natural gas or fuel oil. The dryer is normally inclined and rotated to ensure good mixing
of the material being treated. In thermal screw units, hollow augers known as screw conveyors, transport
soil through an enclosed trough. Hot oil or steam is circulated through the auger to indirectly heat the
soil.
For electrical equipment, batch desorbers are used. The difference between thermal desorption units and
incinerators is the end point objective which determines the temperature to which the material is raised.
LTTD only volatilizes contaminants, hence, has lower temperatures than incinerators. Although the solid
phase, whether soil or electrical equipment would no longer be considered “contaminated”, the vapour
stream requires further treatment as all contaminants have been transferred to this phase. The method
of treatment is dependent on the nature of the contaminant, concentration and other physical factors.
For PCBs, vapours are commonly incinerated at high temperatures, although absorption by activated
carbon is possible for low concentration vapours. If the gas phase is subject to condensation or
scrubbing, further treatment of the concentrated liquid state by a non-combustion technology is possible.
Potential pollution sources for this pre-treatment technique are the vapour phase, which has to be
treated properly, and in some cases concentrated liquids.
4.3.1.8 Solvent washing
Electrical equipment such as capacitors and transformers are difficult to treat, but if PCBs are removed by
solvent, the contaminated solvent has many disposal options. This technology has also been used
successfully for the treatment of contaminated soil. It is fit for PCB removal from containers (i.e. drums)
and electrical equipment (i.e. transformer carcases, capacitors, etc…). Although occasionally adequate for
casings, the internal components of the transformers (core and windings) fail to meet objectives when a
traditional technique of soaking the equipment with solvents is used.
Autoclaving is a batch process using solvent to extract PCBs from electrical equipment. The system works
in cycles. After loading the waste to be cleaned, a vacuum is applied and solvent charged. The chamber
is heated to drive off water. The solvent, containing PCBs, is drained and distilled to produce clean
solvent for re-use and PCB wastes for further treatment (generally high temperature incineration or alkali
reduction).
The techniques of solvent washing have problems to compete with less laborious techniques with higher
efficiency like waste incineration which can cope with the entire equipment, possibly after shredding.
The most important pollution source of solvent washing is the contaminated solvent. In case the solvent
is not treated well, it might cause surface water pollution, ecotoxicity to aquatic organisms and indirect
health effects.
4.3.1.9 Adsorption/absorption
Sorption is the general expression for both absorption and adsorption processes. Sorption is a pre-
treatment method that uses solids for removing substances from gaseous or liquid solutions. Adsorption
involves the separation of a substance (liquid, oil) from one phase and its accumulation at the surface of
another (zeolite, silica, etc.). In the case of absorption a material is transferred from one phase to
another, interpenetrates the second phase to form a solution (e.g. organic compounds such as PCBs
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transferred from liquid or vapour phase into activated carbon). The sorbent then requires treatment to
destroy the contaminant. For activated carbon contaminated with PCBs, incineration is commonly used.
These pre-treatment technologies may be used to concentrate contaminants and separate them from
aqueous wastes. The concentrate and the adsorbent or absorbent will require destruction treatment.
Sorption pre-treatments should produce wastewater which meets discharge criteria if initial
concentrations are low. There are several sorption technologies commercially proven and developed.
Potential pollution sources are improper removal of sorbents and wastewater. Removal of sorbents might
cause soil and groundwater pollution. Discharging of untreated wastewater can be the cause of surface
water pollution, ecotoxicity to aquatic organisms and indirect health effects.
4.3.2 Alkali reduction including sodium
Sodium reduction technology is a technique applicable mainly for PCB removal from oil transformers. It is
a variant of a technique where sodium ions are solvated in ammonia, but here no ammonia is used and
the sodium ions are solvated in the oil itself. The solvated electrons in the solution act as powerful
reducing agents removing the halogens (primarily chlorine) from the PCB molecules. The sodium reacts
with the chlorine atoms in the PCBs to form non-toxic salt and biphenyls. The solvated electron reaction
is highly exothermic. In application, contaminated oil is placed into a sealed treatment vessel and mixed
at room temperature, and brought into contact with the solvated electrons. Depending on the matrices
treated, pre-treatment and/or post-treatment may be required. Possible pre-treatments are water
removal, crushing, screening and washing. Possible post-treatments include pH adjustment. Most of this
processed oil can be resold as reclaimed oil and return to service.
Treatment systems using this technology are both transportable and fixed. A mobile system in operation
has a capacity of 15,000 litres of oil per day. The process is patented and has a destruction efficiency
estimated by SNC Lavalin of 95 % to 99 %. A similar approach is the dechlorination of organic
compounds in mineral oils which can be undertaken by alkalis other than sodium. The use of potassium
tert-butoxide (t-BuOK) has been commercialized in Japan since 2004. There is one operating plant
treating 36,000 l/day. Destruction efficiencies of 99.98 % to 99.99 % were reported.
Sodium is a hazardous, reactive element and it is a challenge to manage the reagents involved in the
treatment process safely.
Potential impacts related to alkali reduction (reduction destruction method) are summarised in Table 5-2.
4.3.3 Base catalysed decomposition process (BCD)
The Base Catalyzed Decomposition process treats liquid and solid wastes in the presence of a reagent
mixture consisting of a high boiling point hydrocarbon, an alkali (sodium hydroxide or sodium
bicarbonate) and a proprietary catalyst. When heated (315 to 500 ºC), the reagent produces highly
reactive atomic hydrogen, which reacts with organochlorines and other wastes. The residues produced
from decomposition are an inert carbon residue and sodium salts. After the reaction, solid residues are
separated from the residual oil by gravity or centrifugation. The oil and catalyst may be recovered for
reuse.
The operation of this process can be either on a continuous basis or by batch. In practice, the
contaminated liquid is pumped into a heated reactor containing the hydrocarbon oil, sodium hydroxide
and the catalyst. The reaction is rapid. For solid waste treatment, the waste needs to be premixed with
the catalyst and fed into a heated thermal desorption unit. Depending on the pollutant concentration in
the feed, some can be collected from the thermal desorption condensate. If the contaminant level is high
and the decomposition is not complete, then the resulting condensate is treated in a liquid BCD reactor.
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Some pre-treatment may be required depending on the waste to be treated. The possible pre-treatment
steps include premixing, shredding, screening and dewatering.
The destruction efficiency of this proven technology is very high (99.9999 %). The process can treat
100 kg/h to 20 t solid waste /h on a continuous basis and 1 to 5 t solids/batch with 2 to 4 batches a day.
For liquid waste, the capacity is typically 4,500 to 9,000 l with 2 to 4 batches a day. Higher
concentrations in the waste require longer reaction time. The possible configuration of the technology
ranges from modular to transportable units as well as fixed plants.
The technology requires the use of chemical products in large quantities, which requires skilled operators
and well-defined safety procedures. Further analysis of the material could be required since the
condensate has to be treated if concentrated in the contaminants. There was a measurable discharge of
dioxins and organochlorines to the atmosphere for the older plants but this problem has been addressed
by the replacement of the old hydrogen donor with the hydrocarbon oils now in use. The air emissions
are as low as monitoring equipment can detect and ancillary liquid and gas scrubbing units further
minimize pollution risks.
Potential impacts related to the base catalysed decomposition process, are summarised in Table 5-2
(reduction destruction method).
4.3.4 Gas Phase Chemical reduction (GPCR)
The GPCR process is a two-stage process, beginning with heating the waste in the absence of oxygen to
temperatures around 600 ºC, causing organic compounds to desorb to the gas phase. The solid or liquid
phase of the waste is treated and cooled for non-hazardous disposal. In the second stage, a gas-phase
thermo-chemical reaction of hydrogen with organic compounds occurs at a high temperature (approx.
850 °C) in a reaction vessel. The organic compounds are reduced by the hydrogen to methane, hydrogen
chloride and minor amounts of low molecular weight hydrocarbons in the GPCR reactor. The reduced
gases are then scrubbed to remove the particulates and acid before being stored for reuse as a fuel. The
process can also operate without any external hydrogen supply if the methane produced, is converted
back to hydrogen.
As this reduction reaction occurs in the gas phase, pre-treatment is required for liquid and solid wastes
These pre-treatments (vaporizer, thermal desorption batch processor (TRBP), TORBED Reactor Systems
and liquid waste pre-heater systems (LWPS)) are part of the GPCR technology. The water and aqueous
solutions could be evaporated using a steam heated vaporizer and then fed into the process. The bulk
solid wastes are processed via a Thermal Reduction Batch Processor (TRBP) or thermal desorption, which
is an oven-type chamber where the contaminants are volatilised. The organic vapours are then sent to
the GPCR reactor. Contaminated soils/sediments can be pre-treated with the TORBED reactor, which
allows higher throughput. Dewatering of waste material is not required.
Measured destruction efficiencies are 99.9999 % for PCBs. This process is flexible and can be applicable
to bulk solids, contaminated soils/sediments and liquids including oils. Some limitations are identified. For
example, the pre-treatment can be limiting in the case of large equipment to be decontaminated. The
treatment of waste containing arsenic as well as mercury produces highly toxic arsenic and mercury
compounds.
Even though mobile units are available, this technology remains mainly as large fixed plants. The
capacity of mobile units is limited by the necessary ancillary equipment. The size and complexity of this
ancillary equipment is significant.
The benefits of this technology are the high efficiency of the process (low emissions) and the range of
matrices and contaminants that can be treated. All PCB wastes, including transformers, capacitors and
oils can be treated using this system. On the other hand, its limited capacity can be a disadvantage
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depending on the amount of waste to be treated and some by-products are generated which need to be
disposed of (used liquor and solid residues). This technology could be considered as ‘high tech’ meaning
that some skilled operators would be required to operate such a plant. The principal raw materials and
ancillaries required for this process are electricity, hydrogen (at least during start-up), water and caustic.
The use of hydrogen at high temperatures is a significant risk and comprehensive fire safety and security
measures are required for its management.
GPCR technology is recommended for low and high concentration POP destruction, in the described
matrices, for industrial regions. GPCR is also recommended for use in remote locations. Access to fuel,
spare parts and properly trained maintenance personnel would be required, but hydrogen and electricity
could be generated locally.
Potential impacts related to the gas phase chemical reduction (reduction destruction method) are
summarised in Table 5-2.
4.3.5 Cement kiln co-processing
Combustion technologies suffer from poor public perception. There is a strong belief amongst the public
that such technologies generate harmful dioxins and furans (PCDD/F) and release them to the
atmosphere. Regulatory controls on emission rates need to be installed to address these concerns. The
European Union requires a temperature greater than 850 ºC to be maintained for at least two seconds to
destroy PCDD/F and to avoid precursors, and in case of more than 1 % of halogenated organic
substances, expressed as chlorine, the temperature has to be raised to at least 1,100 ºC. The US-EPA
requires a 2 second residence time at 1,200 ºC and 3% excess oxygen or 1.5 second resident time at
1,600 ºC and 2 % excess oxygen in the stake gas.
Unlike other currently applied incineration processes with a two stage incineration process, cement kiln
co-processing is an single stage process. Temperatures reach 1,450 °C in a cement kiln and the
combustion gases stay above 1,200 °C for five to six seconds destroying most POPs in the process. The
cement kiln is an oven that rotates to expose limestone, sand and clay evenly to make cement clinker.
The clinker process includes a large quantity of lime (in excess) that will neutralize any traces of sulphur
and chlorine. Mineral elements are fixed in the crystalline pattern of the clinker. Dust is produced,
collected and reintroduced into the process. The cement kiln does not produce any liquid or solid waste.
The use of hazardous waste as fuel, including chlorinated solvents such as PCBs, has proven to have no
impact on the quality of the cement product. Furthermore, the use of the cement as a building material
has shown no long term environmental or safety consequences. The lack of solid residues after treatment
is a distinct advantage over other incineration technologies.
SNC Lavalin (2007) quotes a demonstrated destruction efficiency ranging between 99.95% and
99.999999 % and they reach a emission limit of 0.1 ng TEQ/Nm³ and a maximum concentration of
0.4 μg/Nm³ of PCBs in cement.
The technology will destroy POP-contaminated liquid, non aqueous waste, powder, sludge and soil. Pre-
treatment may be required to create the physical conditions for entering the waste into the kiln. Liquid
hazardous waste is either injected separately or blended with a primary fuel or a sorbent. Solid waste is
mixed and burned along with the primary fuel. Wastes must be blended with a fuel suited to the cement
process itself. Under proper conditions, the risk to the environment and humans can be minimal.
Irregularities in the process may cause incomplete combustion resulting in polluting emissions.
Highly qualified technical personnel are necessary to operate the system. Considering the process
technology, there is medium potential for exposure. Formerly, Cement kiln disposal (co-processing) was
not an accepted technology by the Basel Convention because there is insufficient evidence that the
process is “dioxin-free” (GEG, 2004). As more data are provided on emissions which prove that the
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technology meets appropriate standards (such as those of the EU), this was be reconsidered and cement
kiln co-processing is now included on the list of acceptable destruction technologies for POPs and PCBs.
The environmental benefits of co-processing waste and hazardous waste in cement kilns can be
summarized as follows:
decrease the combustion of virgin fuels;
decrease the need to extract and refine virgin fuels;
decrease the need to construct alternate treatment facilities (cement kilns are already
constructed);
decrease the use of non-combustible raw materials (i.e. replacing some limestone and other
precursors with slag and ash);
decrease the need to quarry and transport the non-combustible raw materials;
decrease the need to transport hazardous waste over long distances (the economics of the
cement industry mean that kilns are generally within 200 to 300 km of their customers, due to
transportation costs, and are thus widely distributed over every country);
decrease the need to dispose of non-hazardous waste in landfills (no solid waste generated, solid
residues are incorporated into the cement clinker); and
decrease the need for treating or disposing of hazardous non-combustible waste.
As with many developing countries, the cement kilns in Vietnam are a combination of old, out-dated
plants and new, state-of-the-art, facilities. Only the most modern plants should be considered for
hazardous waste destruction (including PCBs and other POPs). The technology should only be used in
cement plants that can demonstrate competent waste management systems and good kiln temperature
control, in accordance with the guidance documents elaborated by the World Business Council for
Sustainable Development and the cement industry. These documents provide insight into the regulatory
control of plants, waste selection, air emission control and monitoring amongst other elements
(http://www.wbcsdcement.org).
It is important that cement kilns, when active in the field of waste incineration, respect the same
emission limits as imposed on waste incineration plants, and take measures to avoid environmental
impacts. The most frequent environmental complaints are related to dust, fine-dust PM10, odour and
noise.
Potential impacts related to cement kiln co-processing (combustion/incineration) are summarised in Table
5-2.
4.3.6 Plasma arc decomposition
The principles of plasma arc decomposition are that an electrical arc is struck between two electrodes.
Chlorinated organic compounds are transformed into their elemental states and recombined into mineral
gases. The plasma arc technology directs an electric current through a low pressure gas to create a
plasma. The waste is injected into the plasma at a temperature that can reach 3,000 to 15,000 °C.
Plasma arc decomposition is available in three processes. Although the main goal of the technology is the
destruction of PCBs, it is worthwhile to investigate the energy balance of the energy consuming plasma
arc process and the valorisation of the obtained gasses. Safe waste and Power (www.
Safewasteandpower.com) suggests a net energy production, but this largely depends upon the nature of
the waste fed to the system. The technology is used for energy recovery from a large scale of carbon
based substances, like PCB-containing oils. These three processes however do not include energy
recovery but do include extensive gas treatment.
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The three processes are the pact process, the Plasma Converter System and the Plascon process. Since
the application possibility in Vietnam seems limited, these thermal non-combustion methods are not fully
described.
The most important potential source of pollution from this technique is improper treatment of the
obtained gasses, possibly leading to air pollution.
4.3.7 Wet air oxidation (WAO)
WAO is the oxidation of soluble or suspended components in an aqueous environment using air as
oxidant. It can treat liquid waste and sludges with high organic contents. The process oxidizes and
hydrolyzes organic contaminants in water at temperature of 150 to 320 °C and pressures of 10 to
210 bars, which is below the critical temperature and pressure of water. At these elevated temperatures
and pressures, the solubility of oxygen in water is dramatically increased, providing a strong driving force
for oxidation. With residence times between 60 to 120 minutes, the technology converts organics into
CO2, H2O, and short chain biodegradable compounds such as acetic and formaldehyde. Depending upon
waste characteristics, bioremediation as a post-treatment may be required. Wastewater with low pH may
cause corrosion damage to the metals used in the WAO. PH adjustment as pre-treatment may be
required. Post-treatment evaluation for the potential products of incomplete oxidation must be
considered prior to implementing this technology.
WAO is a mature technology with more than 300 units installed worldwide. Capacities of Zimpro WAO
installations are between 0.5 and 66 m³/h. However it is not clear how effective the technology is in
treating PCBs. Tests on the actual contaminated waste should be conducted to evaluate its suitability. It
could possibly be used for the destruction of low concentration of PCBs depending on test results.
The WAO process does not always achieve complete oxidation of the organic compounds. By-products to
the environment will be produced with this technology, but can be eliminated with further treatment like
activated carbon for vapours and biotreatment for liquid. High levels of electricity are required, although
heat energy can be recovered. Some concentrated wastes might require pure or enriched oxygen.
Titanium, expensive and not easily available, is recommended to prevent corrosion. There is low risk to
the environment and humans. The technology is intrinsically safe with regards to the risk of runaway
reactions. In the presence of chloride and high temperature, the process requires high performance
construction materials and preventive maintenance is very important. Qualified technical personnel are
necessary to operate the system. Considering the process technology, there is high potential risk for
worker exposure. This technology is available on compact skids and on large scale static installations.
Potential impacts related to wet air oxidation (combustion/incineration) are summarised in Table 5-2.
4.3.8 Other techniques
All techniques described above are considered by SNC-Lavalin as applicable in Vietnam, in one way or
another. Technology is either already present (cement kilns) or companies have been found interested in
importing the technology and applying it in a local Vietnamese context. However, treatment of PCBs and
PCB-containing waste can be performed abroad when transfrontier movement of the waste and
treatment in e.g. Australia, Japan or Europe would be environmentally and economically more feasible or
desirable than treatment at the place of origin of the waste. Techniques that are used abroad and that
are fit for PCB destruction, apart from the techniques mentioned above, are mainly different types of
waste incineration:
Rotary kiln incinerator with after burner and various air pollution devices;
Fluidized bed incinerator;
Static incinerator.
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These incinerators are only found in industrialized countries because of their capital costs and also
because highly trained personnel are required. Regular maintenance and services, intensive control
procedures including analytical facilities are also necessary. A continuous supply of fresh water, large
quantities of chemicals for the scrubber and a reliable supply of electricity and fuel are needed. It should
also be recognized that gas scrubbers are required with a good control/treatment of the other residues
like ashes and so forth.
Potential impacts related to these kinds of incineration techniques (combustion/incineration) are
summarised in Table 5-2.
4.4 PROJECT ACTIVITIES RELATED TO SITE REMEDIATION
PCB site remediation activities include in-situ activities on PCB pollution in soil or groundwater. Treatment
of excavated and transported soils is not mentioned when this is covered by the techniques discussed in
paragraph 4.3. Hereafter the techniques like soil washing, thermally enhanced soil vapour extraction and
soil flushing, as final treatment methods for in situ soils are explained.
Potential impacts related to site remediation activities (site remediation) are summarised in Table 5-2.
4.4.1 Soil washing
Soil washing is a volume reduction technology for excavated contaminated soil. Soil comprises varying
sized particles, from fines to boulders. As contaminants are only adsorbed onto the smaller particles,
separating the particles by size allows for more economical and efficient treatment. Soil washing
comprises a multi-stage sizing procedure, beginning with the removal of large particles (stones, cobbles,
boulders, etc.) by mechanical screening and then mixing the soil with water to form a slurry which is
then separated by a variety of methods, most developed for mining ore extraction techniques. The fines
generated contain the majority of contaminants. The stones, cobbles and boulders, once washed clean of
fines, are generally-contaminant-free and can be used as fill. The concentrated fines are less expensive
to transport, store, treat or destroy, whichever management strategy is selected.
Soil washing can be performed in large static installations or in small scale mobile installations, with
comparable results.
4.4.2 Thermally enhanced soil vapour extraction (SVE)
Under this approach for in situ treatment, heating is used to increase the volatilization rate of semi-
volatiles and facilitate extraction. Once extracted the contaminants need to undergo a further off-site
treatment as described in chapter 4.3.
Heating can be realised by steam/hot air injection or electrical resistance/ electromagnetic/fiberoptic/
radio frequency heating. The system is designed to treat some PCB congeners. After application of this
process, subsurface conditions are excellent for biodegradation of residual contaminants.
The following factors may limit the applicability and effectiveness of the process:
Debris or other large objects buried in the media can cause operating difficulties;
Performance in extracting certain contaminants varies depending upon the maximum temperature
achieved in the process selected;
Soil that is tight or has a high moisture content has a reduced permeability to air, hindering the
operation of thermally enhanced SVE and requiring more energy input to increase vacuum and
temperature;
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Soil with highly variable permeabilities may result in uneven delivery of gas flow to the
contaminated regions;
Air emissions may need to be regulated to eliminate possible harm to the public and the
environment. Air treatment (and permitting) will increase project costs;
Residual liquids and spent activated carbon may require further treatment;
Thermally enhanced SVE is not effective in the saturated zone, however, lowering the aquifer can
expose more media to SVE (this may address concerns regarding light non-aqueous phase
liquids);
Hot air injection has limitations due to the low heat capacity of air.
Remediation projects using thermally enhanced SVE systems are highly dependent upon the specific soil
and chemical properties of the contaminated media. This technology may be suitable for some specific
sites and should be evaluated on a case by case basis.
4.4.3 Soil flushing
For soil flushing methods water, or water containing an additive to enhance contaminant solubility, is
applied to the soil or injected into the groundwater to raise the water table into the contaminated soil
zone. Contaminants are leached into the groundwater, which is then extracted and treated by one or
more methods as described above in chapter 4.3. The target contaminant group for soil flushing is
inorganic wastes including radioactive contaminants. The technology can be used to treat PCBs but it
may be less cost-effective than alternative technologies for this type of contamination. There has been
very little commercial success with this technology. The addition of environmentally compatible
surfactants may be used to increase the effective solubility of some organic compounds, however, the
flushing solution may alter the physical/chemical properties of the soil system. The technology can
mobilize a wide range of organic and inorganic contaminants from coarse-grained soils.
Factors that may limit the applicability and effectiveness of this process include:
Low permeability or heterogeneous soils are difficult to treat;
Surfactants can adhere to soil and reduce effective soil porosity;
Reactions of flushing fluids with soil can reduce contaminant mobility;
The potential of washing the contaminant beyond the capture zone and the introduction of
surfactants to the subsurface concerns regulators. The technology should only be used where
flushed contaminants and soil flushing fluid can be contained and recaptured;
Above ground separation and treatment costs for recovered fluids can impact the economics of
the process.
4.4.4 In situ vitrification
In-situ vitrification uses electricity to melt contaminated soil or wastes at high temperature. The organic
pollutants are destroyed by pyrolysis and inorganic compounds are immobilized within the vitrified glass.
Large graphite electrodes are inserted into the soil. Electricity arcs from one electrode to another through
the soil. Temperatures reached vary from 1,400 to 2,000 °C. The heat reduces the soil into a molten
form. The electrodes move deeper as the ground liquefies and continue to melt the soil until the
maximum depth is reached. The estimated achievable depth is 9 meter. The electricity is then shut off
and the soil solidifies into glass. The organic pollutants are reduced into gases that are collected and
transported for treatment.
When the vitrification process is completed, the fused glass block can be left in place. The blocks can
weigh as much as 1,400 tons and are not subject to breakdown or other decomposition from the
environment.
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The in-situ vitrification technology is commercially available (Geomelt, Geosafe). The technology is
suitable for a wide range of soil, dewatered sludge, sediment, and wastes. Permeability and density tests
should be performed for each site. The soil should have sufficient amount of glass-forming materials
(silicon, aluminium oxides) and metals. The technology has been applied on matrices contaminated with
PCBs. Destruction efficiencies have been reported between 90 and 99.99 %. The vitrification process is
limited by the availability of power.
Volatile organic compounds and combustion products can escape from the off-gas treatment system. The
soil should be dried prior to melting to prevent the release of dangerous gases. Electrodes, a
transformer, off-gas collection hood, off-gas treatment system and water are the required materials. A
mobile skid is available. SNC Lavalin estimates that there is low risk to the environment and humans,
considering that the off-gas treatment system is designed in a way to prevent leaks. Considering the
process technology, there is low potential for worker exposure. The technique is expensive and therefore
useful for highly contaminated and mixed waste sites.
4.4.5 TiO2 enhanced photocatalysis
Organic compounds, such as PCBs, can be completely degraded in an aqueous environment by UV
irradiation in the presence of oxygen and TiO 2 based photocatalysts. The solution is placed into the
reactor with TiO2 as a photocatalyst. The photocatalyst is made out of titanium dioxide (0.1 to 0.5 % by
weight) on glass micro-spheres, which are immobilized on a fixed support or on the reactor wall for easy
separation once the reaction is completed. If not, the reactor has to be supplemented by liquid-solid
separation as a post-treatment step. Skimming could be a separation method used since the TiO 2 micro-
spheres float on the water surface due to their low bulk density. Once the solution to be treated is into
the reactor with the catalyst, the irradiation process starts with an UV source between 300 to 360 nm
and contaminants are degraded. This process is usually rapid.
This technology is commercially available (Purifics Photo-Cat). It can reduce PCBs in soil, water and
aqueous solutions and sludge to acceptable discharge standards. Destruction efficiency mounts up to
99.99 % for PCBs. No by-products to the environment can be produced with this technology. The
technology requires electricity. It is available on skids and the installations are compact. Considering the
process technology, there is low potential for worker exposure. The technology is fit only for small scale
treatment (groundwater), as this technology is not ideal for scale-up to larger operations. It can be used
as part of a treatment train for cleaning an aqueous wastewater or treating contaminated groundwater.
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5 ANALYSIS OF POTENTIAL IMPACTS (SCOPING)
In this section, impact identification is carried out. The aim of this scoping is to identify all impacts which
appear to be of potential importance at this stage. The list of impacts is not exhaustive for the following
reasons:
A number of projects elements are only in the planning phase so that their characteristics and as
a result the exact importance of their environmental impact cannot be assessed;
It is necessary to limit the assessment to a manageable number of relevant impacts that are
selected by the expert team.
The scoping exercise is provided under the form of activity/impact matrices (Table 5-1, Table 5-2).
For clarity reasons the PCB management and disposal projects have being analysed in two different
tables. The first table includes all management issues until final storage. In the second table the
different treatment techniques are taken into consideration. Furthermore the different activities/projects
likely to be carried out when managing and/or disposing PCB’s have been grouped as a function of their
potential environmental impacts. For each of the different treatment, disposal and remediation methods,
dismantling associated pre-treatment and post treatment techniques have also been taken into account.
It should also be noted that when identifying potential effects also impact linked to construction activities
are taken into consideration.
Further on, in the impact assessment section, the origin/cause of the impacts will be discussed. The
assessment will be based to a maximal extent on quantitative criteria. The assessment criteria which will
be outlined and discussed in each separate chapter and will primarily be based on environmental quality
objectives, basic values and limits from the legislation of Vietnam whenever available. Given the
importance of the project, however, the assessment will also be carried out in relation to international
quality objectives and guidelines. Reference will be made in particular to the World Bank’s Operational
Policies and Directives. Other assessment criteria which will be applied are e.g. surface loss,
modifications expressed as percentage, increase of diminution, etc. The assessment output will be based
on the following criteria:
Magnitude: referring to the quantum of change to be experienced;
Extent: referring to the area which will be affected;
Significance: referring to the importance of the magnitude considering the present situation;
Special sensitivity: referring to region specific situations of sensitivity e.g. protected habitats.
For the assessment of the importance of impacts other factors such as reversibility and duration will also
be taken into account. Both direct and indirect effects will be considered.
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Table 5-1: Scoping for potential impacts related to presence, management, transportation and storage of PCB containing materials
Impact Presence of PCB Testing Handling oils, Replacement, retro filling, Temporary (final) Transportation
containing equipment materials and recycling storage
materials waste (packaging,
labelling)
Water and aquatic resources
Ground water contamination X2 (X)3 X X X (X)
Surface water contamination X (X) (X) X X (X)
Soil and waste
Soil contamination X (X) X X X (X)
Waste production X X X
Climate, air and noise
Air emissions of POPs X X (X)
Dust formation (X) (X)
Noise production (X)
Ecosystems
Loss of ecol. valuable areas X (X)
Ecotoxicity to terrestrial life X X X X
Ecotoxicity to aquatic life X (X) X X
Land use
Land use change X
Losses of sites with X
archaeological, historical and
cultural value
2
Potential environmental impact
3
Potential environmental impact not likely to occur
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Impact Presence of PCB Testing Handling oils, Replacement, retro filling, Temporary (final) Transportation
containing equipment materials and recycling storage
materials waste (packaging,
labelling)
Man and his social economic living environment
Direct health risks (direct X (X) X X X (X)
exposure)
Indirect health risk X X X X
Nuisance (dust, noise) (X)
Social effects (resettlement) X X X
Social effects (employment) X (X)
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Table 5-2: Scoping for potential impacts related to treatment, disposal and site remediation.
Impact Reduction destruction Oxidation treatment Combustion/ Site Remediation
method incineration
Water and aquatic resources
Ground water contamination X (X) X
(ground)water use X X X
Surface water contamination X X X X
Soil and waste
Soil contamination, X (X) X
Waste production (X) X X (X)
Climate air and noise
Air emissions X X X X
Dust formation (X) (X) X (X)
Noise production X X X (X)
Smell (X) X X
Ecosystems
Loss of ecol. valuable areas X (X) X
Ecotoxicity to terrestrial life X X X (X)
Ecotoxicity to aquatic life X X X X
Land use
Land use change X (X) X (X)
Landscape alteration X X X
Losses of sites with archaeological, (X) (X) X
historical and cultural value
Man and his social economic living
environment
Direct health risks (direct exposure) X X X (X)
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Impact Reduction destruction Oxidation treatment Combustion/ Site Remediation
method incineration
Indirect health risk X X X (X)
Nuisance (noise, visual effects, X X X (X)
traffic,…)
Social effects (resettlement) (X) (X) X
Social effects (economic/employment) (X) X X
Social effects (transport) X X X
Social effects (use of resources) (X) X X (X)
Below a description of the “typical effects” to be expected from the PCB project is provided. The activities are subdivided in accordance to the subdivision made
in the scoping tables.
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PRESENCE, MANAGEMENT, TRANSPORTATION AND STORAGE
A typical environmental impact likely to occur in relation to the presence and further handling until
storage of PCB containing materials is pollution of soil and consequently groundwater as a result of
leakage or accidents. The presence of PCB containing materials may already have led to soil and
groundwater contamination. This should be investigated. Further on improper handling, transport, and
storage may also provoke leaks.
When in connection to water bodies the leaks may lead to further dispersion of PCBs and may result into
a pollution of surface water.
Indirectly these effects may give rise to exotoxicological effects both for terrestric fauna and flora and for
aquatic biota. As a result fauna and flora may undergo an impact from PCB handling, transport and
storage activities.
The management of PCBs may also result in to production of wastes (possibly contaminated). These
should be managed in a proper way.
Noise production resulting from management, transportation and storage of PCBs in expected to be
minimal. Only the construction of a storage facility or transport activities may produce some noise.
Direct effects on ecosystems, sites with archeological, historical or cultural value are not likely to occur;
only in case storage facilities are build, some loss with respect to these areas can be noted.
Risk to man can be the result of direct exposure and/or the consequence of exposure upon dispersion of
PCBs. Direct exposure can occur to workers being exposed directly to fumes or through contact with
PCBs during handling or as a result of leaks. Inhabitants living nearby the project site and workers can
also be exposed to PCBs through air pollution, soil pollution or pollution of groundwater. In an extreme
case impacts can occur from eating foodstuff in which PCBs from leaks have been accumulated. It
should be stressed here that proper management should improve the health situation and minimize
burden to man.
Nuisance impacts from PCB management activities will be limited to some increased traffic due to
transport and maybe some noise and dust from traffic.
Social and economic effects will probably also be limited. Some impacts may however occur with respect
to the income of people active in PCB recycling. Resettlement will only be of any importance in case of
the construction of storage facilities.
TREATMENT, DISPOSAL AND REMEDIATION
The likelihood of impacts to occur as well as the importance of the impacts related to treatment, disposal
and site remediation will be higher as compared to the handling, storage and transportation.
The different treatment and disposal methods, exception made for site remediation, generally have both
a construction phase and a phase of operation (possibly followed by dismantling).
The construction phase provokes some typical activities leading to environmental impacts. These may
include:
The pumping of ground water to allow the construction activity;
The clearance of the site: removal of vegetation and in some instances removal of the top soil
layer;
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A lot of transportation activities resulting from the construction works;
The settlement of workers accompanied by the production of waste and waste water;
The need of recourses e.g. water, energy.
For each of the treatment and disposal methods involving construction activities, potential environmental
impacts are:
Lowering of the ground water table;
Increase in the noise level;
Air emissions and air pollution from transport: i.e. dust, NOx, TSP;
Direct loss of ecotopes and fauna and flora;
Change in the land use pattern;
Loss of sites with archaeological, cultural or historical value;
Nuisance to man: noise, dust and traffic;
The use of recourses (e.g. water) which may be scarce;
Needs for resettlements: movements of the population;
Littering with waste.
The treatment techniques (including the associated pre-treatment needs) are possibly leading to a
number of typical impacts.
Several of the pre-treatment and treatment techniques including soil remediation are responsible for the
discharge of waste water. Water pollution is thus another potential typical environmental impact. Next
to this, also other aspects of the water balance may be impaired due to the need for water and in a few
cases for cooling water.
Pre-treatment, in particular shredding, but also treatment techniques may have a high sound power
level. These activities may thus result in a noise impact.
Although PCB treatment and disposal aims at minimizing dangerous wastes, some waste products are
still resulting from the processes. This asks for a further proper waste management. Contamination of
soil and as a consequence ground water should be prevented at the treatment plants. Nevertheless it is
not to be excluded and deserves the necessary preventive measures. Site remediation however is aiming
at improving the quality of soil and groundwater.
As already indicated in the section on the impacts of the construction activities, the treatment and
disposal activities may also during operation lead to a direct loss of ecological valuable sites and sites of
archaeological, cultural or historical value. The erection of plants will also have an impact on land use
and on the structure of the landscape. This will be in particular the case for the larger combustion/inci-
neration plants. For the smaller oxidation treatment units this will not be the case.
The typical effects on man may be significant and varying in nature and intensity. The impacts most
likely to occur are:
Direct health effects on workers when coming into contact with PCB wastes;
A multitude of indirect effects (workers and inhabitants) resulting from exposure to PCBs through
inhalation of polluted air, drinking of polluted groundwater or surface water, and consuming
foodstuffs enriched with PCBs;
Nuisance impacts of different nature:
Stress, sleeplessness and other impacts from noise,
Traffic and dust nuisance,
Odour,
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Visual discomfort resulting from landscape changes.
It should be stressed that the treatment and disposal as well as remediation activities generally should
lead to minimize the health risk for the population of Vietnam.
The operation of a plant for treatment and disposal of PCB’s may also bring along a number of socio-
economic impacts. These may directly affect the population and provoke some resettlements. It may
also be that some employment opportunities are created and that the income of some people may
increase. On the other hand the recyclers may loose business. The implantation of the treatment facility
may provoke some environmental pressure (i.e. waste) on the local population; on the other hand it may
lead to further development of a region due to indirect employment, the attraction of people, the need
for more roads,…
Finally the presence of a treatment and disposal unit will lead to a higher demand of resources, i.e. water
and energy and as such a disequilibrium may be created if the carrying capacity is surpassed.
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6 ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT
METHODOLOGY
6.1 INTRODUCTION
In this chapter a methodology is described allowing to prepare an EIA for the different projects to be
planned and implemented in the framework of the overall PCB management and disposal project.
In the first place attention will be paid to the information needs for the project description. Indeed, in
order to be able to prepare a valuable EIA, the project compounds have to be known and described with
a sufficient degree of detail. This is the case for each technical alternative. Thereupon the various
disciplines for which potential environmental impacts have been delineated at the occasion of the scoping
will be dealt with. For each discipline the following issues will consecutively be provided:
The information needed and the information sources for:
- the baseline description,
- the assessment of the impacts;
The assessment methodology and the criteria to be used for the assessment.
Before going into more detail on the information needs and impact methodology for each discipline, the
following remarks of a more general nature are useful at this stage:
The geographical area to be covered for each EIA will depend on the size of each individual project
and on the distribution/dispersion potential for the different pollutants and the area potentially to be
affected. Apart from some transportation effects the effect of PCB management and disposal will
mainly be restricted to a distance of maximally a few km from the site of operation. In case of
management activities it is likely that all activities take place within the borders of the site of
operation. Since expected emissions and discharges will be negligible or low, their impact is not
expected to reach beyond a distance of 1 km to 2 km from the border of the operation site. In case of
treatment, project emissions may be more significant and also social impacts may be expected. Based
upon expert experience with EIA’s on treatment plants for hazardous substances, the dispersion of
relevant levels of air, water or groundwater pollution will not reach further than some 2 to 5 km from
the site of operation. Further effects on fauna, flora and man will also be limited to that area.
Experience with EIA’s has learned us that for waste treatment facilities a study area with a diameter of
5 to 10 km is largely sufficient. Only in the case there would already be a significant pollution problem
of soil and (ground)water impact may cover a larger area. This will have to be verified for each
individual project. The study area has to be demarcated for each location alternative to be studied.
In case considerable construction activities take place in order to carry out the project (i.e. new
treatment plant) also effects during the construction phase and eventually the dismantling phase have
to be assessed;
The baseline environmental situation
In this framework report no description of the baseline environmental situation is given since the
baseline situation is always project-specific. However the topics to be treated, the data needed
for the description of the baseline situation and the information sources that exist for gathering
data in the baseline situation are described. This is not done in a separate chapter but it is
integrated in this chapter; it is provided separately for each discipline to be studied.
The description of the baseline situation will primarily be based on existing studies and on most
recent information and data available from the respective public services and agencies, on national
and international scientific literature data and on a field recognition trip. The degree of detail for the
description should mainly be based on the following two questions that are related to one another:
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- Which environmental characteristics can possibly be influenced by the project elements?
- Which area characteristics can possibly play a role in the prediction of the effect?
This means that it is of no use to provide a comprehensive description of a wide range of
characteristics that cannot be affected by the project and do not provide any added value in
the impact assessment.
For the framework “Environmental and Social assessment Report” however the information
needs for the description of the baseline situation will be comprehensive so that all elements
are covered. For the EIA of each project the issues of relevance will have to be selected
from the list taking into account the potential effects predicted.
For the description and assessment of the impacts, the following scheme is applied:
- Description of the baseline situation;
- Evaluation of the actual situation in relation to the assessment criteria;
- Determination of the contribution of the project to the environmental quality
- Prediction and description of the environmental situation to be expected in the presence of
the project;
- Evaluation of the importance of the environmental impact to be expected.
6.2 PROJECT DESCRIPTION
In order to be able to carry out an environmental impact assessment of a specific project, sufficient
information of an acceptable quality has to be available on the characteristics of the project. The
information needed is different in nature. It concerns the following issues:
The general situation of the project in the study area;
All issues related to the construction phase;
The different project components during the phase of operation;
Facilities and activities related to the project.
In this chapter a comprehensive overview will be provided on the information needs and as a result on
the information to be provided in an EIA related to the management of PCBs. Since this document is
aiming at providing a framework for different specific projects, the information needs outlined will cover
the feeds for the full spectrum of PCB management and disposal issues.
It should be stressed that, apart from some information on specific aspects of the general situation of the
project, the bulk of information in the project characteristics should be provided by the project initiator.
Moreover it should be clear that the more detail is given on the project characteristics, the higher the
quality of the EIA can be.
6.2.1 General situation of the project in the study area
In this section some information of general nature should be gathered to provide a general description of
the location and the physical and geographical situation of the project.
The information needed here includes:
A geographical map (at least 1/10,000) showing the exact location of the project and the exact
project area;
A general description of the surroundings of the project;
A description and map of the topography of the surroundings;
The administrative situation (owner, available permits);
The on-site infrastructure proposed.
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As indicated above, most information should be provided by the project initiator. Other information
sources are:
For the geographic map and data: National Hydrogeological Union;
For the topographic data: MONRE Service Centre for Land and House Management.
6.2.2 The pre-construction and construction phase
The description of the construction phase involves:
An overview of the different phases and the timing of the project;
A description of the consecutive activities during construction:
- Preparation works i.e. excavation, pumping of groundwater, removal of soil,
- The building activities,
- The transport needs for the construction,
- The development of temporary settlements,
The use of resources and waste production to be expected.
6.2.3 The phase of operation
The components to be described for the operation phase within the framework of the PCB management
and disposal project will vary widely according to the type of the site specific project for which an EIA has
to be prepared.
It speaks for itself that the description of a management project involving retrofilling will vary widely form
the information to be provided for a PCB incineration project. A selection should thus be made of the
information needs provided below. The following comprehensive overview of the information needs can
be provided:
Description of the PCB containing equipment to be managed or treated (kind of equipment, volume
of PCB content, type and concentration of PCB’s);
Description of historic experiences concerning the PCB equipment: leakages, other accidents;
Description of the operations and handling foreseen on the location (i.e. sampling, labelling,
packaging, recycling, retro filling) and description of the way the operations will be carried out;
Description of the (preventive) measures already foreseen to prevent pollution;
Description of the way transport will be carried out: type of trucks, packaging, preventive measures
foreseen, quantity to be transported;
Description of the storage facilities: type of construction, storage conditions, preventive measures
foreseen, quantity to be stored, packaging;
Description of the pre-treatment techniques used: process description, capacity foreseen per day and
per year, operation time schedule, acceptation procedure for PCB equipment;
Description of the treatment and/or disposal techniques: process description, treatment/disposal
capacity, regime (continuous flow versus batch), operation time, acceptance procedure;
Presence of groundwater extraction on site and in the immediate surroundings (number of wells,
depth of extraction well, results regarding water quality, capacity, …);
Kind of surface covering, presences of impermeable paving, …;
Existing procedures in the case of the occurrence of accidents, spill procedures;
Transport activities linked to (pre) treatment and disposal: transportation needs (quantities) and
mode, numbers of vehicles per day and per year;
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Utilities linked to treatment and disposal units: description of energy supply, description of equipment
or measures to prevent/treat possible environmental pollution: water treatment unit, air purification
equipment;
The sound power level and the use pattern of equipment and utilities to be used for (pre) treatment;
Description of the storage needs associated with the treatment and disposal units: storage capacities
needed for each type of product; storage quantities per year; description of the storage facilities: size,
measures foreseen to prevent pollution, storage conditions;
Quantification and description of the origin and use of resources: water supply (groundwater, surface
water, …) energy supply (including energy carrier: gas, coal, …);
Quantification of the use of materials and chemicals;
Estimation of the waste production: description of the quantities of different types of waste expected
to be produced, description of the storage facilities for waste, the waste management and the final
fate of each of the different types of waste;
Description of the different sources for emissions and waste water production: expected and
maximum allowed flow rate, temperature and composition of the off gasses; characteristics of the
emission point (stack) i.e. height, diameter; flow rate and characteristics of the waste water (i.e. temp,
COD, BOD, N, P, SS, …).
When it is foreseen that operation will only be temporarily, the EIA should also provide some insight in
the impacts related to the termination of the project. In general, however, little is known to allow
predicting effects. In any case the subject should be touched by providing an idea on the actual insight
in the demolition and decommissioning phase of the project.
6.2.4 The actual environmental performance of the facility
When the project is carried out in an existing facility an overview should be provided on the overall
environmental performance of this facility before the project is implemented. This overview should
provide general information on:
The general lay out of the facility;
The (production) capacity of the plant;
The global man power and the man power of the environmental and/or safety and health
department;
The existence of an environmental management system and/or emergency plans;
Mean measures already taken and equipment in operation for environmental protection;
The existence of an environmental monitoring plan
With respect to the emissions to the different compartments and/or the pollution in the different
compartments we refer to the data and information needs described in the sections 6.3 up to 6.5 of this
report.
Specific information needed with respect to the actual situation on PCB management should include:
The number and the characteristics of the PCB containing equipment (name of manufactures, power
rating, PCB content)
The actual condition of the equipment;
The maintenance situation of the equipment
The operational situation of the equipment
The existing status for management of PCB’s and PCB containing equipment: procedures, people
involved, preventive measures.
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…
For transformer servicing facilities further specific data should be gathered on:
The procedures for servicing;
The existing safety and health protection procedures;
The training organized for the staff;
The protective clothing and other protective materials available;
The monitoring carried out.
The data on the environmental performance of the facility can be obtained from the owner of the plant
and the staff involved. To that aim a questionnaire should be established and discussed with the project
initiator.
6.3 AIR, CLIMATE AND NOISE
Air, climate and noise include a variety of impacts of physical and chemical nature. The impacts on air
are in general resulting from the production of emissions into the air from processes, combustion, energy
supply or traffic. Certain air pollutants may further lead to smell effects, depletion of ozone, climate
change or acid deposition. In the context of PCB management however, this is not expected. The
importance of climate conditions finds its origin in its role for predicting distribution of air pollutants.
Noise may be produced during construction activities and transport. In treatment facilities, equipment
such as compressors, ventilators, etc may also result in noise. In general impacts may be air pollution
with different compounds and smell.
The presence of PCB containing materials as well as their handling leads to emissions into the air. These
emissions are not likely to be high but anyway an impact on air quality may occur. This may also be the
case due to dust formation when constructing a storage or treatment facility or as a result from transport
by truck.
An important potential environmental impact from the treatment and disposal techniques is air pollution.
This is in particular the case for combustion and incineration techniques. Reduction destruction methods
may also lead to air pollution. Next to the stack emissions also diffuse emissions into air may occur. This
is in particular the case during pre-treatment i.e. shredding and screening. PCB’s are the mayor
component to be taken into account for air pollution. Next to this, attention should also be focused on
dust and smell (i.e. cement kiln) and dust produced by traffic.
The potential impacts in case of PCB management and disposal are further summarized in the Table 5-1
and in the Table 5-2.
Air pollution and noise may further lead to impacts on human health (exposure and toxicity of airborne
pollutants, hearing impairment) or to nuisance (annoyance from noise, dust, smell).
6.3.1 Data and information needed
Emission data:
- Measured emissions from actual situation in plant or emission factors for power plant for
relevant components: NOx, SO2, PM10, CO2, CO;
- All emission sources from the project likely to produce relevant emissions to air;
- Emission factors for the different emission sources i.e. PCB containing materials, emissions
due to traffic (NOx, PM10) handling and treatment of PCBs;
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- For the emissions of PCB, measurements do not appear to be of relevance since emissions
are diffuse in nature;
- General noise emission factors (sound power level) for the use of (pre)treatment equipment.
Data on baseline situation:
- Data on general climatological situation at the nearest station: monthly mean temperature,
monthly mean precipitation, yearly average and monthly data on wind direction, windspeed,
cloudiness and humidity;
- Actual air quality monitoring data (according to availability) and/or description of major
sources; no air quality monitoring for project purposes is needed;
- Actual noise situation: description of major sources; no measurements needed for project.
Assessment criteria:
- Standards and guidelines for ambient air quality: SO2, NOx, PM10, CO, PCB, chlorinated
hydrocarbons (if relevant);
- Standards for noise.
6.3.2 Information sources
The emission data originating from measurements at the existing plants should be provided by the owner
of the plant. The emission sources related to the project should either be provided by the project initiator
or be determined by the EIA expert. If no measured emission data can be obtained from the owner of
the plant, the data which are relevant for the impact assessment, should be generated by the EIA expert
based upon the technical characteristics of the processes and the characteristics of the off gas production
on the one hand and existing emission factors from EPA or the EU (CITEPA, 2001; US EPA, 1995; Bush et
al. 2005; EEA, 2007; Emissieregistratie Nederland, 2008;) on the other hand.
PCBs emission factors (air and noise) are to be provided by the EIA expert (see tables 6.3 and 6.6).
Data on the climatological characteristics are to be obtained from the Centre for Hydrometereology from
North and South Vietnam.
Actual air quality monitoring data are provided by the DONREs, the National Environmental Monitoring
stations. Monitoring data can be obtained from operators in case a monitoring plan on air quality is due.
Specifically for PCBs no monitoring data will be available. Exception made for situations where substantial
PCB leaks are noted, no air quality monitoring of PCBs will be needed. It can be assumed that air
concentration of PCBs will be zero. In case substantial leaks are recorded, air quality should be
monitored for 24 h on the spot of the leak at 1 m height and respectively 500 m and 1000 m off wind of
the leak.
Data on noise emissions is also provided via existing monitoring plans or should be determined by the
EIA expert.
Standards and guidelines are given in the Vietnamese legislation. Besides this, also World Health
Organisation and EU standards and guidelines are gathered.
6.3.3 Assessment methodology and criteria
Firstly the climate conditions, the reference situation concerning air quality (for the relevant parameters,
i.e. SO2, NOx, PM10, CO and PCBs and the noise situation are described. The actual situation is related to
the standards and guidelines for air quality. For noise a qualitative description will be given.
The standard and guidelines to be applied are summarized in following tables.
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Table 6-1: Standards and guidelines for air quality (WHO, 2000, TCVN 5937,2005)
Parameter Vietnam International
WHO EU
guideline standard
CO (µg/m³) 10000 (8hr) 10000 (max)
30000 (1hr)
NOx (µg/m³) 40 (year) 40 (year) 40 (year)
200 (hr) 200 (hr)4
SO2 (µg/m³) 50 (year) 125 (24 hr) 20 (year)5
125 (24 hr) 125 (24 hr)
350 (1 hr)
PM10 (µg/m³) 150 (24 hr) 706 (24 hr) 50 (24 hr)
50 (year) 40 (year)
300 (1hr)
PCB (mg/m³) 0.57
Table 6-2: Guideline values for community noise in specific environments (WHO, 1995)
Specific Environment Critical health effect(s) LAeq [dB(A)] Time LAmax fast
base [dB]
[hours]
Outdoor living area Serious annoyance, daytime and 55 16 -
evening 50 16 -
Moderate annoyance, daytime and
evening
Dwelling, indoors Speech intelligibility & moderate 35 16
Inside bedrooms annoyance, daytime and evening
Sleep disturbance, night-time 30 8 45
Outside bedrooms Sleep disturbance, window open 45 8 60
(outdoor values)
School class rooms & Speech intelligibility, disturbance of 35 during -
pre-schools, indoors information extraction, message class
communication
Pre-school Sleep disturbance 30 sleeping 45
bedrooms, indoor time
School, playground Annoyance (external source) 55 during -
outdoor play
Hospital, ward Sleep disturbance, night time 30 8 40
rooms, indoors Sleep disturbance, daytime and 30 16 -
4
NOx: EU standard for ecosystem protection: 30 µg/m³ (year)
5
For ecosystem protection
6
WHO prescribed exposure effect analysis
7
TCL (Baars et al., 2001)
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Specific Environment Critical health effect(s) LAeq [dB(A)] Time LAmax fast
base [dB]
[hours]
evenings
Hospitals, treatment Interference with rest and recovery #1
rooms, indoors
Industrial Hearing impairment 70 24 110
commercial shopping
and traffic areas,
indoors and outdoors
Ceremonies, festivals Hearing impairment (patrons: <5 100 4 110
and entertainment times/year)
events
Public addresses, Hearing impairment 85 1 110
indoors and outdoors
Music and other Hearing impairment (free-field value) 85#2 1 110
sounds trough head-
phones/ earphones
Impulse sounds from Hearing impairment (adults) - - 140
toys, fireworks and #2
firearms Hearing impairment (children) - - 120
#2
Outdoors in parkland Disruption of tranquillity #3
and conservations
areas
#1: As low as possible
#2: Peak sound pressure (not LAF, max) measured 100 mm from the ear.
In a second phase the relevant sources of air pollution will be identified. For all relevant pollution
sources emissions will be calculated using emission factors.
The majority of emissions of PCBs arise from leaks from electrical transformers and capacitors which
contain PCBs and are in poor condition.
General emission factors for PCBs are presented in Table 6-3. It should be noted that PCB emissions
from transformers and capacitors during normal operation are negligible. There are limited data
available on emissions of PCBs from electrical equipment (European Environment Agency, 2000; USEPA
1987).
In order to obtain an idea of PCB emissions, emission estimates are calculated based upon the
evaporation process for different activities.
When PCB containing oils are removed from transformers, a very small part of the PCBs will evaporate.
This will lead to either releases of PCBs in the ambient air or accumulation of PCBs in the workplace
atmosphere.
Emissions from removing PCB containing oils from transformers can be estimated using the following
formula:
P.M
Ls
0.0083144 T
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Whereby: Ls specific loss (g/m³)
P vapour pressure (kPa)
M molecular weight (g/mol)
T temperature (K)
Molecular weight and vapour pressure are congener dependent. Taking into account the ranges of
vapour pressures cited in the literature for various congeners, maximum specific losses of 1 – 40 mg/m³
are calculated for liquids consisting of pure PCBs:
Molecular Vapor pressure (kPa) Specific loss (g/m³) Maximum
weight specific loss
(g/mol) (mg/m³)
Monochlorobiphenyls 188,65
Dichlorobiphenyls 233,1 5,1E-05 - 4,2E-04 4,8E-03 - 4,0E-02 40
Trichlorobiphenyls 257,54 1,5E-05 - 1,1E-04 1,6E-03 - 1,1E-02 11
Tetrachlorobiphenyls 291,99 1,4E-06 - 9,0E-05 1,6E-04 - 1,1E-02 11
Pentachlorobiphenyls 326,43 1,4E-06 - 1,7E-05 1,9E-04 - 2,2E-03 3
Hexachlorobiphenyls 360,88 9,8E-08 - 7,0E-06 1,4E-05 - 1,0E-03 1
Heptachlorobiphenyls 395,32
Octachlorobiphenyls 429,77
Nonachlorobiphenyls 464,21
Decachlorobiphenyls 498,66
If the congener composition of the PCBs is unknown, the value of 11 mg/m³ is advised because tri- and
tetrachlorobiphenyls have been the most widely used in transformer applications.
The specific losses from oils containing only a fraction of PCBs can be obtained by multiplying the
maximum specific losses for pure PCBs with the weight fraction of PCBs in the mixture:
Western PCB based transformer oils contain 60 – 70 wt% of PCBs: multiply by 0.65
Soviet PCB based transformer oils (Sovtol-10) contains 90 wt% of PCB’s: multiply by 0.90
PCB contaminated transformer oils containing 500 ppm of PCBs: multiply by 0.0005
An estimate of total loss is obtained by multiplying the maximum specific loss, corrected for the PCB
content of the mixture, with the total amount of PCB holding transformer oils handled.
Evaporation from spills can be calculated by Sutton’s formula:
M Pt Pw
m" 0.002 u 0.78 x 0.11 P P
ln 1
8.3144T t w
Whereby: m” evaporation rate (kg/m²/s)
u wind speed (m/s)
x characteristic length of spill (m) – spill diameter
M molecular weight (g/mol)
Pt atmospheric pressure (Pa)
Pw vapour pressure (Pa)
T temperature (K)
Using a standard wind speed op 0.1 m/s for inside spills and a spill diameter of 1 m, evaporation rate of
pure PCB’s amounts to:
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Molecular Vapor pressure (Pa) Evaporation rate (kg/m²/s) Maximum
weight evaporation rate
(g/mol) (g/m²/hr)
Monochlorobiphenyls 188,65
Dichlorobiphenyls 233,1 5,1E-02 - 4,2E-01 1,6E-06 - 1,3E-05 47,6
Trichlorobiphenyls 257,54 1,5E-02 - 1,1E-01 5,2E-07 - 3,8E-06 13,7
Tetrachlorobiphenyls 291,99 1,4E-03 - 9,0E-02 5,5E-08 - 3,5E-06 12,7
Pentachlorobiphenyls 326,43 1,4E-03 - 1,7E-02 6,2E-08 - 7,4E-07 2,7
Hexachlorobiphenyls 360,88 9,8E-05 - 7,0E-03 4,7E-09 - 3,4E-07 1,2
Heptachlorobiphenyls 395,32
Octachlorobiphenyls 429,77
Nonachlorobiphenyls 464,21
Decachlorobiphenyls 498,66
If the congener composition of the PCBs is unknown, the value of 13,2 g/m²/hr is advised because tri-
and tetrachlorobiphenyls have been the most widely used in transformer applications. When room
volume and air refreshment rata are known, then wind speed can be calculated from these values and
substituted into Sutton’s formula.
The specific losses from oils containing only a fraction of PCBs can be obtained by multiplying the
maximum specific losses for pure PCBs with the weight fraction of PCBs in the mixture:
Western PCB based transformer oils contain 60 – 70 wt% of PCBs: multiply by 0.65;
Soviet PCB based transformer oils (Sovtol-10) contains 90 wt% of PCBs: multiply by 0.90;
PCB contaminated transformer oils containing 500 ppm of PCBs: multiply by 0.0005.
Table 6-3: Emission factors for PCB emissions (Annema et al, 1995)
Source PCB emission to air (%/year) PCB emission to soil and water
(%/year)
Transformerr 0.006 0.054
Capacitors 0.16 1.44
The emission factors related to traffic are summarized in Table 6-4.
Table 6-4: Emission factors for traffic and construction activities (g/km) (USEPA, 1995)
Parameter NOx CO TSP VOC
Automobiles 3.8 5.7 0.06 1.0
Heavy dirty trucks 25 2 2.5 2.5
(>15 tonnes, diesel)
Excavation 2.69(1)
(1) total dust in kg/Ha/month
For specific treatment facilities, emission with depend on the specifications of the processes.
The specific noise contribution of the project will be determined for the construction phase and the
operation phase. For each phase the relevant noise sources are identified and the emission related
sound power lever will be determined. For general noise sources ‘typical’ sound power levels are
summarized in table 6.5. For specific installations it is expected that the levels will be provided by the
initiator and his engineering company.
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Table 6-5: Sound power levels LW for different noise sounds
Machine/noise source LW (db (A))
Excavator 104
Dumper 104
Bulldozer 104
Levelling machine 104
Truck 105-110
Shredder 126
For all relevant air emission parameters the contribution to the ground level air concentration will be
calculated using a bi-Gaussian distribution model taking into account the climatological data. Receptor
areas will be defined.
Based upon the sound power levels, the specific noise contribution from the project components will be
calculated using the IMMI model.
Based on the results of the dispersion modelling, the potential impacts on the ambient air quality will be
assessed. To that aim the contribution to air quality will be compared to the national and international
air quality standards and guidelines (see above). The assessment for noise will be based on the level of
the noise contribution in the surroundings of the project and the comparison of the expected levels with
the guideline values (see table 6-2).
6.4 SOIL AND GROUNDWATER
Impacts on soil and groundwater concern the whole range of alterations related to quality of soil and
groundwater on the one hand and characteristics of soil and groundwater on the other hand. These
characteristics may include geological, hydro geological or pedological features related to structure and
composition of soil or related to groundwater flow or vulnerability. In this section also the production
and the management of waste is considered.
In the Table 5-1 and in the Table 5-2 the potential impact from the PCB management and disposal
project is summarized.
Impacts on soil and groundwater quality may further lead to direct exposure for humans or fauna and
flora. Furthermore indirect exposure resulting from bioaccumulation of pollutants in cultured food may
also occur. Changes in groundwater hydrology may lead to changes of the water balance and as such
affect flora or limit groundwater use for fauna and men.
6.4.1 Data and information needed
Data on the baseline situation:
- Pedological characteristics at the site (description of the upper 1.5 m of the soil, soil types);
- Geological description (overview of present layers in the underground, illustrated by one or
more geological cross-section);
- Hydrological description (groundwater vulnerability overview and characteristics of relevant
aquifers, aquitards, impermeable layers: permeability, groundwater velocity, direction
groundwater flow, …);
- Overview sources of potential soil contamination (situated on a plan):
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a description of the different steps of the process,
the locations on the site which are considered critical to soil pollution, for instance
location of PCB containing equipment, disposal sites, storage of hazardous components,
presence of underground pipes, sewage, …,
general management regarding accidents, handling of hazardous components, …;
- Overview of accidents resulting in a potential soil pollution (+ undertaken actions);
- Quality data regarding soil and groundwater;
Assessment criteria:
- Background values,
- soil sanitation values
used in Vietnam to assess soil and groundwater contamination.
6.4.2 Information sources
For the description of the baseline situation following information sources can be used:
Data on pedagogical, geological and/or hydrogeological archives, soil maps, drilling logs, etc.:
National Hydrogeological Union and data obtained from the operator on investigations in the scope of
preparatory works of construction activities ;
Data on ground and groundwater quality, groundwater flow direction and groundwater vulnerability,
presence of extraction wells, etc.: National Hydrogeological Union;
Results of soil contamination studies: data to be provided by the operator of the plant. If no data are
available, monitoring should be carried out as outlined further in 6.4.3.2.;
Existing Vietnamese legislation relevant for soil and groundwater;
Field information (photos of the site, of locations where soil pollution occurs (visual or organoleptic),
where PCB-containing equipment is situated, etc). This information is needed to define the places
where soil samples could be taken.
6.4.3 Assessment methodology and criteria
6.4.3.1 Characteristics of PCBs relevant for soil and groundwater
Mobility
If released into soil, PCBs experience tight adsorption. The adsorption is generally increasing with the
degree of chlorination of the PCB.
They generally do not leach significantly in aqueous soil systems. The higher chlorinated congeners have
a lower tendency to leach than the lower chlorinated congeners. In the presence of organic solvents,
PCBs may leach quite rapidly through soil.
Degradation
PCBs are mixtures of different congeners of chlorobiphenyl. The relative importance of the environmental
fate mechanisms generally depends on the degree of chlorination. In general, the persistence of PCBs
increases with an increase in the degree of chlorination. Mono-, di- and trichlorinated biphenyls
biodegrade relatively rapidly, tetrachlorinated biphenyls biodegrade slowly, and higher chlorinated
biphenyls are resistant to biodegradation. Although the biodegradation of higher chlorinated congeners
may occur very slowly on an environmental basis, no other degradation mechanisms have been shown to
be important in natural water and soil systems. Therefore, biodegradation may be the ultimate
degradation process in water and soil. Polychlorinated biphenyls degrade into less-chlorinated PCBs.
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When released into water, adsorption to sediment and suspended matter is an important process; PCB
concentrations in sediment and suspended matter have been shown to be greater than in the associated
water column. Although adsorption can immobilize PCBs (especially the higher chlorinated congeners) for
relatively long periods of time, eventual re-solution into the water column has been shown to occur. The
PCB composition in the water is enriched by the lower chlorinated PCBs because of their greater water
solubility, and the least water soluble PCBs (highest chlorine content) remain adsorbed.
Volatilization/evaporation
Vapour loss of PCBs from soil surfaces appears to be an important fate mechanism, with the rate of
volatilization decreasing with increasing chlorination. Although the volatilization rate may be low, the total
loss by volatilization over time may be significant because of the persistence and stability of PCBs.
In the absence of adsorption, PCBs volatilize from water relatively rapidly. However, strong PCB
adsorption to sediment significantly competes with volatilization, with the higher chlorinated PCBs having
a longer half-life than the lower chlorinated PCBs. Although the resulting volatilization rate may be low,
the total loss by volatilization over time may be significant because of the persistence and stability of the
PCBs.
Bioaccumulation
PCBs have been shown to bioconcentrate significantly in aquatic organisms. Accumulation increases with
the more highly chlorinated congeners.
Parameters (http://www.fao.org/DOCREP/003/X2570E/X2570E08.htm)
Property Parameter Unit Value Conclusion
Melting point °C -
Vapour
mPa
pressure
Density g/cm3
Very slightly
Degradation DT50soil Years
degradable
Solubility Sw mg/l <0.1 Not soluble
Mobility Log KOC >3.4 Slightly mobile
ADI mg/kg/day 9.00E-5
Permissible Human:
Concentrations
Direct contact mg/kg dm soil 45
Consumption of vegetables mg/kg dm soil 6
Consumption of drinking-
μg/l 1.8
water
6.4.3.2 Assessment methodology
For the construction phase as well as the exploitation phase following impacts could be relevant:
Alterations in soil use (f.e. increase of paved surface), increase of area which is in use for the project;
Alteration of the soil profile due to construction (removal of soil, foundations, …);
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Alteration in soil structure and soil stability due to f.e. setting of soil (impact of storage, movement of
trucks, …);
Change in soil and groundwater quality due to exploitation, storage, good practices;
Erosion due to impact of wind and water (removal of vegetation, borders, …);
Changes in groundwater pattern (f.e. extraction wells), hydraulic parameters, height of groundwater
table, infiltration, … .
These impacts are considered for the study area which is in the case of soil equal to the project area. For
groundwater the boundaries of the study area are function of the impact on groundwater, f.e. influence
of a possible extraction well.
Especially the impact on soil and groundwater quality is relevant. Soil can become contaminated with
PCBs through accidents involving the removal and maintenance of transformers and capacitors or
through improper disposal of PCB containing substances. Accurate determination of the PCB content of
soils suspected to be contaminated is necessary for the responsible parties to make the appropriate
decisions regarding site clean up and remediation.
To detect a potential contamination with PCBs, it is important to do at least one drilling in each zone
which is identified as a risk location. If the PCB holding equipment is located on an impermeable surface
however, no sampling is required. If the impermeable surface is not bordered by a curb preventing liquid
substances to be washed off, the areas around the impermeable surface will have to be sampled if there
are any signs/possibilities that oil/liquid wastes may have penetrated the soil. As the contamination
spreads from the surface it is always important to take a sample of the upper soil and 2 samples at
greater depth (for example: 0.5 to 0.75 m and 1 tot 1.25 m). Not only the concentration of PCBs but also
the organic matter and clay content must be analysed. If the upper soil sample is contaminated a deeper
sample can be analysed. If also this sample gives a concentration above the sanitation value it is
necessary to sample and analyse the groundwater. For the project only soil samples will be taken.
Locations where no hard surface is present or where the surface is characterised by a number of cracks
will be chosen above the areas where an impermeable surface is present.
The number of drillings performed at one location will be function of the area of the risk zone.
The impact evaluation results in an overview of relevant mitigation measures. In this case the mitigation
will primarily exist out of monitoring needs and periodical soil investigation to ensure no pollution of the
soil occurs. In the case of accidents where PCB’s could come into the environment a spill procedure will
be needed to make it possible to intervene immediately.
6.4.3.3 Criteria
The concentration of PCBs in the soil above which some action should be considered will depend
primarily on the exposure estimated in the baseline risk assessment based on current and potential
future land use. Other factors include the impact the residual concentration will have on groundwater and
potential environmental impacts.
An overview of existing criteria8 is given in Table 6-6 and Table 6-7. No criteria for assessment of PCB
contamination in soil exist in Vietnam.
8
Derivation methods of soil screening values in Europe. A review and evaluation of national procedures towards
harmonisation, Carlon C. et al., JRC Scientific and technical reports (EUR 22805 EN), 2007, 306p
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Table 6-6: Assessment criteria relevant for soil
mg/kg d.w. Screening values Screening values Screening values Screening values
for negligible risk for intermediate for potentially for potentially
(warning) risk unacceptable risk unacceptable risk
(residential use) (residential use) (industrial use)
Netherlands 0.02 1
Germany 0.8
Sweden 4
Belgium (Brussels) 0.9 10.4
Belgium (Flanders) 0.011 0.033
Table 6-7: Assessment criteria relevant for groundwater
µg/l Screening values Screening values Screening values
for negligible risk for intermediate for potentially
(warning) risk unacceptable risk
Netherlands 0.01 0.01
Belgium (Brussels) 0.1
Austria 0.06 0.1
6.5 WATER AND AQUATIC RESOURCES
Knowledge of PCB behavior in an aquatic environment is important to determine information
requirements and assessment methodology.
PCBs in water are transported by diffusion and currents. PCBs in surface water essentially exist in three
phases: dissolved, particulate and colloid associated. The heavier and less soluble congeners in the water
column are the more likely to be associated with particulates and colloids and the smaller the risk that
they freely exchange into the vapor phase. The more soluble, lower chlorinated (and ortho-rich)
congeners are predominantly in the dissolved state in the water column and can readily partition into the
vapor phase. In general, PCB-solubility is low. Experimental and monitoring data have shown that PCB
concentrations in sediment and suspended matter are often higher than in the associated water column,
but the opposite has been shown as well. Apparently, the partitioning behavior of PCBs in the water
tends to be location specific.
PCBs leave the water column by partitioning onto sediments and suspended particulates, and by
volatilization at the air/water interface. PCBs can be immobilized for relatively long periods of time in
aquatic sediments. The adsorption of dissolved PCBs onto solids is greatest for solids composed primarily
of organic matter and clay. The more highly chlorinated component (and ortho-poor) PCBs, which have
lower water solubility and higher octanol-water partition coefficient (K ow), do have a greater tendency to
bind to solids as a result of strong hydrophobic interactions. In contrast, the low molecular weight PCBs,
which have higher water solubility and lower Kows, sorb to al lesser extent on solids and remain largely
into the water column.
PCB input into aquatic reservoirs is predominantly from wet and dry deposition and from the recycling of
sediment-sorbed PCBs into the water column.
Recycling of PCBs, due to volatilization of PCBs from the water column and subsequent release of PCBs
from sediments, occurs when atmospheric inputs decrease. The rate of re-dissolution of PCBs from
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sediment to water increases in warmer periods because of more rapid volatilization of PCBs from water
with higher temperatures. Environmental redistribution of PCBs from aquatic sediment is most significant
for the top layers, while PCBs in the lower layers may be effectively sequestered from redistribution.
6.5.1 Data and information needed
Data on baseline situation:
- Inventory of all water bodies and aquatic resources that might be affected by the project;
- Data on actual use of water bodies and aquatic resources (domestic water supply, irrigation
purposes, bathing, fishing, aquatic breeding and cultivation, …)
- Data on hydrographical and hydraulic characteristics;
- Data on flow characteristics ;
- Data on water quality;
- Data on sediment composition (organic matter, clay);
- Data on sediment quality.
Emission data:
- Inventory of all possible sources of contamination:
Direct discharge into surface waters: e.g. waste water from electrical industry, waste
water contaminated by leakage of hydraulic fluids, …;
Indirect discharge into surface waters: e.g. runoff of water from accidental spillage of
PCB-containing hydraulic fluids, disposal of waste oils into street drains, runoff from
farmland to which PCB containing sludge has been applied;
Atmospheric deposition of PCBs;
- Characterisation of contamination sources: overview of relevant pollutants, e.g. in case of
PCBs it is important to know weather it concerns higher or lower chlorinated PCB-congeners;
- Quantification of possible contamination: e.g. calculation based on pollutant concentration
and waste stream flow, deposition factors.
Assessment criteria:
- Water quality standards and guidelines;
- Background values.
6.5.2 Information sources
The information sources for water and aquatic resources impact assessment may be multiple:
Vietnamese legislative acts on water conservation;
Monitoring data on water quality and characteristics of water emissions: VEA and the operators of
plants; in case no information can be obtained from existing information sources, on-site monitoring
should be carried out by the EIA expert.
Data on hydrologic and hydrographic characteristics of rivers, i.e. width, depth, flow rate of water:
Centre for Hydrometeorology;
International literature on water quality standards, e.g. WHO publications, EPA publications;
Field survey;
Water and sediment sampling;
Etc.
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6.5.3 Assessment methodology and criteria
6.5.3.1 Assessment method
At first a baseline study will be conducted. All relevant water bodies and aquatic resources that might be
affected by the project are listed. Hydrographical, hydraulic and flow characteristics are described, as
well as quality characteristics and actual use. The depth of this baseline study depends on information
available. If no information on water and sediment quality of relevant water bodies is available, two
water samples and two sediment samples upstream and downstream the project impact have to be taken
and analysed on general parameters (pH, temperature, suspended solids, …) and relevant pollutants
(PCBs, …). Clay and organic matter content of sediment samples has to be determined as well. Actual
water and sediment quality are compared to available standards and guidelines as given in Table 6-8.
Next, possible impacts during construction and operational phase are determined, described and
assessed:
Possible impacts during construction phase:
- Alteration of hydrographical characteristics due to construction works: description based on
actual characteristics and scope of planned interventions (e.g. length of dikes to be filled up);
- Influencing of water quality due to accidental spillage during construction: qualitative
description based on an estimation of used equipment.
Most likely impacts during operational phase:
- Influencing of water and sediment quality due to direct or indirect discharging and
atmospheric deposition: description based on identification, characterisation and
quantification of pollution sources. In case of discharge of waste water, quantities of
pollutants discharged and contribution to pollutant quantities in receiving surface waters are
calculated if sufficient data are available. For PCBs in particular, partitioning between water
column and sediment has to be studied. Assessment of impacts is related to the extent of
pollution and possible exceeding of quality standards. If no information on waste water
streams is available, at least one sample should be taken and analysed;
- Influencing of water quantity due to discharge of waste water and rainwater from hardened
surfaces: description based on waste water flow, rainfall, hardened surface and receiving
surface water flow.
If the impact assessment results in important negative impacts on water or aquatic resources, measures
will be proposed to avoid or mitigate expected impacts.
6.5.3.2 Criteria
Relevant criteria in the assessment of potential impact on water and aquatic resources are given in the
tables 6-8 and 6-9.
Table 6-8: Water quality standards and guidelines
Organisation Standard/guideline
US Environmental Protection Maximum contaminant level for 5 µg/l
Agency (EPA) community water systems and non-
transient non-community water
systems for PCBs
US Environmental Protection Maximum contaminant level goal 0 µg/l
Agency (EPA) for PCBs in water
US Clean Water Act PCB criterion to protect freshwater 0.014 ng/l as a 24 hr average
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Organisation Standard/guideline
aquatic life
US Clean Water Act PCB criterion to protect saltwater 0.030 ng/l as a 24 hr average
aquatic life
Belgium (Flanders) Quality standard surface water, ≤ 7 ng/l
median for total PCBs
Table 6-9: Industrial waste water: Vietnamese limits of Parameters and Maximum Allowable
Concentrations of Pollutants
Parameters and substances Unit
A B C
Temperature °C 40 40 45
pH 6-9 5,5-9 5-9
Odour - ND ND -
Colour (at pH=7) Co-Pt 20 50 -
BOD5 (20°C) mg/l 30 50 100
COD mg/l 50 80 400
Suspended solids mg/l 50 100 200
Arsenic mg/l 0.05 0.1 0.5
Mercury mg/l 0.005 0.01 0.01
Lead mg/l 0.1 0.5 1
Cadmium mg/l 0.005 0.01 0.01
Chromium (VI) mg/l 0.05 0.1 0.5
Chromium (III) mg/l 0.2 1 2
Copper mg/l 2 2 5
Zinc mg/l 3 3 5
Nickel mg/l 0.2 0.5 2
Manganese mg/l 0.5 1 5
Iron mg/l 1 5 10
Tin mg/l 0.2 1 5
Cyanide mg/l 0.07 0.1 0.2
Phenol mg/l 0.1 0.5 1
Mineral oil and fat mg/l 5 5 10
Animal-vegetable fat and oil mg/l 10 20 30
Residual chlorine mg/l 1 2 -
PCBs mg/l 0.003 0.01 0.05
Chemical for vegetable protection: mg/l 0.3 1 -
organic phosphorus
Chemical for vegetable protection: mg/l 0.1 0.1 -
organic chloride
Sulphide mg/l 0.2 0.5 1
Fluoride mg/l 5 10 15
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Parameters and substances Unit
A B C
Chloride mg/l 500 600 1,000
Ammonia (as N) mg/l 5 10 15
Total nitrogen mg/l 15 30 60
Total phosphorus mg/l 4 6 8
Coliform MPN/100 ml 3,000 5,000 -
Bioassay 90% fish alive after 96 hr. in WW
Gross alpha activity Bq/l 0.1 0.1 -
Gross beta activity Bq/l 1.0 1.0 -
A: Industrial waste waters containing the values of parameters and concentrations of substances which are equal to
or lower than the values specified in the column A may be discharged into the water bodies used for sources of
domestic water supply
B: Industrial waste waters containing the values of parameters and concentrations of substances which are lower
than or equal to the values specified in the column B may be discharged only into the water bodies used for
navigation, irrigation purposes or for bathing, aquatic breeding and cultivation, etc.
C: Industrial waste waters containing the values of parameters and concentrations of substances which are greater
than the values specified in the column C may be discharged into specific water bodies permitted by authority
agencies
ND: not detectable
6.6 FAUNA AND FLORA
The discipline “Fauna and Flora” includes all potential impacts on terrestrial and aquatic ecosystems. It
may concern either the direct loss of valuable or protected biotopes or species or the deterioration of
biotopes or organisms as a result of ecotoxicity through air, water or soil or changing conditions of soil,
groundwater or water supply.
The potential impacts of PCB management concern both the above mentioned effects, including:
Direct loss of biotope resulting from the construction of a storage facility or treatment facility;
Deterioration of aquatic/terrestrial biotopes or species due to eco-toxicity resulting from pollution
with PCBs.
6.6.1 Data and information needed
Data on the baseline situation
- An overview of the protected areas (and their protection status) in the study area;
- A description of the biotopes;
- An identification of rare species;
- A photo impression.
Assessment criteria
- Ecotoxicological no effect levels.
6.6.2 Information sources
The information sources for fauna and flora impact assessment may be multiple. In particular the
following sources are needed:
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Legislative acts on nature conservation and identification and delineation of protected areas: Vietnam
Environment Administration (VEA);
International conventions i.e. the Ramsar Convention on Wetlands (1971), the Bern convention, the
convention on Biological Diversity and the convention on the Protection of the World Cultural and
Natural Heritage;
Local university departments on nature conservation;
International literature on ecotoxicology i.e. WHO publications;
Field verification by the EIA expert.
6.6.3 Assessment methodology and criteria
The description of the baseline situation starts with a general description of the surroundings on a macro
level. There upon the protection status of the study area is provided and the ecologically valuable areas
are identified.
All special protected areas in the study area are described into more detail based upon literature
information and field recognition. The description includes:
The characterization of the different terrestrial and aquatic biotopes;
The identification of rare species;
The evaluation of the protection status, the health status and the vulnerability of the biotopes;
A visual overview of the biotopes in the study area.
The methodology and criteria for the assessment of the impacts will vary accordingly to the type of effect
to be expected. The first group of effects is related to
The loss or deterioration of protected areas or nature reserves or in particular ecologically valuable
areas or rare and/or valuable plant communities;
The loss of biotopes as a result of construction activities: construction of storage and other facilities;
The deterioration or drastic change of terrestrial biotopes as a result of soil/ or groundwater
pollution: ecological valuable biotopes, rare or valuable plant communities;
Gain of biotopes as a result of the remediation of the site.
These effects can be quantitatively assessed by inventorying and calculating the area surface for which
the alterations are expected. This will be coupled to the ecological value of the biotopes affected. A
second group of effects concerns the potential disturbance of fauna and flora as a result of noise, dust,
traffic,… . Again the assessment criteria will be the surface of the area expected to be disturbed.
Indirect ecotoxicological effects on fauna and flora resulting form leaks, emissions and discharges is a
next effect group of effects which is potentially relevant. To assess these effects ecotoxicological criteria
will be used i.e. the no effect level for acute and chronic ecotoxicity for different groups of organisms
versus the expected exposure. It should be noted that these effects may also be positive due to a
reduction of the risk as a result of the management plan.
Ecotoxicological data for PCBs are summarized in Table 6-6.
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Table 6-10: Geometric mean values for the 50 % effect concentration (L(E)C50), for the
lowest observed effect concentration (LOEC) for the No Observed effect concentration
(NOEC) for PCBs in the aquatic environment (Callebaut and Vanhaecke, 2000)
L(E)C50 µg/l NOEC µg/l LOEC µg/l
Micture of PCB’s
Crustaceans 22 1.7
Fish 55
PCB 77 – fish 250,000
PCB 81 – fish 15,600
PCB 101 – crustaceans 510
PCB 126 – fish 219 219
Mixture of 5 PCB’s fish 25
Arochlor9 1254
Crustaceans 0.94
Fish 0.32
Arochlor 1242
Crustaceans 10
Fish 1
Arochlor 1248
Crustaceans 52
Fish 3.4
Arochlor 1221 – fish 500
Arochlor 1232 – fish 30
Arochlor 1260 – fish 51
The predicted no effect concentration from a mixture op PCBs to aquatic organism was calculated to be
34 ng/l according to the EU Technical Guidance Document (Callebaut and Vanhaecke, 2000)
Ecotoxicological no observed effect concentrations for birds and mammals are very rare. The following
data could be recorded:
NOEC for the bird Gallus domestics: 2-400 mg/kg food (McKinney et al, 1976, Romijn et al 1991);
NOEC for mammals (PCB 153): 1mg/kg food (Romijn et al 1991).
9
Arochlor: technical polychlorinated biphenyl mixture with different percentage of chlorine
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7 COMPARISON OF ALTERNATIVES
In an environmental and social impact assessment, the possible alternatives should be evaluated. The
following types of alternatives should be considered:
The zero alternative: this is the evolution of the present situation without the PCB project being
implemented;
The alternative with the planned situation if the project is carried out.
For the latter several alternatives or scenarios may be studied i.e.:
Location alternatives: comparison of different possible locations for the project to be carried out;
Technical alternatives: comparison of different techniques/processes/methodologies to carry out
the project.
The alternatives may be of different origin:
They may originate from a feasibility study in which an (economic viable) solution is aimed at to
conduct a management or disposal project;
They may be asked for by the different governmental or other agencies involved in the EIA
procedure, or during the first public consultation round;
They may be proposed as a result of a study on “Best Available Technologies not Entailing
Excessive Costs” (BATNEEC) for a certain project.
For each of the alternatives a full project description should be given (see chapter 6.2). If, however,
when carrying out the scoping it already appears that an alternative will have a very high environmental
and social impact in comparison to the other alternatives to be studied or when an alternative appears
not to be realistic, it can be argued in the EIA report not to elaborate this alternative in the EIA process.
In this case no full project description is needed for this alternative.
It should be clear that for all alternatives all impact categories indicated in the scoping process should be
studied in detail (see Table 5-1 and Table 5-2). In order to be able to compare the different alternatives
studied the principles of multi-criteria analysis have to be applied. To that aim – for standardisation and
comparison reasons - all impacts are classified according to the following schedule:
0 No effect
+ Slight positive effect: this is an improvement of the existing situation for a specific impact
with limited magnitude, extent and significance
++ Moderate positive effect: this is a significant improvement of the existing situation for a
specific impact leading to surpassing the criteria used and characterised by a clear
magnitude or extent
+++ Highly positive effect: this is a significant effect with an important magnitude and extent
- Slight negative effect: this is a deterioration of the situation for a specific impact without
surpassing the criteria set; the impact can generally by mitigated and is reversible or
limited in extent and magnitude
-- Moderate negative effect: this is a deterioration of the situation for a specific impact giving
raise to surpassing the criteria used: it is characterised by a clear magnitude or extent,
however mitigation may lower the effect
--- Highly significant negative effect: this is a significant deterioration of the situation for a
specific impact characterised by a large magnitude and extent
---- Very important negative effect: this is a significant deterioration of the situation for a
specific impact characterised by a large magnitude and extent and irreversible in nature
without mitigation possibilities.
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In that way the impacts from different nature are brought into one scale which will allow inter-
comparison. In a next step it will be necessary to establish an acceptable methodology for valuation and
rating of the environmental resources of different nature. This valuation depends on the specific
importance given to each environmental component or resource, taking into account the local situation
and in particular specific sensitivities.
In order to evaluate the relative importance given to the different environmental issues, valuation factors
are proposed. This may be agreed upon between the group of experts involved in carrying out the EIA.
It is to be advised however that the major stakeholders are involved in valuating the environmental
issues since they are supposed to be well aware of the project and local sensitivities. In the particular
case of the PCB project it is proposed that EVN, DONRE, VEA and one NGO are involved in participation
to the evaluation.
Once the valuation factors have been attributed, the impact assessment score has to be multiplied by the
valuation factor for each impact. The valuated scores obtained in the way are to be added up to come to
a total environmental score. The alternative with the lowest (negative) score is then ranked to be the
alternative having the smallest environmental effect. However, the comparison also has to be subject of
a qualitative discussion and interpretation.
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8 ENVIRONMENTAL AND SOCIAL MANAGEMENT AND
MONITORING PLAN
8.1 LEGAL FRAMEWORK
Both the Vietnam Government and the WB requires mitigation measures to be recommended as an
integral output of the EA process. The WB requires that this information is presented in a particular
format within an ”Environmental Management Plan” (EMP). Doing so, it represents good practice in EA
reporting and also facilitates more effective and practical implementation of recommended measures.
Meanwhile, the Vietnam Government request the contents of an EMP must be in two Chapters of EIA
report which will be reviewed and approved in a Central Appraisal Committee or a Provincial Appraisal
Committee respectively.
The following are legal documents related to rules of EMP contents:
the World Bank’s OP 4.01
the Circular No 05/2008/TT-BTNMT of the Ministry of Resource & Environment issued December
08, 2008 on guiding to implement SEA, EIA and EPC
In general, the EMP should list all requirements to ensure effective mitigation of every potential
environmental impact identified within the EA; even those that are already assumed to be part of the
design. In this way, the EMP becomes a transparent summary of all the commitments made in the EA
and how those commitments will be delivered. This is critically important during implementation, as it
enables PMUs, the Borrower, the WB and regulatory authorities to implement (or track) project
commitments.
8.2 EMP FRAMEWORK
The EMP must include the following information:
Summary of typical environmental impacts that could occur as a result of project activities
Identification of feasible mitigation measures including responsibilities and cost for
implementation
Identification of suggested monitoring indicators including responsibilities and cost for
implementation;
Institutional arrangements: human resources to implement the EMP;
Capacity development and training;
Implementation schedule;
Reporting procedures.
Mitigation
The EMP identifies feasible and cost-effective measures that may reduce potentially significant adverse
environmental impacts to acceptable levels. The plan includes compensatory measures if mitigation
measures are not feasible, cost-effective, or sufficient. The EMP includes following activities:
It identifies and summarizes all anticipated significant adverse environmental impacts;
It describes each mitigation measure, including the type of impact to which it relates and the
conditions under which it is required (e.g. continuously, in the event of contingencies), together
with designs, equipment descriptions, and operating procedures;
It estimates any potential environmental impacts of these measures; and
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It provides linkage with any other mitigation plans if required for the project.
The following strategies were employed for an EMP (in order of priority):
Avoid the impact. To “avoid” means to be able to change some aspect of the project design,
construction, or operation such that the impact no longer occurs (e.g., changing the alignment of
a road so it avoids a national park).
Minimize the impact. To “minimize” means to implement measures that will reduce impacts to
acceptable levels (e.g., ensuring that construction equipment meets TCVN industrial emission
standards).
Rectify the impact. To “rectify” means to allow an impact to occur, then afterwards take
measures to rehabilitate the environment to a level whereby the impact is within acceptable
limits (e.g., filling in used limed pits as part of construction clean-up).
Compensate for the impact. To “compensate” means to allow the impact to occur, then
afterwards provide non-monetary compensation (first priority) or monetary compensation
(second priority) for losses created by the impact (e.g., if a farmer must be resettled, the first
compensation priority is to provide replacement land and housing. If replacement land and
housing cannot be provided, the replacement value of losses should be calculated and provided
to the farmer.).
The mitigation measures will be elaborated as a table with the following possible structure:
Issue Description Typical mitigation Monitoring Responsible Timing Cost
of typical measures indicators
impacts
Construction phase
Air
Soil
Operational phase
Surface water
Air
Soil
Monitoring
Environmental monitoring during project implementation provides information about key environmental
aspects of the project, particularly the environmental impacts of the project and the effectiveness of
mitigation measures. Such information allows corrective action to be taken when needed. Therefore, the
EMP identifies monitoring objectives and specifies the type of monitoring, with linkages to the impacts
assessed in the EIA report and the mitigation measures described in the EMP. The monitoring section of
the EMP provides:
a specific description and technical details of monitoring measures including:
the parameters to be measured;
methods to be used;
sampling locations;
frequency of measurements;
detection limits (where appropriate);
definition of thresholds that will signal the need for corrective actions; and
monitoring and reporting procedures to ensure early detection of conditions that necessitate
particular mitigation measures, and furnish information on the progress and results of mitigation.
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The monitoring needs will be worked out in a table which will be similar to the table containing the
mitigation plan. Following structure may be used.
Parameter of Frequency Methodology Example Assessment Investment Recurring
concern location criteria cost cost
(quoted (annually)
Vietnamese
standard)
Wastewater, for example
Flow rate Random Open channel
check or related device
monthly with known
relation water
height – flow rate
BOD Random Winkler method
check or or O2-specific
monthly electrode
...
Soil, for example
PCBs Periodically
(every 5
years)
….
To ensure that the mitigation and monitoring is performed, it will be necessary to elaborate a number of
operational procedures. For example:
What to do in the case of accidents;
Visual control of the state of for example impermeable floors;
…
Institutional arrangements
Experience on other projects has found that there is substantial benefit in assigning one person in each
management unit to take responsibility for implementing their respective duties in the EMP. In the case
of the PCB project, the following recommendations are made:
Assign one person to PMU as Environmental Safeguards Specialist.
Assign one person for each PMU of demo-project (sub-PMU) as Environmental Officer.
Retain at least one Safeguards Independent Monitoring Consultant to review and monitor EMP
implementation.
The environmental safeguard specialist/environmental officer positions will be part-time posts held by
regular staff within the PMUs and sub-PMUs. It is expected that environmental officers will hold other
posts within sub-PMU (social safeguards, engineering, etc);
The Environmental Officer is responsible for ensuring that the registration and updating of all relevant
EMP documentation is carried out. It is the responsibility of the Project Manager to ensure that all
personnel are performing according to the requirements of this procedure and to initiate the revision of
controlled documents, when required by changes in process, operating procedures, legislation,
specifications, audit findings or any other circumstances, by informing the Environmental Officer of the
changes. A controlled document is official only if the issue/revision has been approved. The
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Environmental Officer and Project Manager are responsible for ensuring that the latest versions of
documents are used to conduct tasks which may impact on the project environment.
The safeguard independent monitoring position will be on contract with PMUs.
Capacity Development and Training
To support timely and effective implementation of environmental project components and mitigation
measures, the EMP defines who is responsible for carrying out the mitigation and monitoring measures.
For example for operation this includes responsible persons for supervision, enforcement, monitoring of
implementation, remedial action, financing, reporting, and staff training. If necessary, the EMP
recommends the establishment or expansion of such units, and the training of staff, to allow
implementation of EA recommendations.
The relevant Vietnamese institutions will be defined and the capacity requirements for the involved
institutions will be evaluated but also the capacity requirements of the operator will be discussed.
Implementation Schedule and Cost Estimates
For all three aspects (mitigation, monitoring and capacity development), the EMP also provides:
an implementation schedule for measures that must be carried out as part of the project,
showing phasing and coordination with overall project implementation plans;
the capital and recurrent cost estimates and sources of funds for implementing the EMP. These
figures are also integrated into the total project cost tables.
For these two last elements it is important that insight is given in the plans and organizational structure
of the project owner or organizer.
Reporting procedures
It is vital that an appropriate document handling and retrieval system be developed for all EMP
documentation. This will ensure that there is adequate EMP documentation control and will facilitate
easy document access and evaluation. EMP documentation should include:
EMP implementation activity specifications;
training records;
site inspection reports;
monitoring reports; and
auditing reports.
Responsibilities must be assigned to relevant personnel for ensuring that the EMP documentation system
is maintained and that document control is ensured through access by, and distribution to, identified
personnel.
The following environmental monitoring and reporting framework will apply to the project:
- Each construction contractor will provide monthly reports to PMUs on the implementation of the
requirements contained in the relevant demo-project EMP and the results of the environmental
performance monitoring outlined in the EMP.
- During construction, for each demo-project, sub-PMUs will engage an independent organization
to conduct periodical environmental monitoring and prepare reports for submission to the PMUs,
DONRE and WB. The timing and frequency of these reports will vary depending on the sub-
projects and will be defined in the sub-project EMP.
- During operation, for each demo-project, sub-PMUs will engage an independent organization to
conduct periodical environmental monitoring for at least the first 2 years of operation and reports
to PMUs, DONRE and WB. The timing, frequency and duration of these reports will vary
depending on the demo-projects and will be defined in the demo-project EMP.
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Document control is important for the effective functioning of an EMP. A document handling system must
be established to ensure adequate control of updating and availability of all documents required for the
effective functioning of the EMP. This procedure applies to the EMP as well as procedures and policies
relating to the EMP, which must be controlled (i.e. identified, registered and changes recorded).
The EMP and procedure documents must be controlled and only distributed according to a distribution list
compiled by the Environmental Officer. Documents should be numbered and controlled according to the
distribution list. These documents shall be marked “controlled copy”. Holders of controlled documents
shall sign the distribution list when they receive a new or revised document and must destroy the old
version. Whole documents should not be reprinted and older versions destroyed when only a few pages
are affected by the revision.
8.3 OVERVIEW OF POTENTIAL ENVIRONMENTAL AND SOCIAL
MITIGATION MEASURES
8.3.1 Mitigation measures for activities related to PCB management
As discussed in Chapter 4.2, PCB management activities can be divided into different kind of processes:
identification and labelling of PCB-containing products and equipment (including the testing to
determine the PCB content);
transportation of PCB containing products/waste;
PCB (temporary) storage;
Decontamination of PCB containing equipment and retro-filling activity.
The implementation of mitigation measures is, for certain, relevant with respect to the three last
processes. In fact the mitigation measures can be subdivided into 3 groups. Into the first group belong
the measures which are related to infrastructure, the second group are measures which are process
related, the third group exists of measures which are related to codes of good practice and management
principles. For each of the measures, mentioned in Table 8-1, following items are described (if relevant):
the first column (issue) gives the type of measures (infrastructural, process or management
related);
the second column (target) indicates if the measure is applicable for a location within the plant, a
process step or concerns a management aspect;
the third and fourth column (indicator) give some more information regarding the mitigation
measure itself;
the fifth column gives an idea how regular the application of the measurement must checked.
The occurrence of spills and accidents is related to each of these processes. Spill management is
important and is, therefore, worked out as a separate item. Also environmental monitoring is considered
to be a separate process step.
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Table 8-1: Overview of typical mitigation measures and monitoring for activities related to PCB management
Issue Target Description Indicator Timing
Transportation of PCB containing products/waste
Infrastructural needs Loading/unloading area preferably Presence of Monthly
an impermeable floor containment equipment, control
a separate collection system for absorbents
contaminated surface water if spills do occur
curbs to prevent spreading of PCB
containing products in the case of
a spill
Loading/unloading Well maintained equipment Lack of deficiencies Monthly
mechanism Enough place to operate control
Transportation means airtight containers, drums, plastic bags with
measures to prevent leakage
emergency equipment on vehicles Monthly
communication equipment for emergencies control
Process needs Registration and labelling of Including information regarding Each transport
transported product/waste characteristics of PCB’s like condition, origin,
quantity, type of packaging container, …
Cleaning up by using surfactant Discharged water to specialized disposal After each
installation transport
Management needs
Trained personnel (drivers Regular training sessions regarding Every 6
and loaders) characteristics and background knowledge of months
PCBs
Packing and transporting of PCBs
Accidents and emergency response measures
Procedures/codes of good Transportation plan (planning of necessary documents must be in order Each transport
practice route and agenda,
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Issue Target Description Indicator Timing
accommodation and fuel
charging, measures for
addressing troubles or breakdown
of vehicles, …)
Acceptance guidelines Checking the transported load, the labelling Each transport
and note abnormalities into register
PCB storage (temporary)
Infrastructural needs Storage area Anti-seepage: Visual inspection Monthly
Impermeable floor Materials used: must be incompatible with control
Leachate collection system PCBs, resistant to erosion, corrosion
Preferably covered (inside) Absence of any kind of openings (floor
drains, sewers, …)
Absence of cracks
No visible signs of contamination
Storage facilities Separate storage in function of Volume of the curbed area must be able to Weekly
type of PCB product or waste contain 1/5 of the total storage inspection
(applicable for all kind of Check labeling If any
hazardous products) – PCBs with breakage or
Presence of equipment to retain the spill
similar properties may be stored damage
(absorbents), personal protection equipment
together occurs,
and tools, communication equipment, fire
Storage areas separated by curbs, fighting facilities, air cleaning system cleaning up
different rooms and
Transport alleys must be present replacement of
package must
Air tight drums and containers
be undertaken
Handling equipment loading/unloading equipment Check for mechanism failure of the handling Monthly
f.e. lifting hook and handling equipment control
space Check the available free space When
problems are
observed,
immediate
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Issue Target Description Indicator Timing
action must be
taken
Adequate ventilation Fans (portable) Lack of deficiencies
Process needs Registration and labelling of Including characteristics of PCB’s Weekly check
stored product/waste like condition, origin, quantity,
type of packaging container,
storage date, position in storage
facility, …
Cleaning up by using surfactant Discharged water to specialized disposal Periodical and
surface, walls and equipment installation after closure
PCB contaminated material (in must be brought to specialized disposal site Periodical and
airtight drums) after closure
Management needs
Trained personnel Regular training sessions Regarding characteristics and background Every 6
knowledge of PCBs, months
receiving and storing of PCBs
Keeping the facility in good working
conditions
Checking of mechanism failure
Accidents and emergency response measures
Decontamination of PCB containing equipment and retrofill activity
Infrastructural needs Closed loop dehalogenation Generation of solid waste within Analysis of waste Monthly
technology the reactor inspection and
analysis
No production of off-gas
Monitoring of transformer oil PCB’s concentration At the end of
the
decontaminati
on
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Issue Target Description Indicator Timing
Adequate ventilation Fans when integrated ventilation Important to ensure that air is supplied at a Periodical
is not foreseen higher lever than it is extracted inspection
Suitable filtration to prevent air Presence of filters which exist out of 2 parts:
emissions electrostatic filter to remove aerosol and
activated carbon filter to remove vapour
Process needs
Cleaning up by using surfactant Discharged water to specialized disposal Periodical and
surface, walls and equipment installation after closure
PCB contaminated material (in must be brought to specialized disposal site Periodical and
airtight drums) after closure
Management needs
Trained personnel Regular training sessions Regarding characteristics and background Every 6
knowledge of PCBs, replacement liquids months
Decontamination PCB containing equipment
/ retrofilling
Keeping the facility in good working
conditions
Checking of mechanism failure
Accidents and emergency response measures
PCB Treatment plan Explaining the detailed activities, Check if transformer is approved for yearly update
the risks of the different handling retrofilling, dependant of age of equipment,
actions, … condition of transformer, is necessary
technology available, are suitable
replacement fluids available, …
Check required characteristics of PCB yearly update
replacement oils: electrical characteristics,
fire resistance properties, density, coefficient
of thermal expansion, viscosity, flash point
and flammability, combustion by-products, …
Protect personnel Provide protective clothing like Replace periodically Every 6
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Issue Target Description Indicator Timing
One piece chemical resistant suit months
Chemical resistant gloves
Boots, or disposable covers for
shoes
Approved face breathing mask
Safety Inspect working of fire equipment Replace periodically Every 6
months
Spill management
Management needs Elaborate a spill response Identifying Yearly update
plan Reporting requirements (names,
phone numbers of appropriate
agencies)
Immediate response procedures
Information on containers,
labelling, disposal requirements
for cleanup debris
Methods for determining spill
boundaries
Decontamination procedures for
different PCB use areas
Required records
Post-cleanup sampling
requirements
Avoid spreading Avoid spills from running out Containment equipment and absorbents at all Weekly
relevant areas inspection
Spill control Absorptive material should be spread on the contaminated area immediately
and should be left in place for at least one
hour or longer to ensure that all PCB fluid
have been absorbed
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Issue Target Description Indicator Timing
Removal of contaminated soil if PCB contamination cannot be determined Within 24
visually at least 15 cm of soil depth must be hours
excavated
Removal of absorptive material In steel containers
after use and contaminated soil,
also exposed clothing, boots, …
All equipment in exposure area Within the
should be washed down with week
solvent
Prevent emission of PCBs to the Pump out the air with air pump whose outlet Within 24
atmosphere is fixed with carbon fiber absorber hours
Use plastic cloth to cover surface of polluted
spot to diminish the vaporization of PCB’s
Training sessions Exercise every available spill periodically
which may occur
Protect personnel Provide personal protective
clothing and equipment (see
higher)
Protect surrounding Inform responsible authorities Within 24
hours
Prevent pedestrians and vehicles Placement of barricades around the immediately
entering contaminated area
Safeguard personnel When exposed, medical attention immediately
must be organized
Inspiration of PCBs Move exposed people to ventilation room
Give artificial respiration
In function of seriousness hospitalization will
be necessary
Dermal contact with PCBs Swab skin with soap or neutral detergent
Take contaminated cloths of and clean
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Issue Target Description Indicator Timing
In function of seriousness send to hospital
Eye contact with PCBs Rinse eye with water
In function of seriousness send to hospital
Ingestion of PCBs Send to hospital at once
When conscious use syrup of insert finger to
induce vomiting
Evacuation of personnel Foresee room for care and
and, if necessary, people support
present in the immediate
surroundings
Environmental monitoring
PCB Detection of potential Visual inspection for leaks at Leak detected Weekly
pollution storage facility
PCB in soil (mg/kg) and Define background level Soil investigation (drillings and Concentrations in soil (top soil and soil Start of activity
groundwater (µg/l) piezometers) immediately under top soil) and groundwater In case of
1 drilling / area <20 m² of spills or
1 piezometer / area < 50m² <1 mg/kg dw soil storage on
<0,1 µg/l groundwater soil.
Follow-up potential pollution Regular investigation at spots If the soil/groundwater conditions poses risk Periodically
in soil and groundwater defined as critical for the current or future use of the site (f.e. every 10
remediation is necessary years) and
after closure of
the facility
PCB in air (µg/m³) Define background level Start of activity
Weekly check
at relevant
spots
Monitor ambient air quality Measure PCB content and Concentration < 0.5 mg/m³ Every 6
hydrocarbon content in emission months and
after closure of
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Issue Target Description Indicator Timing
gas facility
Monitor air discharge Measure PCB content and Concentration < 0.5 mg/m³ Every 4
hydrocarbon content in emission months
gas
Detection of air pollution Monitor air quality in (storage) Concentration in air <0.5 mg/m³ Ad hoc
facility in case of leak
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8.3.2 Mitigation measures related to PCB treatment and disposal
For the PCB treatment and disposal a number of pre-treatment and treatment techniques exist. The possible mitigation measures are elaborated in a way which
is different from the concept which is chosen for the activities related to PCB-management. Here the mitigation measures are given in relation to the impact
group as there is less difference in the impacts for the different techniques.
One of the impacts which are considered is the impact on the social environment. The social environment refers to how people and communities behave, their
relationships, education and occupation, and the conditions in which they live. For example increased levels of unemployment could be due to poor living
conditions. Levels of education and employment directly influence the social environment, especially the rate of social development. Low levels of education limit
people’s access to employment opportunities as well as constraining the growth of the economy. Economic growth and global competitiveness in turn can be
constrained by a lack of appropriately skilled people. Poor levels of public health place also immense pressure on human well-being.
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Table 8-2 Overview of typical mitigation measures and monitoring related to PCB treatment and disposal
Issue Target Description Indicator Timing
Water
Ameliorate water run off Foresee drainage, containments,
with slight slope
Reduce discharge of Use separate discharge systems
industrial wastewater for household wastewater, rain
and industrial wastewater
Buffering of wastewater To get more homogenous
before treatment composition of waste water
before treatment
Purification of industrial Foresee the necessary waste Concentrations in treated waste water must Monthly control
wastewater water treatment installation be less than those determined in the
At least sedimentation basin and environmental permit
oil trap
Optimisation of nutrient Efficiency of wastewater
dosage treatment installation
Soil, groundwater and waste
Protect groundwater Limit use of groundwater as
resources industrial water
Avoid soil and groundwater Store chemicals, fuels/oils in Check for visual spots of contamination or weekly
contamination covered areas with concrete signs of cracks in the floor
(impermeable) floors and curbs to
prevent spreading
Handle chemicals, … with the throughout
greatest care
Ensure prompt clean-up of any Immediately,
spills followed by
corrective
actions within
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Issue Target Description Indicator Timing
the months
Waste disposal Construct isolated and fenced
temporary disposal areas
weekly clear and transport waste
to accredited waste treatment
installations
No disposal of waste in direct
surrounding of surface water
waste management plan Describing the different waste
streams (solid, fluid, hazardous,
…)
identification of temporary
disposal sites on map
destination of the different
disposal streams
monitor requirements (register,
…)
Air and noise
Minor emissions from Cover vehicles carrying dispersible
vehicles and equipment materials
Minimize size and duration of
exposed areas
Keep vehicles and equipment well
maintained
Cover temporary stockpiles
Reduction of dust formation Sprinkling or brushing of roads
Wheel washing
Establishing and enforcement of
speed limits
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Issue Target Description Indicator Timing
Prevention of unnecessary Use of machinery complying with
emission of gasses BAT(NEEC)
Limit noise impact for Provide noise protection At places where an excess of noise regularly Periodical check
workers equipment occur f.e. by poorly working machines
Limit noise generation for Keep equipment well maintained Equipment with excess of noise Regular check
surroundings Replace old noisy equipment by Take into
new more silent ones (BATNEEC) account in the
Avoid nightly acitivities yearly made
investing plan
Use acoustic shields or place
noise reducing equipment at very
noisy activities
Ecosystem
Aquatic ecosystem Changes to water quality may Ensure quality of discharged wastewater in Periodical
affect aquatic ecosystems surface water inspection
Vegetation and habitat Dust generation, air pollution and Foresee cleaning of site periodically
adverse effects on water quality Check air purification systems
may affect growth of vegetation
Protected areas Avoid impact or foresee In function of
compensation growth activity
Man and his social economic living environment
Changes to economic Employment opportunities Impact on number of employees In function of
activities and production growth of
changes in
activity
Changes to traffic volumes and
traffic safety
Changes to accessibility Schedule works to be completed
in efficient and timely manner
Effects on public health Elaborate procedures which must Cooperate with local authorities
be followed in case of incidents
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Issue Target Description Indicator Timing
Land use changes Elaborate a dossier explaining Cooperate with local/national authorities In function of
what will be realised and evaluate growth activity
possible impacts
Implement compensation if
necessary
Effects on physical or If effect occurs possible Maximal integration in existing landscape
cultural heritage compensation must be studied
Effect on landscape Reduce visual impact f.e. adequate plantation programme in and
around the project site
Monitoring
Parameter of Target Description (collection, Indicator Timing
concern handling, analysis
Soil and
groundwater (see
table 8.1)
Waste water (typical
components)
Flow rate (m³/hour) Determination of flow Open .channel calibrated - Continuous
rate device (venturi) with known
relation
BOD (mgO2/l) Detection of pollution O2 concentration <50 Monthly:
measurement before and after
incubation
COD (mg O2/l) Detection of pollution Potassium dichromate method <80
Chlorinated Detection of pollution Gas chromatographic method < 1000 Monthly
hydrocarbons (µg/l) after extraction with adapted
sovent
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Monitoring
PCB’s (µg/l) Detection of pollution Gas chromatographic method 3-50 (depending on receiving water body Monthly
after extraction with adapted – see table 6-9)
solvent
pH Detection of pollution Electrometric method (pH 5,5-9 Continuous
electrode)
Salinity (mg/l) Detection of pollution Colorimetric method < 1000 Monthly
(electrode)
Air pollution (typical
components)
TSP (PM10) Detection of emission Isokinetic sampling 24h <4 2x/year
emission (µg/m³ or device.
mg/m³)
PCB emission Detection of emission Isokinetic sampling 24h device <0,5 2x/year
(µg/m³) Gaschromatography
Dioxines/furanes Detection of emission Isokinetic sampling 24h device < 0,5 2x/year
emission (ùg/m²) Gaschromatography
PCB + dioxin Air quality Air quality monitoring point to Toxic equivalents (TEQ) 2x/year
deposition pg/d be set up 0,5, 1 and 2 km 1-4 pg/kg.d.
direction of predominant
offwind – one month
3 Bergeroff deposition bottles
per sampling point
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8.4 ROLES AND RESPONSIBILITIES OF STAKEHOLDERS
The roles and responsibilities of the different Ministries and Agencies at both the national and provincial
levels have been reviewed by Breeze and Associates Inc (2007b) and are summarized in section 2.1 of
this report.
In this section 2.1 an overview is provided of the authorities involved in the different aspects of the PCB
management. Furthermore the findings of Breeze and Associates Inc (2007b) on the needs for
improvement are summarized in the same section.
This overview provides the basis for the implementation of the environmental management and
monitoring plan. For this implementation there will always be a key role for the project initiator who will
be the main responsible for carrying out the mitigation measures and monitoring. This project initiator
may either be EVN or another (private) company involved in the management of PCB’s, i.e.:
Owners/developers of storage facilities for PCB’s
Owners/developers of refilling /recycling stations for PCB’s
PCB transport organizers
Owners of PCB treatment facilities
Responsible for power plants
For each project the environmental management plan has to be implemented in close collaboration and
under the supervision of the respective Government Agencies (see 2.1.1.). Most likely (since it concerns
local projects) the environmental management plan will be implemented by the project initiator (plant
owner) in close collaboration and under control of a steering committee with representatives of:
DONRE/VEA: for ensuring data collection is carried out properly, for assessing monitoring data
and for control that prescribed measures are carried out
Provincial Peoples Committees: to ensure that all directives from the environmental management
plan are implemented
Other Ministries are to be part of the steering committee when the environmental management plan is
related to projects that fall within their competences (i.e. Ministry of transportation for PCB transport
projects) or when effects may occur that are related to their responsibility (i.e. Ministry of Health when
health effects are important).
In case mitigation measures encompass the level of individual projects and are more general in nature a
major responsibility should be taken by VEA, together with MONRE to arrange for these measures to be
implemented ( in the framework of the PCB management project).
This will be the case for the following types of measures:
Development of material for sensibilisation of workers and citizens in general;
Setting up of training on characteristics of PCB’s, preventive measures for packing and
transporting PCB’s
Development and organisation of training on emergency response
Setting up of a monitoring program for transformer oil
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9 RESULTS PUBLIC CONSULTATION MEETINGS
9.1 LEGAL FRAMEWORK
Vietnam requirements
The Circular number 05/2008/TT-BTNMT of the Ministry of Resource & Environment issued
December 08, 2008 guiding to implement SEA, EIA and EPC:
- The project proponent send to the Commune People Committee and the Commune Fatherland
Front Committee a formal information of project description, including environmental and
social potential impacts; mitigation measures; and other related problems;
- The Commune People Committee and the Commune Fatherland Front Committee open public
announcement of information of project or arrange a public meeting if necessary;
- The Commune People Committee and the Commune Fatherland Front Committee give their
opinions in writing to the project proponent. The opinion shall be added to EIA report to
submit to Appraisal Committee.
The Decision No 80/2005/QD-TTg of The Prime Minister issued April 18, 2005 promulgating the
Regulations on public supervision for investment projects:
- Community has a right to supervise all activities of investment projects, including
environmental impacts and mitigation measures;
- Public supervision shall implement through the local Fatherland Front Committee.
Bank Requirements
For all Category A and B projects proposed for World Bank (IBRD or IDA) financing, during the impact
assessment process, the borrower (VEPA and EVN) consults project-affected groups and local
nongovernmental organizations (NGOs) about the project’s environmental aspects and takes their views
into account. The borrower initiates such consultations as early as possible.
As indicated in chapter 3, the borrower consults these groups at least twice for Category A projects:
shortly after environmental screening and before the terms of reference for the EA are finalized;
and
once a draft EA report is prepared.
In addition, the borrower consults with such groups throughout project implementation as necessary to
address EA-related issues that affect them.
The primary purpose of the public consultations provision in the World Bank rules (Operational Directive
(OD) 4.01and OP/BP/G 4.0) and EIA rules in Vietnam is to protect the interests of affected communities,
especially the poor and vulnerable. Experience has shown a strong link between project sustainability and
effective public consultation.
Stakeholder group’s benefits from public consultation may include for example:
Fewer conflicts and delays translate into improved profitability for investors;
Governments improve decision making and secure greater transparency and accountability;
Public agencies and NGOs may gain credibility and further understanding of their mission;
Affected people can influence the project to reduce adverse impacts, maximize ancillary benefits
and ensure that they receive appropriate compensation;
Additional opportunities will arise during project design to ensure that vulnerable groups are given
special attention, that equity issues are considered and that the needs of the poor receive priority;
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Environmental and Social Management Plans which result from the EA process are more effective.
The objectives for consultation at each stage and some methods on how this can be done are
summarized in the following table.
Table 9-1: Public Consultation during the EA Process
EA Stage Objectives Example Methods
Scoping Identify key stakeholders; Individual meetings
- Introduce the project; with key stakeholders
- Understand the value of e.g. local government,
environmental parameters; NGOs, select number
- Understand how land is of locally affected
currently used and learn people;
whether there are - Questionnaires;
elements of the baseline - Scoping workshop.
previously unknown.
Completion of Draft Report and discuss results Disclosure of EIA
EIA Report of EIA; report or its summary,
- Obtain feedback and inviting feedback;
acceptance of results. - Organize public
meeting, focus groups,
workshops or seminars.
Following disclosure and consultation on the draft EIA report, the proponent / Project owner is
responsible for revising the EIA report to reflect the comments and views obtained during consultation.
Responsibility
The Project owner is responsible for ensuring that project affected people and local NGOs are
appropriately informed during the EA process. The Project owner must also organize the disclosure of the
EIA report (or its summary) to locally affected populations and then organize meaningful consultation
with these. The Project owner must also ensure that the views of affected people and local NGOs are
taken into consideration in project design and implementation. A mechanism for continuing consultation
with these stakeholders must be included in the EMP and carried out throughout project implementation
to address any issues or impacts that may arise.
Consultation Techniques and reporting
The public participation process can be broken down into four key stages, each of which is a prerequisite
for the next:
Information gathering: collection of baseline data from the public to feed into impact prediction;
Information dissemination: stakeholders are informed about the project;
Consultation: stakeholders are given the opportunity to voice their views about the project; and
Participation: an extension of consultation, where stakeholders become joint partners in the
design and implementation of projects and take part in decision-making.
Different techniques can be used for each stage as described in following Table.
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Information Information Consultation Participation
Gathering Dissemination
Questionnaires/ Media (radio, TV, Focus Village
surveys/ polls. newspapers). groups/workshops. committees.
Key informant Displays, Conferences/ Round tables.
interviews. exhibits. seminars.
A report on public consultation can be developed with content as following
1. Introduction
- Background and Objective of Project.
- Purpose of Consultation in EIA Preparation.
- Requirement for Consultation (of WB and of the goverment).
- Identification of Project Affected Groups.
- Outline of Consultation Report.
2. Summary of consultation activities undertaken
- Overview of how consultation undertaken, when, by whom.
- Summary of persons consulted.
3. Result of consultation during project scoping
- Issues Identified by Stakeholders.
- How these issues were taken into account.
4. Result of consultation on draft EIA report
- Issues Identified by Stakeholders.
- How these issues were taken into account.
5. Recommendations for ongoing consultation Annexes
- Summary of Project (should provide project description in brief,
potential impact of project, and mitigation measures for some
significant impact).
- Detail proceedings / minutes for each consultation activity.
- Complete List of Participants for each consultation activity.
If the report is included in the EIA report however it can focuss on the results of the consultation
meetings and on the way how the input is taken into account in the EIA.
Public consultation for the PCB management Project
For the projects to be carried out within the framework of the PCB Management Project it is
recommended to organize two consultation meetings in case an EIA is due or in case a EIA is
prepared (see also section 3.3).
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The stakeholders that should be invited are those who have an interest or a stake in the Project
including ‘those who are likely to be affected by the project as well as those who may have an
influence over the project’.
The following stakeholder groups have been identified by the consultant for being invited to the
consultation meetings for projects implemented within the framework of the PCB management
projects:
Donor: World Bank
Project implementing agency: EVN
Lead agency for the country’s National Implementation Plan for the Stockholm Convention:
MONRE
Implementing agency for POP activities: VEPA
Department of National Resources and Environment of the Province: DONRE
Provincial Peoples Committee ensuring that national directives are implemented in the provinces
and their local (district) representatives from the villages that may be affected
Local community representatives/leaders from the villages that may be affected
Local citizens that may be affected
Non governmental organizations which are organized in the Provinces in which the project is
proposed
Other organized interest groups like associations of industrial sectors
Representatives from (Provincial Departments of) Ministries with responsibilities related to the
project:
Ministry of Health
Ministry of Industry and Trade
Ministry of Construction
Ministry of Science and Technology
The stakeholders have to be invited at least two weeks before the consultation meeting takes
place. Invitations should be addressed by the project initiator either by
An invitation letter: to all representatives from Ministries and Government Departments
A publication in a local newspaper: for the public
An announcement at the entrance of the site of the project
Comments can be made in different ways:
Spoken comments during the meeting
Written comments up to a maximum of two weeks after the meeting
All comments should be summarized in the minutes of the meeting to be completed with the list
of attendants and with an addendum of the written comments.
The comments should be taken into account in preparing respectively the draft and final EIA.
Comments not taken into account should be addressed separately by providing responses to the
comments in the chapter on public consultation of the EIA.
9.2 PUBLIC CONSULTATION FRAMEWORK
All subprojects require at least one public consultation and the results of the consultation require
documentation in the EMP. The public consultation can be conducted either prior to preparing a draft EMP
in order to discuss key environmental issues and proposed management actions to be included in the
EMP, or after a draft EMP is completed to act as a basis of discussion and to elicit any additional
environmental issues that may be of concern to affected groups. In either case, early consultation is
preferred.
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If a public consultation is being conducted to address social aspects of the subproject, EMP public
consultation may be combined with it to discuss environmental and social aspects in an integrated
manner. This should reduce the time and expense in preparing for and conducting the consultation.
The developer is responsible for organizing, conducting and documenting public consultations. Public
consultation should introduce the subproject to the local residents and determine if there are any
particular subproject concerns. Consultations should also include representatives of local government
(Commune’s People Committee) and local organizations (for example Fatherland Front, Women's Union,
and concerned local NGOs).
Documentation of the public consultation should include the following information:
Manner in which notification of the public consultation was announced: media used, date(s),
description or copy of the announcement;
Date(s) consultation(s) was (were) held;
Location(s) consultation(s) was (were) held;
Who was invited
o Name, Organization or Occupation, Telephone/Fax/e-mail number/address (home and/or
office);
o Who attended
o Name, Organization or Occupation, Telephone/Fax/e-mail number/address (home and/or
office);
Meeting Program/Schedule, including what was presented and by whom;
Summary Meeting Minutes (Comments, Questions and Response by Presenters), especially including
issues raised by the local residents;
Decisions reached and actions agreed upon to address issue raised, including schedules to implement
agreed actions, deadlines, and responsibilities for the actions; and
Any signed agreements arising as a result of consultation.
The documentation should reflect all comments, whether or not the developer agrees or
disagrees. The minutes should also have signatures (name, title) of the chairman of the dialogue.
Stakeholder analysis
The stakeholders are defined as those who have an interest, or a stake in the Project, including “those
who are likely to be affected by the project as well as those who may have an influence over the
project”10. Based on the review of the secondary data, fieldwork, and formal and informal
meetings/consultations, the following stakeholder groups has been identified , and their characteristics,
interests, and influence are summarized in the table below:
10 Social Analysis Sourcebook: Incorporating Social Dimensions into Bank-supported Projects, World Bank, 2003. P.10.
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Table 9.2. Stakeholder analysis
Stakeholder Relevant Characteristics Interests Influence
categories Stakeholders
Social situation, Location, Commitment to Status Quo High,
Size, Organizational vs. Openness to Change Medium, or
Capability Low
Donor World Bank (WB) Large international Interest in developing project High
development organization that will help HW and PCB
with focus on environmental management development in
pollution prevention. Vietnam
Government MONRE, MOIT Borrower. Responsible for Strong interest in High
policymakers HW management. improvement of policy
framework on sound PCB
management
Implementing VEA, EVN, ISEA Responsible for overall Strong interest in successfully High
agencies implementation of PCB implementing PCB
Management Demonstration Management Demonstration
Project. Project as designated
implementing agency.
Other EPD Under MOPS, responsible for Interest in implementing PCB Medium
interested investigation, dealing with Management Demonstration
authorities legal violations of HW Project, development of legal
management. requirements.
MOC Responsibilities for settting Interest in implementing PCB Medium
the sector standards for the Management Demonstration
construction of all HW Project
transportation systems and
facilities in Vietnam.
Moreover, MOC can direct
PPCs in planning for the
construction of hazardous
waste facilities
MOH Responsibilities for Interest in implementing PCB Medium
overseeing the management Management Demonstration
of medical wastes at health Project and development of
care facilities and, in the legal requirements.
coordination with MOC and
MONRE, for planning,
selecting technologies and
establishing medical waste
incinerators
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Stakeholder Relevant Characteristics Interests Influence
categories Stakeholders
Social situation, Location, Commitment to Status Quo High,
Size, Organizational vs. Openness to Change Medium, or
Capability Low
MOLISA Responsibilities for workers’ Interest in implementing PCB Medium
safety and occupational Management Demonstration
health, including providing Project and technical
guidelines and PCB good guildelines
practices for workers who
may be working with PCB
equipment
Provincial In charge of socio-economic Strong interests in Medium
People’s development planning in development of PCB
Committees local level storages.
(PPCs)
DONREs In charge of provincial Strong interest in PCB High
environmental management. management
District Responsible for working with Strong interest in building Medium
Authorities sub-PMUs to carry out and operating PCB storages
bulding and operating PCB in their respective districts.
storages
Intended Workers Working with PCB Strong interest in bulding and High
beneficiaries, contaminated equipments operating PCB storages
but also
adversely Local Living near PCB storages Strong interest in bulding and Medium
affected Communities operating PCB storages
persons
Overview of Project-Level Public Consultation Activities
The Demo-projects must involve as many stakeholder groups as possible in the process of
implementation. Table 9.3 summarizes a consultation process for demo-project.
Table 9.3 Summary consultation process for demo-project
Activity Type of Participation
Stakeholder Groups* Timing & Duration Output Constraints
Donor (WB); Government Up to signing contract. Project -
Project policymakers (MONRE, MOIT Contract.
Identification – Borrower); Implementing
agencies (VEA, EVN)
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Activity Type of Participation
Stakeholder Groups* Timing & Duration Output Constraints
Donor (WB); Government Formal Consultation Formal Difficulty of full
Policymakers (MONRE, MOIT Workshops (3 workshops workshop coverage and
– Borrower); Implementing during Consultancy Services minutes; definitional issues
agencies (VEA, EVN, ISEA); – Inception, Interim, & incorporation of all project
Public
Other interested authorities; Final) of feedback affected
Consultations
Private sector firms; & NGOs. into Project communes.
design and
into related
reports
Those mentioned above, plus Informal Consultations –
District and Commune PCs; throughout Consultancy
Local communities in general Services.
Preparation WB; VEA, EVN, ISEA. Following identification of PIP. Time constraints.
of Project Project components and by
Implementati WB disclosure date.
Feasibility and Preliminary Design
on Plan (PIP)
PMUs (Prepared under Commenced during latter EIA & EMP Time and
separate contract by another half of Feasibility and resource
Consultant.) Preliminary Design constraints.
Consulting Services and Difficulty of
Preparation expected to be completed coordination
of EIA & EMP by WB disclosure date. because EIA is
under separate
contract from all
other
components.
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Activity Type of Participation
Stakeholder Groups* Timing & Duration Output Constraints
Project implementation done Entire implementation Improved Time and
by PMUs and sub-PMUs with period. Transport resource
assistance from VEA, EVN, Network in constraints.
ISEA and DONREs Mekong Delta. Difficulty of full
coverage and
Information dissemination definitional issues
on details of project for of all Project-
Intended beneficiaries (Local respective Project area affected areas
Project Communities); Other populations significantly in and groups.
Implementation, affected & interested groups. advance of commencement Limited expertise
Supervision & on social issues
Monitoring and M&E in
implementing
Continuous consultations
agencies.
during Project
implementation so that it
minimizes anticipated as
well as unexpected negative
impacts during
implementation
VEA, EVN, ISEA; PMUs; Group discussions with local M&E Report. Time and
DONREs; DIONREs; Local communities and other resource
communities in general; affected persons. constraints.
Other interested groups. Difficulty of full
Project M&E coverage and
definitional issues
of all Project-
affected areas
and groups
* Only lists main stakeholder groups to be involved, and this does not mean the participation is limited to the listed stakeholder groups.
9.3 PUBLIC CONSULTATIONS ORGANISED IN THE SCOPE OF THE
FRAMEWORK EA & SA PREPARATION PROCESS
In the scope of the preparation of the Framework Environmental and Social Impact Assessment, two
public consultation meetings have been organised by EVN on the aim of the project and the first draft
report of the Framework EA & SA:
on 24th of June 2008 in Hanoi
on 26th of June 2008 in Ho Chi Minh City.
By this, both northern and southern demonstration provinces are covered.
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The aim of the consultations was to inform future stakeholders on the planned project and to give them
the possibility to provide input and remarks on the first draft report on the framework EA & SA for
ARCADIS to improve the report.
Minutes of both public consultations and a list of people who attended the consultations are provided in
appendix 1
At the moment of the consultation meetings a first draft of the environmental and social framework
report had been prepared. The results of this draft report were presented to the participants of the
consultation meetings. Several remarks were made by the participants. Apart from some detail remarks
that are reported in the minutes (appendix 1), the following major issues resulted from the remarks of
the participants at the meetings:
- The need to provide recommendations on how to apply the EIA legislation in Vietnam with
respect to the PCB management project, taking also into consideration the World Bank Policy:
this comment has been addressed in the report by providing a clear overview of the World
Bank and Vietnamese EIA regulations and procedures and by providing a guidance on the
screening procedure and disciplines covered in site specific impact assessments on PCB
management, disposal and remediation. The analysis of the local situation was taken into
account; as a result it is recommended to expand the need for a full EIA to facilities for
storage, retrofilling, replacement and recycling of PCB containing equipment. In this section
the instruction for assessment of environmental and social impacts was also taken into
consideration in finalizing the report.
- During the course of the drafting of the framework report on environmental and social impact
assessment, the ‘ PCB management project’ has been classified in cat. B instead of cat. A:
the consultant has taken into account this change.
- There appeared to be a need to also focus on the potential social impacts of the PCB
management project: in the final report the social aspects received more attention from the
consultant.
- In an environmental impact assessment report effects should be quantified to a maximal
extend: the consultant agreed with this statement and has put additional effort in quantifying
potential effects: i.e. emissions, discharges,…
- In the draft report the mitigation and monitoring measures were rather limited and not fully
adapted to the local situation; an emergency plan was lacking: an additional search for
monitoring and mitigation measures was carried out in international literature; this has been
completed with data obtained from the local consultant
- The sources of data should be clearly indicated and both Vietnamese and international
standards should be applied: together with the local consultant all sources of data have been
identified; moreover all the international standards in the report have been complemented
with specific Vietnamese standards
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10 KNOWLEDGE GAPS AND UNCERTAINTIES IN ASSESSMENT
If the description of the project elements is not complete or is not available in a sufficient degree of
detail this will lead to a higher degree of uncertainty in assessment. As a result the assessment will
become more general without possibilities to quantify the impacts. The same applies when the baseline
situation cannot be described due to a lack of data on the actual situation of the environment.
Therefore the major gaps in knowledge and uncertainties in assessment for each of the environmental
issues studied will be listed. In a further stage this list can also be used for identifying monitoring needs.
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11 REFERENCES
Annema, J.A., Beurskens, J.E.M, Bodar, C.W.M. (ecls) (1995) Evaluations of PCB fluxes in the
environment. RIVM report 601014011 Bilthoven, The Netherlands.
Assessment Requirements - Practices and Lessons Learned in East and Southeast Asia
Baars, A.J.; Theilen, T.M.C, Janssen, P.J.C.M., Hesse, J.M., Van Apeldoorn, M.E., Heijerinck,
M.E.M, Verdam, L, Zechmaker, M.J. (2001). Re-evaluation of human toxicological maximum
permissible risk levels, Bilthoven, Netherlands RIVM Report 711701025
Breeze and Associates Inc. (2007a). Assessment of the policy, regulatory and legislative framework
– Final Report. GEF PCB Waste Management and Disposal Demonstration Project (P099460)
Breeze and Associates Inc. (2007b). Assessment of the policy, regulatory and legislative framework
– Supplementary Report. GEF PCB Waste Management and Disposal Demonstration Project (P099460)
Bush, T. King K., Passant N., Tsagatakis I (2005). NAEI UK Emission Mapping Methodology.
Information available on following website: http://www.naei.org.uk/data_warehouse.php.
Callebaut K., Vanhaecke P. (2000) Development of a framework based on quality criteria for
licensing the dumping of dredged material into the waters of the Maritime zone according to the Paris
Convention. Report for the Flemish Government 125pp.
CITEPA (2001). Calculating emissions into the air: general methodological descriptions. Report for the
“Centre Interprofessionnel Technique de la Pollution Atmosphérique”.
Dang P. N. (2004). Introducing Strategic Environmental Assessment into Vietnam Laws.
ECD (2008): Capacity assessment on supervision and enforcement of PCB management
Emissieregistratie Nederland (2008). Methodologies used for the PRTR (Pollutant Release and
Transfer Register) in the Netherlands. Documents available on following website:
http://www.emissieregistratie;nl/erpubliek/misc/documents.aspx.
ERM (1998). Hazardous Waste Management Strategy for Vietnam
European Environment Agency (2000): Emission inventory guidebook, Electrical equipment
containing PCB’s
European Environment Agency (2007). Emep + Corinair Emission Inventory Guidebook. 2007
Hazardous substances databank: http://www.toxnet.nlm.nih.gov
Mc Kinney J.D., Chae K., Gupter B.D., Moore J.A., Goldstein J.A. (1976). Toxicological
assessment of the hexachlorobisfenyl isomers and 2, 3, 7, 8-tetrachlorodebenzofurain in chicks. 1.
Relation of chemical parameters: Toxicol. Appl. Pharmacol. 36, 65-80
MONRE (2006): Vietnam National Implementation Plan of the Stockholm Convention
Obbard J. P., Lai Y.C. and Briffett C. (2004) Environmental Assessment in Vietnam: Theory and
Practice, Journal of Environmental Assessment Policy and Management. 4(3), p: 267- 295
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Romijn (A.), Luttik R., van de Meent D., Sloof W., Canton of H (1991): Presentation and analysis
of a general algoritm for risk assessment on secondary poisoning. RIVM Report nr 619-102-002
SNC-Lavalin (2007): PCB Management and Disposal Demonstration Project - Analysis of PCB
Treatment & Disposal Options for the Socialist Republic of Vietnam . Draft Report to The World Bank, July
2007.
Tan Alan K.J. (2000) APCEL Report: Environmental Law (ASEAN-10). Faculty of Law, National
University of Singapore (http://sunsite.nus.edu.sg).
The Center for Environmental Research and Community Development (2008). Final report on
CS4 - Capacity Assessment on Supervision and Enforcement of PCB Management . Preparation of Vietnam
PCB Management and Disposal Demonstration Project (Grant # TF057892)
Tieu Chiran Vietnam (TCVN 5937, 2005) Air quality – ambient air quality standards.
US Department of Health and Human Services. Public Health Service. Agency for Toxic
Substances and Disease Registry (2000): Toxicological profile for polychlorinated biphenyls (PCBs)
USEPA 1987. Locating and Estimating Air Emissions from Sources of Polychlorinated
Biphenyls (PCB). USEPA – 450/4-84.007
US EPA (1995) AP 42: Compilation of air pollutant Emission factors, volume 1, Chapter 13
WHO (1995) Bergland, B., Lindwall, T., Schwela, D.H. Guideline for Community Noise, WHO Geneva
WHO (2000) Air Quality guidelines for Europe, WHO regional publications. European series no 91
World Bank - GEF (2007). GEF PCB Waste Management and Disposal Demonstration Project. Annex 4
– Detailed Project Description
World Bank (2006). Environmental Impact Assessment Regulations and Strategic Environmental
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APPENDICES
1. Minutes of the consultation meetings and list of people attending the public consultation rounds
2. Policy Needs Assessment
3. Environmental Management Plan Template for demonstration sites.
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ANNEX 1. MINUTES OF THE CONSULTATION MEETINGS AND LIST OF
PEOPLE ATTENDING THE PUBLIC COLSULTATION ROUNDS
Vietnam Environment Administration The World Bank
PCB Management Demonstration Project (PDF-B)
CS6 – Environmental Impact Assessment
MINUTES OF CONSULTATION WORKSHOP
24 June, 2008
Time: 13:30 – 16:30
Place: Berner Hall, Vietnam Electricity, 18 Tran Nguyen Han, Hanoi
Subject: Workshop on Public Consultation for EIA framework of CS6
Chair: Ms. Le Thi Ngoc Quynh – Deputy Director of Science, Technology and Environment
Department, Vietnam Electricity (EVN)
Participants:
1. From Government Agencies: Vietnam Environment Administration (VEA), Technical Safety and
Industrial Environment Agency;
2. From Provincial Departments: Department of Natural Resources and Environment (DONRE) Nam
Dinh, DONRE Hanoi, Department of Industry and Trade (DOIT) Hai Phong, DOIT Quang Ninh;
3. From EVN: Department of Science-Technology & Environment, Department of International
Cooperation, Office of EVN; PC 1, PC Hai Duong, Nam Dinh, Quang Ninh, Hai Phong, Hanoi, Pha
Lai JSC, and Electricity Transmission Companies of Ninh Binh, Quang Ninh, Hai Phong;
4. From Institutes/Centers/Universities: University of Civil Engineering, University of Natural
Science, Research Centre for Environmental Technology and Sustainable Development (CETASD),
Centre for Environmental Engineering of Towns and Industrial Areas (CEETIA), Centre for
Environmental Change & Sustainability (CECS), Institute of Industrial Chemistry;
5. From Project Office of PCB-WB Project and Consultants Arcadis-Vidaneco.
Main Content
A – Opening
1. Ms. Le Thi Ngoc Quynh welcomed participants and stated the objectives of the consultation
workshop.
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2. On behalf of Consultant of component CS6, Mr. Stijn Vermoote and Mr. Paul Vanhaecke –
ARCADIS Belgium presented the draft report of EIA framework.
B – Discussion
3. Mr. Pham Manh Hoai – CETASD – asked about the methodology applied by Arcadis to assess
the PCB’s impacts to human and environment through PCB storage and transportation.
4. Answer from Arcadis: the methodology was mainly based on the exposure risks from PCB oil
and PCB-contaminated transformers. Each stage (e.g. storage, transportation) has different emission and
exposure limits. Quantitative method is applied to calculate potential impacts. When implementing the
project, e.g. at the transportation stage, if preventive solutions (e.g. to prevent spills and leaks) are
provided and well practiced, potential adverse impacts will be avoided.
5. Mr. Do Thanh Bai - Institute of Industrial Chemistry – suggested Consultant add more
inputs for quantification of pollution to calculate potential impacts in PCB management, treatment and
disposal activities.
6. Answer from Arcadis: In general, in order to quantify a pollution load, there are common
calculating methods to define pollution level (e.g. in air, water). Arcadis is now further studying the
database of the U.S Environmental Protection Agency about emission factors and other relevant
information.
7. Ms. Nguyen Anh Thu – Independent Consultant said, the report presented an EIA framework;
however, suggestions for minimizing these impacts were not provided yet. Ms. Thu suggested, in case
Consultant Arcadis did not have sufficient practical experience in Vietnam, international experience are
welcomed to be used to reduce impacts. It was also suggested that Arcadis consult with local experts to
come up with reduction measures appropriate with current situation of Vietnam.
8. Answer from ARCADIS: Vidaneco is the local consulting company of Arcadis in Vietnam, which
has experienced domestic experts. For Ms. Thu’s suggestion, as reduction measures must base on
specific and practical impacts, moreover, the report offered framework for common assessment only, it is
very difficult to bring out specific measures. However, Arcadis would supplement into the report typical
impacts and their respective specific reduction measures (e.g. exposure, emergency responses ).
9. Mr. Nguyen Ba Yem – Nam Dinh PC: for risks and occupational safety related to handling
PCB-contaminated equipment, materials and PCB wastes, Nam Dinh PC is implementing EVN’s guideline
for safe handling with electrical equipment. However, there still lack standards and guidelines for proper
handling with PCB-containing or PCB- contaminated materials (clouts, paper…). He suggested relevant
authorities should issue regulations and safety instructions in near future, so that they have a base to
follow to avoid exposure and cross-contamination risks.
10. Mr. Nguyen Anh Tuan - Project coordinator remarked that the report presented quite good
and adequate methodology on EIA. The targeted subjects to this activity include: (i) those who know well
about EIA but little about PCBs, thus objective of CS6 is to provide an EIA framework which will serve as
a guide, and (ii) those who directly execute the project, then help them understand potential impacts and
preventive measures. Up to now, Pha Lai is the only site selected as the demonstration site for the
project, other sites in other provinces havenot been determined yet. Therefore, the responsibility of CS6
Consultant is to establish an EIA framework at Pha Lai to serve as a model and a detailed guideline to be
applied in other sites. Based on report of CS6 Consultant, Mr. Tuan gave following comments:
- Legal/policy framework which has been assessed in the report should extend to analysis
of EIA in Vietnam regarding PCB;
- When developing the TOR, the World Bank required the EIA framework should be used
not only as a frame instruction for other demonstration sites of the project (not for Pha
Lai only), but also for other similar projects in the future in Vietnam;
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- The Ministry of Natural Resources & Environment has issued EIA and social impacts
assessment instruction, Consultants could refer to this document;
- Apart from EIA, the World Bank also required this report to assess social impacts;
however, this content in the report was still vague, Consultants should supplement and
focus more on this part.
11. Answer from ARCADIS: Arcadis would acknowledge Mr. Tuan’s suggestion on assessment of
legal frame and social impacts. About referring to instruction of MONRE, Arcadis found that this
document would be difficultly used by the project, for demonstration sites of this project are scatteredly
located in 15 different provinces.
12. Ms. Le Thi Ngoc Quynh – EVN highly appreciated the overview and multiple aspects assessed
in Arcadis’ EIA content; however, Ms. Quynh recommended that Consultants should focus only on issues
directly related to the project (e.g. exposure). Consultants had the responsibility to report to WB on the
real situation in Pha Lai. Pha Lai is relatively isolated with surrounding areas, so environmental impacts
would also be limited (e.g. no impacts on historical, archaeological values, fauna and flora)
13. Mr. Do Tien Doan – Project officer spoke: the report of Consultants consisted of 2 sections:
(i) WB’s safeguards policy and (ii) Vietnam’s EIA process; thus, Mr. Doan suggested Consultants Arcadis
should have a combined section which meet both WB and Vietnam requirements. On the other hand, in a
recent meeting between CS6 Consultant and WB, WB informed that this project was no longer classified
in Category A project but Cat. B (because it involved in management only, not disposal as original
approach), thus Consultants should recheck with WB and then adapt the report accordingly.
14. Answer from ARCADIS: report content was divided into 2 activities (management and
disposal), so it would be easy to change according to WB’s new requirements.
C – Closing
15. On behalf of EVN – the leading of CS6, Ms. Le Thi Ngoc Quynh acknowledged suggestions and
comments from participants and EVN would work with Consultant to complete EIA report.
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PCB Management Demonstration Project (PDF-B)
Consulting Service 6 – Environmental Impact Assessment
Public consultation meeting minutes
June 26, 2008
Time: 8:30 – 11:30
Location: Meeting room of Power Company No 2, 72 Hai Ba Trung, Ho Chi Minh city
Subject: Public consultation on EIA framework of CS6 component
Lead by: Ms. Le Thi Ngoc Quynh – Vice director of Division on Science, technology and
Environment, Vietnam Electricity (EVN)
Participants:
1. Representatives of VEA and Sub-branch of VEA in the East-South
2. Representatives of Provincial Departments: Department of Natural Resources and Environment
(DONRE) Can Tho and Ho Chi Minh, Department of Industry and Trade (DOIT) Ho chi Minh city.
3. From EVN: Department of Science-Technology & Environment, PC 2, PC Ho Chi Minh city, Lâm
Đồng, Đồng Nai, Cần Thơ, Bà Rịa-Vũng Tàu, Thu Duc Thermal Electricity Company, Can Tho
Thermal Electricity Company, Phu My Thermal Electricity Company, Eastern Electricity
Transmission Company, Western Electricity Transmission Company, Electricity Transmission
Company No. 4.
4. From Institutes/Centers/Universities: University of Civil Engineering, Institute for Resources and
Environment in Ho Chi Minh city, VENETCO
5. From Project Office of PCB-WB Project and Consultants Arcadis-Vidaneco.
Major contents
A – Opening
6. Ms. Le Thi Ngoc Quynh welcomed participants and presented the objectives of the meeting as
well as general information of the project and CS6.
7. Representative of the consulting firm ARCADIS Belgium, Mr. Stijn Vermoote and Mr. Paul
Vanhaecke – presented the draft report on EIA framework
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B – Discussion
8. Mr. Nguyen Hung – Phu My Thermal Electricity Company wonders the reason that the
Pha Lai Themral Electricity Company is replacing 19 PCB containing transformers is due to PCB or
due to their expiration. On the other hand, he wonders if PCB could be generated during the
operation process. If so, is there any measure to reduce PCB concentration?
9. Ms. Le Thi Ngoc Quynh – EVN answers: Replacement of 19 transformers in Pha Lai is followed
the company’s plan. However, it matches with the activities and objectives of the PCB
Management Demonstration Project so that the project will support the company to build up a
storage facility for these transformers and other potential PCB containing equipments. On the
other hands, PCB is not generated during the operation process but due to intentionally added
into oil.
10. Ms. Anh Xuan – Sub-branch of VEA in the East-South comments: the report on EIA
framework is quite good but is not detailed enough when describes the impact level of project
activities.
11. ARCADIS answers: The report is just an EIA framework to which any specific EIA report can
follow so that it can only be in a general form.
12. Ms. Le Thi Bich Thuy – VENETCO has following comments:
The report on EIA framework does not include the task of screening to see if the project falls
into category 1 or 2 in order to comply with Vietnamese regulations.
The report on EIA framework does not mentions the reporting systems in order to comply
with Vietnamese regulations (decree 21)
The report lacks of social plan
The report lacks of pre-construction phase
Due to Vietnam situations, the potential impacts of project activities may be more than those
indicated in the report. It is guessed that those impacts were indicated based on the
knowledge of foreign consultants who lives and works in more developed countries.
Therefore, the Arcadis may need to consult more with local consultants to have a deeper
analysis in this issue.
13. ARCADIS answers:
Agree to include in the EIA framework the task of screening to see if the project falls into
category 1 or 2 to comply with Vietnamese regulations
Will review again the requirement of Vietnamese regulations on the reporting systems
Agree to include in the EIA framework the analysis and plan on social issue
The pre-construction phase is already in the report but is emerged in the construction phase
Will analyzed deeper on the potential impacts taking into account the real situation of
Vietnam
14. Mr. Thanh – Institute for Resources and Environment in Ho Chi Minh City asks: The
project does not have the disposal component, why does the EIA framework report also include
this component?
15. Ms. Le Thi Ngoc Quynh - EVN: The report include disposal component for the follow up
project.
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16. Ms. Anh Xuan – Sub-branch of VEA in the East-South comments: The EIA framework
should also include the mitigation measure and emergency plan.
17. ARCADIS answers: Since it is just a framework, a detail mitigation measure can not be
included. However, it is agreed that a general mitigation and emergency plan will be considered.
C – Conclusion
18. On behalf of EVN – the leading of CS6, Ms. Le Thi Ngoc Quynh acknowledged suggestions and
comments from participants and EVN would work with Consultant to complete EIA report.
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Consultation meeting Hanoi 24/06/08
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Consultation meeting Ho Chi Minh City, 26/06/2008
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ANNEX 2. POLICY NEEDS ASSESSMENT
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Table 11-1: Policy Needs Assessment - Summary Table (Breeze and Associates, 2007a)
Vietnam Current Practice Best Practice Gap Recommendations
Policy Framework
27 policies “Life cycle” policy frameworks Life cycle gaps 1) Develop a “life cycle” policy framework
Integrating regulation(s) Inconsistent 2) Develop integrating regulations with
economic instruments
Economic instruments / technical Overlap
support technical support
Limited support
3) Provide clear definitions
Clear definitions
Limited compliance PCB equipment
PCB materials
Establishing Priorities
No formal priorities Different priorities established: Priorities not yet established 4) Develop a practical, staged plan based on analysis of capacity
Priority 1 5) Plan should have:
Thresholds for high risks
> 100,000 mg/kg
Definitions for sensitive sites
> 500 mg/kg Set a balanced pace - 16 years
Be reviewed in 5 years
Priority 2
6) As a starting point for discussion
> 50 mg/kg Priority 1 - > 500mg/kg
Priority 2 > 50 mg/kg
Priority 3
Priority 3 > 5 mg/kg
> 2 mg/kg PCB Free < 5 mg/kg
> 5 mg/kg
PCB free
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Vietnam Current Practice Best Practice Gap Recommendations
< 2 mg/kg
< 5 mg/kg
Priorities – Sensitive Sites
No definition for sensitive sites for PCBs Long list of sensitive sites: Sensitive sites not defined for PCBs 7) Develop a list of sensitive sites to meet Vietnam’s needs based
on:
Hospitals
Schools Analysis of capacity
Food and feed National considerations
Senior’s
Drinking water
Potable water
Aquatic spawning
Endangered species
Phase Out - Timelines
No formal timelines Phase out timelines range from 10 to Timelines not yet set 7) Establish timelines starting with high concentrations / sensitive
20+ years sites
Increments for each priority range 7) Move incrementally from high to low with completion target of
from 3 to 10 years 2020 or 2025
7) As a starting point for discussion
Priority 1 (S) – 5 yrs
Priority 1 (Not S) – 9 yrs
Priority 2 (S) – 13 yrs
Remaining – 17 yrs (2025)
Disposal Deadlines
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Vietnam Current Practice Best Practice Gap Recommendations
NIP sets disposal deadline as 2028 End of storage deadlines range No deadlines 8) As a starting point for discussion
from 1 to 2 years
2 years for PCBs in storage when disposal facilities
established
1 year for PCBs coming out of service after disposal facilities
available
Restrictions and Bans
Restrictions: Bans: No bans: 9) As a starting point for discussion
Import Manufacture Import
Bans:
Export Import Manufacture
Manufacture
Municipal landfilling Mixing / diluting Dust suppression
Imports (except for labs)
Direct releases Reuse / recycling
No restrictions: Dust suppression
Mixing / diluting Dust suppression
Reuse / recycling
Discharges to environment Restrictions:
Mixing / dilution (5 to 50 mg/kg)
Restrictions: Export (with PIC)
Liquids in landfills (5 to 50 mg/kg)
Mixing / diluting (>5 mg/kg)
Export
Reuse / recycling (>5 mg/kg)
Municipal landfilling (solids >
50 or liquids > 5) Municipal landfilling (> 5 mg/kg for liquids)
In-Service Equipment
Several chemical regulations on: All regulate in-service equipment. Unclear how or when the chemical 10) Require registration
regulations apply to PCBs
Chemical identification Registration
11) Require annual updates
Registration / declaration Routine reporting
Chemical safety Repair / retrofilling 12) Establish operating standards
Inspection and reporting Storage
Worker safety 13) Establish worker safety practices in technical guidelines
Monitoring / inspection
14) Establish standards for on-site storage
15) Develop two guidelines to support in-service regulations
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Vietnam Current Practice Best Practice Gap Recommendations
PCB Waste Management
Dec. 155, Dec. 23 and Cir. 12 in place Integrated HW and waste PCB Inconsistency between Dec. 155 and Dec 23 16) Amend HW Reg’s to ensure consistency
“cradle to grave” requirements / Cir.12
“Cradle to grave” HW requirements 17) Define “out of service” as HW
Supportive technical guidelines Few supporting guidelines
18) Develop technical guidelines:
Financial guarantees for HW facilities Placarding / labeling inconsistent
Generator registration
No financial guarantees for private facilities Transfer, transportation and storage
Decontamination of transformers
19) Amend technical guidelines:
Dec. 60/2002, MOSTE
TCXDVN 320-2004, MOC
HW in Cement Kilns
20) Require financial guarantees
Contaminated Sites
LEP commitments Comprehensive site ID and clean-up Few formal activities in place for site ID and 21) Assign responsibility to owners:
policies and programs clean-up
Site ID Notification
Measures to stop at source Requirements for notification and No implementing provisions for rapid Studies
Rehab rapid response response and clean-up responsibility Leaking equipment
Compensation Action to stop discharges and clean-up
Compensation for effected parties
NIP commitments
Site ID 22) Coordinate a PCB clean-up program with NIP POP
commitments
Clean-up of POP hot spots
Policy Compliance
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Vietnam Current Practice Best Practice Gap Recommendations
Some inspection and enforcement efforts Clear PCB regulations Inconsistent regulations 23) Develop outreach program
for HW
Brochures
Technical guidelines for industry Limited technical support
Some technical support for: Ad’s
Visible inspection and enforcement Limited resources / inspections Presentations
Industry
DONREs 24) Develop technical guidelines (See Rec. 18)
Significant sanctions Sanctions will not promote compliance
Some resources 25) Develop inspection protocols and enforcement mechanisms
Protocols for inspection staff
New sanctions 26) Provide necessary resources
27) Assess cost of compliance and increase sanctions to provide
disincentives
Environmental Monitoring
More than a dozen monitoring initiatives Environmental monitoring programs No formal program in place 28) Establish national program coordinated with NIP PP #10 and
undertaken for POPs and PCBs Korean initiative
No formal database
First round sampling in two years
NIP (PP #10) commits to building National monitoring programs for
laboratory capacity receiving environments Coordinate with ASEAN nations
Uncertain laboratory capacity
VN with Korea on POPs database
National Inventories
HW data beginning to be collected Annual inventories: No routine submissions of “life cycle” data 29) Require tabulated reports by DONRE for submission to VEA
(see Rec. 10 and 11) biannually
In-service
Several one time PCB inventories
undertaken Phased out No national “life cycle” inventory 30) Require VEA to consolidate and analyze for submission to PM,
Storage Minister and public
Most extensive underway by EVN / Disposal Limited analysis
Experco
Annual analysis and submission of
results
Public Involvement
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Vietnam Current Practice Best Practice Gap Recommendations
LEP confers rights to individuals: Access to: Limited individual access to data collected 31) Develop communications program for POPs / PCBs
EIA reports Information
Limited individual access to the decision 32) Require all reports available using on-line register
Registered commitments Decision making making
Lists of chemicals Justice 33) Require applications be available for comment
Degraded sites Limited individual access to justice
Data available:
Waste plans 34) Develop guidelines for disadvantaged groups
Inventory reports
Monitoring reports 35) Prepare outreach guidelines aimed at small sources
Reports from owners
Applications for new facilities /
opportunities for involvement
Capacity Building and Training
Initial training provided at national and in Integrated HW and PCB training Limited training provided for HW and no 36) Develop training for national / provincial levels as part of HW
selected provinces by VEA through VCEP provided to all government staff training for PCBs training:
involved in implementing the PCB
Training for all Ministries with PCB responsibility
regulations
Training for VEA in:
- Engineering assessment / licensing
- Inspection / enforcement
Training for DONRE in:
- Generator registers
- Engineering assessment / licensing
- Inspection and enforcement
- Monitoring
Cost Recovery Mechanisms
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Vietnam Current Practice Best Practice Gap Recommendations
LEP - Polluters responsible for Polluter pays principle is a core No implementing regulation for LEP 37) Establish a process to set:
remediation, compensation element principles
User fees for storage transportation, treatment and disposal
VEF mobilizes funding from national and Administration fees for government costs
donor
38) Develop cost allocation formula
39) Put the following economic instruments in place to make:
Owners responsible for mgt
Owners responsible for site clean-up
Electrical utilities responsible for system survey / mgt
Roles and Responsibilities
Line Ministries responsible for key Environment agencies responsible Overlapping responsibilities 1) In short term, give MONRE uniform State management for PCBs
aspects:
Inconsistent interpretations and compliance 2) In short term, give MONRE provisions proposed for new PCB
HW
regulation
Chemical programs
3) In long term, consider a transition plan towards clear
environmental responsibilities
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ANNEX 3: ENVIRONMENTAL MANAGEMENT PLAN TEMPLATE
The following is a suggested template that PMU and facility owner can use to develop an environmental
management plan.
1. Introduction (Recommended 1-2 pages)
a. Subproject Background
b. General information of the site and the owner
c. Objectives
2. Subproject Description and Setting (Recommended 2-3 pages)
Provide a brief summary of the subproject and its setting, including a map showing local and regional
characteristics. This information will be extracted from the EIA approved by the WB and from EPC
approved by the government of Vietnam.
a. Subproject Map – a map of the subproject area and its regional context should be
provided showing subproject components the affected subproject area.
b. Subproject Summary – only key project details should be included such as what activities
will be carried out, area of the storage sites, height of the store (if applicable), capacity
of the store, etc.
c. Environmental Setting - The environmental setting should describe major environmental
features.
3. Key Environmental and Social Issues (Recommended 2-3 pages)
Using the subproject EIA/EPC, a summary of key environmental impacts arising from each subproject
phase (construction and operation) should be provided. The list of impacts will be used to describe
specific environmental mitigation and management actions to reduce and/or eliminate subproject
impacts.
a. Key Environmental Issues
b. Key Social Issues (if any)
4. Key Mitigation and Management Actions
The EMP should describe mitigation and/or management actions that facility’s owner will implement
to reduce and/or eliminate subproject impacts to an acceptable level as determined by Vietnamese
regulatory authorities and to ensure compliance with World Bank Safeguards. These mitigation and
management actions will form part of No Objection conditions.
While it recognized that the extent and magnitude of these mitigation and management actions will
vary with subproject characteristics, a generic mitigation and management action template is
provided Table 8.1.
The mitigation plan wil include:
a. Identifies and summarizes all adverse environmental impacts.
b. Describes, with technical details each mitigation action for each type of impact.
c. Describes indicator and timing.
d. Provides linkages to other plans.
5. Supervision, Follow-up and Monitoring
The EMP describes measures for supervision of facility’s owner to ensure that the subproject is being
constructed in compliance with environmental and social commitments and suggested mitigation
measures. Specifically supervision describes the following:
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a. Structure and function of the environmental supervision unit
b. Types of data that will be collected to measure EMP compliance
c. Types of action taken in the event of non-compliance
d. Reporting mechanisms
Environmental monitoring during subproject implementation provides information about key
environmental aspects of the subproject, particularly environmental impacts and the effectiveness of
mitigation measures. The EMP identifies monitoring objectives and specifies the type of monitoring,
with linkages to the impacts assessed in the EA report and the mitigation measures described in the
EMP. Specifically, the monitoring section of the EMP provides the following:
a. Specific description and technical details of monitoring measures to be implemented
including parameters to be measures, methods, sampling locations, frequency, analyses,
and definition of thresholds for corrective action.
b. Monitoring and reporting procedures.
6. EMP Timeline and Costs
The EMP should provide an implementation schedules and capital and recurrent costs of
implementation.
7. Public Consultation and Disclosure
All subprojects require at least one public consultation and the results of the consultation
documented in the EMP. The public consultation can be conducted either prior to preparing a draft
EMP in order to establish key environmental issues to be included in the EMP, or after a draft EMP is
completed to act as a basis of discussion and to elicit any additional environmental issues that may
be of concern to affected groups.
8. Suggestions for EMP Preparation and Review
The focus of the EMP is to describe, in a clear and concise manner, how mitigation and management
actions will be implemented to reduce subproject impacts to acceptable levels; it is not intended to
replicate the subproject EIA or EPC, although this information shall form the basis of the EMP.
The subproject description should only summarize those design aspects that could result in an
environmental impact requiring a mitigation or management action; it is not necessary to describe
the subproject in detail and provide unnecessary textual description, tables or drawings;
The EMP should include a map that clearly indicates the area affected by the subproject and also
a regional context to allow for easy location;
The EMP should only summarize the environmental and social setting of the subproject;
The EMP should only summarize key issues or impacts of the EIA/EPC; it is not necessary to
repeat them in detail;
The EMP should provide clear and detailed mitigation or management commitments on behalf of
the PMU for each and every key impact of concern, including responsibility and timeline for
implementation;
The EMP should include a detailed description of costs as these will form part of subproject
financing.
The developer should ensure that adequate public consultation is completed.
The WB should review the EMP and ensure that all key subproject impacts have a specific
management or mitigation action to reduce the impact to an acceptable level;
Costs of the EMP should be tallied and included as part of subproject financing costs;
The WB should verify that adequate consultation has been completed and that there are no
outstanding issues on behalf of subproject stakeholders, local organizations or government
regulators.
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