action form initial environmental …nds warehouse design has been undertaken by rbhs, and...

Action Form INITIAL ENVIRONMENTAL EXAMINATION

Amendment - following Scoping Statement

Amendment of RBHS and Liberia MOSHW FARA IEE for:

Construction of Central Warehouse for Liberia Notional Drug Service -

Scoping Statement (Dec. 2013), Revised Scoping Statement (Sept. 2014}

PROGRAM/ACTIVITY DATA: Program/ Activity Number:

Program Activity Title:

Country/Region:

Functional Objective: Program Area:

Program Elements:

Period Covered:

LOP Estimated Amount

IEE Prepared By:

Construction of Central Warehouse for Liberia National Drug Service {Rebuilding Basic Health Services Project/ Liberia Ministry of Health and Social Welfare FARA toward Support for the implementation of Liberia's 2011- 21 National Health and Social Welfare Plan and Policy)

Liberia/West Africa

3: Investing in People 3.1-Health 3.1.1-HIV/AIDS 3.1.2-Tuberculosis 3.1.3-Malaria 3.1.6-Maternal and Child Health {MCH) 3.1.7-Family Planning and Reproductive Health {FP/RH) 3.1.8-Water Supply and Sanitation

thru 2016

$4 million

Jane Obbagy, GEMS/The Cadmus Group, Inc. [email protected]

IEE Amendment (Y /N): YES

If Yes, original IEE:

• USAID/liberia Rebuilding Basic Health Services (8 Jan 2009): http://gemini.info.usaid.gov/egat/envcomp/document.php?doc id=37723

• Liberia Ministry of Health and Social Welfare Fixed Amount Reimbursement Agreement toward Support for the implementation of Liberia's 2011-21 National Health and Social Welfare Plan and Policy http://gemini.info.usaid.gov/egat/envcomp/document.php?doc id=39123

Other Relevant Environmental Compliance Documentation:

Action Form: Amendment of RBHS ond Liberia MOHSW FARA IE Es for NOS Warehouse Construction 1

• Environmental Assessment Scoping Statement for Construction Of A Central Warehouse For The Liberian National Drug Service (Dec. 2013). Resolves Deferral for construction in USAID/Liberia Health DO-level umbrella IEE). Scoping Stmnt: http://gemini.info.usaid.gov/egat/envcomp/document.php?doc id=40171

• Revised Scoping Statement for Liberia NOS (Aug. 2014). Attached hereto.

Submitted By:

Current Date

Expiration Date

Shawna Hirsch, USAID/Liberia Mission Environmental Officer, [email protected]

18 February 2015

31 December 2016

ENVIRONMENT AL ACTION RECOMMENDED: Categorical Exclusion Negative Determination x

Positive Determination x Deferral

ADDITIONAL ELEMENTS: EMMP: x I Conditions: x I PVO/NGO: I Pesticides:*

*22 CFR 216.3 {b){l) applies

BACKGROUND: USAID awarded a Cooperative Agreement (CA) to John Snow, Inc. (JSI) at the end of FY 2008 to

implement the Rebuilding Basic Health Services {RBHS) project in Liberia. The 2008 CA was designed to

provide technical support and capacity building for the M inistry of Health and Social Welfare {MOHSW),

fund direct services through non-governmental organizations {NGOs) and community based

organizations (CBOs), and included provisions to renovate small health facilities.

In 2011 USAID/Liberia redesigned the RBHS CA and eliminated from the scope of work the renovation of

small health facilit ies and shifted these activities to MOHSW via a fixed amount reimbursement

agreement (FARA) mechanism, designed to provide support to the Gol for a broad array of health and

development objectives. Included under the FARA construction component was support for

construction for a central pharmaceutical warehouse for the Liberia National Drug Service {NDS), with

technical assistance from RBHS. NDS Warehouse design has been undertaken by RBHS, and construction

is to be carried out by the MOHSW, with financing provided by the Global Fund and by USAID.

The site identified by MOHSW for the central NDS warehouse was formerly controlled and operated by

the Liberia Petroleum Refinery Company {LPRC), and shows surface indications of contamination with

pet roleum products. Construction on contaminated petroleum brownfield sites poses a set of concerns,

inter alia: the health risks contamination can pose to construction workers and abutters, particularly

during construction, and the possibility of construction or operations further spreading contamination

At minimum, proceeding with construction would require an IEE amendment, as required by both the

RBHS and FARA IEEs for construction in environmentally sensitive areas, with a positive determination

being foreseeable. USAID/Liberia, in consultation with the BEO for Global Health Bureau Environmental

Officer, therefore commissioned an EA scoping statement addressing NDS central warehouse

construction. It was expected that if the scoping statement found that a 22 CFR 216 positive

determination was not merited, the scoping statement would serve as the basis for as an IEE

Action Form: Amendment of RBHS and Liberia MOHSW FARA IEEs for NOS Warehouse Construction 2

amendment, establishing a negative determination with conditions for warehouse construction. If the

scoping statement found potential impacts were significant and adverse, having the scoping statement

in hand would expedite the process of completing an EA, and thus completion of the warehouse itself.

The scoping statement that resulted from this effort is attached.

SUMMARY OF FINDINGS The scoping statement found that currently planned construction does not present significant adverse

impacts- while potent ial adverse impacts do exist, these can be controlled below the level of

significance with straightforward mitigation measures. The scoping statement specifies these mitigation

measures in its Table 4.

However, the scoping statement also found that two issues are significant if future development of the

NOS site (i.e., beyond the currently planned construction) includes the construction of additional

warehouse space and shipping infrastructure. These are

• Possible human exposures to petroleum and refinery by-products in soils that reside in areas

targeted for future NOS Warehouse expansion activities, as new buildings and shipping facilities

are constructed to address the increased scale of warehouse operations

• Increasing social/community tensions resulting from the lack of significant stakeholder dialogue

to obtain representative local residential perspectives on further development of the NOS site.

ACTIONS TAKEN 1. The attached scoping statement is affirmed as satisfying the analytical requirements for a 22 CFR

216 initial Environmental Examination for proposed Liberia NOS warehouse construction, and it

resolves the Deferral for the construction of a National Drug Supply (NOS), central pharmaceutical/

drug warehouse exceeds 1,000 square meters, as stipulated in the USAID/Liberia Health DO-level

umbrella IEE.

2. The scoping statement finds that, with straightforward mitigation measures, the planned warehouse construction does NOT present significant adverse impacts. As such, the action form amends the MOSHW FARA and RBHS IEEs (since both MOSHW and RBHS are actors in the NOS warehouse) to assign a Negative Determination with Conditions to NOS warehouse construction. The conditions are the mitigation measures specified in the scoping statement.

3. Per the scoping statement, the action form also establishes that any future USAID-supported construction beyond that currently planned (i.e., placement of additional structures/facilities on the site) does raise potentially significant issues and is not covered by this ND w/ conditions) .

4. The revised scoping statement is fully consistent with the previous version: the previous version only required special protect ive gear and procedures for construction workers and special handling of soil from the site " In the absence of soil sampling data that definitively show there is no petroleum product contamination within the footprint of the NOS construction zone." (The first condition in Table 3/Section 2.7).


5. Such sampling data is now available, and shows no contamination within the construction footprint. And thus, in the revised version, (1) these conditions are removed entirely, and (2) the sampling results documenting this are provided.

6. BOTH the RBHS and FARA IE Es are amended as follows:

a. NOS warehouse construction as described in the attached scoping statement receives

a 22 CFR 216 Negative Determination, subject to the condition that the mitigation

measures enumerated in Table 4 of the scoping statement are implemented in full.

It is understood that RBHS, in its technical assistance role, does not generally have

control over on-the-ground construction activities. RBHS will take all practicable

measures to support and promote implementation of these mitigation measures by

MOHSW.

This determination is conditioned on construction as described in the scoping

statement. As such, construction is restricted to the described facility footprint.

b. Any future USAID-supported development of the site beyond the currently planned

construction footprint receives a positive determination unless and until: (1) the

additional soil analysis described in Table 3 of the scoping statement is conducted and

shows no contaminants of concern; and (2) community consultation as described in

Table 3 are undertaken and the BEO determines that the activity design adequately

addresses community issues.

c. With respect to NOS warehouse construct ion only, these IEEs are extended through end

December 2016.


APPROVAi. OF _Bf.COMMENDED ENVIRONMENTAL ACTION Amendment of RBHS and Liberia MOSHW FARA IEE for:

Construction of Central Warehouse for Liberia National Drug Service -

Scoping Statement (Dec. 2013), Revised Scoping Statement (Sept. 2014)

CLEARANCE:

CONCURRENCE:

AFR Bureau Environmental Officer: _ __._&..:::;_.......__,,C...::ai..-0f--1. ___ _

Brian Hirsch

Filename: ____ _____ (USAIO/AFR BEO)

Mission Environmental Officer: '---";J ~~1ndf ,e/1 ADDITIONAL CLEARANCES:

Shawna Hirsch

Date~p~~

Date:

Approved: ~ Disapproved 0

Date: __ ......:____:,.. __

USAID/Liberia/ HE Systems

Strengthening Sub-Team Leader: -·--~-"JI"-'--=-· ~.::.=-'------'Date: Z/t 1-/IS-, I

Ben Zinner

USAIO/Liberia/HE Deputy Team Leader: ~~:11 ()..L )-1 Sophi,e Parwon

-~ \,-USAID/Liberia/HE Team leader: ~t "'~ .uc l ·v-

Tara Milani

Regional Environmental Advisor:

Jody Stallings (USAID/WA}

GH Bureau Environmental Officer: N/ '"' I

Rachel Oagovitz

Date: L/ I~ }!j-

J \,.' / Date: ~A--.-:'':;_;,;....;,;_~-

Date: 8 z-i, I tS

Date: _ _ _ __ _

Action Form: Amendment of RBHS and Liberia MOHSW FARA IEEs for NDS Warehouse Construction

AP~RO_'i_Aj,.(>f R~C{)!'/1~1 ENDE.0 Er:~\·•~ONMf.Nl:.A l. A('~j ON

Amendment of RBHS and Liberia MOSHW FARA IEE for:

Construction of Central Warehouse for Liberia National Drug Service

CLEARANCE:

Mission Director, USAID/Liberia: ------- ----- Date:

John Winfield

CONCURRENCE:

AFR Bureau Environmental Officer: ____ _ Date:------Brian Hirsch

Filename: _ _ ________ (USAln/AFR BEO)

ADDITIONAL CLEARANCES:

M ission Environmental Officer: -------- Date:

Shawna Hirsch

USAID/Liberia/ HE Systems Date:

Strengthening Sub-Team leader: Ben Zinner

Approved: LJ Disapproved lJ

- -----

USAID/Liberia/HE Deputy Team leader: -- · __ Date:------

Sophie Parwon

USAID/Uberia/HE Team Leader: ____ _________ Date:------

Regional Environmental Advisor:

Tara~~J j .. / ' ' / 1---r:Y ! '~ ... t -;?() -- . / _; .. -· . : } Date

USAID/West Africa Jody S}Bllings ,,

GH Bureau Environmental Officer: Date:

Rachel Dagovitz

PROGRAMMIC ENVIRONMENTAL ASSESSMENT SCOPING STATEMENT for the Construction of the National Drug Service Warehouse by USAID/Liberia

XX AUGUST 2013

ENVIRONMENTAL ASSESSMENT SCOPING STATEMENT for CONSTRUCTION OF A CENTRAL WAREHOUSE FOR THE LIBERIAN NATIONAL DRUG SERVICE REVISED VERSION 8 August 2014

This document was produced for review by the United States Agency for International Development. It was prepared The Cadmus Group, Inc. under USAID’s Global Environmental Management Support Project (GEMS).

COVER PHOTO: Land Near the Proposed Site for the NDS Warehouse Photo credit: G Heaner, 2013

ENVIRONMENTAL ASSESSMENT SCOPING STATEMENT for CONSTRUCTION OF A CENTRAL WAREHOUSE FOR THE LIBERIAN NATIONAL DRUG SERVICE

REVISED VERSION 8 August 2014 SUBMITTED TO: USAID/Liberia P.O. Box 10 1445 1000 Monrovia, Liberia SUBMITTED BY: THE CADMUS GROUP, INC. (PRIME CONTRACTOR) 100 5TH AVENUE, SUITE 100, WALTHAM, MA 20451, USA ATTN: JANE OBBAGY TEL: +1.617.673.7178 FAX: +1.617.673.7378

[email protected]

See Annex II for list of scoping team members

Prepared under: The Global Environmental Management Support Project (GEMS), Award AID‐OAA‐M‐11‐00021. The Cadmus Group, Inc., prime contractor (www.cadmusgroup.com). GEMS Activity AF38. Revised under GEMS II (Award AID‐OAA‐M‐13‐00018, The Cadmus Group Inc., prime contractor to incorporate results of soil sample tests.

DISCLAIMER Until and unless this document is approved by USAID as a 22 CFR 216 Scoping Statement, the contents do not necessarily reflect the views of the United States Agency for International Development or the United States Government.

i

ABBREVIATIONS BEO Bureau Environmental Officer CA Cooperative Agreement CBOs Community Based Organizations CEA Cumulative Effects Assessment CFC Chlorofluorocarbon EA Environmental Assessment EIS Environmental Impact Statement EMMP Environmental Mitigation and Monitoring Plan FARA Fixed Amount Reimbursement Agreement GHG Greenhouse Gas GoL Government of Liberia IEE Initial Environmental Examination JSI John Snow, Inc. LEPA Liberia Environmental Protection Agency LPRC Liberia Petroleum Refinery Company LWSC Liberia Water and Sewer Company m Meters m2 square meters mm Millimeters MOHSW Ministry of Health and Social Welfare NIC National Investment Commission NDS National Drug Service NGOs Non-Governmental Organizations No. Number RBHS Rebuilding Basic Health Services USAID United States Agency for International Development WHO World Health Organization

ii

TABLE OF CONTENTS Executive Summary ............................................................................................................................................................ 1

1.0 Introduction ........................................................................................................................................................... 3

1.1 Background: NDS Warehouse construction activity .................................................................................. 3

1.2 Environmental Compliance History and Context ...................................................................................... 5

1.3 Scoping Statement Objectives and Coverage ............................................................................................... 5

1.4 Technical Approach ......................................................................................................................................... 7

2.0 Scope and Significance of Environmental Issues ............................................................................................ 7

2.1 Proposed Construction and Operational Activities .................................................................................... 7

2.2 Environmental Features of the Proposed Site ........................................................................................... 10

2.3 Views and Concerns of Local Residents ..................................................................................................... 13

2.4 Sampling Activities ......................................................................................................................................... 13

2.5 Summary of Environmental and Social Issues .......................................................................................... 15

2.6 Determination of Significant Issues ............................................................................................................ 15

2.7 Issues Eliminated from Further Consideration ......................................................................................... 18

3.0 Schedule for Preparing the EA ......................................................................................................................... 23

3.1 EA Methodology ............................................................................................................................................ 23

3.2 Staffing for EA Preparation .......................................................................................................................... 24

Annex I – Bibliography .................................................................................................................................................... 25

Annex II – List of Scoping Statement Preparors ........................................................................................................ 26

Annex III – Stakeholder Discussions ............................................................................................................................ 27

Annex IV – SGS Analytical Sampling Results ............................................................................................................. 28

LIST OF TABLES Table 1: Scope of Issues Considered in Preparing the Scoping Statement ............................................................... 6

Table 2: Test Pit Sampling Characteristics .................................................................................................................... 14

Table 3: Significant Issues Entailed in Future Development of the NDS Site ....................................................... 17

Table 4: Issues Eliminated from Further Consideration in the NDS Warehouse EA .......................................... 18

LIST OF FIGURES Figure 1: Map of NDS Site Relative to Former LPRC Activities ............................................................................... 4

Figure 2: Proposed NDS Construction Site ................................................................................................................... 9

Figure 3: Land Features of the NDS Warehouse Site ................................................................................................. 10

iii

Figure 4: Oil Debris Observed within LPRC Site ....................................................................................................... 11

Figure 5: Remaining On-site Storage Tank within LPRC Area ................................................................................. 11

Figure 6: Oil Sheens in Wetlands within former LPRC site ...................................................................................... 12

Figure 7: Location of Sampling Test Pits ...................................................................................................................... 14

1

EXECUTIVE SUMMARY

Under USAID’s Global Environmental Management Support Project, The Cadmus Group, Inc. was commissioned by USAID/Liberia to develop a Scoping Statement of the proposed construction of a centralized National Drug Service (NDS) warehouse in Gardnersville, Monrovia, Liberia. Activity and context. According to USAID/Liberia and the Liberian NDS, an agency under the Ministry of Health and Social Welfare (MOHSW), the construction of a centralized warehouse will help improve the inventory, tracking and control of drugs and medical supplies and thus reduce losses throughout the supply chain. MOHSW proposed that the NDS Warehouse be constructed within a 1,000 acre site that was formerly operated by the Liberia Petroleum Refinery Company (LPRC) to refine and store petroleum products. The LPRC site was selected for the construction of the NDS Warehouse because it is located in close proximity to the Freeport of Liberia, where many of the medical supplies to be stored in the NDS Warehouse enter Liberia. The site also is located next to access roads which will be used to distribute the medical products throughout the country. In addition, rehabilitating a portion of the LPRC industrial site is considered to be a potential benefit according to the Liberia Environmental Protection Agency (LEPA). That is, rehabilitation enhances the value of the property and its future uses. Purpose. Per 22 CFR 216.3(a)(4), the purpose of this Scoping Statement is, in summary, to review the proposed activity to determine which potential environmental, health and social impacts of warehouse construction and operation may be adverse and significant, and thus must be addressed in a follow-on environmental assessment (EA) prior to construction, and which are not significant and may be eliminated from consideration in an EA. (In the event that no issues are found to be significant, an EA is not necessary.) LEPA has determined that the Government of Liberia’s (GoL) environmental impact assessment (EIA) requirements have been met. Sources of information. The findings and recommendations presented in this Scoping Statement are based on documents provided to Cadmus; discussions with nearby residents, USAID, and USAID implementing partners; observations made while conducting a site visit in July 2013; and soil sampling results obtained during July 2014. Summary of findings: currently proposed construction. Consistent with 22 CFR 216, the analysis assumes that issues are not considered significant for the purpose of undertaking an EA if the impacts can be addressed through straightforward mitigation measures. Environmental, health and social issues identified by the analysis that fall into this category include:

Water and soil runoff during the construction and operation of the NDS Warehouse.

Construction and operational wastes.

The need for safe drinking water at the site during construction and operation, given that groundwater at the site should not be used.

Community issues regarding employment opportunities, loss of a soccer field, and the remaining storage tank at the former LPRC site.

2

Mitigation measures are identified for each of the above issues. Because issues attendant to the currently proposed construction are not considered significant for the purpose of undertaking an EA, we anticipate that currently proposed construction will be awarded a negative determination with conditions per 22 CFR 216.3(a)(2)(i) and these mitigation measures will be required as conditions attendant to that determination. Summary of findings: potential future development of site beyond proposed warehouse construction zone. Some uncertainty exists as to whether runoff from the former LPRC area has contributed to petroleum hydrocarbon contamination in areas outside of or beyond the proposed construction footprint for the NDS Warehouse project. Although the sampling data included in this report do not suggest surface soil contamination, analytical results from sampling points across the entire NDS site at depths greater than 2-3 feet are not currently available. In addition, local residents raised some concerns about the overall development of the NDS site relative to community needs including, but not limited to, the construction of a school. Therefore, any USAID support related to NDS expansion plans (i.e., beyond the currently planned construction zone) would require a 22 CFR 216 EA.1 The purposes of the EA would be to:

Determine the presence or absence of petroleum by-products in the soil, outside of the currently planned construction zone for the NDS Warehouse, and in areas targeted for expansion activities related to the increased scale of warehouse operations, to assess potential risks to human health and the environment in areas; and

Obtain a more representative sample of community perspectives on development assistance relative to NDS Warehouse scaling activities and additional construction undertakings.

1 Development efforts funded by USAID, such as the assistance being provided to construct the NDS Warehouse, are

to be undertaken in accordance with Title 22 CFR Regulation 216 (Reg. 216) to ensure that environmental and social considerations are integrated into the decision-making process. This regulation requires, among other things, the review of proposed interventions to determine if there will be any associated classes of actions which normally have a significant impact on the environment. 22 CFR 216(d)(1) lists the actions that typically have a significant impact on the environment. If such classes of actions are identified, in most cases more detailed reviews of these actions and assessment of potential impacts on the environment are to be undertaken through the preparation of Scoping Statements, EAs, or (very rarely) Environmental Impact Statements (EIS).

3

1.0 INTRODUCTION

Under USAID’s Global Environmental Management Support Project (GEMS), The Cadmus Group, Inc. was commissioned by USAID/Liberia to develop a Scoping Statement of the proposed construction of a centralized National Drug Service (NDS) warehouse in Gardnersville, Monrovia, Liberia. Per 22 CFR 216.3(a)(4), the purpose of this Scoping Statement is, in summary, to review the proposed activity to determine which potential environmental, health and social impacts of warehouse construction and operation may be adverse and significant, and thus must be addressed in a follow-on environmental assessment (EA) prior to construction, and which are not significant and may be eliminated from consideration in an EA. (In the event that no issues are found to be significant, an EA is not necessary.) This section of the scoping statement provides:

Background information related to the construction of a centralized warehouse, including USAID assistance in this matter, and considerations influencing the selection of the site proposed for the NDS Warehouse.

The applicability of USAID Scoping Statements requirements to NDS Warehouse construction, and the basis for determining if an EA is needed to review Scoping Statement issues in more detail.

The objectives and scope of review, and the approach undertaken to prepare the Scoping Statement.

1.1 BACKGROUND: NDS WAREHOUSE CONSTRUCTION ACTIVITY USAID awarded a Cooperative Agreement (CA) to John Snow, Inc. (JSI) at the end of Fiscal Year 2008 to implement the Rebuilding Basic Health Services (RBHS) project in Liberia. The 2008 CA was designed to provide technical support and capacity building for the Ministry of Health and Social Welfare (MOHSW), fund direct services through non-governmental organizations (NGOs) and community based organizations (CBOs), and included provisions to renovate small health facilities. In 2011 USAID/Liberia redesigned the RBHS CA and eliminated from the scope of work the renovation of small health facilities and shifted assistance to MOHSW for a central pharmaceutical warehouse with technical assistance from RBHS.2 Drugs are imported into Liberia and stored within a 1,360 square meter (SM) space at the JFK Hospital and 1,200 SM of rented space at two sites in Monrovia. According to USAID and National Drug Service (NDS)3, an agency under MOHSW, these sites were no longer adequate for warehousing. NDS/MOHSW contend that storage in a centralized warehouse will improve the inventory, tracking and control of drugs and medical supplies and help reduce the siphoning off of drugs at different points in the supply chain process. In addition, the centralized warehouse will serve as the storage site for distributing drugs and medical supplies to health facilities throughout the country.4

2 Scope of Work for a Supplemental Environmental Assessment to Support the Construction of a National Drug Service Warehouse Project in Monrovia, Liberia, 2013. Prepared by USAID/Liberia.

3 NDS is an agency under MOHSW which is responsible for the procurement, storage and distribution of drugs and other pharmaceuticals for and to health facilities throughout the country.

4 Scope of Work for a Supplemental Environmental Assessment to Support the Construction of a National Drug Service Warehouse Project in Monrovia, Liberia, 2013. Prepared by USAID/Liberia.

4

MOHSW proposed that the centralized NDS Warehouse be constructed within a 1,000 acre site that was formerly operated by the Liberia Petroleum Refinery Company (LPRC). This site contained an oil topping and reforming plant, designed to process about 15,000 barrels of per day of crude oil, and storage tanks. The refinery was taken out of service circa 1984.5 The National Investment Commission (NIC), an agency of the Liberian government, owns the former LPRC property in Gardnerville, Monrovia. NIC plans to rent a 10-to 25-acre parcel within the former LPRC property to NDS/MOHSW on the basis of a 25-year renewable lease. The 10-to-25 acre parcel is estimated to be 50-75m distant from and at an elevation that is five meters higher than the location of the former petroleum storage area. See Figure 1 for an outline of the site. The former LPRC site is shaded in dark grey and the NDS site is south of the former LPRC operation, and the bitumen contaminated wetland (also circled). Figure 1: Map of NDS Site Relative to Former LPRC Activities

5 United Nations Fuel Study Briefing, Liberia, 2004.

NDS

5

The LPRC site was selected for the construction of the NDS Warehouse because it is located in close proximity to the Freeport of Liberia, where many of the medical supplies to be stored in the NDS Warehouse enter Liberia. The site also is located next to access roads which will be used to distribute the medical products throughout the country. In addition, rehabilitating a portion of the LPRC industrial site is considered to be a potential benefit according to the Liberia Environmental Protection Agency (LEPA). That is, rehabilitation enhances the value of the property and its future uses.6 An Environmental Assessment Form covering the construction of the centralized NDS Warehouse was prepared by MOHSW and submitted to LEPA. MOHSW received a permit for construction of the warehouse from LEPA on June 28, 2012.

1.2 ENVIRONMENTAL COMPLIANCE HISTORY AND CONTEXT NDS Warehouse design has been undertaken by RBHS, and construction is planned to be carried out by the MOHSW, with financing provided by the Global Fund and by USAID under a Fixed Amount Reimbursement Agreement (FARA). The FARA is designed to provide support to the GoL for a broad array of health and development objectives, including the construction and/or renovation of small health clinics and facilities. The Initial Environmental Examination (IEE) stated that if construction activities were undertaken and exceeded 10,000 square feet or 1,000 SM, a supplemental environmental review would need to be completed. An Africa Bureau Environmental Review Form (ERF) and accompanying environmental review report (ERR) was prepared by RBHS for MOHSW and submitted to USAID/Liberia in February 2012 for construction of the proposed 3300 m2 NDS warehouse. USAID/Liberia consulted with the Global Health Bureau Environmental Officer (BEO), who advised that, inter alia, the potential contamination of the site from petroleum operations and the risks this could pose to construction workers and abutters, and the possibility of construction or operations further spreading contamination, merited a 22 CFR 216 Scoping Statement. This would allow the process to proceed directly to an EA, if necessary, without loss of time. Alternately, if the Scoping Statement found that no impacts rose to the level of significance, the Scoping Statement would provide the analysis and mitigation measures necessary to approve the activity at the IEE level.

1.3 SCOPING STATEMENT OBJECTIVES AND COVERAGE

1.3.1 OBJECTIVES OF SCOPING STATEMENT Per 22 CFR 216.3(a)(4), the objectives of this NDS Warehouse Scoping Statement are to:

Gather data, including stakeholder input, to identify environmental, health and social issues that are adverse and significant, and thus require the preparation of an EA.

Identify and eliminate from the scope of the EA issues that are not significant or have been

covered by earlier environmental review, or approved design considerations, narrowing the discussion of these issues to a brief presentation of why they will not have a significant effect on the environment.

6 LEPA Environmental Assessment Form for the NDS Warehouse, 2012. Also see Section 40 of the Environmental

Protection Act of the Republic of Liberia.

6

Describe the timing of the preparation of environmental analyses, variations required in the format of the EA, and the tentative planning and decision-making schedule.

Describe how the EA will be conducted and the disciplines that will participate in the

analysis. The Scoping Statement was prepared to address USAID Reg. 216 requirements only; LEPA has determined that the Government of Liberia’s (GoL) environmental impact assessment (EIA) requirements have been met.

1.3.2 RANGE OF ISSUES CONSIDERED Drawing from the World Bank’s environmental assessment sourcebook and from the experience of Cadmus team members in evaluating contaminated sites, the following potential impacts were identified for consideration by the scoping analysis: Table 1: Scope of Issues Considered in Preparing the Scoping Statement

Issue Area Potential Impacts to Consider

Air Quality Increased particulate matter emissions

Increased sulfur dioxide emissions

Increased nitrogen oxide emissions

Increased carbon monoxide and carbon dioxide emissions

Increases in greenhouse gas emissions (other than oxides of carbon)

Volatilization of petroleum products if excavation is performed in contaminated areas

Water Quality Altered hydrologic regimes

Altered hydrogeological regimes

Increased heavy metals, acidity, or thermal discharges associated with wastewater

Increased turbidity (suspended solids)

Risk of groundwater contamination

Increased liquid wastes (e.g., surface runoff, sanitary wastes)

Potential for the mobilization of subsurface contaminants relative to the location of runoff infiltration areas and contaminated soils

Solid and Hazardous Wastes Increases in oil/fuel waste generation

Increases in solid wastes, pharmaceutical waste products, and contaminated soils

Resources Effects on subsidence on surface resources

Agricultural land losses

Loss of forestry resources

Effects on surface water resources

Effects on ground water resources

Disruption to infrastructure

Effects on fisheries

Ecology and Biodiversity Loss of natural habitats and biodiversity species

Loss of endangered species

Effects of induced development on ecology

Effects of riverine ecology and fisheries

Impacts due to effluents or emissions

Impacts associated with increased noise levels

7

Issue Area Potential Impacts to Consider

Social Resettlement issues

Effects on indigenous peoples

Loss of cultural heritage or religious sites

Loss of livelihood

Induced development issues

Effects on aesthetics and landform

Noise issues

Traffic safety issues

Occupational and Public Health and Safety

Potential exposures to:

Heat

Noise

Fire, explosive, electrical hazards

Dust

Non‐ionizing radiation

Hazardous materials

1.4 TECHNICAL APPROACH Our analysis began with review of relevant documents prepared by USAID/Liberia, MOHSW, and LEPA. These documents are listed in Annex I. This information was supplemented by discussions with stakeholders including local residents during a site visit in July 2013; these discussions are summarized in Section 2.3. In addition, surface soil sampling activities were undertaken within the proposed construction zone for the NDS Warehouse project in July 2014. These results can be found in Annex IV. Annex II includes a listing of professionals involved in the evaluation of environmental and social issues associated with the construction of the NDS Warehouse and preparation of this Scoping Statement.

2.0 SCOPE AND SIGNIFICANCE OF ENVIRONMENTAL ISSUES

This section of the Scoping Statement:

Describes the proposed construction and operational actions associated with the NDS Warehouse and associated environmental and social issues.

Summarizes the environmental features of the proposed construction site; and information gathered through stakeholder consultations.

Outlines the criteria for characterizing an issue as significant.

Lists and explains the characterization of issues associated with the construction of the warehouse as either significant triggering an EA or eliminated from further consideration in an EA.

2.1 PROPOSED CONSTRUCTION AND OPERATIONAL ACTIVITIES

2.1.1 WAREHOUSE CONSTRUCTION7 MOHSW’s Environmental Mitigation and Monitoring Plan (EMMP) for the NDS Warehouse contained the following summary of the proposed construction activities:

7 MOHSW EMMP for the Central Pharmaceutical Warehouse, February 2012.

8

Rehabilitating roughly 300 m of the gravel road within the industrial park, including provisions for

drainage.

Repairing approximately 800 m of the paved public access road leading to the site.

Light grading to prepare the site for construction, which is flat with a light slope towards the east.

Using gravel, sand, and laterite for the construction of the parking, loading and storage areas; however, paving these areas with asphalt is also being considered.

Constructing a steel-frame warehouse featuring: o A metal or composite insulated roof and siding o A concrete foundation and floor o Receiving and dispatching docks with overhead doors, pallet racking and shelving o A receiving and inspection area o A packing/dispatching/shipping area o Climate controlled cold storage o A secure storage area for flammable and hazardous products o Bathroom facilities

Excavating approximately four feet of ground to install the concrete foundation and backfilling it with structural fill (soil material).

Obtaining a water sample from a hand dug well to analyze for drinking, washing, showering, the cleaning, and bathroom purposes since municipal water may not be available within the industrial park and there are no bodies of surface water in the vicinity of the construction site.

Installing a septic system with a soak away pit to collect water discharges associated with cleaning activities and bathroom facilities.

Installing a diesel-powered generator since there is no electric power available at the site.

MOHSW anticipates that construction activities will generate small quantities of wastes such as cement, concrete, masonry block, steel bar, metal sheets, and wood. These waste streams would either be recycled or disposed of in the Monrovia land fill. Runoff of liquid waste, such as water, will be controlled through grading, small temporary erosion control check dams, and small retention ponds. The emission of dust and noise associated with construction equipment will be controlled through the use of equipment containing the appropriate mufflers and exhaust systems. See Figure 2 for the boundaries of the construction site for the NDS Warehouse.

2.1.2 OPERATION OF THE NDS WAREHOUSE8 According to LEPA, the design of the NDS Warehouse is not expected to have an adverse visual impact on the environment.9 This observation was reiterated by local residents interviewed during the July 2013 site

8 Most of the information summarized in this section was extracted from the MOHSW EMMP for the Central

Pharmaceutical Warehouse, February 2012. 9 LEPA Environmental Assessment Form for the Central NDS Warehouse, 2012.

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visit.10 The site will be graded to allow for the control of rainwater runoff and to prevent soil erosion. In addition, drainage channels and culverts will be installed to control rain runoff and soil loss. A seven to eight foot high chain link fence will be installed along the boundaries of the site; with security lights mounted on the buildings and on some poles at locations around the site. The new warehouse will be equipped with safety showers for employee use in the event of becoming contaminated with a drug or medical product. Fire protection hose reels will be installed, fire extinguishers will be placed at designated locations around the building, and emergency exit doors will be located around the building. Figure 2: Proposed NDS Construction Site

10

Based on G. Heaner conversations with local residents on 13 July 2012 during a tour of the proposed site for construction.

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The NDS Warehouse is expected to employ 5-10 workers. Currently these workers are employed by NDS and perform duties at the existing NDS warehouse locations throughout Monrovia. These workers have received safety training covering the receipt, storage, and dispensing of drug and medical products within a climate-controlled building, and follow NDS’s established procedures for the storage and disposal of controlled and expired pharmaceuticals and drugs. During daily operations of the warehouse, wastes such as paper wood, metal, and plastic packing material will be generated at an estimated rate of five cubic meters per month. These wastes will be recycled or disposed of in the Monrovia landfill. Expired or unused pharmaceutical products will be shipped to the incinerator constructed and operated by NDS in Montserrado County located 20- 30 kilometers from Monrovia. A diesel generator will be installed to provide power for warehouse use. The plans state the generator will be placed on a concrete pad to minimize oil drips to the ground. During use (which for the foreseeable future should be assumed to be 24/7), the generator is estimated to consume approximately five to eight gallons per hour, release pollutants to the air, and generate noise. In addition, waste oil will be generated during routine maintenance of the generator. The warehouse will need approximately 100–200 gallons of water per day. The water will be used for cleaning activities and bathroom facilities generating an estimated 50–100 gallons of wastewater per day. The wastewater will be disposed of through an on-site septic system with soak a way pit. Based on the proposed size of the septic system and estimated volume of wastewater, the system will need to be pumped out once every five years. The cleaning and maintenance of the septic system will be managed by NDS through the use of a commercial septic system disposal company. Alternatively, some consideration is being given to extending the Liberia Water and Sewer Company (LWSC) water pipe to the site. Analysis of the water from LWSC pipes elsewhere in Monrovia indicates fecal coliform contamination.11

2.2 ENVIRONMENTAL FEATURES OF THE PROPOSED SITE Based on observations made during a tour in July 2013 of the proposed construction site for the NDS Warehouse and information provided by LEPA, the land is fairly flat and is covered with scrub brush and a few scrub trees. See Figure 3. Figure 3: Land Features of the NDS Warehouse Site

11

E-mail from Joe Moyer on July 23, 2013.

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The vast majority of LPRC storage facilities and equipment have been removed. One or two small buildings remain on-site as well as some old dikes and storage facility foundations. In the area of the old storage tanks there are visible signs of oil and or oil sludge on the surface of the ground. See Figure 4. Figure 4: Oil Debris Observed within LPRC Site

In addition, local residents indicated oils may have been stored at the site until 2003 or later. Figure 5 is a storage tank on-site that residents’ claim contains materials.12 See Figure 6, the red circle identified the location of the storage tank shown in Figure 5. Figure 6 also includes the bitumen contaminated wetlands referenced in Figure 1. Figure 5: Remaining On-site Storage Tank within LPRC Area

During the site tour, it was observed that there are wetlands located near the proposed construction site that contain sludge or other refinery by-products.13 These wetlands are estimated to be approximately 300 m from the NDS construction site.14

12

Discussions with local residents during field visit in July 2013. 13

Site field visit conducted on 13 July 2013 by G. Heaner.

12

Figure 6: Oil Sheens in Wetlands within former LPRC site

Currently a portion of the site proposed for the NDS Warehouse is used as a soccer field by local residents and for open defecation. The soccer field reportedly can be relocated to area outside the boundaries of the proposed site for the NDS Warehouse, along with the existing informal goal posts or provisions can be made to install new goal posts. 15

14

E-mail correspondence with USAID RBHS Representative, Joe Moyer. 15 Information obtained from the Environmental Assessment Form prepared for the NDS Warehouse by MOHSW and

submitted to LEPA; 2012.

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2.3 VIEWS AND CONCERNS OF LOCAL RESIDENTS During the preparation of the NDS Warehouse Scoping Statement, information was gathered from local stakeholders including a community leader, youth leader, and a few of the residents around the site. The listing of individuals interviewed can be found in Annex III. The information obtained during these consultations indicated the following regarding the views and concerns of local residents:

1. Local Monrovia/Gardnersville residents believe that the remaining tank on the LPRC site (see Figure 5) contains toxic materials. As NDS Warehouse construction occurs, they also believe, there is an increased likelihood Liberians will enter the area and extract materials from the storage tank, increasing the potential for a spill creating additional environmental problems in and around the NDS construction site.

2. Local residents would appreciate being offered the opportunity to provide input into plans for developing the LPRC property and the NDS Warehouse site. In particular, they would like the plans to:

Include the removal of the old and structurally damaged storage tank to minimize potential health concerns related to releases of stored materials to the environment.

Consider hiring local residents for construction related activities.

Address their concerns that the site may be contaminated and that the wet season is preferable to the dry season because the area doesn’t have an intense odor, the pollution seems to be localized to areas where the water accumulates, and dust containing particulates isn’t blown around.

3. Local residents claimed to have submitted written letters to the government and called the local radio station about the issues at the site, but no one has responded.

4. A few local residents indicated that the area is known to be inhabited by “criminals” since it is remote. One local resident declared himself an ex AFL (armed forces of Liberia), as did another man. They mentioned that they don’t like Americans, they don't like the Liberian government, and they don’t like other governments because they could help Liberia but they don’t.

5. Local community residents agree that the site is appropriate for rehabilitation/reuse purposes; they openly say “we cannot build here” because of the potential contamination issues.

2.4 SAMPLING ACTIVITIES RBHS contracted with SGS Environmental Services in Wilmington, NC, USA to obtain soil samples from test pits primarily within the proposed area of the NDS Warehouse construction project to analyze for petroleum contaminants. Sampling results were obtained from four test pits that were approximately 1-3 feet deep. Three of the test pits were in the vicinity of the proposed construction zone for the NDS Warehouse

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building (pit Numbers [Nos.] 4 6, and 8). The fourth test pit (No. 2) was located between the visible sludge area (see Figure 6) and in the direction of possible future expansion of the warehouse complex as currently proposed. See Figure 7 for the location of the test pits within the 15 acre NDS Warehouse site. Figure 7: Location of Sampling Test Pits

The surface soil samples were analyzed for benzene, toluene, ethylbenzene, and xylene (BTEX), polycyclic aromatic hydrocarbons (PAHs), and oil and grease; these represent contaminants associated with petroleum waste products. See Table 2. Table 2: Test Pit Sampling Characteristics

Test Pit Number No.

Depth of Soil Sample

Petroleum Contaminants Analyzed in Soil Samples

BTEX PAHs Oil and Grease

2 1 foot x x x

4 2 feet x x x

6 1 foot x x x

6 3 feet x x x

8 3 feet x x x The sampling results indicated non-detectable levels of BTEX, PAHs, and oil and grease in the surface soil from the test pits. (See Annex IV for the complete set of sampling results.) In addition, the testing included an analysis of water extracted from a nearby hand dug well.

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The analytical results from the hand dug well indicated contamination of total coliform in the too numerous to count category, and it must be assumed that all shallow groundwater is so contaminated. This is consistent with open defecation in the area. For other characteristics including pH, turbidity, and chemicals constituents, the water quality results were within World Health Organizations (WHO) guidelines.

2.5 SUMMARY OF ENVIRONMENTAL AND SOCIAL ISSUES Based on the information gathered, the potential environment, health and safety issues identified in section 1.3.2 (Range of Issues Considered) applicable to the construction and on-going operation of the NDS Warehouse site include:

Soil erosion and sedimentation of water bodies related to road improvements, excavation, and changes in land use associated with building construction and auxiliary operations.

Generation of solid, hazardous, and medical wastes during construction and day-to-day operation of the warehouse.

Occupational health and safety issues related to the availability of properly maintained sanitation facilities and water sources for construction workers and warehouse employees.

Inadvertent introduction of contaminants to local drinking water supplies from septic discharge.

Community issues related to employment and overall economic development opportunities associated with the construction and operation of the NDS Warehouse.

Air emissions and noise related to the need for and use of a generator as part of the operation of the NDS Warehouse.

Spillage related to waste accumulation, fueling activities, or the operation of equipment located outside the warehouse building.

The task of the analysis is now to determine whether or not these issues rise to a significant level. This is addressed in the following sections.

2.6 DETERMINATION OF SIGNIFICANT ISSUES

2.6.1 CONSIDERATIONS FOR DETERMINING SIGNIFICANT ISSUES Three key considerations were used in assessing the above-listed activities for significance:

Consistent with 22 CFR 216, issues are not considered significant for the purpose of undertaking an EA if their impacts can be addressed through straightforward mitigation measures.

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Direct, indirect and cumulative16 impacts must all be considered in determining significance. (An impact or issue that is significant in any one category or in combination across all categories must be deemed significant.)

Environmental, health/safety, and social impacts are all a basis for determinations of significance.

2.6.2 SIGNIFICANT ENVIRONMENTAL ISSUES Applying the considerations above, no issues associated with currently planned construction are deemed significant. That is, if the recommended mitigation measures outlined in Section 2.7 are undertaken, the potential impacts associated with the construction and operation of the NDS Warehouse can be managed and reduced so they are not considered significant.

However, two issues are significant if future development of the NDS site (i.e., beyond the currently planned construction) includes the construction of additional warehouse space and shipping infrastructure. These are set out in Table 3. Any USAID support to further physically develop the site beyond the currently planned warehouse construction and road improvements would thus require an EA addressing these issues.

16 Cumulative effects refer to “impacts on the environment that result from the incremental impact of an action when added to other past, present, and reasonable foreseeable future actions.” They include effects which result from multiple activities over time or geographic areas, including the project being assessed, and may last for many years beyond the life of the project that caused the effects. Typically the cumulative effects assessment (CEA) of a proposed project considers the overall effects of “associated facilities” on those same environmental and human resources and systems in the project area of influence. (See http://www.usda.gov/rus/water/ees/pdf/AECI_FEIS/Sect_4.pdf for the definition of cumulative effects offered by the Council on Environmental Quality. This definition is used in the National Environmental Policy Act, and is the reference document for USAID EIA regulations.)

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Table 3: Significant Issues Entailed in Future Development of the NDS Site

Issue Basis for Determination of Significance

Indicated EA Analysis

Construction Activities

Possible human exposures to petroleum and refinery by‐products in soils that reside in areas targeted for future NDS Warehouse expansion activities, as new buildings and shipping facilities are constructed to address the increased scale of warehouse operations.

The photographs obtained during the July 2013 site visit indicate that petroleum and refinery by‐products are present on the ground within the former LPRC site. Although no information is available regarding the chemical composition of these materials, as activities at the NDS Warehouse site increase in size or scale, there is an increasing likelihood that future construction and operational activities may either:

Alter the landscape resulting in migration

of petroleum and refinery by‐products

from the former LPRC site to the NDS

Warehouse site; or

Expose humans to hazardous materials

during excavation and construction

activities.

Therefore, assessing the presence or absence of petroleum and refinery contaminants provides the information that is necessary to determine whether special measures need to be implemented to:

Minimize human contact with

contaminated soils; and

Manage and dispose of earthen waste

streams in an environmentally appropriate

manner.

Engage in a program to gather and analyze soil samples along the perimeter of the NDS Warehouse site adjacent to the former LPRC site to determine the presence or absence of petroleum and refinery contaminants. The soil samples should be taken at depths greater than 3 feet. The analysis of soil samples should be focused on the following petroleum and refinery by‐products:

Arsenic

BTEX

Lead

PHAs

Total petroleum

hydrocarbons

Construction & Operation

Increasing social/ community tensions resulting from the lack of significant stakeholder dialogue to obtain representative local residential perspectives on further development of the NDS site.

Data gathered from a limited number of community residents indicated discontent regarding the lack of economic growth opportunities associated with NDS site development and with governmental organizations including United States Government. Therefore gathering additional data is needed to assess whether these views are widely held or other community perspectives exist that may influence the further development of the NDS Warehouse site.

Gather stakeholder data through the conduct of focus groups or interviewing a larger number of community residents to probe for information related to local residential views/expectations concerning the development of the NDS site.

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Issue Basis for Determination of Significance

Indicated EA Analysis

Note: Based on discussions with local residents in July 2013, the Scoping Statement team determined that the most appropriate step to take to address community concerns was to move the soccer field and to offer local residents jobs during construction. The Scoping Statement team concluded that by engaging in some social/community development efforts, these actions would go a long way in mitigating potential hostility. If no actions are taken during construction, the feelings/concerns most likely will grow in intensity.

2.7 ISSUES ELIMINATED FROM FURTHER CONSIDERATION The issues eliminated from further consideration in the EA are enumerated in Table 3. These issues are eliminated because they intrinsically do not rise to a significant level, or because basic, straightforward mitigation measures that we believe will reliably control these issues and their impacts below the level of significance. Both these mitigation measures and justifications for determination of non-significance are set out in Table 4. In most instances, the proposed mitigation measure is a commonly accepted good practice to reduce the impact in question. The mitigation measures are in some cases those already identified by MOHSW or LEPA, and in some cases developed by the scoping team. The proposed construction zone for the planned NDS Warehouse and auxiliary facilities (e.g., parking lots, septic systems) will be awarded a negative determination with conditions per 22 CFR 216.3(a)(2)(i) and these mitigation measures will be required as conditions attendant to that determination. Table 4: Issues Eliminated from Further Consideration in the NDS Warehouse EA

Issue Proposed Mitigation Measures(to be specified as a condition attendant to a

Negative Determination for warehouse construction)

Basis for Eliminating Issue from EA Consideration

Construction Activities

Potential impairment or destruction of the physical environment near the NDS Warehouse due to erosion and siltation runoff during road repair and construction.

Construct the warehouse and auxiliary facilities (e.g., parking lots, septic systems), if practical, during the drier periods when there is less rain. Install or use temporary silt fences, and check dams during construction to reduce erosion and siltation. If construction occurs during the rainy season, fill piles should be covered to reduce erosion.

The proposed mitigation measures, when implemented, should reduce potential impacts to the physical environment (runoff and siltation) during construction.

Increased discontent among local residents due to unmet community

Identify and hire several local residents, including women, who are qualified to assist with construction related activities.

The proposed mitigation measure addresses potential concerns about limited

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expectations regarding employment opportunities during the construction of the NDS Warehouse.

community economic development benefits and gender issues during construction.

Soil and water contamination in the area of the NDS Warehouse due to improper management and storage of construction waste materials resulting in chemical runoff to the environment.

Develop and implement a waste management plan that includes storage of construction materials on temporary pads to minimize the potential for spillage to the ground, and disposal of wastes in appropriate landfills. For example:

Install drip pans at petroleum products

dispensing points.

Store potential pollutants such as fuel, oil

and chemicals on sealed surfaces to

prevent soil contamination.

Collect and recycle used oil and lubricants.

Contain and clean up spills as soon as

possible.

The proposed mitigation measures address the generation, storage, and disposal of construction wastes. These mitigation measures are considered best management practices to help reduce the potential for spillage of wastes to the ground during construction.

Construction worker exposure to pathogenic organisms (e.g., e‐coli) while using sanitation facilities within the warehouse construction footprint that have not been properly maintained to control the population of biological organisms.

Provide temporary sanitation facilities,

situated at least 50 feet from standing

water or water boreholes.

Provide proper maintenance and cleaning

of temporary sanitation facilities to reduce

the potential for the spread of diseases.

Providing temporary and well maintained sanitation facilities is a best practice designed to reduce the potential spread of disease associated with human waste products.

Construction worker exposure to pathogenic organisms (e.g., e‐coli) in local and untreated water supplies that are being used for drinking water and washing purposes, in the absence of supplies at the construction site that meet WHO water quality standards.

In the absence of groundwater sampling data, no wells should be dug in the NDS Warehouse construction area or former LPRC area. Provide construction workers with bottled water to reduce the possibility of consuming contaminated water from the local LWSC pipe or hand dug well in the area.

In the absence of water treatment options or potable drinking water, providing bottled water to construction workers helps avoid the potential for sickness due to contaminated water supplies.

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Increased, and most likely, intensified perceptions among local residents that their concerns/issues are not being considered if the soccer field is not replaced during the construction of the NDS Warehouse and auxiliary facilities.

Relocate the soccer field and goal posts (or install new goal posts) to an area that can be easily accessed by community residents for recreational purposes.

Relocating the soccer field to an area outside of the NDS construction site communicates to local residents that their concerns about recreational uses of the open space have been factored into construction plans.

Increased, and most likely, intensified perceptions among local residents that their concerns/issues are not being considered if the existing LPRC storage tank or its contents are not removed or better managed during NDS Warehouse construction. Local residents perceive that the contents of the tank are harmful to human health and environment.

Determine whether materials reside within the existing and deteriorated storage tank and install a fence around it (regardless as to whether any materials reside in the tank) to reduce access by local residents to a perceived human health and environmental risk. The determination could be made visually or by inserting a probe into the structure to determine the presence or absence of materials. The fence should be designed and constructed in such a manner to effectively restrict access by humans. Signs should be posted so that they cannot be removed indicating the presence of wastes that could be hazardous. USAID should work with NIC to develop a long‐term plan to remove the tank in an environmentally safe manner. This activity might be undertaken in the form of a memorandum of understanding.

By removing the contents of the storage tank or installing fencing around the vessel, reduces perceived residential concerns about public health and safety issues related to the storage of harmful waste products in the communities in which they reside.

Operations

Increased soil erosion and siltation due to regular access to and use of the NDS Warehouse and associated facilities, such as parking lots, related to inadequate site development.

Design the new NDS building and associated facilities to include the installation/construction of appropriately sized drainage channels and culverts that connect to existing drainage structures, appropriate distances from wetlands and other water sources within the area, and any contaminated soils.

The proposed mitigation measures are considered best practices for reducing the potential for soil erosion that may occur during normal operations of a facility such as a warehouse.

NDS worker reliance on untreated local water sources for drinking water purposes that pose a health risk since the water may be contaminated with pathogenic organisms (e.g., e‐coli) due to the lack of an on‐site supply that meets

Provide the warehouse with bottled or trucked water for the purposes of drinking, cooking and showering that meets the minimum WHO and USAID standards. Boreholes should not be installed.

In the absence of water treatment options or potable drinking water, providing bottled or trucked water helps ensure that workers avoid sickness due to contaminated water supplies.

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WHO water quality standards.

Increased potential for spreading pathogenic organisms (e.g., e‐coli) within the warehouse as a consequence of using local water supplies for toilets and fire suppression systems that have not been treated to reduce bacterial contamination levels to meet WHO standards.

Provide the warehouse with trucked water for the purposes of fire suppression and use in toilets or treat local water supplies to meet the minimum WHO and USAID standards, including arsenic. Boreholes should not be installed.

In the absence of water treatment options, providing trucked water for toilets and fire suppression helps reduce the potential for spreading bacterial contaminants within the NDS site.

The lack of, or insufficient use of, waste storage areas that control and contain materials during routine operations of the NDS Warehouse contributing to: 1) the potential for spillage to the environment resulting in soil and water contamination; and 2) theft of unsecured drug and medical supplies by local residents.

Prepare a waste management plan that includes:

Classification of wastes as non‐hazardous and hazardous.

Recycling or disposal options.

Container labeling.

Placement of waste in storage areas that are protected from the weather and spillage to the ground.

The plan should include:

Sludge from sanitary septic/cesspool containers

Packaging materials

Kitchen wastes

Medical wastes

Kitchen wastes

Office wastes

Security measures to reduce theft Prepare areas on‐site for waste storage that feature protection from the weather and spill control to minimize soil contamination.

The mitigation measures outlined to manage the generation, storage, and disposal of operationally generated wastes are considered best management practices to reduce potential environmental impacts associated with spillage to the ground and the possibility of theft.

Septic system overflows and leakage to the ground contributing to environmental contamination in the vicinity of the NDS Warehouse due to the lack of regular system maintenance.

Clean out the septic tank/cesspool containers on a regularly scheduled basis to avoid runoff to nearby wetlands and streams.

Periodic clean‐out and maintenance of septic systems is considered a best practice to reduce the potential for environmental contamination and exposure to human waste products.

Air emissions, elevated noise levels, and potential spills related to the

Incorporate into the purchase order

specification requirements for noise

deadening materials and mufflers and high

Specifying the technical requirements of the electrical generator and purchasing the

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installation and operation of an on‐site electrical generator.

efficiency equipment to reduce air

emissions.

Install spill containment measures around

the electrical generator.

equipment that meets or exceeds the environmental conditions will help reduce potential impacts to the environment related to emissions and noise.

Generation, spillage, and release of chlorofluorocarbons (CFCs) or greenhouse gas (GHGs) associated with the NDS Warehouse cooling system contributing to global warming.

Ensure that the equipment specifications

include a prohibition on the use of CFCs

and GHGs.

Install containment systems around the

cooling equipment to collect inadvertent

spills from filling and maintenance

activities.

Prohibiting the use of specified chemicals is a recognized method for reducing the potential release of chemicals, such as CFCs or GHGs, which have environmental impacts.

Spills occurring during refueling activities or in storage areas designated for oils contributing to soil and water contamination in the vicinity of the NDS Warehouse due to the lack of, or insufficiently sized, containment systems.

Install containment systems around fueling

and oil storage areas to control spillage to

the environment.

Provide asphalt surfaces to minimize

contact with the environment.

Implementation of spill control and containment measures is a best management practice to reduce the potential for chemicals to reach the environment in the event of a spill.

Unmet community expectations related to long‐term employment opportunities and community economic development goals associated with the operation of the NDS Warehouse related to the lack of effective stakeholder dialogue with local residents.

Provide local residents with job opportunities related to exterior facility maintenance, and to engage in efforts to remove all remaining LPRC structures/tanks to demonstrate that local/community concerns are being incorporated into development efforts.

Implementing actions that have recognizable economic benefits for the community, in most instances, reduces unmet expectations and discontent towards development interventions.

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3.0 SCHEDULE FOR PREPARING THE EA

As discussed, USAID support to further develop the NDS site beyond the immediately planned warehouse construction and road improvements will require an EA that is narrowly focused on (1) soil contamination and (2) community perspectives regarding the NDS construction and future uses of the NDS site in more detail. USAID/Liberia could begin preparing this EA immediately, so that it is in place to guide further site development, or at a future time. In any case, this section sets out a summary technical approach and staffing requirements.

3.1 EA METHODOLOGY The EA should be conducted following the sequence of tasks outlined below.

TASK 1: PREPARE DETAILED EA WORK PLAN

Establish a specific list of contaminants (e.g., petroleum hydrocarbon contaminants such as PAHs, BTEX) to be analyzed as part of the soil sampling activities in the warehouse expansion areas and identify the locations to sample the soil and the distances between the sampling locations.

Re-engage the environmental firm used to sample and analyze for the presence of petroleum hydrocarbons in surface soils within the proposed NDS Warehouse site to sample soil in areas targeted for warehouse expansion activities.

Revise, if necessary, the listing of contaminants to analyze for to determine the presence or absence in soil samples.

Identify other stakeholders to obtain feedback from regarding the former LPRC site and future development of the NDS Warehouse site.

Prepare and submit to USAID/Liberia a schedule for undertaking and completing Tasks 2-4.

TASK 2: CONDUCT VISIT TO LIBERIA TO GATHER ADDITIONAL INFORMATION

Oversee soil sampling activities to ensure the established sampling plan is implemented.

Gather additional environmental information focused on environmentally sensitive areas in the NDS Warehouse expansion areas and site hydrology, if available.

Conduct stakeholder meetings to gather additional perspectives regarding the further development of the NDS site.

Review and provide updates to USAID/Liberia regarding in-country visit to gather additional information.

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TASK 3: ANALYZE SAMPLING AND STAKEHOLDER DATA

Review and analyze the soil sampling results to determine concentrations of chemical constituents.17

Determine if the concentration levels pose a human health risk.

Analyze the stakeholder feedback to identify perspectives or issues that should also be considered during expansion activities associated with the NDS Warehouse operation.

TASK 4: PREPARE DRAFT AND FINAL EA DOCUMENTS FOR USAID/LIBERIA

Prepare the first draft of the EA for the expansion activities associated with the ongoing operation of the NDS Warehouse site and submit to USAID/Liberia for review and comment.

Schedule and conduct a conference call with USAID/Liberia and others, as necessary, to discuss the results and the potential impacts associated with NDS Warehouse expansion activities.

Incorporate USAID/Liberia comments into the EA and submit final draft to USAID/Liberia and BEO for review and comment.

Address USAID’s comments and produce final EA.

3.2 STAFFING FOR EA PREPARATION The specialists required to prepare the EA for the expansion activities associated with the ongoing operation of the NDS Warehouse site include the following:

Environmental engineer(s) with specific experience in soil contamination, remediation, and human risk assessment.

Social scientist with the experience to develop an approach for gathering stakeholder information from Liberian community representatives, analyze the results, and develop a summary for inclusion in the EA.

Team leader with environmental management and environmental assessment experience and knowledge of USAID Environmental Procedures.

Professional writer(s) or editor(s) with experience in report design and layout, copy editing, and report preparation services.

17

Ideally, hydrology and contamination information would be combined to assess the risk of further site development spreading or accelerated the spread of contamination from the site to ground and surface waters. However, in the absence of existing models, this is almost certainly beyond the reasonable budget of an EA.

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ANNEX I – BIBLIOGRAPHY

1. Environmental Mitigation & Monitoring Plan for MOHSW NDS Pharmaceutical Warehouse, February 2012.

2. Environmental Protection Agency of Liberia Environmental Assessment Form for the NDS Warehouse, 2012.

3. Initial Environmental Examination and Request for Categorical Exclusion for Ministry of Health and Social Welfare Fixed Amount Reimbursement Agreement toward Support for the implementation of Liberia’s 2011—21 National Health and Social Welfare Plan and Policy.

4. Ministry of Health and Social Welfare NDS Central Warehouse Environmental Review Report, February 2012.

5. Monrovia Industrial Park Boundary Layout Map, October 3, 2012. 6. Monrovia Industrial Park NDS Warehouse Plan Map, October 2, 2012. 7. Scope of Work for a Supplemental Environmental Assessment to Support the Construction of a

National Drug Service Warehouse Project in Monrovia, Liberia, 2012. 8. United Nations Joint Logistics Centre, Fuel Study Briefing, January 2004. 9. USAID/Liberia Environmental Review Form for Program Area 3.1 Health Small Grant Activities for the

NDS Warehouse. 10. Water Sampling Results from MOHSW, September 13, 2013. 11. SGS Environmental Services, Laboratory Sampling Results, July 2014.

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ANNEX II – LIST OF SCOPING STATEMENT PREPARORS

Jane E. Obbagy, The Cadmus Group, Inc. John Martin, The Cadmus Group, Inc. Gwendolyn Heaner, Ph.D., G-K Consulting

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ANNEX III – STAKEHOLDER DISCUSSIONS

Discussions about the proposed construction of the NDS Warehouse were undertaken with the following individuals: Joe Moyer Infrastructure Advisor, RBHS Rebuilding Basic Health Services Joan Atkinson System Strengthening Advisor, Health Team USAID Day break Mouth Community Mr. Lincoln Sackor - Youth president (0886-489287) Shedrick Henderson - Town Secretary Frank Nijor Wamah - 0886351850 Amos Sackor - 0886987921 Community down the road from the old LPRC factory Emmanuel Tokpah - Town Chief Harrison Weah - Older Community Member

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ANNEX IV – SGS ANALYTICAL SAMPLING RESULTS

Report Number: 31401068

Client Project: Liberia Samples

Laboratory Report of Analysis

Joe Moyer

JSI Research and Training Institute

44 Farnsworth St

Boston, MA 02210

Dear Joe Moyer,

Enclosed are the results of the analytical services performed under the referenced project for the received

samples and associated QC as applicable. The samples are certified to meet the requirements of the National

Environmental Laboratory Accreditation Conference Standards. Copies of this report and supporting data will be

retained in our files for a period of five years in the event they are required for future reference. All results are

intended to be used in their entirety and SGS is not responsible for use of less than the complete report. Any

samples submitted to our laboratory will be retained for a maximum of thirty (30) days from the date of this report

unless other arrangements are requested.

If there are any questions about the report or services performed during this project, please call Michael D. Page

at (910) 350-1903. We will be happy to answer any questions or concerns which you may have.

Thank you for using SGS North America Inc. for your analytical services. We look forward to working with you

again on any additional analytical needs.

Sincerely,

SGS North America Inc.

__________________________________________________________________

Michael D. Page Date

Project [email protected]

To:

Print Date: 07/28/2014 N.C. Certification # 481

1 of 44

Laboratory Qualifiers

Report Definitions

DL Method, Instrument, or Estimated Detection Limit per Analytical Method

CL Control Limits for the recovery result of a parameter

LOQ Reporting Limit

DF Dilution Factor

RPD Relative Percent Difference

LCS(D) Laboratory Control Spike (Duplicate)

MS(D) Matrix Spike (Duplicate)

MB Method Blank

Qualifier Definitions

* Recovery or RPD outside of control limits

B Analyte was detected in the Lab Method Blank at a level above the LOQ

U Undetected (Reported as ND or < DL)

J Estimated Concentration.

E Amount detected is greater than the Upper Calibration Limit

TIC Tentatively Identified Compound

ND Not Detected

P RPD > 40% between results of dual columns

D Spike or surrogate was diluted out in order to achieve a parameter result within instrument calibration

range

Samples requiring manual integrations for various congeners and/or standards are marked and dated by the analyst. A

code definition is provided below:

M1 Mis-identified peak

M2 Software did not integrate peak

M3 Incorrect baseline construction (i.e. not all of peak included; two peaks integrated as one)

M4 Pattern integration required (i.e. DRO, GRO, PCB, Toxaphene and Technical Chlordane)

M5 Other - Explained in case narrative

Note Results pages that include a value for "Solids (%)" have been adjusted for moisture content.


2 of 44

Sample Summary

Client Sample ID Lab Sample ID Collected Received Matrix

Pit 2 - Sample 1- 1ft 31401068001 07/07/2014 10:06 07/11/2014 12:00 Soil-Solid as dry weight



Pit 6 - Sample 2 - 3ft 31401068004 07/07/2014 12:28 07/11/2014 12:00 Soil-Solid as dry weight

Pit 8 - Sample 1 - 3ft 31401068005 07/07/2014 12:57 07/11/2014 12:00 Soil-Solid as dry weight


3 of 44

Case Narrative

A portion of each container was subsampled and shipped to Accutest Laboratories in Dayton, NJ for Oil and Grease analysis, per client request. SW846 8260B The spike recoveries for the matrix spike (MS) of sample ID (Pit 4 Sample 1 2ft) were below the control limits due to probable matrix interference. The matrix spike duplicate (MSD) recoveries were within control limits however the RPDs between the MS and MSD were above the control limits. The LCS/LCSD samples demonstrate precision and accuracy.

Print Date: 07/28/2014 N.C. Certification # 4814 of 44

Detectable Results Summary

* No Detectable Results *


5 of 44

Client Sample ID: Pit 2 - Sample 1- 1ft

Client Project ID: Liberia Samples

Lab Sample ID: 31401068001-A

Lab Project ID: 31401068

Collection Date: 07/07/2014 10:06

Received Date: 07/11/2014 12:00

Matrix: Soil-Solid as dry weight

Solids (%): 80.90

DL LOQ/CLResult Qual Units DFParameter

Results by SW-846 8260B

Results of Pit 2 - Sample 1- 1ft

Date Analyzed

Benzene ND ug/Kg 1U 5.400.965 07/11/2014 17:22

Ethyl Benzene ND ug/Kg 1U 5.400.894 07/11/2014 17:22

Toluene ND ug/Kg 1U 5.400.876 07/11/2014 17:22

m,p-Xylene ND ug/Kg 1U 10.81.91 07/11/2014 17:22

o-Xylene ND ug/Kg 1U 5.401.09 07/11/2014 17:22

Surrogates

1,2-Dichloroethane-d4 92.0 % 155.0-173 07/11/2014 17:22

4-Bromofluorobenzene 101 % 123.0-141 07/11/2014 17:22

Toluene d8 103 % 157.0-134 07/11/2014 17:22

Batch Information

Prep Batch: VXX5076

Prep Method: SW-846 5030B SL

Prep Date/Time: 07/11/2014 16:47

Prep Initial Wt./Vol.: 5.72 g

Prep Extract Vol: 5 mL

Analytical Batch: VMS3268

Analytical Method: SW-846 8260B

Instrument: MSD4

Analyst: JHL


6 of 44






Received Date: 07/11/2014 12:00


Solids (%): 80.90


Results by SW-846 8270D


Date Analyzed

1-Methylnaphthalene ND ug/Kg 1U 38677.5 07/18/2014 11:16


Acenaphthene ND ug/Kg 1U 38666.9 07/18/2014 11:16

Acenaphthylene ND ug/Kg 1U 38669.0 07/18/2014 11:16

Anthracene ND ug/Kg 1U 38667.5 07/18/2014 11:16

Benzo(a)anthracene ND ug/Kg 1U 38670.2 07/18/2014 11:16

Benzo(a)pyrene ND ug/Kg 1U 38679.5 07/18/2014 11:16

Benzo(b)fluoranthene ND ug/Kg 1U 38675.8 07/18/2014 11:16

Benzo(g,h,i)perylene ND ug/Kg 1U 38679.0 07/18/2014 11:16

Benzo(k)fluoranthene ND ug/Kg 1U 38685.9 07/18/2014 11:16

Chrysene ND ug/Kg 1U 38668.9 07/18/2014 11:16

Dibenz(a,h)anthracene ND ug/Kg 1U 38667.0 07/18/2014 11:16

Fluoranthene ND ug/Kg 1U 38678.5 07/18/2014 11:16

Fluorene ND ug/Kg 1U 38688.2 07/18/2014 11:16

Indeno(1,2,3-cd)pyrene ND ug/Kg 1U 38669.5 07/18/2014 11:16

Naphthalene ND ug/Kg 1U 38676.2 07/18/2014 11:16

Phenanthrene ND ug/Kg 1U 38667.2 07/18/2014 11:16

Pyrene ND ug/Kg 1U 38682.4 07/18/2014 11:16

Surrogates

2-Fluorobiphenyl 86.4 % 148.0-123 07/18/2014 11:16

Nitrobenzene-d5 94.9 % 146.0-117 07/18/2014 11:16

Terphenyl-d14 91.0 % 144.0-140 07/18/2014 11:16

Batch Information

Prep Batch: XXX4087

Prep Method: SW-846 3541

Prep Date/Time: 07/15/2014 08:44



Analytical Batch: XMS2038

Analytical Method: SW-846 8270D

Instrument: MSD10

Analyst: DTF


7 of 44






Received Date: 07/11/2014 12:00


Solids (%): 80.90


Results by EPA 1664A M (SUB)


Date Analyzed

HEM-Oil & Grease ND mg/Kg 1U 07/25/2014 0:00

Laboratory: Accutest Laboratories

Analytical Date/Time: 07/25/2014 00:00

Prep Method:

Prep Date/Time:


740

8 of 44






Received Date: 07/11/2014 12:00


Solids (%): 79.60




Date Analyzed

Benzene ND ug/Kg 1U 6.191.11 07/11/2014 17:48


Toluene ND ug/Kg 1U 6.191.00 07/11/2014 17:48


o-Xylene ND ug/Kg 1U 6.191.25 07/11/2014 17:48

Surrogates



Toluene d8 103 % 157.0-134 07/11/2014 17:48

Batch Information

Prep Batch: VXX5076


Prep Date/Time: 07/11/2014 16:47





Instrument: MSD4

Analyst: JHL


9 of 44






Received Date: 07/11/2014 12:00


Solids (%): 79.60




Date Analyzed


















Pyrene ND ug/Kg 1U 38181.5 07/18/2014 11:39

Surrogates

2-Fluorobiphenyl 84.9 % 148.0-123 07/18/2014 11:39

Nitrobenzene-d5 91.0 % 146.0-117 07/18/2014 11:39

Terphenyl-d14 92.4 % 144.0-140 07/18/2014 11:39

Batch Information

Prep Batch: XXX4087


Prep Date/Time: 07/15/2014 08:44





Instrument: MSD10

Analyst: DTF


10 of 44






Received Date: 07/11/2014 12:00


Solids (%): 79.60




Date Analyzed




Prep Method:

Prep Date/Time:


700

11 of 44






Received Date: 07/11/2014 12:00


Solids (%): 78.10




Date Analyzed

Benzene ND ug/Kg 1U 5.951.06 07/11/2014 18:14


Toluene ND ug/Kg 1U 5.950.964 07/11/2014 18:14


o-Xylene ND ug/Kg 1U 5.951.20 07/11/2014 18:14

Surrogates


4-Bromofluorobenzene 99.0 % 123.0-141 07/11/2014 18:14

Toluene d8 103 % 157.0-134 07/11/2014 18:14

Batch Information

Prep Batch: VXX5076


Prep Date/Time: 07/11/2014 16:47





Instrument: MSD4

Analyst: JHL


12 of 44






Received Date: 07/11/2014 12:00


Solids (%): 78.10




Date Analyzed


















Pyrene ND ug/Kg 1U 39183.6 07/18/2014 12:01

Surrogates

2-Fluorobiphenyl 84.8 % 148.0-123 07/18/2014 12:01

Nitrobenzene-d5 89.3 % 146.0-117 07/18/2014 12:01

Terphenyl-d14 91.4 % 144.0-140 07/18/2014 12:01

Batch Information

Prep Batch: XXX4087


Prep Date/Time: 07/15/2014 08:44





Instrument: MSD10

Analyst: DTF


13 of 44






Received Date: 07/11/2014 12:00


Solids (%): 78.10




Date Analyzed




Prep Method:

Prep Date/Time:


690

14 of 44

Client Sample ID: Pit 6 - Sample 2 - 3ft





Received Date: 07/11/2014 12:00


Solids (%): 77.40



Results of Pit 6 - Sample 2 - 3ft

Date Analyzed

Benzene ND ug/Kg 1U 6.141.10 07/11/2014 18:40


Toluene ND ug/Kg 1U 6.140.994 07/11/2014 18:40


o-Xylene ND ug/Kg 1U 6.141.24 07/11/2014 18:40

Surrogates



Toluene d8 103 % 157.0-134 07/11/2014 18:40

Batch Information

Prep Batch: VXX5076


Prep Date/Time: 07/11/2014 16:47





Instrument: MSD4

Analyst: JHL


15 of 44






Received Date: 07/11/2014 12:00


Solids (%): 77.40




Date Analyzed


















Pyrene ND ug/Kg 1U 39985.3 07/18/2014 12:24

Surrogates

2-Fluorobiphenyl 88.6 % 148.0-123 07/18/2014 12:24

Nitrobenzene-d5 93.9 % 146.0-117 07/18/2014 12:24

Terphenyl-d14 93.1 % 144.0-140 07/18/2014 12:24

Batch Information

Prep Batch: XXX4087


Prep Date/Time: 07/15/2014 08:44





Instrument: MSD10

Analyst: DTF


16 of 44






Received Date: 07/11/2014 12:00


Solids (%): 77.40




Date Analyzed




Prep Method:

Prep Date/Time:


630

17 of 44






Received Date: 07/11/2014 12:00


Solids (%): 67.50




Date Analyzed

Benzene ND ug/Kg 1U 7.351.31 07/11/2014 19:06


Toluene ND ug/Kg 1U 7.351.19 07/11/2014 19:06


o-Xylene ND ug/Kg 1U 7.351.49 07/11/2014 19:06

Surrogates


4-Bromofluorobenzene 99.0 % 123.0-141 07/11/2014 19:06

Toluene d8 103 % 157.0-134 07/11/2014 19:06

Batch Information

Prep Batch: VXX5076


Prep Date/Time: 07/11/2014 16:47





Instrument: MSD4

Analyst: JHL


18 of 44






Received Date: 07/11/2014 12:00


Solids (%): 67.50




Date Analyzed










Benzo(k)fluoranthene ND ug/Kg 1U 459102 07/18/2014 12:47




Fluorene ND ug/Kg 1U 459105 07/18/2014 12:47




Pyrene ND ug/Kg 1U 45998.1 07/18/2014 12:47

Surrogates

2-Fluorobiphenyl 94.2 % 148.0-123 07/18/2014 12:47

Nitrobenzene-d5 95.2 % 146.0-117 07/18/2014 12:47

Terphenyl-d14 94.5 % 144.0-140 07/18/2014 12:47

Batch Information

Prep Batch: XXX4087


Prep Date/Time: 07/15/2014 08:44





Instrument: MSD10

Analyst: DTF


19 of 44






Received Date: 07/11/2014 12:00


Solids (%): 67.50




Date Analyzed




Prep Method:

Prep Date/Time:


710

20 of 44

Batch Summary

SW-846 8260B SW-846 5035 SLAnalytical Method: Prep Method:

VXX5076

07/11/2014 16:47

Prep Batch:

Prep Date:

Client Sample ID Analysis Date Instrument AnalystLab Sample ID Analytical Batch

LCS-S for HBN 44952 [VXX/5076] 07/11/2014 11:10 MSD4 JHL140913 VMS3268

LCSD-S for HBN 44952 [VXX/5076 07/11/2014 11:36 MSD4 JHL140914 VMS3268

MB-S for HBN 44952 [VXX/5076] 07/11/2014 16:15 MSD4 JHL140915 VMS3268

Pit 2 - Sample 1- 1ft 07/11/2014 17:22 MSD4 JHL31401068001 VMS3268



Pit 6 - Sample 2 - 3ft 07/11/2014 18:40 MSD4 JHL31401068004 VMS3268

Pit 8 - Sample 1 - 3ft 07/11/2014 19:06 MSD4 JHL31401068005 VMS3268

Pit 4 - Sample 1-...(140904MS) 07/11/2014 19:32 MSD4 JHL140917 VMS3268

Pit 4 - Sample 1...(140904MSD) 07/11/2014 19:59 MSD4 JHL140918 VMS3268


21 of 44

Blank ID: MB-S for HBN 44952 [VXX/5076]

Blank Lab ID: 140915



Method Blank

Parameter Result LOQ/CLDL Units DFQual

QC for Samples:

31401068001, 31401068002, 31401068003, 31401068004, 31401068005

Benzene ND 5.000.933 ug/Kg 1U

Toluene ND 5.001.30 ug/Kg 1U

Ethyl Benzene ND 5.001.00 ug/Kg 1U

m,p-Xylene ND 10.01.85 ug/Kg 1U

o-Xylene ND 5.000.910 ug/Kg 1U

Surrogates

1,2-Dichloroethane-d4 102 55.0-173 % 1

Toluene d8 103 57.0-134 % 1

4-Bromofluorobenzene 104 23.0-141 % 1

Batch Information

Prep Batch: VXX5076

Prep Method: SW-846 5035 SL

Prep Date/Time: 7/11/2014 4:47:03PM

Prep Initial Wt./Vol.: 5 g




Instrument: MSD4

Analyst: JHL


22 of 44

Blank Spike ID: LCS-S for HBN 44952 [VXX/5076]

Blank Spike Lab ID: 140913

Date Analyzed: 07/11/2014 11:10

Spike Duplicate ID: LCSD-S for HBN 44952 [VXX/5076

Spike Duplicate Lab ID: 140914

Date Analyzed: 07/11/2014 11:36


Blank Spike Summary


Parameter Spike Result Rec (%) Spike Result Rec (%) RPD (%)CL

Blank Spike (ug/Kg)

RPD CL

Spike Duplicate (ug/Kg)

31401068001, 31401068002, 31401068003, 31401068004, 31401068005QC for Samples:

Benzene 30.0 33.5 3.2112 30.0 34.6 115* 82.0-113 30.00

Toluene 30.0 34.0 2.6113* 30.0 34.9 116* 83.0-111 30.00

Ethyl Benzene 30.0 32.4 3.0108 30.0 33.4 111 72.0-115 30.00

m,p-Xylene 60.0 65.3 3.2109 60.0 67.4 112 73.0-114 30.00

o-Xylene 30.0 32.1 2.8107 30.0 33.0 110 74.0-113 30.00

Surrogates

1,2-Dichloroethane-d4 93 93 55.0-173

Toluene d8 103 103 57.0-134

4-Bromofluorobenzene 101 102 23.0-141

Batch Information



Instrument: MSD4

Analyst: JHL

Prep Batch: VXX5076

Prep Method: SW-846 5035 SL

Prep Date/Time: 07/11/2014 16:47

Spike Init Wt./Vol.: 5 g Extract Vol: 5 mL

Dupe Init Wt./Vol.: 5 g Extract Vol: 5 mL


23 of 44

Original Sample ID: 31401068002 (Pit 4 - Sample 1- 2ft)

MS Sample ID: 140917

MSD Sample ID: 140918

Analysis Date: 07/11/2014 17:48

Analysis Date: 07/11/2014 19:32

Analysis Date: 07/11/2014 19:59



Matrix Spike Summary

Parameter Sample Spike Result Rec (%) Spike Result Rec (%) RPD (%)

Matrix Spike (ug/Kg) Spike Duplicate (ug/Kg)

CL RPD CL

QC for Samples: 31401068001, 31401068002, 31401068003, 31401068004, 31401068005

Benzene ND 36.9 14.5 35.3 31.9 90 75*39 * 30.0075.0-133

Ethyl Benzene ND 36.9 12.7 35.3 30.1 85 81*35 * 30.0074.0-126

Toluene ND 36.9 14.6 35.3 32.3 91 76*40 * 30.0066.0-128

m,p-Xylene ND 73.7 25.6 70.7 60.4 85 81*35 * 30.0080.0-118

o-Xylene ND 36.9 12.4 35.3 29.8 84 83*34 * 30.0080.0-121

Surrogates

1,2-Dichloroethane-d4 8992 55.0-173

4-Bromofluorobenzene 101102 23.0-141

Toluene d8 103104 57.0-134

Batch Information



Instrument: MSD4

Analyst: JHL

Prep Batch: VXX5076


Prep Date/Time: 07/11/2014 16:47

MS Init Wt./Vol.: 5.11 g Extract Vol.: 5 mL

MSD Init Wt./Vol.: 5.33 g Extract Vol.: 5 mL


24 of 44

Batch Summary

SW-846 8270D SW-846 3541Analytical Method: Prep Method:

XXX4087

07/15/2014 08:44

Prep Batch:

Prep Date:


MB for HBN 45155 [XXX/4087] 07/18/2014 10:31 MSD10 DTF141134 XMS2038

LCS for HBN 45155 [XXX/4087] 07/18/2014 10:54 MSD10 DTF141135 XMS2038

Pit 2 - Sample 1- 1ft 07/18/2014 11:16 MSD10 DTF31401068001 XMS2038



Pit 6 - Sample 2 - 3ft 07/18/2014 12:24 MSD10 DTF31401068004 XMS2038

Pit 8 - Sample 1 - 3ft 07/18/2014 12:47 MSD10 DTF31401068005 XMS2038

Pit 8 - Sample 1 ...(140907MS) 07/18/2014 13:10 MSD10 DTF141136 XMS2038

Pit 8 - Sample 1...(140907MSD) 07/18/2014 13:32 MSD10 DTF141137 XMS2038


25 of 44

Blank ID: MB for HBN 45155 [XXX/4087]

Blank Lab ID: 141134



Method Blank

Parameter Result LOQ/CLDL Units DFQual

QC for Samples:

31401068001, 31401068002, 31401068003, 31401068004, 31401068005

Naphthalene ND 31361.8 ug/Kg 1U

2-Methylnaphthalene ND 31360.3 ug/Kg 1U

1-Methylnaphthalene ND 31362.9 ug/Kg 1U

Acenaphthene ND 31354.3 ug/Kg 1U

Fluorene ND 31371.6 ug/Kg 1U

Phenanthrene ND 31354.5 ug/Kg 1U

Anthracene ND 31354.8 ug/Kg 1U

Fluoranthene ND 31363.7 ug/Kg 1U

Pyrene ND 31366.9 ug/Kg 1U

Benzo(a)anthracene ND 31357.0 ug/Kg 1U

Chrysene ND 31355.9 ug/Kg 1U

Benzo(b)fluoranthene ND 31361.5 ug/Kg 1U

Benzo(k)fluoranthene ND 31369.7 ug/Kg 1U

Benzo(a)pyrene ND 31364.5 ug/Kg 1U

Indeno(1,2,3-cd)pyrene ND 31356.4 ug/Kg 1U

Dibenz(a,h)anthracene ND 31354.4 ug/Kg 1U

Benzo(g,h,i)perylene ND 31364.1 ug/Kg 1U

Acenaphthylene ND 31356.0 ug/Kg 1U

Surrogates

Nitrobenzene-d5 103 46.0-117 % 1

2-Fluorobiphenyl 104 48.0-123 % 1

Terphenyl-d14 108 44.0-140 % 1

Batch Information

Prep Batch: XXX4087


Prep Date/Time: 7/15/2014 8:44:19AM

Prep Initial Wt./Vol.: 32 g




Instrument: MSD10

Analyst: DTF


26 of 44

Blank Spike ID: LCS for HBN 45155 [XXX/4087]

Blank Spike Lab ID: 141135

Date Analyzed: 07/18/2014 10:54


Blank Spike Summary


Parameter Spike Result Rec (%) CL

Blank Spike (ug/Kg)

31401068001, 31401068002, 31401068003, 31401068004, 31401068005QC for Samples:

Naphthalene 3130 3330 107 72.0-116

2-Methylnaphthalene 3130 3340 107 75.0-120

Acenaphthene 3130 3370 108 74.0-118

Fluorene 3130 3440 110 77.0-123

Phenanthrene 3130 3450 110 74.0-128

Anthracene 3130 3430 110 73.0-128

Fluoranthene 3130 3550 114 74.0-130

Pyrene 3130 3550 114 74.0-121

Benzo(a)anthracene 3130 3490 112 72.0-123

Chrysene 3130 3480 111 72.0-128

Benzo(b)fluoranthene 3130 3370 108 63.0-116

Benzo(k)fluoranthene 3130 3640 116 74.0-125

Benzo(a)pyrene 3130 3550 114 71.0-126

Indeno(1,2,3-cd)pyrene 3130 3650 117 76.0-137

Dibenz(a,h)anthracene 3130 3630 116 73.0-138

Benzo(g,h,i)perylene 3130 3660 117 77.0-143

Acenaphthylene 3130 3500 112 75.0-122

Surrogates

Nitrobenzene-d5 106 46.0-117

2-Fluorobiphenyl 108 48.0-123

Terphenyl-d14 112 44.0-140

Batch Information



Instrument: MSD10

Analyst: DTF

Prep Batch: XXX4087


Prep Date/Time: 07/15/2014 08:44

Spike Init Wt./Vol.: 32 g Extract Vol: 10 mL

Dupe Init Wt./Vol.: Extract Vol:


27 of 44

Original Sample ID: 31401068005 (Pit 8 - Sample 1 - 3ft)

MS Sample ID: 141136

MSD Sample ID: 141137

Analysis Date: 07/18/2014 12:47

Analysis Date: 07/18/2014 13:10

Analysis Date: 07/18/2014 13:32



Matrix Spike Summary

Parameter Sample Spike Result Rec (%) Spike Result Rec (%) RPD (%)

Matrix Spike (ug/Kg) Spike Duplicate (ug/Kg)

CL RPD CL

QC for Samples: 31401068001, 31401068002, 31401068003, 31401068004, 31401068005

2-Methylnaphthalene ND 4415 4780 4607 3990 87 18108 30.0074.1-111

Acenaphthene ND 4415 4810 4607 4000 87 18109 30.0071.0-125

Acenaphthylene ND 4415 4990 4607 4170 90 18113 30.0073.0-140

Anthracene ND 4415 4750 4607 3970 86 18107 30.0066.9-119

Benzo(a)anthracene ND 4415 4910 4607 4030 87 20111 30.0051.8-127

Benzo(a)pyrene ND 4415 4930 4607 4070 88 19111 30.0078.5-137

Benzo(b)fluoranthene ND 4415 4800 4607 3990 87 19108 30.0062.3-134

Benzo(g,h,i)perylene ND 4415 5170 4607 4320 94 18117 30.0056.2-149

Benzo(k)fluoranthene ND 4415 4960 4607 4100 89 19112 30.0079.7-133

Chrysene ND 4415 4930 4607 4100 89 18112 30.0072.7-124

Dibenz(a,h)anthracene ND 4415 5130 4607 4270 93 18116 30.0058.6-146

Fluoranthene ND 4415 4930 4607 4140 90 18111 30.0064.6-129

Fluorene ND 4415 4890 4607 4040 88 19110 30.0072.4-128

Indeno(1,2,3-cd)pyrene ND 4415 5140 4607 4290 93 18116 30.0029.1-157

Naphthalene ND 4415 4760 4607 3990 87 18108 30.0049.9-137

Phenanthrene ND 4415 4830 4607 4020 87 18109 30.0055.8-128

Pyrene ND 4415 4990 4607 4120 89 19113 30.0068.5-140

Surrogates

2-Fluorobiphenyl 91.491.6 48.0-123

Nitrobenzene-d5 94.492.2 46.0-117

Terphenyl-d14 94.695.1 44.0-140

Batch Information



Instrument: MSD10

Analyst: DTF

Prep Batch: XXX4087


Prep Date/Time: 07/15/2014 08:44

MS Init Wt./Vol.: 33.51 g Extract Vol.: 10 mL

MSD Init Wt./Vol.: 32.17 g Extract Vol.: 10 mL


28 of 44

Batch Summary

EPA 1664A M (SUB)Analytical Method: Prep Method:

SUBPrep Batch:

Prep Date:


Pit 2 - Sample 1- 1ft 07/25/2014 00:00 MNL31401068001 SUB



Pit 6 - Sample 2 - 3ft 07/25/2014 00:00 MNL31401068004 SUB

Pit 8 - Sample 1 - 3ft 07/25/2014 00:00 MNL31401068005 SUB


29 of 44

07/28/14

Technical Report for

SGS North America, Inc

31401068, Liberia

Accutest Job Number: JB72399

Sampling Date: 07/07/14

Report to:

[email protected]

Total number of pages in report:

Certifications: NJ(12129), NY(10983), CA, CT, DE, FL, IL, IN, KS, KY, LA, MA, MD, MI, MT, NC,

OH VAP (CL0056), PA, RI, SC, TN, VA, WV, DoD ELAP (L-A-B L2248)

This report shall not be reproduced, except in its entirety, without the written approval of Accutest Laboratories.

Test results relate only to samples analyzed.

New Jersey • 2235 Route 130 • Dayton, NJ 08810 • tel: 732-329-0200 • fax: 732-329-3499 • http://www.accutest.com

Test results contained within this data package meet the requirements

of the National Environmental Laboratory Accreditation Program

and/or state specific certification programs as applicable.

Client Service contact: Matt Cordova 732-329-0200

Nancy ColeLaboratory Director

New Jersey

07/28/14

e-Hardcopy 2.0Automated Report

13

Accutest Laboratories is the sole authority for authorizing edits or modifications to thisdocument. Unauthorized modification of this report is strictly prohibited.

1 of 13JB7239930 of 44

Table of Contents-1-

Sections:

Section 1: Sample Summary ................................................................................................... 3Section 2: Summary of Hits .................................................................................................... 4Section 3: Sample Results ........................................................................................................ 5

3.1: JB72399-1: 31401068001 ............................................................................................. 63.2: JB72399-2: 31401068002 ............................................................................................. 73.3: JB72399-3: 31401068003 ............................................................................................. 83.4: JB72399-4: 31401068004 ............................................................................................. 93.5: JB72399-5: 31401068005 ............................................................................................. 10

Section 4: Misc. Forms ............................................................................................................ 114.1: Chain of Custody ........................................................................................................... 12

12

34

2 of 13JB7239931 of 44

Accutest Laboratories

Sample Summary

SGS North America, IncJob No: JB72399

31401068, Liberia

Sample Collected Matrix Client Number Date Time By Received Code Type Sample ID

JB72399-1 07/07/14 10:06 MP 07/24/14 SO Soil 31401068001

JB72399-2 07/07/14 11:37 MP 07/24/14 SO Soil 31401068002

JB72399-3 07/07/14 12:22 MP 07/24/14 SO Soil 31401068003

JB72399-4 07/07/14 12:28 MP 07/24/14 SO Soil 31401068004

JB72399-5 07/07/14 12:57 MP 07/24/14 SO Soil 31401068005

Soil samples reported on a dry weight basis unless otherwise indicated on result page.

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Summary of Hits Page 1 of 1 Job Number: JB72399Account: SGS North America, IncProject: 31401068, LiberiaCollected: 07/07/14

Lab Sample ID Client Sample ID Result/Analyte Qual RL MDL Units Method

JB72399-1 31401068001

No hits reported in this sample.

JB72399-2 31401068002


JB72399-3 31401068003


JB72399-4 31401068004


JB72399-5 31401068005


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Sample Results

Report of Analysis

New Jersey

Section 3

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Report of Analysis Page 1 of 1

Client Sample ID: 31401068001 Lab Sample ID: JB72399-1 Date Sampled: 07/07/14 Matrix: SO - Soil Date Received: 07/24/14

Percent Solids: 71.4 Project: 31401068, Liberia

General Chemistry

Analyte Result RL Units DF Analyzed By Method

HEM Petroleum Hydrocarbons <740 740 mg/kg 1 07/25/14 JOO EPA 1664A M

Solids, Percent 71.4 % 1 07/24/14 16:10 AC SM2540 G-97

RL = Reporting Limit

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General Chemistry





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General Chemistry





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General Chemistry



Solids, Percent 77 % 1 07/24/14 16:10 AC SM2540 G-97


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General Chemistry





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Misc. Forms

Custody Documents and Other Forms

Includes the following where applicable:

• Chain of Custody

New Jersey

Section 4

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JB72399: Chain of CustodyPage 1 of 2

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Accutest Laboratories Sample Receipt Summary

Accutest LaboratoriesV:732.329.0200

2235 US Highway 130F: 732.329.3499

Dayton, New Jerseywww/accutest.com

Accutest Job Number: JB72399 Client:

Date / Time Received: 7/24/2014 Delivery Method:

Project:

4. No. Coolers: 1

Airbill #'s:

Cooler Security

1. Custody Seals Present:

Y or N

2. Custody Seals Intact:

3. COC Present:

4. Smpl Dates/Time OK

2. Cooler temp verification:

Cooler Temperature Y or N

1. Temp criteria achieved:

3. Cooler media: Ice (Bag)

Quality Control Preservatio Y or N N/A

1. Trip Blank present / cooler:

2. Trip Blank listed on COC:

3. Samples preserved properly:

4. VOCs headspace free:

Sample Integrity - Documentation Y or N

1. Sample labels present on bottles:

2. Container labeling complete:

3. Sample container label / COC agree:

Sample Integrity - Condition Y or N

1. Sample recvd within HT:

3. Condition of sample:

2. All containers accounted for:

Sample Integrity - Instructions

1. Analysis requested is clear:

2. Bottles received for unspecified tests

3. Sufficient volume recvd for analysis:

4. Compositing instructions clear:

5. Filtering instructions clear:

Intact

Y or N

Comments

Y or N N/A

Cooler Temps (Initial/Adjusted): #1: (0.3/0.3); 0

JB72399: Chain of CustodyPage 2 of 2

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3 f4Dt0&~ Ol-L4-711-AFR(LBR)-MIN-01, REV. 01, 0612013

SAMPLE IDENTIFICATION I ASSAYS REQUIRED

As Received, no prep required: D

SGS Prep Codes: Sample Preparation Required: NIA

Other/Special D:

SGS Analytical Codes Elements Required

Client Authorization (signature): __________ _ Date:----------

LABORATORY INFORMATION (TO BE FILLED IN BY SGS STAFF) Sample condition upon receipt:

Received date:

Received by: Logged in date:

TERMS AND CONDITIONS I QUALIFICATIONS AND LIMITATIONS

All SGS services are rendered in accordance with the applicable SGS Conditions of Service accessible at l1t'p:!'Y1.1w;_sas ccr·l'1Y·ns_a !'.i_ccr··1.t·o•1'.; hi"'· Attention is drawn to the limitations of liability and to the clauses on indemnification and jurisdiction. By signing this document. the Client confirms that he/she accepts the applicable SGS Conditions of Service.

Approved by: Eduan Naude

I

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SGS North America Inc.

Sample Receipt Checklist (SRC)

Client: JSI Work Order No.: 31401068

1. ~Shipped Notes: Hand Delivered

2. COC Present on Receipt X NoCOC

Additional Transmittal Forms

3. Custody Tape on Container ~No Custody Tape

4. Samples Intact ~Samples Broken I Leaking

5. ~Chilled on Receipt Actual Temp.(s) in °C: _3 ________ T_h_e_rm_o_m_et_e_r_ID_#_:_L_o_..g_in_1_-_D _ _ Ambient on Receipt

Walk-in on Ice; Coming down to temp. Temperature Blank Present

6. Sufficient Sample Submitted X Insufficient Sample Submitted

7. Chlorine absent HN03<2 HCL <2 Additional Preservatives verified (see notes)

8. X Received Within Holding Time =Not Received Within Holding Time

9. _No Discrepancies Noted X Discrepancies Noted

= NCDENR notified of Discrepancies*

10. No Headspace present in VOC vials Headspace present in VOC vials >6mm

Comments: None of the Volatiles Vials were labeled with sample information.

Inspected and Logged in by: Russell Holz Date: ---7-/-11-/-20_1_4 ___ _

*NCDENR must be notified when collection, holding time or preservation requirements are not met. Ml_11.9