environmental compliance audit - world...
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Environmental Compliance Audit
Manila Second Sewerage Project
Manila Water Company Inc.
December 2003
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Environmental Compliance Audit
Reference R03-80
Prepared for
Manila Water Company Inc.
Prepared by
Maunsell Philippines Inc
11/F Ayala Life - FGU Center
6811 Ayala Avenue
Makati City
Philippines
Tel +632 843 6336
Fax +632 843 6125
December 2003
510500004
© Maunsell Philippines Inc 2003 The information contained in this document produced by Maunsell Philippines Inc is solely for the use of the Client identified on the cover sheet for the purpose for which it has been prepared and Maunsell Philippines Inc undertakes no duty to or accepts any responsibility to any third party who may rely upon this document. All rights reserved. No section or element of this document may be removed from this document, reproduced, electronically stored or transmitted in any form without the written permission of Maunsell Philippines Inc.
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Quality Information
Document Environmental Compliance Audit
Ref 51050004 j :\51050004\administration\reports\rev 1\rev1.eca.mssp.mwci.8dec03.doc
Date December 2003
Revision Revision 1
Description Manila Second Sewerage Project
Originator
Eliza Paruñgao/Luc Valencia
Checked
Naniel Aragones
Approved
Jess P. Bayrante
Environmental Manager
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Environmental Compliance Audit December 2003
Table of Contents
1.0 Introduction 1
2.0 Scope and Coverage of the Audit 2
3.0 Methodology 3
4.0 Manila Second Sewerage Project 4
4.1 Background 4
4.2 Project Status 4
4.2.1 Septage Management 4
4.2.2 Rehabilitation of Sewer Netw orks 5
4.2.3 Closed Circuit Television Inspection on Sewer Networks 5
4.2.4 Rehabilitation of Ayala Sewage Treatment Plant 5
4.2.5 Community Sanitation Projects 6
4.2.6 Laboratory and Maintenance Equipment 8
4.2.7 Consultancy Support Services 8
5.0 Audit Findings 9
5.1 Compliance With ECC Conditions 9
5.1.1 MSSP 9
5.1.2 STP 13
5.1.3 Notice of Violation (NOV) 17
5.2 Compliance With Environmental Management Plan 17
5.2.1 Septage Collection and Sea Disposal 17
5.2.2 Upgrading of the Magallanes (Ayala) Sewage Treatment and Network Facility 17
5.2.3 Sewerage Projects 22
5.3 Compliance With Philippine Environmental Guidelines 28
5.3.1 Sanitation Code 28
5.3.2 Effluent Standards 28
5.3.3 Ecological Solid Waste Management Act 30
5.3.4 Toxic Substances and Hazardous and Nuclear Wastes Control Act 31
5.3.5 Clean Air Act 31
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Environmental Compliance Audit December 2003
5.4 Compliance With International Environmental Guidelines 32
5.4.1 World Bank Environmental Guidelines 32
5.4.2 London Convention 33
5.5 Compliance with Other Relevant Guidelines 34
5.5.1 Occupational Safety and Health Standards 34
5.5.2 Agriculture Chemicals Regulations 35
6.0 Conclusion and Recommendation 36
6.1 Conclusion 36
6.2 Recommendations 36
7.0 References 38
LIST OF ANNEXES
Annex A ECC of MSSP
Annex B ECC of STP Projects
Annex C Results of Sea Disposal Monitoring
Annex D PCG Permits
Annex E Minutes of Meeting – Environmental Training
Annex F Typical Environmental Monitoring Plan
Annex G Typical Environmental Management Plan
Annex H Permit to Operate
Annex I Monitoring Data
Annex J Certification from DENR Declaring Wastes as Non-hazardous
Annex K FPA Permit
LIST OF TABLES
Table 1 Underground Sewage Treatment Plant
Table 2 ECC Compliance Status of STP Projects
Table 3 EMP Septage Collection, Transport and Disposal
Table 4 Integrated EMP for MSSP and STP Projects
Table 5 Ayala STP Effluent Quality Analysis
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Environmental Compliance Audit December 2003
LIST OF TECHNICAL ABBREVIATIONS AND NOMENCLATURE
Abbreviations Description AALA Agreement Amending Loan Agreement
AC Authority to Construct ASTM American Society for Testing and Materials
BFAR Bureau of Fisheries and Aquatic Resources
BOD Biochemical Oxygen Demand
CAA Clean Air Act
CCTV Closed Circuit Television
COD Chemical Oxygen Demand
CSS Consultancy Support Services
DAO DENR Administrative Order
DENR Department of Environment and Natural Resources
DO Dissolved Oxygen
DOH Department of Health
DPWH Deparment of Public Works and Highways
ECC Environmental Compliance Certificate
EGF Environmental Guarantee Fund
EIA Environmental Impact Assessment
EIS Environmental Impact Statement
EMB Environmental Management Bureau
EMP Environmental Monitoring Plan
GPS Global Positioning System
IEE Initial Environmental Examination
IRR Implementing Rules and Regulations LGU Local Government Unit
LTO Land Transportation Office
MBAS Methylene Blues Active Substances MMDA Metro Manila Development Authority
MMT Multipartite Monitoring Team
MOA Memorandum of Agreement
MPN Most Probable Number
MSSP Manila Second Sewerage Project
MWCI Manila Water Company, Inc.
MWSS Manila Waterworks and Sewerage System
NCR National Capital Region
NGO Nongovernmental Organization
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Environmental Compliance Audit December 2003
NPI New or Proposed Industry
NOV Notice of Violation
NTU Nephelometric Turbidity Unit
OEI Old or Existing Industry
OSHS Occupational Safety and Health Standards
PD Presidential Decree
PCG Philippine Coast Guard
PCO Pollution Control Officer
PCU Platinum-Cobalt Unit
PO Permit to Operate
PPE Personal Protective Equipment
STARRT Safety Task Assessment Risk Reduction Talk
STP Sewage Treatment Plant
TSS Total Suspended Solids
WBGEG World Bank General Environmental Guidelines
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Environmental Compliance Audit December 2003 Page i
Executive Summary
Manila Water Company, Inc. (MWCI) commissioned Maunsell to conduct an Environmental Compliance Audit (ECA) for the Manila Second Sewerage Project (MSSP) funded by the World Bank. This ECA was undertaken
as part of MWCI’s compliance to environmental regulatory requirements and fulfilment of conditions of the
MSSP loan package.
The ECA focused on whether:
• MWCI conforms with the conditions of MSSP’s Environmental Compliance Certificate (ECC) and
commitments made in the Environmental Impact Statement (EIS) • MWCI executes MSSP’s Environmental Management and Monitoring Plan
• MWCI implements MSSP in accordance with Philippine Environmental Guidelines, International
Environmental Guidelines, and other relevant laws, policies and regulations.
The table below summarizes the findings of the audit:
Compliance Status
Complied Audit Criteria
Yes No Remarks
MSSP Environmental Compliance Certificate • Project components �� Project implementation is in accordance with the components
as identified in the ECC. Separate ECC’s were secured for community sanitation projects.
• Endorsements, approvals and other pre-construction requirements
�� Endorsements, approvals and permits secured prior to construction.
• Relocation NA There are no settlement issues at the selected project sites. • Construction �� Occupational safety and health guidelines were observed and
mitigation measures as identified in the ECC were implemented.
• Septage management �� Operation of septage in collection, transport and disposal is in accordance with the ECC.
• Monitoring �� Monitoring and reporting were inadequate to meet ECC requirements.
• Training �� Training for engineers and contractors was conducted prior to start of construction activities.
• Environmental liability protection
�� No Environmental Guarantee Fund (EGF) was established.
• Transfer of ownership �� There has been no transfer of ownership to date. STP Environmental Compliance Certificate • Pre-construction/
Construction Phase �� MWCI complied with some requirements although there are
inadequacies in fulfilling requirements on orientation and posting of ECC.
• Operation Phase NA STP’s are still under construction. Environmental Management and Monitoring Plan • Septage collection �� • Septage transport ��
Measures as identified in EMMP are implemented.
• Septage sea disposal NA Sea disposal ceased operation in June 2002. • STP �� Measures as identified in EMMP are implemented.
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Environmental Compliance Audit December 2003 Page ii
Compliance Status Complied Audit Criteria Yes No
Remarks
Sanitation • Submission of plans,
designs, etc. �� No submittal of such documents to Department of Health
(DOH) was made by MWCI. • Septage disposal methods �� No approval was secured from DOH on sea disposal and
land application of septage. Effluent • Effluent quality
�� Parameters such as temperature, pH, oil/grease, heavy metals and BOD within standards. Occasional exceedances were only noted for TSS, COD and total coliform.
• Monitoring �� Effluent monitored weekly. • Permitting �� Permit to Operate (PO) secured for Ayala STP. Solid Waste Management • Solid waste management
program �� MWCI currently implementing company-wide segregation
program. Chemicals and Hazardous Wastes Management • Chemicals management �� Chemical use limited to disinfectants. • Hazardous waste
management �� No hazardous wastes generated from the facility.
Air Quality Management • Emission quality �� Project not a significant source of emission. • Monitoring NA • Control facilities �� Vegetative buffer and odor control pit facility present at Ayala
STP. • Permitting �� No permits were secured for the odor control pit facility and
standby generators. World Bank General Environmental Guidelines • Effluent quality �� Several exceedance with total coliforms were noted. • Air quality �� Project not a significant source of emissions. Vegetative
buffer and odor control pit facility present at Ayala STP. • Solid waste management �� MWCI currently implementing company-wide segregation
program. • Hazardous waste
management �� No hazardous wastes generated from the facility.
• Noise –– No monitoring to assess compliance. • Record-keeping and
reporting �� MWCI still in the process of organizing documents, records,
data, etc. London Convention • Permitting �� Permits secured from the PCG and other endorsements were
secured. • Monitoring �� Monitoring inadequate to assess impacts on water quality and
marine biota. Occupational Health and Safety • Personal protective
equipment (PPE) �� On-site workers provided with PPE.
• Safety training and monitoring
�� Training and safety logging conducted by contractors. Random checks conducted by MWCI.
Agricultural Chemical Use • Permitting �� Permits secured from Fertilizer and Pesticide Authority on
land application of septage
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Environmental Compliance Audit December 2003 Page 1
1.0 Introduction
In February 1997, the Metropolitan Waterworks and Sewerage System (MWSS) was privatised. This resulted in the operation of two concessionaires namely, the Manila Water Company Inc. (MWCI) for the East Zone and
the Maynilad Water Services Inc (MWSI) for the West Zone.
The Manila Second Sewerage Project (MSSP) aims to reduce the environmental pollution and health hazards from untreated wastewater through the improvement of sewerage and sanitation services in Metro Manila. To
implement this project, a USD$36 million loan from the World Bank was secured by the Government of the
Republic of the Philippines through MWSS, MWCI and MWSI.
As part of compliance to environmental regulatory requirements and fulfilment of conditions of the loan
package, MWCI commissioned Maunsell to conduct an Environmental Compliance Audit for the MSSP. This
report documents the findings of the study.
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Environmental Compliance Audit December 2003 Page 2
2.0 Scope and Coverage of the Audit
The first environmental compliance audit for the Manila Second Sewerage Project of Manila Water Company, Inc. covered the East Zone Concession. The components are outlined in Section 4.
This audit focused on compliance within the period of 2002-2003. However, since this is the first environmental
compliance audit, project activities prior to the period of coverage were also referenced in order to obtain a more precise assessment.
The limitations of the audit are as follows:
1. The audit covers only the components of MSSP for the East zone/concession and parts of the ECC
which are applicable to MWCI’s east zone concession. These are identified in the discussion.
2. The audit represents the results of site visits, interviews and data gathered from MWCI records.
3. Compliance issues as per ECC/EMP stipulations relating to the construction phase of the Ayala
Wastewater Treatment Plant Rehabilitation Project were not included in this audit. All rehabilitation
works were completed in October 2001 and April 2003 for Phase 1 and Phase 2, respectively. As such, only the requirements for the operation phase were considered by the audit team.
4. Community Sanitation Projects were only audited for applicable ECC/EMP requirements as the
facilities such as the sewage treatment plants (STPs) are yet to be completed.
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Environmental Compliance Audit December 2003 Page 3
3.0 Methodology
The procedures and techniques adopted for this study is consistent with ASTM Practice E-2107-00 for Environmental Regulatory Compliance Auditing and World Bank Environmental Sourcebook Update No. 11.
The methodology utilized in the study consisted of the following:
• Desk Review and Assessment of Documents
All relevant documents (reports, correspondences, permits, agreements, etc.), which are available at MWCI were reviewed and evaluated. An audit questionnaire was prepared to provide reference to status of the
project, compliance with ECC conditions and EIS commitments as well as compliance with applicable rules,
regulations and other legislation. A checklist of commitments and stipulations relevant to the audit report
was also prepared based on the EIS and ECC.
• Field Survey and Audit Proper
A meeting with MWCI representatives was conducted prior to the site visit for coordination. Site visits were
then undertaken between 14-30 October 2003. The various construction sites of sewage treatment plants were inspected as well as rehabilitation works on the sewer network and septage collection and disposal.
Photodocumentation was undertaken as well as interviews with on-site personnel and contractors’
representatives.
An interview with EMB Central Office and EMB-NCR personnel was scheduled. However, the EMB-NCR
office was in the process of relocating to another site during the scheduled interview, as such, none was
conducted.
The following persons were interviewed:
Name Company
Eva Matibag Manila Water Company Inc.
Ben Velasco Manila Water Company Inc.
Benjie Sacdalan Manila Water Company Inc.
Gilbert Apruebo Manila Water Company Inc.
Val Tanqueco Manila Water Company Inc.
Rolando S. Antonio Safety Engineer, JFE Construction
Cenon Bulatchino Site Manager, JFE Construction
Mon Dolores Manila Water Company Inc.
Dan Gozar Environmental Management Bureau – Central Office
Esperanza Sajul Environmental Management Bureau – Central Office
• Report Preparation
This report details the findings of the study as well as presents recommendations to address potential issues.
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Environmental Compliance Audit December 2003 Page 4
4.0 Manila Second Sewerage Project
4.1 Background
The MSSP was initiated by the Metropolitan Waterworks and Sewerage Systems (MWSS) in 1996 through a
loan with the International Bank for Reconstruction and Development. An Environmental Compliance
Certificate was issued on 10 October 1996. Concurrent with securing this loan, MWSS was privatised in February 1997. This resulted in the creation of two concessions. The East Zone was acquired by the MWCI
and the West Zone by Maynilad Water Services, Inc. The East Zone covers the cities of Quezon, Pasig,
Mandaluyong, San Juan, Pateros, Taguig, Rizal, Marikina, Manila and parts of Makati.
Under the General Conditions of the Loan Agreement, MWSS was required to formulate and implement an
Environmental Management Plan (EMP) and an initial EMP was prepared in January 1996. The Agreement
also required MWSS to implement the project according to appropriate environmental practices (Article III).
On 1 August 1997, MWSS and MWCI entered into a Concession Agreement to operate the system of
waterworks and sewerage services in the East Zone. On 16 March 1998, MWSS and MWCI entered into a
Project Agreement for the management and implementation of the East Zone component of the MSSP. The
agreement also carries the requirement to implement the EMP in a manner satisfactory to the Bank. Subsequently, on 17 March 1998, an Agreement Amending Loan Agreement (AALA) was signed assigning
project components to the concessionaires.
The ultimate objectives of the MSSP are to:
• Reduce the pollution of Metro Manila waterways and Manila Bay;
• Reduce the health hazards associated with human exposure to sewage in Metro Manila; and
• Establish a gradual low-cost improvement of sewerage services in Metro Manila by expanding MWSS’ septage management program.
4.2 Project Status
The MSSP has the following components for the East Service Area: (1) Provision for Septage Management; (2)
Rehabilitation of Sewer Networks; (3) Closed Circuit Television (CCTV) Inspection on Sewer Networks; (4)
Rehabilitation of Ayala Wastewater Treatment Plant; (5) Community Sanitation Projects; (6) Purchase of Laboratory and Maintenance Equipment; and, (7) Consultancy Services. The project is implemented by the
Wastewater Department of MWCI. The status of project implementation is discussed in the following section.
4.2.1 Septage Management
A Barge Loading Station for septage disposal trail has been constructed at Napindan Hydraulic Research
Center in Makati City. Construction of the facility started on 8 May 2000 and was completed on 2 March 2001.
The Barge loading station was designed to accommodate 700 tons of septage to be disposed of at a
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Environmental Compliance Audit December 2003 Page 5
designated sea disposal site. The site for the barge loading station is currently being leased from the
Department of Public Works and Highways. The facility is no longer used as a barge loading station since
MWCI has ceased septage sea disposal on 30 June 2002. Currently, septage and sludge recovered from the wastewater treatment plants and septic tanks from the East Zone, is applied as soil conditioner in lahar areas.
This is discussed in detail in Section 5.2.1. At present, the loading station is used for parking and temporary
storage area for various supplies and materials (Plate 32).
4.2.2 Rehabilitation of Sewer Networks
The rehabilitation works were divided in three phases. The areas covered by this project are as follows:
• Phase 1 – Magallanes Interchange, Makati City
• Phase 2 – Makati City (Forbes Park, San Lorenzo Village and Salcedo Village) and Quezon City
(Mayaman St., Maningning St., Makisig St., Mabuhay St., Sct. Gandia St. and Malvar St.)
• Phase 3 – Makati City (Dasmariñas Village) and Quezon City (Kamuning, South Triangle, Project 2, Project 3, Project 4, Project 6, PhilAm Life Subdivision, Heroes Hill, Malaya Subdivision and Roxas
District)
As of January 2001, Phase 1 and Phase 2 have been completed by MWCI. Construction is still on going for Phase 3 (Plate 1). To date, approximately 75% of the sewer network under Phase 3 have been rehabilitated.
4.2.3 Closed Circuit Television Inspection on Sewer Networks
A van equipped with CCTV unit specifically designed for pipeline inspection was purchased by MWCI in June
2002 (Plate 2). The following sewer networks have been inspected by MWCI:
• Phase 1 – Makati Sewer Network (Legaspi Village, San Lorenzo Village, Ecology Village, Chino Roces Ave., Pasong Tamo Ext., South Super Highway, Magallanes Village, EDSA, Dasmariñas
Village, Forbes Park, Urdaneta Village and Bel -Air Subd.) and Quezon City Network (South Triangle,
East Ave., Malaya Subd., Diliman, Project 1, Project 2, Project 3, Project 4, Project 6, Kamuning,
Heroes Hill and PhilAm Life Subd) • Phase 2 –Quezon City Network (South Triangle, EDSA, Project 4)
Inspection of sewer networks under Phase 1 and 2 were completed in July 2001 and October 2001,
respectively.
4.2.4 Rehabilitation of Ayala Sewage Treatment Plant
The Ayala Sewage Treatment Plant (STP) currently services Legaspi Village, Ecology Village, Chino Roces Avenue, Magallanes Village, Dasmari ñas Village, Forbes Park, Urdaneta Village and Bel-Air Subdivision.
Phase 1 rehabilitation of the Ayala STP started in November 2000 and was completed in October 2001. The
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Environmental Compliance Audit December 2003 Page 6
rehabilitation works include retrofitting of various process units (i.e., sedimentation tanks, aeration tanks, air
blowers, sludge drying beds, dosing facilities, etc.), pump replacements, improvements in the air-blower rooms,
de-clogging operations and repair works on the pipeline. For Phase 2, rehabilitation works commenced in December 2001 and was completed in April 2003. Several equipment, including the existing electrical system,
were replaced. A new odor control facility, automated dissolved oxygen (DO) and 1,000 KVA generator set
facility were also installed at the Ayala STP. Plates 3 – 6 show current conditions onsite.
4.2.5 Community Sanitation Projects
Community sanitation projects (CSP) consist primarily of construction of underground STPs. A total of 24
STPs servicing about 21,000 households are programmed to be constructed within this year and/or first quarter 2004. The location and areas serviced by the various STPs are shown in Figure 3. Selected STP projects,
most of which are located in Makati City, have not been implemented due to design and development issues.
The details and the status of STP projects are summarized in Table 1.
Table 1
Underground Sewage Treatment Plants
Location No. of
Households
Estimated
Capacity
(m3/day)
Remarks
PhilAm Homes, Quezon City 800 6,041 Concreting and steel works
ongoing (Plate 7)
Kalayaan Avenue, Quezon City 1800 4,414 Concreting on going (Plate 8)
Pag-asa BLISS Housing, Quezon City 600 780 Steel works on going (Plate 9)
Sikatuna BLISS Housing, Quezon City 600 609 Steel works on going (Plate 10)
Belarmino CST, Quezon City 800 1,640 Steel works on going (Plate 11)
Visayas Avenue, Quezon City 750 1,050 Existing communal septic tank
being demolished (Plates 12-13)
UP Campus, Quezon City (a) 7,027 Lean concrete laying ongoing (Plate 14)
K1 Karangalan Village, Cainta, Rizal 850 931 Steel works on going (Plate 15)
K2 Karangalan Village, Cainta, Rizal 777 1,193 Concrete curing on going (Plate
16)
K3 Karangalan Village, Cainta, Rizal 961 764 Steel works on going (Plate 17)
K4 Karangalan Village, Pasig City 945 1,265 Excavation works on going
(Plate18)
K5 Karangalan Village, Pasig City 401 577 Steel works on going (Plate 19)
K6 Karangalan Village, Pasig City 318 504 Repair of retaining walls on going
(Plate 20)
K7 Karangalan Village, Pasig City 957 968 No site activities. Construction
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Environmental Compliance Audit December 2003 Page 7
Location No. of
Households
Estimated
Capacity
(m3/day)
Remarks
pending issuance of permit to cut
trees and revised STP design
(Plate 21)
K8 Karangalan Village, Pasig City 742 968 Excavation works on going (Plate
22)
K9 Karangalan Village, Pasig City 588 777 Temporary holding tank
constructed (Plate 23) Caniogan BLISS, Pasig City 144 200 No site activities according to
MWCI.
Guadalupe BLISS, Makati City 760 851 Excavation works on going (Plate
24)
Mandaluyong MRH 180 300 Concreting works on going (Plate
25)
Lakeview Manors, Taguig 458 513 No site activities according to
MWCI.
Maharlika Village MRH, Taguig 420 470 Steel and concreting works on
going (Plate 26)
Centennial Village, Taguig 1,140 2,960 Steel and concreting works on going (Plate 27)
Fortville, Taguig 1,140 1,142 Steel and concreting works on
going (Plate 28)
Bagong Lipunan, Taguig 1,213 1,750 Mobilization and site survey on going (Plate 29).
Diego Silang Village, Taguig 2,880 Rehabilitation works on-going
(Plate 30).
Tejeros BLISS, Makati City Will not be implemented
San Miguel Village, Makati City Will not be implemented
San Lorenzo Village, Makati City Will not be implemented
Kaimitoville, Valle Verde, Pasig City Will not be implemented
Coryville Condominium, Makati City Will not be implemented
Note: (a) for UP Campus only
Part of the CSP is the rehabilitation of existing treatment facilities. Rehabilitation works on the Karangalan Village Lift Stations were completed by MWCI in December 2002. For Pamayanang Diego Silang Sewage
Treatment Plant, the rehabilitation works is yet to commence although the project has been awarded to a
contractor ( Plate 30).
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4.2.6 Laboratory and Maintenance Equipment
Vehicles, machinery and tools needed for the mai ntenance of the sewerage system together with specialized equipment, tools, spare parts and materials for the MWSS laboratory were secured through the MSSP.
4.2.7 Consultancy Support Services
Part of the MSSP funding was allocated for Consultancy Support Services (CSS). The CSS are intended for
the following programs:
• Master planning for sewerage and sanitation projects • Studies and database compilation on septage collection, disposal and treatment
• Environmental impacts monitoring, assessments and reporting of the project
• Preparation of succeeding sewerage development projects
• Development of detailed design packages
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5.0 Audit Findings
This section discusses MWCI’s compliance with ECC conditions, Environmental Management and Monitoring Plan, relevant environmental guidelines and MWCI’s Environmental Policy.
5.1 Compliance With ECC Conditions
In December 1994, MWSS submitted an Environmental Impact Statement (EIS) for MSSP. An ECC was
issued on 10 October 1996 covering the various components of MSSP for the East and We st Zone
concessions. A copy of the ECC for the MSSP project is attached as Annex A. ECCs were also secured for
the construction of each STP. The location of these STPs and ECC details are presented in Annex B.
5.1.1 MSSP
• ECC Condition No. 1 – This Certificate is valid only for the implementation of the Manila Second Sewerage Project (MSSP) that includes the following components:
A. Septage Collection and Septage Sea Disposal;
B. Dagat-Dagatan Pilot Sewage Treatment Plant;
C. Upgrading of the Ayala and Manila Central Sewerage System; D. Strain Drainage Improvement; and
E. Other advanced septage treatment plant in Quezon City, Taguig and other Pasig River adjoining
areas.
Complied with throughout the project implementation period. The components of the project are
implemente d in accordance with this condition. To date, MWCI conducts septage collection but has
ceased septage sea disposal since 30 June 2002. Apart from the Dagat-Dagatan Pilot Sewage Treatment
Plant and Manila Central Sewerage System, all other items are included in the East Zone. Separate ECCs were secured by MWCI for the construction of each STP.
• ECC Condition 2 – Endorsements from the different Local Government Units (LGU) concerned to include
the coastal municipalities of Bataan, Zambales and Cavite shall be secured before project implementation;
Complied. Endorsements from identified LGUs were issued as summarized below:
Office of the Provincial Governor, Bataan 12 January 2000 Office of the Governor, Zambales 20 July 2000
Office of the Governor, Cavite 3 April 2000
Copies of these endorsements were transmitted to EMB on 5 August 2002 as part of the ECC Compliance Monitoring Report (January – March 2002).
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• ECC Condition 3 – The proponent shall closely coordinate with the DPWH regarding the settlem ent of the
ROW, specifically, for the Estero de Vitas; the MMDA regarding the dumping of sludge to San Mateo
Landfill; the LLDA; the BFAR; DOH; EMB and the relevant regional offices of the DENR before and during project implementation;
Complied. The agencies mentioned above are members of the MMT. This is discussed in more detail
under Condition 12. Furthermore, there were no right-of-way issues as there was no relocation required. Also, sludge is not being dumped in the San Mateo Landfill. Dried sludge from the Ayala STP are
collected by individuals and used as fertilizer.
• ECC Condition 4 – Affected families shall be properly informed and consulted before any plan to relocate/resettle them is consummated;
Not applicable as of this audit. According to MWCI, no families were relocated for the East Zone
projects. MWCI selected project sites where there are no existing settlements.
• ECC Condition 5 – An acceptable Relocation Program to include a just and fair compensation scheme for
affected households shall be submitted to the EMB within thirty (30) days upon receipt of the ECC;
Not applicable as of this audit. A Relocation Program was not necessary since there were no families
that required relocation.
• ECC Condition 6 – Measures to mitigate noise, odor and dust/particulates generated during construction and operation of loading stations and other related facilities shall be effected;
Complied. The loading station is no longer operational as a barge loading station. During the use of the
Napindan transfer station, the airtight pipe system conveyed septage from the vacuum tankers to the barge to minimize odor. Currently, it is used as a depot for MWCI vehicles and materials. For other related
facilities such as the Ayala STP, measures are in place to mitigate noise, odor and dust from operational
activities. For STPs under construction, mitigating measures are being implemented to minimize such
impacts. These measures are detailed in the Environmental Management Plan. For operational activities such as septage collection, vacuum tankers with sealed suction hoses are being used.
• ECC Condition 7 – An adequate buffer zone vegetated with appropriate tree species shall be established
at the periphery of the Sewage Treatment Plants (STPs) to be constructed to minimize odor.
Not applicable as of this audit. All STPs are still under construction. The Ayala STP was observed to
have an adequate vegetative buffer (Plates 3 and 6).
• ECC Condition 8 – All cut, stripped and exposed surfaces shall be rehabilitated immediately to minimize
soil erosion and siltation;
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Not applicable as of this audit. As previously noted, construction activities are still on-going at the STP
sites. According to the project contractors, the site will be rehabilitated as necessary. For rehabilitation of sewer networks, excavated sections of the road are immediately restored upon completion of works (Plate
1).
• ECC Condition 9 – Proper collection, storage and transport of septage from septic tanks shall be effected;
Complied. On 30 October 2003, the audit team observed septage collection from a residence along 18 th
Street in Quezon City. Vacuum tankers with sealed suction hoses were used. The team then followed the
tanker to the Philam Sewage Treatment Plant where septage is temporarily stored in the existing Imhoff tanks. During transport, the audit team observed occasional swerving of the tanker on the way to the
Philam Sewage Treatment Plant.
• ECC Condition 10 – Health and sanitation practices shall be observed at all times and protective gadgets/devices shall be provided to workers to avoid accidents and hazards posed by the project;
Complied with as of this audit. As observed during the site reconnaissance, construction workers were
provided with protective gadgets/devices such as hardhats, earplugs and safety shoes (Plate 25). Portable toilet and trash bins are likewise provided on site. Compliance with the Occupational Safety and Health
Standards (OSHS) are further discussed in Section 5.5.1.
• ECC Condition 11 – All septage/effluent shall meet the National Water Quality Standards and shall be disposed of only at the designated disposal sites identified by the Philippine Coast Guard (PCG) in
accordance with the 1972 London Convention on the Prevention of Marine Pollution by Dumping of Waste
and Other Matter;
Complied with within the septage sea disposal operation period. MWCI have ceased septage sea
disposal since 30 June 2002. The one-year trial period amounted to 25,396 cu m of septage disposed to
sea. This was equivalent to about 7,000 septic tanks that have been emptied. During this time, monitoring
of water quality was undertaken at the disposal site as well as the nearby coastal waters. The results of these activities are summarized in Annex C.
Permits and the disposal of septage were coordinated with PCG (Annex D). Compliance with the
provisions of the London Convention is discussed in detail in Section 5.4.2.
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• ECC Condition 12 – A Mutipartite Monitoring Team (MMT) composed of representatives from the BFAR,
LLDA, MMDA, DOH, PCG, DPWH, MWSS, LGU concerned and the affected parties shall be formed within
60 days from the receipt hereof to ensure effective environmental monitoring at all phases of project development/implementation;
Complied. Based on agreements, a MMT was formed in 18 March 2003 to monitor effects of septage sea
disposal in the water. To date, MWCI have not pushed to reconvene the MMT. However, according to the EMB, an MMT is still required even if septage sea disposal is no longer being conducted. The EMB is in
the process of responding to queries sent by MWCI on this matter.
The Memorandum of Agreement (MOA) for the MMT still requires the signature of some invited members. The EMB had stated that the refusal of some members to sign the MOA does not invalidate it since
majority have signed including the DENR Secretary.
• ECC Condition 13 – Regular monthly monitoring of affected water resources to include the coastal waters of Bataan, Zambales and Cavite for biological, physical and chemical parameters including BOD, DO,
turbidity, suspended solids, color, nitrogen, phosphorus, oil/grease, fecal coliforms and total coliforms shall
be undertaken, the results of which shall be submitted to EMB and the relevant DENR Regional Office on a
quarterly basis;
Not complied. Water quality monitoring was conducted during sea disposal activities. However, there is
no documentary evidence to show that this has been submitted to EMB or its regional office on a quarterly
basis.
• ECC Condition 14 – Annual monitoring of marine biota (planktons, algae and important fish species) in
coastal waters and off-shores of Bataan, Zambales and Cavite shall be conducted, the results of which
shall be submitted to the EMB and the DENR Regions III and IV-A;
Not complied. A preliminary study was conducted in October 2002 and this was submitted as part of the
ECC compliance monitoring report to the EMB. However, the report is insufficient to show adequate
compliance to the requirement of the condition since it is explicitly identified as a preliminary study and this was limited to plankton survey. Post-sea disposal monitoring may also be required to ascertain that the
activity did not pose significant impacts to marine biota. Should MWCI opt to cease annual monitoring,
written approval should be secured from the EMB.
• ECC Condition 15 – All other mitigating measures stated in the EIS document, modifications to them and
as approved by the EMB, shall be strictly implemented;
A detailed discussion of compliance with mitigating measures and the EMP is provided in Section 5.2 . Since the issuance of the ECC, the EMP for MSSP has been revised twice. The latest version (September
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1998) was submitted to EMB on July 2003. It is unclear whether the EMB have issued an approval for the
submitted EMP.
• ECC Condition 16 – An Environmental Guarantee Fund (EGF) shall be established by the proponent
through a MOA to cover the cost of monitoring and compensation/rehabilitation for damages by the project;
Not complied with. A MOA to establish the EGF was not formulated.
• ECC Condition 17 – The proponent shall undertake an environmental training for its various project
component contractors and their staff/workers to gain understanding of the rationale for the required
mitigation and monitoring work and to get acquainted with the standard operations and procedures as well as the health and safety measures of pertinent project components;
Complied with. MWCI conducted an environmental awareness training for its engineers and contractors
prior to the start of construction activities. The training highlighted conditions and requirements of the ECC. The minutes of the meeting is presented as Annex E.
• ECC Condition 18 – On-the-spot monitoring and inspection can be initiated by the EMB and/or DENR
NCR/Regions III&IVA anytime in coordination with concerned groups; and
MWCI Compliance Not Required. To date, there have been no on-the-spot monitoring and inspections
conducted by the DENR.
• ECC Condition 19 – Transfer of ownership of this project carries the same conditions in this ECC for
which written notification shall be made within fifteen (15) days from such transfer.
Complied with. There has been transfer of ownership of the project. The MWSS remains the proponent of the MSSP. Under the Concession Agreement between MWSS and MWCI, MWCI shall have
supervisory responsibility for existing projects. This includes supervision, quality control and contract
administration.
5.1.2 STP
MWCI proposed to construct 24 STPs as part of the community sanitation project. This section presents the compliance status of each project relative to ECC conditions and commitments made in the submitted Initial
Environmental Examination (IEE) Reports. The IEE included the following: an Environmental Monitoring
Program, an Environmental Monitoring Plan (EMP) Matrix, and an Environmental Management Plan. Each of
these are discussed in the succeeding sections. The ECCs for the individual STPs are presented as Annex B.
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• Environmental Compliance Certificate
The ECC compl iance status of the STP projects is summarized in Table 2. The key issue identified in the assessment of ECC compliance of the STP projects was the absence of the ECC at the Guadalupe BLISS site.
A number of STP projects identified in Table 1 are no longer going to be implemented due to design and/or
development issues. In compliance with Condition 8 of the ECCs issued for these projects, MWCI shall inform EMB of any abandonment or indefinite work stoppage. This will also prevent the unnecessary issuance of
notices in the future.
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Table 2. ECC Compliance Status of STP Projects
ECC Condition Compliance Status
P1 P2 P3 P4 P5 P6 P7 P8 P9 P10 P11 P12* P13 P14
Pre-Construction and Construction Phase: 1. All amenities/utilities affected shall be immediately restored and rehabilitated NA NA NA NA NA NA NA NA NA NA NA NA NA
2. Conduct orientation for resident engineers and contractor regarding ECC conditions and mitigating measures
�� �� �� �� �� �� �� �� �� �� �� �� ��
3. Billboard bearing the ECC number shall be displayed in a conspicuous location. �� �� �� �� �� �� �� �� �� �� �� ×× ��
Operation Stage:
4. Operational capacity and service coverage of STP NA NA NA NA NA NA NA NA NA NA NA NA NA
5. Adequate maintenance procedures to avoid objectionable odor NA NA NA NA NA NA NA NA NA NA NA NA NA
Others:
6. Implementation of proposed Environmental Management Plan Refer to discussion Section 5.2.3
7. Stoppage of all activities causing adverse impacts and implementation of remedial measures and compensation of aggrieved parties.
NA NA NA NA NA NA NA NA NA NA NA NA NA
8. In case of abandonment or indefinite work stoppage, submit written notification and restore site to original condition or provide safety and protective measures to prevent adverse environmental impacts
NA NA NA NA NA NA NA NA NA NA NA NA NA
9. Restoration of works/grading of exposed grounds shall be immediate undertaken for safety, enhancement and ecological purposes
NA NA NA NA NA NA NA NA NA NA NA NA NA
10. Posting of ECC in a conspicuous place in the Administration Office �� ×× �� �� �� �� �� �� �� NA �� �� �� 11. Implementation of EMP and reporting of monitoring and compliance annually ×× ×× ×× ×× ×× ×× ×× ×× ×× ×× ×× ×× ×× 12. Written notification to DENR-NCR for approval in case of non-compliance of conditions for technical reasons.
NA NA NA NA NA NA NA NA NA NA NA NA NA
13. DENR-NCR inspection and monitoring of ECC conditions without prior notice NA NA NA NA NA NA NA NA NA NA NA NA NA Note: Legend in succeeding page.
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Legend:
Project/Location ECC Number: Date Issued:
P1 Centralized Sewage Treatment Plant, PhilAm Life Homes, West Avenue, Quezon City NCR-2000-12-11-0267-211 2009-274-QC-211 11 December 2000
P2 Construction and Operation of Sewage Treatment Plant, Guadalupe BLISS, JP Rizal St., Bgy Cembo, Makati City
NCR-2000-10-04-0217-120-2008-213-MK-120 04 October 2000
P3 Construction and Operation of Sewage Treatment Plant, PAG -ASA BLISS, Bgy. Bagong Pag-asa, Quezon City
NCR-2000-10-04-0219-120-2008-221-QC-120 4 October 2000
P4 Construction and Operation of Sewage Treatment Plant, Mandaluyong Medium Rise Housing Project, G. Aglipay St., Old Zaniga, Mandaluyong City
NCR-2002-02-22-059-211-2002-01-34-MD-211 22 February 2002
P5 Construction and Operation of Sewage Treatment Plant, Maharlika Bliss-Maharlika Condominium, Lot 4, Blk 10, Maharlika Village, Taguig
NCR-2000-10-04-0216-120-2008-240-TG-120 04 October 2000
P6 Centralized Sewage Treatment Plant, MRB Condominium, Circumferential Road, Brgy. Western Bicutan, Taguig
NCR-2000-12-22-0265-211-2009-267-TG-211 22 December 2000
P7 Centralized Sewage Treatment Plant, Centennial Village, Circumferential Road, Western Bicutan, Taguig NCR-2000-12-11-0268-211-2009-265-TG-211 11 December 2000
P8 Centralized Sewage Treatment Plant, Sikatuna BLISS, Brgy. UP Campus, Quezon City NCR-2000-12-11-0266-211-2009-275-QC-211 11 December 2000
P9 Centralized Sewage Treatment Plant, Kalayaan Avenue (near Kamias St.), Bgy. Malaya, Quezon City NCR-2001-03-22-032-211-2009-283-QC-211 22 March 2001
P10 Construction and Operation of Sewage Treatment Plant, BLC BLISS and Tenement Housing, Bgy. Lower Bicutan, Taguig
NCR-2000-10-04-0215-120-2008-250-TG-120 04 October 2000
P11 Nine Units of Centralized Sewage Treatment Plan, Karangalan Village, Pasig City NCR-2000-02-19-0289-211-2009-284-PS-211 19 February 2001
P12 Lakeview Manors Sewage Treatment Plant NCR-2001-12-21-278-211-2001-04-111-TG-211 21 December 2001
P13 U.P. STP (MWCI to provide copy of ECC)
P14 Barangay Vasra, Visayas Avenue (MWCI to provide copy of ECC)
�� Complied
×× Not complied
NA Not applicable at the time of the audit.
P13* was not audited. According to MWCI, no site activities have been initiated.
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5.1.3 Notice of Violation (NOV)
On 26 July 2002, MWSS was issued a Notice of Violation for Conditions No. 13 and 14 regarding regular
monthly monitoring of coastal waters and submission of quarterly reports to EMB and relevant DENR Regional
Office and annual monitoring and reporting of marine biota in coastal waters, respectively. The NOV also asked MWSS to provide proof of compliance to condition no. 11 (compliance with effluent standards) as
reported by BFAR and PCG.
On 5 August 2002, MWCI submitted to EMB an ECC Compliance Monitoring Report for the period of January-March 2002.
5.2 Compliance With Environmental Management Plan
The EMP for the MSSP have continuously been revised since the ECC was granted. In November 1996,
EMPs for each component were prepared by Original Engineering Consultants Co., Ltd. In association with
DCCD Engineering Corporation. The EMP was submitted to EMB in November 1996.
On 24 September 1998, MWCI prepared an EMP for the east zone concession. This EMP was submitted to
EMB in September 1998. In 2002, the EMP was further revised and more details included. This was
submitted to EMB in July 2002. According to MWCI, there have been no response from EMB regarding approval of the submitted documents.
This section discusses MWCI’s compliance with the 2002 EMP which is divided into four parts as discussed
below.
5.2.1 Septage Collection and Sea Disposal
The environmental management plan for septage collection and sea disposal was obtained from the 1998 version of the revised EMP. At the time of the audit, the mitigating measures for septage collection and
transport were applicable as sea disposal was no longer being undertaken. Assessment of compliance with
the EMP is presented on Table 3.
5.2.2 Upgrading of the Magallanes (Ayala) Sewage Treatment and Network Facility
The EMP for the Ayala STP was applicable for the duration of the construction phase. At the time of the audit,
the Ayala STP had already finished the construction phase and is operational. As such, compliance to the EMP was not assessed.
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Table 3. EMP - Septage Collection, Transport and Disposal
Potential Impact Mitigating Measure Responsibility Schedule Remarks
A. Septage Collection
Noise pollution during
transfer of septage from
septic tank to tanker
Septage collection will be done
during daytime or as agreed
with the local community
MWCI Every desludging
operation
Complied. Septage collection is done according to
schedule by MWCI as part of desludging program or
as requested by customers. These activities are
undertaken during daytime.
Odor emission during
transfer of septage from
septic tank to tanker
Tankers used will be vacuum
tankers and operations will be
kept airtight
MWCI Every desludging
operation
Complied. Vacuum tankers are used in collection of
septage. Odor emission is minimal and confined to
the open septic tank as well as the tanker during
collection.
B. Septage Transport
Vacuum tanker
spillage/accident
• Training of personnel on safe
and proper use of vacuum
tanker and equipment
• Stand-by emergency team
available to address any
tanker accident
MWCI Quarterly training of
personnel. Regular
maintenance of
tankers.
Complied. According to MWCI, performance of
drivers are assessed monthly by the Health and
Safety Committee.
Diesel fume emissions of
vacuum tankers
Regular maintenance and
check-up of vehicles
MWCI Quarterly Complied. Regular maintenance and checks for
emissions are part of requirements of the Land
Transportation Office prior to registration of vehicle.
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Table 3 continued.
Potential Impact Mitigating Measure Responsibility Schedule Remarks
Spillage during transfer of
septage from tanker to barge
• Loading station is equipped
with an automatic shut off
valve to ensure no spillage
will occur during the transfer
• Hypochlorite solution will be
applied to the affected area
MWCI Regular
maintenance of
tankers and barge
equipment
No longer applicable at the time of the audit.
Tanker breakdown An Emergency Team will
always be on standby to
address breakdown of vehicles
and equipment
MWCI Daily operations Complied. An emergency team is available 24-hours
a day to respond to emergencies.
Hazard and Risk to
personnel
Awareness of operators and
truck drivers on health and
safety regulations (eg,
protective gear, etc.)
MWCI Daily operations.
Quarterly training on
safety and health
regulations
Complied. MWCI have a Health and Safety
Committee which conducts training and assesses
compliance to health and safety policies
C. Septage Disposal
Overlading of barge resulting
to barge sinking
Safety check and permit
issued by Philippine Coast
Guard (PCG) before every
barge sailing
MMT, PCG Before every barge
sailing
Sea disposal has been stopped since June 2002.
Based on document review, permits were secured
from the PCG.
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Table 3 continued.
Potential Impact Mitigating Measure Responsibility Schedule Remarks
Adverse impact on the
coastal water quality
• Regular off-shore monitoring
in key areas to determine
impact of dumping on water
quality
• Water quality monitoring at
the disposal site
• Septage quality monitoring
• Strict compliance to dumping
regulations
MMT • Monthly
• Every dumping
• Before every
barge sailing
• Every barge
sailing
Sea disposal has been stopped since June 2002.
Non-compliance to dumping
restrictions
• Provision of Global
Positioning System (GPS)
to barges
• PCG will escort the barge
from the barge station to
the disposal site to ensure
that the barge will dump on
the designated site
MMT, PCG Every barge sailing No longer applicable at the time of the audit.
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Table 3 continued.
Potential Impact Mitigating Measure Responsibility Schedule Remarks
Spillage of barge due to
adverse weather conditions
• No dumping policy on
rainy/stormy months to
ensure safety of the barge
• Regular check up of the
sea worthiness of the barge
MMT, PCG July, August,
September
Before every barge
sailing
No longer applicable at the time of the audit.
Independent auditors will annually assess the environmental compliance of MWSS and MWCI under
MSSP.
This audit fulfils the requirement of the EMP
commitment.
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5.2.3 Sewerage Projects
In the Initial Environmental Examinations Reports submitted for the proposed STP projects, the following were
submitted:
• Environmental Monitoring Program
Based on the Initial Environmental Examination Reports submitted for the STPs, the typical Environmental
Monitoring Program for the STP Projects indicated the following:
Construction Phase: Visual inspection shall be carried out to e nsure that:
§ Construction schedule of high noise activities is followed
§ Construction trucks are washed down prior to departure from site to avoid mud tracks in the area
§ Standing water is avoided to minimize mosquitoes § Dust control measures are implemented
§ Workers have access to toilet facilities on-site
§ Construction materials are stored so as to avoid inconvenience and danger to the locators,
pedestrians and motoring public.
During the site visits, on-site personnel confirmed that these parameters are monitored visually on a daily
basis.
• Environmental Monitoring Plan
The typical Environmental Monitoring Plan (EMP) Matrix (Annex F) for the construction phase covers the
following parameters: ambient air/odor, solid waste, noise, vehicular traffic and labourers/employees. However, the EMP does not specify what are being monitored in these aspects.
• Environmental Management Plan
The typical Environmental Management Plan is presented as Annex G.
For the above environmental monitoring and management plans, these have been consolidated with the MSSP
EMP and are discussed in Section 5.2. Table 4 presents a consolidated EMP.
The findings on the compliance to EMP commitments showed that housekeeping needs to be improved
particularly in the K6, Karangalan Village site. There is also a commitment to formulate a monitoring program.
While there was a typical one submitted along with the IEE, there is a need to improve this. For example, the frequency of monitoring activities are stated as “daily” while the standard references are DENR Administrative
Orders 34 and 35 which require water quality monitoring. MWCI conducts daily process control monitoring as
well as weekly effluent quality monitoring as part of its commitment in the EMP.
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Table 4. Integrated EMP for MSSP and STP projects
Project Activities Impacts Mitigation Measures Responsible
Unit Schedule Guarantees Remarks
A. Pre-Construction/ Construction Phase
1. Site
Preparation
Works
• Clearing
• Fencing
• Accumulation of solid
wastes
• Slight temporary
disturbance due to dust
• Noise
• Solid wastes shall be segregated and
disposed of properly
• Ground shall be sprinkled with water to
minimize dust
• Site development activities shall be
limited during daytime
Project
Contractor
Before
Construction
• Scope of work
of project
contractor
• ECC
Conditions
Two sites were observed
as being prepared for
construction works:
Karanganlan 7 and
Bagong Lipunan BLISS in
Taguig
2. Delivery of
Construction
Materials
• Increased on-site traffic
due to delivery vehicles
• Noise from delivery
vehicles
• Implement traffic management scheme
• Delivery shall be limited during daytime
• Install temporary sound barriers around
the working area
Project
Contractor
During
construction
• Scope of work
of project
contractor
There were no deliveries
observed duri ng the site
visits
3. Excavation, Civil Air Quality
Works,
Finishing,
Commissioning
and Start-up
• General impacts on air
quality/emissions
• Efficient construction planning and work
scheduling
• Provision of properly maintained storage
area for keeping stocks of construction
materials and equipment
• Development and enforcement of strict
health and safety pollution control
regulations specific for the project site
Project
Contractor
During
construction
and testing
• Scope of work
of project
contractor
• ECC
Conditions
K6, Karangalan Village
was identified as requiring
better housekeeping
efforts (Plate 20)
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Table 4 continued.
Project
Activities Impacts Mitigation Measures
Responsible
Unit Schedule Guarantees Remarks
• Temporary disturbance
due to dust
• Ground shall be sprinkled with water to
minimize dust
• Prompt and fast removal of excavated or
dredged spoils from the construction site
• Dust accumulation will also be prevented
through proper washing of vehicles prior
to its departure from the site
• Good housekeeping of workplace and
construction of affected areas
At the time of the audit and
site visit, there was evidence
of increased dust dispersion
from the construction
activities. However, rains
have been sufficient in
minimizing dispersion.
• Air pollution from
vehicle emissions
• Control of vehicle emissions
Vehicles are being
maintained and emissions
tested as required by the
Land Transportation Office
• Noise due to operation
of equipment and use of
construction tools
• Construction activities shall be limited
during daytime
• Equipment shall be provided with mufflers
and noise suppressors
• Provision of personal protective
equipment to all workers
According to on-site
personnel, construction
activities are limited during
daytime with the exception of
concreting which occurs
during the evening due to the
truck ban. However, this is
done with the permission of
residents. PPE were provided
to workers.
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Table 4 continued.
Project Activities Impacts Mitigation Measures Responsible
Unit Schedule Guarantees Remarks
• Odor from workers’
sewage
• Provide temporary toilet facilities for
workers
Temporary toilet facilities
are provided on-site
Water Quality
• Soil erosion • Provide shores and braces to prevent
soil erosion
Shores and braces are
not necessary due to the
terrain and type of
construction being
undertaken
• Water pollution due to
wastewater, oil
leakage/spills
• Provide temporary drain systems and
storage facilities for excavation soils,
fuel and oils needed for equipment
• Cautious and sensible planning for
construction and post-construction
phases of the project
• Provision of routine chemical and oil
spill clean-up plan
• Formulation of a monitoring program
Drain systems are in
place in all construction
sites. At the time of the
audit, there have been no
recorded or reported oil
spills/leaks. However,
there is inadequate
implementation of
monitoring program.
Solid Waste
• Accumulation of solid
wastes
• Solid wastes shall be segregated and
disposed properly
According to on-site
personnel solid wastes
(such as those produced
by workers) are collected
along with the domestic
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Environmental Compliance Audit December 2003 Page 26
Table 4 continued.
Project Activities Impacts Mitigation Measures Responsible
Unit Schedule Guarantees Remarks
solid waste. Construction
wastes are hauled by an
independent contractor
Health and Safety
• Health and safety of
workers
• All operators will be required to fill up
the Safety Task Assessment Risk
Reduction Talk (STARRT) Card before
entering the construction site and before
doing a particular work
The audit team observed
a toolbox meeting where
the STARRT Card was
filled out and health and
safety instructions were
given to workers
B. Operation Phase*
Operations • Accumulation of solid
waste
• Sludge will be stabilized/dewatered and
used as soil conditioner
MWCI Operation
and
Not applicable at the time
of the audit.
• Noise
• STP shall be constructed underground
• Pumps and other equipment shall be
provided with encasement, mufflers and
noise suppressors
maintenance Not applicable at the time
of the audit.
• Wastewater
• The effluent shall conform with DENR
Standards set forth in DENR
Administrative Order 34 and 35 for
Class C waters.
Not applicable at the time
of the audit.
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Environmental Compliance Audit December 2003 Page 27
Table 4 continued.
Project Activities Impacts Mitigation Measures Responsible
Unit Schedule Guarantees Remarks
• Odor
• Provision of odor control mechanisms
(deodorizer/absorbent/masking agent)
to prevent malodorous emissions
• Maintenance of greenbelt zones with
appropriate tree species
Not applicable at the time
of the audit.
• Health and safety of
operators
• All workers will be required to fill up the
Safety Task Assessment Risk
Reduction Talk (STARRT) Card before
entering the site and doing a particular
work.
Not applicable at the time
of the audit.
* EMP items for operations phase are not yet applicable at the time of the audit
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5.3 Compliance With Philippine Environmental Guidelines
The following sections detail MWCI’s compliance with applicable provisions of the Sanitation Code, Effluent
Standards, Ecological Solid Waste Management Act , Toxic Substances and Hazardous and Nuclear Waste
Control Act and Clean Air Act. The audit team focused on these particular guidelines, as these are the most
relevant audit criteria for the project. Related environmental regulations are also included in the compliance assessment.
5.3.1 Sanitation Code
The Implementing Rules and Regulations (IRR) of Chapter XVII of Code on Sanitation of the Philippines (PD
856) provides specific provisions for sewage and excreta collection and disposal system projects. Section 5 of
the IRR, pertains to public sewerage systems. Under this section, the project proponent is required to submit
plans, design and necessary data and specifications to the Office of Secretary of Health or his duly authorized representative for approval prior to start of work. For existing facilities, as-built plans and specifications should
be submitted for review and approval. The manner of disposal of sludge from septic tanks and STPs should
also be approved by the Department of Health (DOH). For a tr eatment plant in operation, as in the case of
Ayala STP, the facility should be approved by DOH and capable of treating sewage to levels meeting DENR effluent standards. The operator should also provide laboratory facilities to conduct control tests and water
quality examinations. Records from such tests including operating data, cases of breakdown and improper
functioning of the treatment facility should be submitted to local health authorities. A registered sanitary
engineer should also manage the facility.
To date, the MWCI coordination with the DOH is limited to meetings with DOH at the Committee for the
Creation of Supplemental Guidelines for PD 856 of which MWCI is a member since 2001. According to MWCI,
DOH is informed of ongoing and new projects during the meetings. For instance, the DOH was informed during such meetings of the septage sea disposal conducted in 2001-2002 and the current land application of
septage. MWCI, however, was not able to provide proceedings or minutes from such meetings to the audit
team.
There were also no submittals of plans, specifications, operating data, etc., for approval or review to the DOH.
According to MWCI, all approvals are sought from the DENR. Results of monitoring and other operating data
are reported through the Pollution Control Officer (PCO) quarterly monitoring reports.
5.3.2 Effluent Standards
Domestic wastewater generated from Metro Manila and primarily discharged to the Pasig River and its
tributaries. Previous studies show that the water quality of Pasig River and its tributaries fall under Class D Waters as described in the DENR Administrative Order No. 34 Series of 1990 (DAO 1990-34, Revised Water
Usage and Classification/Water Quality Criteria). However, there are several projects being implemented by
the local and national government in partnership with private sector and non-governmental organizations
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(NGOs) with the aim of improving Pasig River, including other waterways in Metro Manila, to Class C. As such,
the most often adopted classification is Class C. The prescribed concentration limits for Class C are detailed in
the DENR Administrative Order No. 35 Series of 1990 (DAO 1990-35, Revised Effluent Regulation). Separate concentration limits were given for old/existing industries (OEI) and new/proposed industries (NPI).
For the projects under the East Zone, only the Ayala STP is operational. Treated wastewater is discharged to
Maricaban Creek, at the southern perimeter of the facility. A Permit to Operate (PO) has been secured by MWCI and this is renewed every six months (Annex H). MWCI currently conducts at least once a week
monitoring at the facility. The results of the monitoring are reported on the quarterly PCO reports. Data
generated from the monitoring since the completion of Phase 1 Rehabilitation in December 2001 was provided
by MWCI to the audit team (Annex I). Among the parameters regularly monitored by MWCI in the effluent samples are pH, temperature, dissolved oxygen, BOD, COD, residual chlorine and total and fecal coliform.
Other parameters such as settleable and dissolved solids, solid, color, phenols, oil and grease, surfactants and
selected heavy metals were also occasionally monitored by MWCI. The data were compared to the DAO
1990-35 Standards for Class C Waters for NPI. A summary statistics of the results of the monitoring are shown in Table 5. The limits as given in the World Bank Environmental Guidelines are also shown in the table. This
will be discussed further in Section 5.4.1.
Table 5.
Ayala STP Effluent Quality Analysis
Parameter Minimum Maximum Average Na
DAO 90-35
Effluent
Standard for
Class C
Waters
World Bank
General
Environmental
Guidelines
(WBGEG)
pH 6.94 8.00 7.57 90 6.5-9.0 6-9
Temperature increase, °C 12.4 28.80 20.81 82 3 3
Total Suspended Solids, mg/L 2.0 127.0 12.4 90 70 50
Dissolved Oxygen, mg/L 2.54 7.77 5.24 47 - -
BOD, mg/L 5.00 50.00 24.41 90 50 50
COD, mg/L 4.9 135.2 43.4 90 100 250
Residual Chlorine, mg/L ND 3.25 0.45 87 - 0.2
Total Coliform, MPN/100mL ND 230,000 4862 87 10,000 400
Fecal Coliform, MPN/100mL ND 23000 737 87 - -
Color, PCU 5.0 20.0 8.9 14 150 -
Turbidity, NTU 2.0 430.0 42.4 14 - -
Settleable Solids (1-hr), mg/L 0 0 0 28 0.5 -
Dissolved Solids, mg/L 134.0 332.0 247.9 14 - -
Surfactant (MBAS), mg/L 0.01 0.29 0.12 12 5 -
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Table 5 continued.
Parameter Minimum Maximum Average Na
DAO 90-35
Effluent
Standard for
Class C
Waters
World Bank
General
Environmental
Guidelines
(WBGEG)
Oil and Grease, mg/L 0.1 5.0 3.1 22 5 10
Phenols, mg/L ND ND ND 7 0.1 0.5
Cadmium, mg/L ND ND ND 13 0.05 0.1
Copper, mg/L ND 0.238 0.024 13 - 0.5
Chromium6+, mg/L ND 0.008 0.001 10 0.1 0.1
Iron, mg/L ND 0.558 0.170 13 - 3.5
Lead, mg/L ND ND ND 13 0.3 0.1
Manganese, mg/L ND 0.120 0.046 13 - -
Zinc, mg/L ND 55.48 4.36 13 - 2.0 Note: Compliance with World Bank Environmental Guidelines discussed in Section 5.4.1. 1 N = Number of monitoring data.
Based on the monitoring data, there have been very few instances where the results of the analysis exceed the
DAO 90-35 standards. Parameters such as pH, temperature, BOD, color, settleable solids, phenols and heavy metals were within the prescribed limit. Exceedance were only noted for such parameters as total suspended
solids (TSS), chemical oxygen demand (COD) and total coliform. TSS exceeded standards on 18 July 2002
and 6 November 2002. For COD, the level exceeded the standard on 10 July 2002. In the case of total
coliform, exceedances were noted on 12 December 2001 and on 12, 20 and 26 March 2002, with levels ranging from 23,000 MPN/100 ml to 230,000 MPN/100 ml.
5.3.3 Ecological Solid Waste Management Act
The Ecological Solid Waste Management Act (RA 9003) and its IRR (DAO 2001-34) provides for state policy
on the adoption of systematic, comprehensive and ecological solid waste management system. The Act also
emphasizes waste minimization at source through recycling, re-use, recovery and composting. Although the
RA 9003 retains primary enforcement and responsibility with local government in solid waste management, it encourages greater private sector participation.
Solid wastes, as covered by RA 9003, include discarded household wastes, commercial wastes, non-
hazardous institutional and industrial wastes, street sweepings, construction debris, agricultural wastes and other non-hazardous/non-toxic solid was tes. Septage sludge/solids are not included in this list.
Section 21, Article 2 of RA 9003, requires the segregation of wastes at the source. The waste should be
segregated prior to collection according to waste type by providing, at the minimum, on-site collection containers labelled as compostable, non-recyclable, special wastes, etc. According to MWCI, it is currently
implementing a company-wide program on waste segregation. Compliance to this program is checked by
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MWCI’s Committee on Health and Safety on a per facility basis. The committee conducts random inspection
and good performance on safety and cleanliness. During the site survey, the audit team was not able to
confirm on-site segregation.
Solid wastes generated at the Ayala STP includes refuse generated from grit separators and domestic wastes.
According to MWCI these are hauled and disposed off-site by a contractor. At the construction sites domestic
solid wastes and construction debris are also disposed in the same manner. Excess excavated soil is also hauled off-site and according to the contractors, this is used as fill material in other construction sites.
5.3.4 Toxic Substances and Hazardous and Nuclear Wastes Control Act
RA 6969 otherwise known as the Toxic Substances and Hazardous and Nuclear Wastes Control Act of 1990
provides for the rules and regulation for management of chemicals, hazardous wastes and nuclear wastes. RA
6969 and its IRR (DAO 1992-29) covers the importation, manufacture, processing, sale distribution, use and
disposal of chemical substances and mixtures that present unreasonable risk/or injury to the health or the environment.
Chemical use at the Ayala STP is limited to sodium hypochlorite. This is used as disinfectant for the
wastewater prior to discharge. Sodium hypochlorite is listed on the Philippine Inventory of Chemicals and Chemical Substances (PICCS). Under Section 16 of Title II of DAO 92-29, users of substances included in the
PICCS are not required to secure clearance from the DENR.
There are also no known hazardous wastes generated from the facility. Based on the provisions of Section 25 of Title III of DAO 92-29, septic tank effluent and associated sullage wastewaters are not classified as
hazardous wastes. In addition to this, a certification was secured from the DENR declaring that the waste
generated from the facility is not considered hazardous (Annex J).
5.3.5 Clean Air Act
The Clean Air Act (CAA), RA 8749 and its IRR, DENR Administrative Order No. 2000-81, provides for a
comprehensive and integrated approach on managing air quality and protecting the public health. The Clean Air Act also provides specific guidelines and permit requirements for stationary and emission control for mobile
sources (i.e., motor vehicles).
In terms of production of air pollutants, the wastewater treatment facilities are not seen as significant source of emissions such as SOX, NOX, CO and particulates. The facilities, however, generate noxious odor due to
aerobic and aerobic digestion of wastewater and septic sludge. At the Ayala STP, an Odor Pit Control Facility
has been in installed to reduce the odor generated from the wastewater (Plate 4). According to MWCI, the
STPs under construction are designed to limit odor. For noise generating equipment such as blowers and standby generators, these were equipped with mufflers and silencers.
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There are no specific monitoring requirements set by the DENR for the project. At present, monitoring for
Ayala STP are performed through the Customer Benchmark Monitoring System wherein facility operators
check out complaints of foul odor from nearby residential areas. In spite of the presence of vegetation buffer and the odor pit facility at the Ayala STP, there have been previous complaints of odor. MWCI procedure is to
immediately address such complaints by visiting the area where the complaint originated and validate the odor
emission. According to MWCI, complaints are isolated and unsubstantiated.
At the construction sites, no noise monitoring is conducted on-site. However, complaints from residents and
homeowners are handled by the contractors. To limit disturbance, construction activities are scheduled during
the day and may extend only up to 9:00 p.m.
For the vacuum tankers, emission testing is conducted yearly in compliance with the requirements of the Clean
Air Act. The tankers are sent to Land Transportation Office (LTO) accredited emission testing centers.
According to MWCI, all vacuum tankers are equipped with exhaust mufflers.
Part of the requirements under the CAA is that the owner or operator should secure an Authority to Construct
(AC) and Permit to Operate (PO) for fuel burning equipment and other emission source installations and control
facilities. For the Ayala STP, there were no POs secured for standby generators and odor pit control from the
DENR.
5.4 Compliance With International Environmental Guidelines
The implementation of the MSSP were also audited as per compliance with the World Bank Environmental
Guidelines and the London Convention. Projects funded by the World Bank should comply with World Bank
Environmental Guidelines, which emphasize resource consumption minimization and elimination or reduction
of pollutants from the source. The London Convention, to which the Philippines is a party to the agreement, provides guidelines on sea disposal of wastes.
5.4.1 World Bank Environmental Guidelines
As there are no specific environmental guidelines for water and sewerage infrastructure projects, the World
Bank General Environmental Guidelines (WBGEG) contained in the Pollution Prevention and Abatement
Handbook was referenced. The WBGEG provides requirements for liquid effluent, air emissions, noise, solid
wastes, hazardous wastes, record-keeping and reporting.
The WBGEG limits for effluents are applicable for process wastewater, domestic sewage and contaminated
stormwater. Effluent monitoring at the Ayala STP is in accordance with the monitoring requirements of
WBGEG. As shown on Table 5 in Section 5.3.2, the WBGEG limits for TSS and total coliform are more stringent than that of the DAO 1900-35 Standard for Class C waters. The limit for TSS and total coliform under
WBGEG are 50 mg/L and 400 MPN/100 ml, respectively while the limit under the DAO 1990-35 are 70 mg/L
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and 10,000 MPN/100 ml. As such, exceedances were only noted for these parameters. Based on the results
of monitoring from December 2001 to present, there have been only two instances where TSS levels exceed
the standards. However, about a fourth of the monitoring results show exceedance with the WBGEG total coliform limit.
As noted in Section 5.3.5, there is no actual monitoring on ambient air quality and noise. There were no
significant issues in solid wastes and hazardous wastes management.
In terms of record-keeping and reporting, there is a need for MWCI to improve management of monitoring data
and documents submitted to public offices especially regulatory entities. Some of the supporting documents
were not readily available. At the time of the audit, MWCI was in the process of organizing records, documents and monitoring data relating to the implementation of MSSP.
5.4.2 London Convention
The London Convention on the Prevention of Marine Pollution by Dumping of Wastes and Other Matter of 1972
is a legally binding international agreement controlling the deliberate dumping of non-ship generated wastes at
sea. Under the agreement, disposal of certain wastes are prohibited while others are permitted through
issuance of special or general permit depending on the characteristics and composition of the waste. The 1996 Protocol to the London Convention provides guidelines for waste characterization, site selection, impacts
assessment, field assessment, permit requirements and compliance monitoring. Specific guidelines for the
assessment of sewage sludge have been formulated.
Prior to the operation of the sea disposal, an Environmental Impact Assessment (EIA) has been undertaken.
The selected disposal site is located at South China Sea, around 40 km southeast of Mariveles Bataan.
Endorsements were secured from the province of Bataan, Zambales and Cavite.
Under the London Convention, contracting parties should designate an appropriate authority to issue permit
and perform record-keeping and monitoring of sea disposal of wastes. The Philippine Coast Guard (PCG) is
mandated to do such task by virtue of Presidential Decree 979 (PD 979), otherwise known as the Marine
Pollution Decree of 1976. According to MWCI, disposal of septage were coordinated with the Philippine Coast Guard (PCG). Prior to disposal, permits were secured from the PCG. Copies of the permits issued to MWCI
are presented in Annex D.
Septage sea disposal were conducted from May 2001 to June 2002 except during rainy/stormy months (July, August and September). During the one-year trial period, a total amount of 25,396 cu m of septage have been
disposed to the sea, equivalent to 7,000 emptied septic tanks. As part of its compliance with the ECC, monthly
water quality monitoring were conducted on occasions when sea disposal were performed. These were
conducted at five designated coastal stations and sampling stations at the dumpsite and control areas. Water quality samples were analyzed for BOD, DO, turbidity, suspended solids, color, nitrogen, phosphorus, oil
/grease, fecal total col iforms and heavy metals. Based on the records provided by MWCI, not all the stations
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Environmental Compliance Audit December 2003 Page 34
were covered through the monitoring period. For the water quality monitoring, trend and statistical analysis
were not performed. As such, there were no conclusions of significance on the impact of septage sea disposal
were derived from the monitoring.
MWCI were also required under the ECC to conduct an annual marine biota monitoring, focusing on plankton,
algae and important fish species at the coastal stations. In Oct ober 2002, a preliminary plankton survey was
completed. The survey is limited to taxonomic identification and estimation of biomass values. As with the water quality monitoring, the study is inconclusive.
Results of the monitoring were submitted both to DENR and PCG. Compliance monitoring was primarily
performed by the DENR, through the assessment of MWCI’s compliance with ECC requirements.
As noted in previous sections, MWCI has ceased septage sea disposal and has since shifted to land
application of septage.
5.5 Compliance with Other Relevant Guidelines
Based on the current project implementation program of MSSP, the project activities were also assessed for compliance with Occupational Safety and Health Standards (OSHS) and regulations on agriculture chemical
use. These are detailed in the following sections.
5.5.1 Occupational Safety and Health Standards
Employers are required to implement the Occupational Safety and Health Standards (OSHS) at the work place
as part of compliance with the Labor Code of the Philippines (PD 442) and its Implementing Rules and
Regulations. The OSHS are compulsory rules on occupational safety and health safeguarding workers against the risks of injury, sickness or death through safe and healthful working conditions.
Currentl y, MWCI is actively involved in ensuring workers’ safety at the MSSP project sites. MWCI conducts
random safety checks and requires contractors to submit daily progress and safety reports. According to MWCI, penalty is given to contractors with lapses in regards to health and safety provisions. The penalties are
explicitly expressed under the terms of the each contract signed by MWCI and the contractors.
As noted in Section 5.1.1, appropriate PPE such as hard hats, safety shoes and hearing protection were provided to site workers. Construction sites were also properly cordoned and appropriate signages were
posted (Plates 15, 16 and 25). Health and safety guidelines and procedures are also conspicuously posted
within the site project office. At the different project sites, safety engineers are on hand providing supervision
and monitoring along with safety briefing prior to start of construction activities. The contractors also maintain a safety log as part of their internal monitoring. To date, none of the contractors has logged an instance of major
incident or accident at the MSSP project sites.
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5.5.2 Agriculture Chemicals Regulations
By virtue of Presidential Decree 1144 (PD 1144) the Fertilizer and Pesticide Authority was created in 1977.
The mandate of FPA is to protect the public from risks inherent in the use of agricultural chemicals.
Since 2000, MWCI has collaborated with Central Luzon Sugarcane Research Institute on research on land application of biosolids. The field trials were conducted in lahar -affected areas in Porac, Pampanga. In 2001,
researchers from CLSRI were able to establish optimum applications for of the septage on lahar soil. Pilot
tests have been conducted by CLSRI. To date, CLSRI is in the process of performing technology transfer to
the farmers. Since MWCI shifted to this type of septage disposal method, approximately 26,000 m3 of septage have been applied to the lahar affected areas in Pampanga. A permit has been secured from the FPA for the
land application of septage (Annex K).
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6.0 Conclusion and Recommendation
6.1 Conclusion
The findings of first environmental compliance audit for MSSP showed the need to address details of
commitments made in the Environmental Impact Statement, Environmental Management Plans and
Environmental Compliance Certificate. While there have been efforts to comply with conditions and stipulations, these are inadequate to state that there has been full compliance. Some of these findings pertain
to the required implementation of monitoring activities and the need to submit reports of such activities to the
EMB.
Specifically, the following conditions were not complied with: Condition 13 which requires monthly monitoring of
affected water resources and submission of results to EMB on a quarterly basis; Condition 14 which requires
the annual monitoring of marine biota and submission of results to EMB; Condition 16 which requires the
establishment of an Environmental Guarantee Fund; and Condition 14 which requires training of engineers and contractors on the ECC conditions, EMP measures and EIS commitments. For the STP projects which are no
longer to be implemented, MWCI should inform EMB in writing as this is required under Condition 8 of the
ECCs.
For the EMP, housekeeping needs to be improved in K6, Karangalan Village. The key issue with EMP
compliance is the implementation of the monitoring program. Review of the submitted EMP for the STP
projects showed that there is a need to clearly define parameters and sampling frequencies.
On other environmental guidelines, the requirement to submit plans and specifications for approval and review
by the DOH was not done. For effluent standards, there have been occasional exceedance with prescribed
standards. Furthermore, the Ayala Wastewater Treatment Plant was found without a Permit to Operate or the
air pollution sources and control facilities from the EMB as required by the Clean Air Act.
It is also concluded that records keeping management is insufficient to handle the volume of data and reports
generated by the project. Considering the numerous components of the project, there is a need to implement a
more systematic way of managing such documents and data. 6.2 Recommendations
The following recommendations are made:
• On the ECC, clarify issues with EMB regarding compliance with conditions such as the establishment
of the EGF; • Should MWCI propose to amend the EMP or any part thereof, written notification and approval has to
be secured from the EMB; • For the STP projects which were not implemented (such as San Miguel Village, San Lorenzo Village,
Kaimitoville, and Coryville Condominium) it is recommended that EMB -NCR be formally informed
through written correspondence that MWCI have decided not to implement the above.
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• Maintain copies of correspondence with EMB which contain evidence of receipt and transmittal. • In line with efforts to improve environmental performance, MWCI should implement more stringent
waste disposal procedures.
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7.0 References
American Society for Testing and Materials. 2000. ASTM Practice E-2107-00 Environmental Regulatory Compliance Auditing.
Department of Health. 1995. Implementing Rules and Regulations of Chapter XVII -“Sewage Collection and
Disposal, Excreta Disposal and Drainage” of the Code on Sanitation of the Philippines (PD 856).
Department of Environment and Natural Resources. 2000. Implementing Rules and Regulations of Clean Air
Act (RA 8749).
Department of Labor and Employment. 1990. Primer on the Occupational Safety and Health Standards.
Bureau of Working Conditions, Manila.
Internati onal Maritime Organization. 1972. London Convention on the Prevention of Marine Pollution by Dumping of Wastes and Other Matter.
Manila Water Company Inc. 2002. Manila Second Sewerage Project IBRD 4019, Environmental Compliance
Report First Quarter 2002.
Manila Water Company, Inc. 2002. Manila Second Sewerage Project IBRD 4019, Environmental Compliance
Report 2nd Quarter 2002, 3rd Quarter 2002.
Manila Water Company, Inc. September 2003. Manila Second Sewerage Project (IBRD Loan No. 4019-PH)
Progress Report No. 10.
Presidential Decree 442. Marine Pollution Prevention Decree of 1976.
Presidential Decree 1144. Decree Creating the Fertilizer and Pesticide Authority and Abolishing the Fertilizer
and Pesticide Authoriy and Abolishing the Fertilizer Industry Authority of 1977.
Republic Act 6969. Toxic Substances and Hazardous and Nuclear Waste Management Act of 1990.
Republic Act 8749. Clean Air Act of 1999.
Republic Act 9003. Ecological Solid Waste Management Act of 2000.
World Bank. 1995. Environmental Auditing – Environmental Assessment Source Book Update No. 11.
Environmental Department. Washington D.C.
World Bank. 1998. Pollution Abatement and Control Handbook. Was hington D.C.