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Preparation for PCB Management and Disposal Demonstration Project in Vietnam – CS6 “Environmental Impact Assessment” Environmental and Social Framework Report Vietnam Electricity (EVN)

11/004382 Final Report September 2008

Vietnam Electricity 18 Tran Nguyen Han Street Hanoi VIETNAM

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CONTENT CONTENT....................................................................................................................................I

LIST OF FIGURES ....................................................................................................................III

LIST OF TABLES......................................................................................................................... V

EXECUTIVE SUMMARY ...............................................................................................................I

1 CONTEXT, SCOPE AND OBJECTIVES ................................................................................ 1

2 POLICY ASSESSMENT WITH RESPECT TO PCB MANAGEMENT AND DISPOSAL .............. 3

3 IMPACT ASSESSMENT PROCEDURE............................................................................... 10

4 PROJECT DESCRIPTION................................................................................................. 29

5 ANALYSIS OF POTENTIAL IMPACTS (SCOPING) ........................................................... 49

6 ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT METHODOLOGY....................... 57

7 COMPARISON OF ALTERNATIVES.................................................................................. 77

8 ENVIRONMENTAL AND SOCIAL MANAGEMENT AND MONITORING PLAN .................... 79

9 RESULTS PUBLIC CONSULTATION MEETINGS............................................................. 101

10 KNOWLEDGE GAPS AND UNCERTAINTIES IN ASSESSMENT ....................................... 110

11 REFERENCES ................................................................................................................ 111

APPENDICES ......................................................................................................................... 113

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LIST OF FIGURES Figure 2-1: Flow chart public stakeholders involved directly in PCB management at local and national levels (VRXUFH: ECD, 2008)..............................................................................................................5

Figure 3-1 World Bank Environmental Assessment requirements versus project cycle ..........................12

Figure 3-2: Selection of Social Analysis Study Methods and Tools ......................................................16

Figure 3-3: Presentation of EIA approval procedure .........................................................................21

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LIST OF TABLES Table 2-1: Overview of authorities involved in the different aspects of the PCB lifecycle .........................4

Table 3-1: Guidance on screening procedure and disciplines covered in site specific impact assessments on PCB management, disposal and remediation ..............................................................................25

Table 4-1: Matrix of pre-treatment and treatment techniques ...........................................................37

Table 5-1: Scoping for potential impacts related to presence, management, transportation and storage of PCB containing materials ..............................................................................................................50

Table 5-2: Scoping for potential impacts related to treatment, disposal and site remediation. ...............52

Table 6-1: Standards and guidelines for air quality (WHO, 2000, TCVN 5937,2005).............................62

Table 6-2: Guideline values for community noise in specific environments (WHO, 1995) ......................63

Table 6-3: Emission factors for PCB emissions (Annema et al, 1995)..................................................65

Table 6-4: Emission factors for traffic and construction activities (g/km) (USEPA, 1995).......................65

Table 6-5: Sound power levels LW for different noise sounds............................................................66

Table 6-6: Assessment criteria relevant for soil................................................................................69

Table 6-7: Assessment criteria relevant for groundwater ..................................................................70

Table 6-8: Water quality standards and guidelines...........................................................................72

Table 6-9: Industrial waste water: Vietnamese limits of Parameters and Maximum Allowable Concentrations of Pollutants..........................................................................................................72

Table 6-10: Geometric mean values for the 50 % effect concentration (L(E)C50), for the lowest observed effect concentration (LOEC) for the No Observed effect concentration (NOEC) for PCBs in the aquatic environment (Callebaut and Vanhaecke, 2000)................................................................................75

Table 6-11: PCB standards and guidelines related to human health ........Error! Bookmark not defined.

Table 8-1: Overview of typical mitigation measures and monitoring for activities related to PCB management...............................................................................................................................85

Table 8-2 Overview of typical mitigation measures and monitoring related to PCB treatment and disposal.................................................................................................................................................95

Table 9-1: Public Consultation During The EA Process .................................................................... 102

Table 11-1: Policy Needs Assessment - Summary Table (Breeze and Associates, 2007a).................... 135

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LIST OF ABREVIATIONS BCD Base catalysed decomposition process BOD Biological Oxigen Demand CO Carbon Monoxide CO2 Carbon Dioxide COD Chemical Oxigen Demand CV Civil servant in charge of environmental protection DIONRE Division of Natural Resources and Environment DoC Department of Construction DOH Department of Health DOIT Department of Industry and Trade DOLISA Department of Labor, Invalid and Social DoNRE Departments of Natural Resources and Environment DOPS Department of Public and Security DOST Department of Science and Technology DTPW Department of Transportation and Public Works EA Environmental Assessment EF Emission Factor EIA Environmental Impact Assessment EMP Environmental management plan EPC Environmental Protection Commitment EPD Environment Police Department ESMP Environmental and Social Management Plan EVN Vietnam Electricity GEF Global Environmental Facility GDOC General Department of Customs GPCR Gas Phase Chemical Reduction HW hazardous waste IA Impact Assessment KOC Partition coefficient octanol-water LEC50 50% effect concentration LEP Law on Environmental Protection LOEC Lowest observed effect concentration LTTD Low temperature thermal desorption LW Sound power level MoC Ministry of Construction MoH Ministry of Health MOIT Ministry of Industry and Trade MOLISA Ministry of Labor, Invalid and Social MoNRE Ministry of Natural Resources and Environment MOPS Ministry of Public and Security MoST Ministry of Science and Technology MoSTE Ministry of Science, Technology and Environment MoTr Ministry of Transportation N Nitrogen NIP National Implementation Plan Stockholm Convention NOEC No observed effect concentration NOx Nitrogen oxides NSEP National Strategy for Environmental Protection P Phosphor

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PCB Polychlorinated Biphenyl PCDD Polychlorinated Dibenzodioxins PCDF Polychlorinated Dibenzofurans PCE Perchloroethylene PEL Permissible exposure limit PM10 Particulate Matter of 10 Microns in diameter or smaller POP Persistent Organic Pollutant PPC Provincial People’s Committee SA Social Assessment SO2 Sulfur dioxide SS Suspended Solids SVE Soil Vapour Extraction SW Solubility coefficient in water TCB Trichlorobenzene TEF Toxic Equivalent Factor TEQ Toxicity Equivalent TiO2 Titanium Dioxide TLV Tolerance Limit Value TSP Total Suspended Particles VEA Vietnam Environment Administration WAO Wet air oxidation WB World Bank WHO World Health Organisation

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EXECUTIVE SUMMARY The last decades Vietnam has experienced a rapid industrialisation and a very important economic development. This has resulted in the generation of an increasing amount of industrial waste including hazardous and toxic waste. In particular POPs, including PCBs, create a hazard for human health and for environmental safety. In Vietnam, the presence of PCBs in the environment is resulting from the import of dielectric fluids contained in transformers, capacitors and other electrical equipment. Being aware of the risks to human health and ecosystems, Vietnam ratified the Stockholm Convention in July 2002, committing to reduce and eventually eliminate 12 POPs, including PCBs. Under this convention, Vietnam is bound to phase out the use of equipment containing PCBs by 2020 and to treat the contained PCBs by 2028. The Ministry of Natural Resources and Environment (MONRE) is the leading agency overseeing the preparation and the implementation of the countries National Implementation Plan for the Stockholm Convention. Within MONRE, Vietnam Environment Administration (VEA) has been designated as the agency to implement POP activities. At present Vietnam does not have a functioning system to safely transport and store PCB containing materials. Neither is there adequate treatment and disposal potential. Major progress has to be made to achieve the goals set forward by the Stockholm Convention and as such to minimize the risks for human health and environment. Within this framework the PCB management demonstration project has been developed, supported by the World Bank and the Global Environment Facility. The project aims to assist Vietnam to establish a sound PCB management system that would minimize potential environmental and health risks from unmanaged PCB oils and equipment. This would entail significant investment in PCB management infrastructure and strengthening of limited technical and management capacity of all key stakeholders including the public and private sectors in Vietnam. The project will develop a National Action Plan for Sound PCB Management and initiate implementation of the first phase of the Action Plan. It is obvious that this project, aiming at better PCB management of PCB equipment and wastes, will ultimately generate positive environmental and social impacts. Improper management of PCBs could however lead to negative environmental and social impacts and therefore is subject to an environmental and social impact assessment. The objective of this EA and SA framework report is to prepare an environmental and social assessment framework to assess all potential environmental and social impacts associated with the activities of the PCB project on the one hand and to identify proper measures to mitigate such impacts on the other hand; this framework covers the full spectrum of PCB management and disposal issues including transportation and storage, treatment, disposal or recycling and site remediation. It is intended to allow a better management of PCBs taking into account all environmental and social/human health issues. Next to this it should be a reliable framework for the preparation of project EIAs necessary for specific PCB management projects in Vietnam. PCB management activities with potential environmental and social impacts are diverse and include: • identification of PCB-containing products and equipment; • testing PCB content of products and oils; • labelling of PCB-free and PCB-containing equipment and waste; • packaging and collection of PCB-waste; • transportation of PCB-waste; • temporary storage of PCB-waste; • recycling.


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A scoping of potential impacts related to PCB management is summarised in the table below.

Table 1: Potential impacts related to PCB management

Impact Presence of PCB containing materials

Testing equipment

Handling oils, materials and waste (packaging, labelling)

Replacement, retro filling, recycling

Temporary (final) storage

Transpor-tation

Water and aquatic resources Groundwater contamination

X (X) X X X (X)

Surface water contamination

X (X) (X) X X (X)

Soil and waste Soil contamination X (X) X X X (X) Waste production X X x Climate, air and noise Air emissions of POPs

X X (X)

Dust formation (X) (X) Noise production (X) Ecosystems Loss of ecological valuable areas

X (X)

Ecotoxicity to terrestrial life

X X X X

Ecotoxicity to aquatic life

X (X) X X

Land use Land use change X Losses of sites with archaeological, historical and cultural value

X

Man and his social economic living environment Direct health risks (direct exposure)

X (X) X X X (X)

Indirect health risk X X X X Nuisance (dust, noise)

(X)

Social effects (resettlement)

X X X

Social effects (employment)

X (X)

X Potential environmental impact


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(X) Potential environmental impact not likely to occur PCB treatment and disposal activities have potential environmental and social impacts as well. Only treatment techniques likely to be applied in Vietnam are described in this framework report. Other techniques will not be subject to EIA in Vietnam. The following techniques are covered:

• pre-treatment techniques: - dewatering, - electrical equipment disassembly, - shredding, - screening, - oil/water separation, - pH adjustment, - low temperature thermal desorption, - solvent washing, - adsorption/absorption;

• alkali reduction including sodium; • base catalysed decomposition process; • gas phase chemical reduction; • cement kiln co-processing; • plasma arc decomposition; • wet air oxidation; • site remediation techniques:

- soil washing, - thermally enhanced soil vapour extraction, - soil flushing, - in situ vitrification, - TiO2 enhanced photocatalysis.

A scoping of potential impacts related to PCB management is summarised in Table 2.


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Table 2: Potential impacts of PCB treatment and site remediation

Impact Reduction destruction method

Oxidation treatment

Combustion/ incineration

Site Remediation

Water and aquatic resources Groundwater contamination (ground)water use

X X

(X) X

X X

Surface water contamination X X X X Soil and waste Soil contamination, X (X) X Waste production (X) X X (X) Climate air and noise Air emissions X X X X Dust formation (X) (X) X (X) Noise production X X X (X) Smell (X) X X Ecosystems Loss of ecol. valuable areas X (X) X Ecotoxicity to terrestrial life X X X (X) Ecotoxicity to aquatic life X X X X Land use Land use change X (X) X (X) Landscape alteration X X X Losses of sites with archaeological, historical and cultural value

(X) (X) X

Man and his social economic living environment

Direct health risks (direct exposure) X X X (X) Indirect health risk X X X (X) Nuisance (noise, visual effects, traffic,…)

X X X (X)

Social effects (resettlement) (X) (X) X Social effects (economic/employment) (X) X X Social effects (transport) X X X Social effects (use of resources) (X) X X (X)

X Potential environmental impact (X) Potential environmental impact not likely to occur Several projects, planned and implemented in the framework of the overall PCB management program, will be subject to environmental and social impact assessment. Methodology and an overview of information needed to prepare an EIA are discussed below. A profound project description is the first essential part of an EIA. It comprises the following components:

• General description of the project in the study area:


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- A geographical map (at least 1/10 000) showing the exact location of the project and the exact project area,

- A general description of the surroundings of the project, - A description and map of the topography of the surroundings, - The administrative situation (owner, available permits), - The on-site infrastructure proposed;

• Description of the pre-construction and construction phase: - An overview of the different phases and the timing for the project, - A description of the consecutive activities during construction:

∼ preparation works i.e. excavation, pumping of groundwater, removal of soil, ∼ building activities, ∼ transport needs for the construction, ∼ development of temporary settlements,

- The use of resources and waste production to be expected; • Description of the RSHUDWLRQDO�SKDVH�LQFOXGLQJ�WKH�DFWXDO�SHUIRUPDQFH�RI�WKH�SODQW:

- Description of the PCB containing equipment to be managed or treated (kind of equipment, volume of PCB content, type and concentration of PCB’s),

- Description of historic experiences concerning the PCB equipment: leakages, other accidents,

- Description of the operations and handling foreseen on the location (i.e. sampling, labelling, packaging, recycling, retro filling) and description of the way the operations will be carried out,,

- Description of the (preventive) measures already foreseen to prevent pollution - Description of the way transport will be carried out: type of trucks, packaging, preventive

measures foreseen, quantity to be transported, - Description of the storage facilities: type of construction, storage conditions, preventive

measures foreseen, quantity to be stored, packaging, - Description of the pre treatment techniques used: process description, capacity foreseen

per day and per year, operation time schedule, acceptation procedure for PCB equipment,

- Description of the treatment and/or disposal techniques: process description, treatment/disposal capacity, regime (continuous flow versus batch), operation time, acceptance procedure,

- Presence of groundwater extraction on site and in the immediate surroundings (number of wells, depth of extraction well, results regarding water quality, capacity, …),

- Kind of surface covering, presences of impermeable paving, …, - Existing procedures in the case of the occurrence of accidents, spill procedures, - Transport activities linked to (pre) treatment and disposal: transportation needs

(quantities) and mode, numbers of vehicles per day and per year, - Utilities linked to treatment and disposal units: description of energy supply, description

of equipment or measures to prevent/treat possible environmental pollution: water treatment unit, air purification equipment,

- The sound power level and the use pattern of equipment and utilities to be used for (pre) treatment,

- Description of the storage needs associated with the treatment and disposal units: storage capacities needed for each type of product; storage quantities per year;


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description of the storage facilities: size, measures foreseen to prevent pollution, storage conditions,

- Quantification and description of the origin and use of resources: water supply (groundwater, surface water, …) energy supply (including energy carrier: gas, coal, …),

- Quantification of the use of materials and chemicals, - Estimation of the waste production: description of the quantities of different types of

waste expected to be produced, description of the storage facilities for waste, the waste management and the final fate of each of the different types of waste,

- Description of the different sources for emissions and waste water production: expected and maximum allowed flow rate, temperature and composition of the off gasses; characteristics of the emission point (stack) i.e. height, diameter; flow rate and characteristics of the waste water (i.e. temp, COD, BOD, N, P, SS, …).

Once this project description has been completed, environmental and social impacts can be described and assessed. Impact description and assessment is divided into several disciplines:

• Air, climate and noise; • Soil and groundwater; • Water and aquatic resources; • Fauna and flora; • Land-use, landscape and archeological, historical and cultural values; • Man and his socio-economic living conditions.

For each discipline the following aspects are described: • Data and information needed: • Emission data:

∼ Identification of emission sources ∼ Quantification of emissions (measurements, emission factors) ∼ …

• Data on baseline situation: ∼ Actual air, water, soil, … quality; ∼ Climatological, geological, hydrological, … conditions ∼ …

• Assessment criteria ∼ Standards and guidelines ∼ Background values ∼ …

• Information sources: • Vietnamese legislation and agencies • Monitoring data • Field information • Sampling • … • Assessment methodology and criteria, e.g.: • Determining relevant impacts • Comparing impacts to available standards, guidelines, … • Evaluating impacts

A well structured EIA follows a fixed structure throughout each discipline:


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• Description of the baseline situation; • Evaluation of the actual situation in relation to the assessment criteria; • Determination of the contribution of the project to the environmental quality; • Prediction and description of the environmental situation to be expected in the presence of the

project; • Evaluation of the importance of the environmental impact to be expected.

In an environmental and social impact assessment, the possible alternatives have to be evaluated. The following types of alternatives should be considered:

• the zero alternative: this is the evolution of the present situation without the PCB project being implemented;

• the alternative with the planned situation if the project is carried out. For the latter several alternatives or scenarios may be studied i.e.:

• location alternatives: comparison of different possible locations for the project to be carried out; • technical alternatives: comparison of different techniques/processes/methodologies to carry out

the project. In order to be able to compare the different alternatives studied the principles of multi-criteria analysis have to be applied. To that aim – for standardisation and comparison reasons - all impacts are classified according to the following schedule: 0 No effect + Slight positive effect: this is an improvement of the existing situation for a specific impact

with limited magnitude, extent and significance ++ Moderate positive effect: this is a significant improvement of the existing situation for a

specific impact leading to surpassing the criteria used and characterised by a clear magnitude or extent

+++ Highly positive effect: this is a significant effect with an important magnitude and extent - Slight negative effect: this is a deterioration of the situation for a specific impact without

surpassing the criteria set; the impact can generally by mitigated and is reversible or limited in extent and magnitude

-- Moderate negative effect: this is a deterioration of the situation for a specific impact giving raise to surpassing the criteria used: it is characterised by a clear magnitude or extent, however mitigation may lower the effect

--- Highly significant negative effect: this is a significant deterioration of the situation for a specific impact characterised by a large magnitude and extent

---- Very important negative effect: this is a significant deterioration of the situation for a specific impact characterised by a large magnitude and extent and irreversible in nature without mitigation possibilities

In that way the impacts from different nature are brought into one scale which will allow mutual comparison. In order to evaluate the relative importance given to the different environmental issues, valuation factors are proposed. This may be agreed upon between the group of experts involved in carrying out the EIA. It is to be advised however that the major stakeholders are involved in valuating the environmental issues since they are supposed to be well aware of the project and local sensitivities. In the particular case of the PCB project it is proposed that EVN, DONRE, VEA and one NGO are involved in the evaluation and identification of the valuation factors.

Once the valuation factors have been attributed, the impact assessment score has to be multiplied by the valuation factor for each impact. The valuated scores obtained in this way are to be added up to come to a total environmental score. The alternative with the lowest (negative) score is then ranked to be the


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alternative having the smallest environmental effect. However, the comparison also has to be subject of a qualitative discussion and interpretation.

Next to the project description, assessment of potential impacts, and comparison of alternatives, an EIA also contains an environmental management and monitoring plan. This plan consists of a set of mitigation, monitoring, and institutional measures to be taken during implementation and operation of the project. The aim is to eliminate adverse environmental and social impacts, offset them, or reduce them to acceptable levels. The plan also includes the actions needed to implement these measures. The environmental management and monitoring plan identifies feasible and cost-effective measures that may reduce potentially significant adverse environmental impacts to acceptable levels. The plan includes compensatory measures if mitigation measures are not feasible, cost-effective, or sufficient. The plan includes following activities:

• identifying and summarizing all anticipated significant adverse environmental impacts; • describing each mitigation measure, including the type of impact to which it relates and the

conditions under which it is required (e.g. continuously, in the event of contingencies), together with designs, equipment descriptions, and operating procedures;

• estimating any potential environmental impacts of these measures; and • providing linkage with any other mitigation plans if required for the project.

Environmental monitoring during project implementation provides information about key environmental aspects of the project, particularly the environmental impacts of the project and the effectiveness of mitigation measures. Such information allows corrective action to be taken when needed. Therefore, the EMP identifies monitoring objectives and specifies the type of monitoring, with linkages to the impacts assessed in the EIA report and the mitigation measures described in the EMP. The monitoring section of the EMP provides:

• a specific description and technical details of monitoring measures including: • the parameters to be measured; • methods to be used; • sampling locations; • frequency of measurements; • detection limits (where appropriate); • definition of thresholds that will signal the need for corrective actions; and • monitoring and reporting procedures to ensure early detection of conditions that necessitate

particular mitigation measures, and furnish information on the progress and results of mitigation.

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Context, scope and objectives The last decades Vietnam has experienced a rapid industrialisation and a very important economic development. This has resulted in the generation of an increasing amount of industrial waste including hazardous and toxic waste. In particular POPs, including PCBs, create a hazard for human health and for environmental safety. The presence of PCBs in Vietnam and its environment is resulting from the import of dielectric fluids contained in transformers, capacitors and other electrical equipment. Based upon initial inventories it has been extrapolated that the quantity of PCB contaminated oil amounts up to at least 13,000 tonnes contained in about 18,600 transformers and 3,350 capacitors. PCB contaminated soil or small electrical equipment is not included (SNC Lavalin 2007). Being aware of the risks to human health and ecosystems, Vietnam ratified the Stockholm Convention in July 2002, committing to reduce and eventually eliminate 12 POPs, including PCBs. Under this convention, Vietnam is bound to phase out the use of equipment containing PCBs by 2020 and to treat the contained PCBs by 2028. The Ministry of Natural Resources and Environment (MONRE) is the lead agency overseeing the preparation and the implementation of the countries National Implementation Plan for the Stockholm Convention. Within MONRE, Vietnam Environment Administration (VEA) has been designated as the agency to implement POP activities. At present Vietnam does not have a functioning system to safely transport and store PCB containing materials. Neither is there adequate treatment and disposal potential. Major progress has to be made to achieve the goals set forward by the Stockholm Convention and as such to minimize the risks for human health and environment. Within this framework the PCB project has been developed, supported by the World Bank and the Global Environment Facility. This project aims to assist Vietnam to establish a sound PCB management system that would minimize potential environmental and health risks form unmanaged PCB oils and equipment. It consists of five components: • PCB management framework and action plan, • PCB management demonstration; • Institutional strengthening; • Monitoring, Enforcement and Evaluation; • Project Management. This implies the development of a management framework followed by demonstration activities to further refine the PCB management system. The project will be dealing with the whole range of PCB management issues from import, handling, servicing and decommissioning to disposal. It is obvious that this project, aiming at better PCB management and disposal of PCB equipment and wastes, will ultimately generate positive environmental and social impacts. Nevertheless as a World Bank funded project, it is subject to the World Bank Environmental and Social Safeguard Policies, implying to carry out an Environmental Impact Assessment. Improper management of PCBs could indeed lead to negative environmental and social impacts.


2

Taking into account this need for the EIA procedure to be followed for PCB related activities, the objective of the present project is: • To prepare an environmental assessment framework to assess all potential environmental and social

impacts associated with the activities of the PCB project on the one hand and to identify proper measures to mitigate such impacts on the other hand; this framework will cover the full spectrum of PCB management and disposal issues including transportation and storage, treatment, disposal or recycling and site remediation. The framework will be discussed with the different in country stakeholders. It is intended to allow a better management of PCBs taking into account all environmental and social/human health issues. Next to this it should be a reliable framework for the preparation of project EIAs to be prepared in association with specific PCB management projects in Vietnam.

• The second objective of the contract will be the preparation of such a project EIA for the PCB management project at the Pha Lai Thermal Power Plant, following the procedures and methodology outlined in the EA framework. This also involves consultation with the project affected population.


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Policy assessment with respect to PCB management and disposal

ROLES AND RESPONSIBILITIES Breeze and Associates Inc. (2007b) summarizes the roles and responsibilities of Ministries and Agencies at both the national and provincial levels. The following analysis is based on a comparison with the best practices of leading jurisdictions identified in the Desk Top and Final Breeze and Associates Reports.

National level The Ministry of Natural Resources and Environment (MONRE) has been given the responsibility to exercise the uniform State management of hazardous wastes and to organize and direct hazardous waste management activities. In addition, MONRE can develop and promulgate directives including sector environmental standards for the selection of HW landfill sites and the technical norms for the design, construction and operation of HW facilities. MONRE also has the responsibility to oversee and conduct inspections and to monitor and report on progress for the management of hazardous wastes. The Vietnam Environment Protection Administration (VEA) has been given the functions of issuing generator registers and licenses for transportation and facilities and to coordinate these functions with the provincial DONREs in accordance with national regulations. VEA can also direct provincial DONREs on data collection and the preparation of annual inventories for hazardous wastes. The Ministry of Construction (MOC) has been given responsibilities in two key areas. First, MOC sets the sector standards for the construction of all HW transportation systems and facilities in Vietnam. They are to collaborate with MOSTE (MONRE) in the development of these standards. Second, MOC can direct PPCs in planning for the construction of hazardous waste facilities. Within this role, MOC can direct PPCs to direct provincial DOCs to develop these plans. The Ministry of Transportation (MOT) has responsibility for setting sector operating standards and issuing general operating licenses for all general goods transporters, vehicle emissions and driver’s licenses. Under Circular 12/2006, VEA and the provincial DONREs must ensure that these general operating licenses from MOT have been issued before issuing any hazardous waste transportation licenses. MOT does not have a direct role in the issuance of the hazardous waste licenses. The Ministry of Science and Technology (MOST) has responsibility for coordinating the development of national standards including the development of standards for hazardous waste treatment technologies including obligated / regulated standards. The Ministry of Industry and Trade (MOIT) – (the former Ministry of Industry (MOI)) has been given key responsibilities for supervising, inspecting and applying measures to ensure that hazardous waste generators in the industrial sector comply with the regulations. They are also responsible for mobilizing capital for pollution abatement and for collecting statistics on HW management in the industrial sector in cooperation with MONRE. The Ministry of Health (MOH) has been given parallel responsibilities for overseeing the management of medical wastes at health care facilities. MOH supervises, inspects and applies measures to ensure that hospitals and health care facilities comply with its regulations. In addition, MOH has the prime responsibility, in coordination with MOC and MONRE, for planning, selecting technologies and establishing medical waste incinerators.


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The Ministry of Labor, Invalid and Social Affairs (MOLISA) is in charge of workers’ safety and occupational health, including providing guidelines and PCB good practices for workers who may be working with PCB equipment. The Environmental Police Department with the Ministry of Public Security was formed in 2007. This Agency is responsible for investigations and prosecutions under the environmental laws of Vietnam.

Provincial level At provincial level, the Provincial People’s Committees (PPCs) have the principal responsibility for ensuring that national directives are implemented in the provinces. In this respect, the PPCs direct the DONREs, DOCs and DTPWs to undertake the responsibilities described below. The Departments of Natural Resources and Environment (DONREs) have been given responsibility to be the one door for all applications for generator registers and licenses. In this respect, the DONREs issue registers and licenses as prescribed by Circular 12/2006, conduct inspections and take enforcement action. These responsibilities are for transporters and facilities that manage wastes from within their individual provinces. Transboundary transactions of wastes by transporters or by storage, treatment and disposal facilities are the responsibility of VEA. The DONREs are also responsible for developing a database and conducting inventories of HW information for submission to VEA. The Departments of Construction (DOCs) are responsible for planning for HW facilities and ensuring that they meet the standards set by the national MOC. The Departments of Transportation and Public Works (DTPWs) prepare feasibility plans and organize the implementation of these plans for hazardous waste management facilities. DTPWs are also responsible for issuing provincial general operating licenses for vehicles. Besides, other above mentioned ministries have their corresponding departments at the provincial level such as DOIT, DOLISA, DOH, and which are responsible for implementing the repsonsibilities of their ministries at the local provinces.

Overview of responsible parties involved in PCB management, disposal and remediation A substantial number of Ministries, departments and other agencies are involved in different aspects of the lifecycle of PCBs. Table 0-1 summarizes these responsibilities.

Table 0-1: Overview of authorities involved in the different aspects of the PCB lifecycle

(Source: Vietnam NIP Stockholm Convention, 2006)


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Figure 0-1: Flow chart public stakeholders involved directly in PCB management at local and national levels (VRXUFH: ECD, 2008)

Need for improvement The Breeze and Associates Inc. (2007b) report identified following findings: • As found in the Breeze and Associates’ Desk Top Report for PCBs, there are no significant gaps in

Ministry and Department responsibilities for hazardous wastes. Significant responsibilities have been assigned to MONRE, VEA and the provincial DONREs to ensure that hazardous waste efforts are coordinated and focused on national level priorities. This division of responsibilities is appropriate and will allow resources to be focused in those areas where they will have the most impact.

• The Breeze and Associates’ Desk Top Report however found that there were areas of significant overlap for PCBs. Breeze and Associates’ review has identified similar overlaps for hazardous wastes:

- MOI, MONRE, the Environmental Police Agency and the DONREs all have roles for inspecting and directing HW generators for the industrial sector;

- Both MOH and MONRE have significant roles for the safe management of hazardous medical wastes. This has led to separate sets of regulations for hazardous wastes for both the industrial and medical sectors. This may result in a lack of understanding and, in the end, poor compliance;

PPC

DOH

DONRE

DOPS

Sub VEPA

DOTr DOIT

Provincial level

DOST DOLISA DOC

GOV

MOLISA MoNRE (VEPA)

MOST DOE

MOPS (

Government level

MOH (DOSTE)

MOC DOE

MOIT (DOE)

MOTr

Commune level CPC

CV

DPC

DIONRE SeC

District level


6

- MOC and MONRE / VEA have overlapping roles for the evaluation of transfer, treatment and disposal facilities as part of the licensing functions;

• There will be need for effective coordination between national Ministries and Agencies including MOH, MONRE, MOC, MOST, the Environmental Police Agency and MOH if the hazardous waste provisions are to be effectively implemented. One technique for achieving the required levels of cooperation would be Memoranda of Understanding between key Ministries prescribing their respective roles and responsibilities and methods for resolving potential conflicts.

POLICY FRAMEWORK In 1998, the Vietnam National Environment Agency (NEA) with funding support from the Asian Development Bank began the development of a national strategy for hazardous waste management. The preparatory work was undertaken by Environmental Resources Management (ERM) from the UK. ERM proposed a national strategy consisting of three elements: development of a regulatory framework, building institutional capacity and the establishment of storage, treatment and disposal facilities. Although the ERM strategy was never formally adopted, the report supported the first significant policy steps by Vietnam to manage hazardous wastes. These included the development of the hazardous waste elements of the Law on Environmental Protection passed by the National Assembly and the Prime Minister’s Decision 155/1999. It provided overall direction and a focus for the countries hazardous waste management program. Breeze and Associates Inc. (2007b) summarizes the policies, regulations and legislation which have been put in place for solid, hazardous and medical wastes at both the national and provincial levels. The following sub-sections describe the policies which are of particular importance to the PCB policy recommendations.

National framework The Law on Environmental Protection (LEP), 2005 provides the foundation for environmental policy in Vietnam. The LEP prescribes policies, measures and resources for environmental protection as well as the rights and obligations of individuals and organizations. Among other policy directions, the LEP includes environmental standards, environmental assessment requirements as well as sections dealing with both municipal and hazardous waste management. The sections on hazardous waste management prescribe requirements for licensing, monitoring, record keeping as well as basic standards for transportation, storage, treatment and disposal. As found in the Desk Top Report of Breeze and Associates, Decision 155/ 1999, Decision 23/2006 and Circular 12/2006 build on the LEP policy requirements. These regulations provide a “cradle to grave” management system that has the potential to ensure the safe management of hazardous wastes including PCBs. These three regulations include definitions, requirements for waste generators, transporters and receivers as well as implementation procedures and responsibilities for State Management Agencies for the Environment (SMAEs). Vietnam became a signatory to the Basel Convention on the Transboundary Movement of Hazardous Wastes in 1995. The requirements to obtain Prior Informed Consent and licenses have been built into Decisions 155 and Circular 12. MOI Circular 01/2006 also imposes restrictions on imports and exports. These restrictions require that MOI issue a letter of consent before a provincial agency can authorize any transboundary movement of PCBs and other prescribed materials. The Law on Chemicals, 2007 regulates chemical activities, safety on chemical activities, rights and duties of organizations, individual joined chemical activities and state management of chemical activities. The Law includes 10 chapters with 71 articles: the general provisions, development of chemical industry, manufacture and trade of chemicals; classification, labelling, packaging and Safety Chemical Note; the use of chemicals, prevention and dealing with


7

chemical problems; classification, registration and providing information on chemicals; protecting the environment and safety for the community, state management responsibility on chemical activities and the execution provision. Decree No. 108/2008/ND-CP dated 07 Oct 2008 of Government provides guidelines and instructions for implementing some articles of the Law on Chemicals. In addition to regulatory and legislative provisions, Vietnam has produced several guidelines to promote the environmentally sound management of hazardous wastes: • Decision 60/2002 from the former MOSTE prescribes technical guidelines for hazardous wastes

landfills. It includes principles, methodologies and criteria to prevent and mitigate the impacts of hazardous waste landfills. It prescribes those HW acceptable for such landfills as well as requirements for their location, design, construction, operation, monitoring and closure.

• TCXDVN 230-2004 from MOC provides hazardous waste landfill design standards. These guidelines complement the MOSTE guidelines.

• Draft Guidelines for the Use of Wastes as Fuels and Materials in the Production of Cement were prepared for MONRE with the assistance of the Vietnam Canada Environment Project (VCEP). The guidelines prescribe waste selection criteria, pre-treatment, transportation, receiving, monitoring and reporting as well as requirements for EIA approvals and licensing. They have not yet been formally approved by MONRE; however they have been a useful resource in the licensing of the HOLCIM cement kiln for hazardous waste.

• A methodology to calculate treatment fees for waste water containing hazard constituent was issued by NEA in 2001. This method calculates industrial and medical waste water treatment fees for wastes containing heavy metals, acids and for textile and dying wastes.

• A methodology to calculate solid waste treatment fees was issued by NEA in 2001 including fees for treatment methods such as sedimentation, solidification, heat treatment and landfill. The guidance also provides a methodology to calculate hazardous waste treatment fees. Based on this methodology, the cost for solid hazardous waste transportation and treatment by secure landfill is about 1,300,000 VND/tonne and the cost for hazardous medical waste treatment by secure landfill is 4,600,000 VND/m³.

In 2003, the Prime Minister approved the National Strategy for Environmental Protection (NSEP). Hazardous wastes were identified as one of the 36 priority projects. In May 2006, VEA drafted a hazardous waste management plan under the NSEP but it still has to be finalized and approved. The intention of the draft plan was to set up a management system including: the legal framework, compliance and enforcement, support services and infrastructure for treatment and disposal. The objectives for the hazardous waste plan were: • in the period of 2006-2010: 100 % HW to be controlled; 60 % HW to be treated; complete the legal

framework, macro planning and approval procedures; • in the period 2010-2020: all HW to be managed, treated, reduced, recycled, reused and safely

disposed of with a minimal quantity going to landfill. Six priority projects were defined for HW over the four year period: • Investigate and assess the status of HW and set up an information system; • Develop and complete the legal framework; • Develop and implement treatment models and develop a collection, transportation, treatment and

disposal network; • Develop and implement demo-projects for recycling, reuse and recovery; • Set up a project to establish HW treatment facilities in the Southern, Northern and Central regions; • Develop national macro planning for HW collection, treatment and disposal. Although this plan was not formally adopted, several nationally funded projects were undertaken in 2005 and 2006 to assess the performance of the current program and to make


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recommendations for further development. These two projects are described in more detail in the Breeze and Associates Inc. (2007b) report.

Provincial frameworks Decision 155/1999, Decision 23/2006 and Circular 12/2006 define specific responsibilities for provincial PCs, DONREs and other departments for the safe management of hazardous wastes. These responsibilities have been described in the previous chapter. To implement these responsibilities, nine provinces have developed policies and have started to put these into action. Hanoi has passed Decision 152 to meet its obligations under the national regulations. Decision 152 builds on national Decision 155 but is restricted to industrial hazardous wastes. In addition to the national requirements, the Hanoi directive further clarifies the responsibilities of DONRE and other departments, introduces additional city standards and defines Nam Son Commune as the location for the central disposal site. HCMC and Long An have each developed two guidelines. The first guideline reproduces Decision 155 while the second reproduces MOSTE Decision 60/2002 on HW landfills. In addition, HCMC has passed Directive 09/2003 aimed at improving the management of medical wastes along the lines described by MOH Decision No. 2575/1999. Dong Nai Decision 2582 is based on Decision 155 but prescribes more detailed requirements for the hazardous waste management system of that province. It also clarifies the responsibilities of the DONRE and other departments. Long An, Hai Phong and Hai Duong have all developed provincial regulations based on Decision 155, however these regulations have not yet been approved by the provincial PCs. Phu Tho Decision 2777/2002 is based on national Decision 155 and requires all industrial and hazardous waste generators and transporters to follow specified hazardous waste requirements. The regulation also appointed the Viet Tri Environmental and Urban Service Company to be responsible for hazardous waste management at a provincially licensed treatment plant. Nam Dinh PPC adopted their Hazardous Waste Strategy in 2006 to guide regulatory development, capacity building efforts and the establishment of facilities. Nam Dinh has also drafted a regulation but the PPC has decided to rely instead on the new national requirements found in Decision 23 and Circular 12.

Need for improvement Breeze and Associates Inc. (2007b) report identified following findings: • Vietnam does not have a formally adopted hazardous waste management strategy or plan. The draft

VEA hazardous waste component of the National Environmental Protection Strategy is a sound first step but it will need to address, more effectively, two essential components defined by ERM – capacity building at the national, provincial and local levels and the establishment of cost effective treatment and disposal facilities.

• As found in the Desk Top Report, Decision 155/1999, Decision 23/2006 and Circular 12/2006 provide the foundation for a basic “cradle to grave” hazardous waste system for the country. The report also concluded that there are a number of inconsistencies between the 1999 and the 2006 policies. These include differences in manifesting requirements and prescribed timelines for issuing generator registers and licenses. These inconsistencies will need to be resolved if significant levels of compliance are to be achieved.

• Nine provinces have started to develop policy frameworks to implement their HW responsibilities. Breeze and Associates’ review of the provincial requirements has shown that the provinces have begun to diverge from the national provisions. This divergence will make it difficult for the regulated community which is managing hazardous wastes across provincial borders to understand the requirements. This lack of understanding will inevitably lead to a lack of compliance.

• In Breeze and Associates’ discussions with selected provincial officials, they found that the provinces and cities now implementing the hazardous waste management regulations are struggling to


9

understand how to achieve compliance. They need additional technical support in the form of guidelines for generators, transporters as well as storage and treatment facilities. They also require inspection and enforcement protocols for government inspectors monitoring facilities and protocols for review engineers preparing licenses for these facilities.

Overall PCB policy needs and options assessment Breeze and Associates (2007a) identified and assessed policy needs and options based on international best practices and made recommendations for a policy, regulatory and legislative framework for Vietnam. Their throughout analysis has been summarised in the table presented in appendix 0 including a needs assessment in following fields: • PCB Policy Framework for Vietnam; • Thresholds and Timelines; • In-Service PCB Equipment and Materials; • PCB Waste Management; • Contaminated Sites; • Policy Compliance; • Environmental Monitoring; • National Inventories; • Public Awareness / Involvement; • Capacity Building and Training; • Cost Recovery Mechanisms; • Roles and Responsibilities. As a base of comparison, Breeze and Associates (2007a) analysed the requirements under the Stockholm Convention and four best practice jurisdictions: Australia, the Philippines, Canada and the European Union.


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Impact assessment procedure Environmental impact assessment is the process in which environmental factors are integrated into project planning and decision-making so as to achieve ecologically sustainable development. In this chapter, a guideline is provided on the EA procedure to be followed by the project initiator when doing a project in the scope of the PCB management, disposal and remediation. Being a World Bank funded project, the environmental and social impact assessment procedures as defined in the World Bank Safeguard rules should be followed in the scope of this PCB Management Demonstration Project. Besides this, EIAs should comply with the current Vietnamese legislation in this field. Both are briefly described in following chapters. As this Framework is not limited to PCB management aspects, EIA rules and legislation to be followed in PCB disposal and remediation projects are also described. Taking into account above described legislation and rules, a decision tree is provided for site specific EIAs as a guidance tool to screen the proper EA procedures and content.

WORLD BANK SAFEGUARD RULES The objective of the World Bank’s environmental and social safeguard policies is to prevent and mitigate undue harm to people and their environment in the development process. They are a cornerstone of its support to sustainable poverty reduction. The effectiveness and development impact of projects and programs supported by the Bank has substantially increased as a result of attention to these policies. Safeguard policies have often provided a platform for the participation of stakeholders in project design, and have been an important instrument for building ownership among local populations.

Environmental assessment The objectives of this item are to provide an overview of the World Bank EIA process. In World Bank operations, the purpose of Environmental Assessment is to improve decision making, to ensure that subproject options under consideration are sound and sustainable, and that potentially affected people have been properly consulted. To meet this objective, the World Bank policy defines procedures to: (a) identify the level of environmental risk (screening) associated with a project, (b) assess the potential environmental impacts associated with the risk and how they should be reduced to acceptable levels (environmental assessment and management), (c) ensure the views of local groups that may be affected by the project are properly reflected in identifying the environmental risk and managing any impacts (public consultation), (d) make certain that the procedures followed in the environmental assessment process are adequately disclosed and transparent to the general public (disclosure) and (e) includes measures for implementation and supervision of commitments relating to findings and recommendations of the environmental assessment (environmental management plan). An environmental assessment should be carried out early in the project cycle during project conception and design stage in order to identify its direct and indirect impacts on physical and social environment and establish linkages. The various steps to be followed during identification, preparation, appraisal, negotiation, implementation, and evaluation of the project, as recommended in the World Bank guidelines, are given in Figure 0-1. Screening and scoping, the most important parts of EIA, need to be certainly and effectively carried out to identify the environmental parameters that will be affected by development projects, and initiate dialogues with affected people for appraising the positive and negative features of the projects for effective public participation. The World Bank undertakes environmental screening of each proposed project to determine the appropriate extent and type of EA. The Bank classifies the proposed project into one of four categories, depending on the type,


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location, sensitivity, and scale of the project and the nature and magnitude of its potential environmental impacts.

(a) Category A: A proposed project is classified as Category A if it is likely to have significant adverse environmental impacts that are sensitive1 diverse, or unprecedented. These impacts may affect an area broader than the sites or facilities subject to physical works. EA for a Category A project examines the project’s potential negative and positive environmental impacts, compares them with those of feasible alternatives (including the “without project” situation), and recommends any measures needed to prevent, minimize, mitigate, or compensate for adverse impacts and improve environmental performance. For a Category A project, the borrower is responsible for preparing a report, normally an EIA (or a suitably comprehensive regional or sectoral EA) that includes, as necessary, elements of other instruments such as an environmental audit, hazard or risk assessment, and environmental management plan (EMP).

(b) Category B: A proposed project is classified as Category B if its potential adverse environmental impacts on human populations or environmentally important areas —including wetlands, forests, grasslands, and other natural habitats — are less adverse than those of Category A projects. These impacts are site-specific; few if any of them are irreversible; and in most cases mitigation measures can be designed more readily than for Category A projects. The scope of EA for a Category B project may vary from project to project, but it is narrower than that of Category A EA. Like Category A EA, it examines the project’s potential negative and positive environmental impacts and recommends any measures needed to prevent, minimize, mitigate, or compensate for adverse impacts and improve environmental performance. When the screening process determines, or national legislation requires, that any of the environmental issues identified warrant special attention, the findings and results of Category B EA may be set out in a separate report. Depending on the type of project and the nature and magnitude of the impacts, this report may include, for example, a limited environmental impact assessment, an environmental mitigation or management plan, an environmental audit, or a hazard assessment. For Category B projects that are not in environmentally sensitive areas and that present well-defined and well-understood issues of narrow scope, the World Bank may accept alternative approaches for meeting EA requirements: for example, environmentally sound design criteria, siting criteria, or pollution standards for small-scale industrial plants or rural works; environmentally sound siting criteria, construction standards, or inspection procedures for housing projects; or environmentally sound operating procedures for road rehabilitation projects.

1 A potential impact is considered “sensitive” if it may be irreversible (e.g., lead to loss of a major natural habitat) or raise issues covered by OP 4.10, ,QGLJHQRXV� 3HRSOHV; OP 4.04, 1DWXUDO� +DELWDWV; OP 4.11, 3K\VLFDO� &XOWXUDO�5HVRXUFHV; or OP 4.12, ,QYROXQWDU\�5HVHWWOHPHQW.


12

Figure 0-1 World Bank Environmental Assessment requirements versus project cycle

(c) Category C: A proposed project is classified as Category C if it is likely to have minimal or no adverse environmental impacts. Beyond screening, no further EA action is required for a Category C project. (d) Category FI: A proposed project is classified as Category FI if it involves investment of Bank funds through a financial intermediary, in subprojects that may result in adverse environmental impacts.

Bank staff “screen” each proposed project to determine which safeguard policies may be triggered. The Project owner is then informed of the actions needed for compliance. The screening criteria applied by the World Bank to determine whether OP 4.01 has been triggered plus other specific requirements of the World Bank are summarized again in the following table: Project stage The World Bank Legal references

Operational Policy 4.01 on Environmental Assessment and associated BP 4.01.

Screening Project Identification

Bank “screens” the project and determines whether it falls into 1 of 3 Categories: A- Likely to have significant adverse impacts that are sensitive, diverse or unprecedented and may affect a broad


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area: Detailed EIA and environmental management plan (EMP) Required B- Potential impacts are less adverse than for Category A, they are site specific, few if any are irreversible and in most cases, mitigatory measures can be designed more readily than for Category A projects. Less detailed EIA Required. C- Minimal or no adverse environmental impacts. No further requirements.

Scoping During Pre- Feasibility or Feasibility studies

For Category A projects, scoping requires the proponent/Project owner to organize:

¾�Field visit by an environmental specialist to prepare scope, procedures, schedule and outline for EA study.

¾�Project affected people and NGOs should be ¾�consulted before ToR for detailed EA study is

finalized. ¾�Bank must approve resulting scope and ToR for

detailed EA study. ¾�The Bank will assist the Project owner / proponent

to do this as needed. For Category B projects, Project owner must discuss and agree EIA scope and ToR with Bank.

Preparation of report

Detailed Design (Prep. Of EIA)

For Category A projects, the Project owner/proponent must retain a independent EA expert(s) not affiliated with the project to carry out EA. For high risk/multi-dimensional Category A projects, the Project owner must also engage an advisory panel of independent, internationally recognized environmental specialists to advise on aspects of the project relevant to the EIA.

Components of an EIA report according to the World Bank safeguard policies Category A include:

• Executive summary: a concise discussion of significant findings of the EIA and recommended actions in the project;

• A policy, legal, and administrative framework; • Project description: description of the project's geographic, ecological, social and temporal

context, including any off-site investments that may be required by the project, such as dedicated pipelines, access roads, power plants, water supply, housing and raw material and product storage materials;

• Baseline data: an assessment of the study areas dimensions and a description of relevant physical, biological, and socio-economic conditions, including any changes anticipated before the project begins, and current and proposed development activities within the project area, even if not directly connected to the project;

• Impact assessment: identification and assessment of the positive and negative impacts likely to result from the proposed project. Mitigation measures, and any residual negative impacts that cannot be mitigated, should be identified. Opportunities for environmental enhancement should be explored. The extent and quality of available data, key data gaps, and uncertainties associated


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with predictions should be identified/estimated. Topics that do not require further attention should be specified;

• Analysis of alternatives: assess investment alternatives from an environmental perspective. This is the more proactive side of EA -enhancing the design of a project through consideration of alternatives, as opposed to the more defensive task of reducing adverse impacts of a given design;

• A mitigation or management plan: consists of the set of measures to be taken during implementation and operation to eliminate, offset, or reduce adverse environmental impacts to acceptable levels. The plan identifies feasible and cost-effective measures and estimates their potential environmental impacts, capital and recurrent costs and institutional, training and monitoring requirements. The plan should provide details on proposed work programs and schedules to help ensure that the proposed environmental actions are in phase with construction and other project activities throughout implementation. The plan should consider compensatory measures if mitigation measures are not feasible or cost-effective;

• An environmental monitoring plan: specifies the type of monitoring, who will do it, how much it will cost, and what other inputs, such as training, are necessary;

• Public consultation: Consultation with affected communities is recognised as key to identifying environmental impacts and designing mitigation measures. The World Bank's policy requires consultation with affected groups and local NGOs during at least two stages of the EA process: (1) at the scoping stage, shortly after the EA category has been assigned, and (2) once a draft EA report has been prepared.

Social assessment Social assessment is the instrument used most frequently to analyze social issues and solicit stakeholder views. Social assessment helps make the project responsive to social development concerns, including seeking to enhance benefits for poor and vulnerable people while minimizing or mitigating risk and adverse impacts. It analyzes distributional impacts of intended project benefits on different stakeholder groups, and identifies differences in assets and capabilities to access the project benefits. A social assessment is made up of analytical, process, and operational elements, combining

• the analysis of context and social issues • with a participatory process of stakeholder consultations and involvement, • to provide operational guidance on developing a project design, implementation, and

monitoring and evaluation (M&E) framework. The scope and depth of the social assessment should be determined by the complexity and importance of the issues studied, taking into account the skills and resources available. To the extent possible, the project social assessment should build on existing data and analysis relevant to the sector and project. Gender, ethnicity, social impacts, and institutional capacity are among the social factors that need to be taken into account in development operations. In the past these factors have been analyzed separately with the result that some issues received attention whereas others were overlooked. Social assessment was developed by the Bank’s Social Policy Thematic Team to provide a comprehensive, participatory framework for deciding what issues have priority for attention and how operationally useful information can be gathered and used. Because this method was developed by Bank staff, the steps in SA are consistent with Bank procedures and existing operational directives. The choice of tools and methods (see Figure 3.2) for a specific social assessment will depend on several factors, such as the project area and the quality of previous social development information specific to the project, region and sector. Resource constraints, the time frame for


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the social assessment, the availability of capable human resources and the information gaps that the social assessment needs to fill will also affect the choice of methodology.

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Figure 0-2: Selection of Social Analysis Study Methods and Tools

Participatory Monitoring and Evaluation

Review of area-specific data

Review of qualitative and quantitative country specific data

Decision for Social Assessement

Bank activities

Need to launch more comprehensive data gathering and analyses

Need to evaluate stakeholders and launch participation activities

Selection of scope of data collection

Media campaigns, seminars, workshops, etc.

Qualitative Analysis

Quantitative and qualitative Analysis

Social Assessement Report

Financial Recources

Human Recources

Selection Factors

Types of AnalysesTimeframe

Diversity of project area

Evaluate appropriateness of tools for participation and stakeholders analysis

ENVIRONMENTAL IMPACT ASSESSMENT AND ENVIRONMENTAL PROTECTION COMMITMENT RULES IN VIETNAM In Vietnam the Law on Environmental Protection (LEP) went into effect on January 10, 1994. It aims to preserve a healthy, clean, and beautiful environment, achieve environmental improvements, ensure ecological balance, prevent and overcome adverse impacts on people, on environment (including nature), on the rational and economical exploitation, and utilization of natural resources. The EIA was mentioned in the LEP. Article 18 stipulates that organizations and individuals must submit EIA reports to be appraised by the state management agency for environmental protection. The result of the appraisal should constitute of one of the bases for the competent authorities to approve the projects or authorize their implementation (SIDA, 2004). The Ministry of Natural Resources and Environment (MoNRE) was created and replaced the Ministry of Science, Technology and Environment (MoSTE) at the end of 2002. Today, MoNRE

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performs the functions of state management over land, water, and mineral resources, environment, hydro-meteorology, survey, and mapping for the whole country. It works on various tasks, including EIA with ministerial and provincial agencies, as well as with the National Assembly offices, and finally with the prime minister. The provincial Departments of Natural Resources and Environment (DoNREs) are delegated to make decisions on numerous issues related to the use and management of local natural resources and environment, combined with environmental and land planning. The Vietnam Environment Administration (VEA) is included in the state management; its main task is to monitor environmental measures. VEA primarily monitors the project owners’ mitigation actions as stipulated in the EIA report. Much of this responsibility, however, is decentralized to the DoNRE (Severinsson, 2004). Depending on the type and size of the planned project and the sensitivity of the natural and social environment, a distinction is made between environmental impact assessment studies (EIA) and environmental protection commitments (EPC). EIA and EPC legislation in Vietnam is stipulated by Decree 80/2006/ND-CP (issued 09/08/2006) detailing and guiding the implementation of a number of articles of the law on environmental projection including EIA and EPC and Decree 21/2008/ND-CP (issued 28/02/2008), amending and supplementing a number of articles of Decree 80/2006/ND-CP on:

• the list of projects subject to EIA, obligation related to public consultations and the appraisal and approval process;

• registration and certification aspects of EPCs. Article 1.3. of the Government's Decree 21/2008/ND-CP, amends and supplements Clause l of Article 6 of Decree 80/2006/ND-CP on the list of projects subject to the making of an environmental impact assessment report. A detailed list of projects subject to EIA is presented in annex to Decree 21/2008/ND-CP. In case environmental impacts are less significant than for those projects subject to EIA, an environmental protection commitment should be drafted to ensure comprehensive development and sustainability. When elaborating EIA reports or project EPCs, it is required to apply Vietnam compulsory environmental standards; environmental standards must be in accordance with the international treaties which were signed by Vietnam. Other important legal documents relevant for the scope of EIAs regarding PCB management and disposal related projects, include:

• The Environment Protection Laws approved by the National Assembly of the Socialist Republic of Vietnam dated November 29, 2005, effected from July 01, 2006;

• Decision number 23/2006/Q -BTNMT of the Ministry of Resource & Environment issued December 26, 2006 on Hazardous waste List. (related with the Basel Convention on the Transboundary Movement of Hazardous Wastes in 1995);

• Decision number 12/2006/ Q -BTNMT of the Ministry of Resource & Environment issued December 26, 2006 stipulating the conditions to set up and the procedures to register, to license, to give a code to manage the harmful waste materials;

• Decree number 68/2005/N -CP issued December 20, 2005 of Government of Chemical Safety; • Notification number 12/2006/TT-BCN issued December 22, 2006 of Ministry of Industry of

Industrial Safety; • Decree No 13/2003/ND-CP issued February 19, 2003 to regulate the list of dangerous cargo

transported by road • Circular No 02/2004/TT-BCN of the Ministry of Industry issued December 21, 2004 to guide to

implement Decree No 13/2003/ND-CP • Circular No 10/2008/TT-BKHCN issued August 8, 2008 to instruct to the procedures to give licence

for hazardous chemicals transportation by road

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• QCVN 03:2008 National technical regulation on the emission of health care solid waste incinerators

• QCVN 03:2008 National technical regulation on the allowable limits of heavy metals in the soils • TCVN 6706-2000 Classification of hazardous wastes; • TCVN 6706:2000 Warning and precautionary sign of hazardous wastes; • TCVN 7629:2007 Hazardous waste thresholds • TCXDVN 320:2004 Hazardous solid waste landfills – Design standard • Decision number 22/2006/Q -BTNMT issued December 18, 2006 of Ministry of Resource &

Environment to obligation to apply the Vietnamese standards of Environment as below: 1. TCVN 5937:2005 Air quality – Ambient air quality standards,

2. TCVN 5938:2005 Air quality – Maximum allowable concentration of hazardous substances in ambient air,

3. TCVN 5939:2005 Air quality – Industrial emission standards – Inorganic substances and dusts,

4. TCVN 5940:2005 Air quality – Industrial emission standards – Organic substances,

5. TCVN 5945:2005 Industrial wastewater – Discharge standards; • Decision number 07/2005/Q -BTNMT issued September 20, 2005 of Ministry of Resource &

Environment to obligation to apply the Vietnamese standards of Environment as below: 1. TCVN 7440:2005 Emission standards for thermal power industry;

• The Vietnamese Environmental Standards issued in 1995 and the Vietnamese Standards of Environment, which obligate to apply issues attaching to Decision number 35/2002/Q -BKHCNMT dated June 25, 2002 (not abrogated by Decision number 22/2006/Q -BTNMT dated December 18, 2006):

• Standards concerning air quality: 1. TCVN 6560:1999 Air quality – Emission standards for health care solid waste

incinerators – Permissible limits,

2. QCVN 02:2008 National technical regulation on the emission of incinerators for health care solid waste;

3. TCVN 6438:2001 Road vehicles – Maximum permitted emission limits of exhaust gas,

4. TCVN 6991:2001 Air quality – Standards for inorganic substances from industrial emissions discharged in industrial zones,

5. TCVN 6992:2001 Air quality – Standards for inorganic substances from industrial emissions discharged in urban regions,

6. TCVN 6993:2001 Air quality – Standards for inorganic substances from industrial emissions discharged in rural and mountainous regions,

7. TCVN 6994:2001 Air quality – Standards for organic substances from industrial emissions discharged in industrial zones,

8. TCVN 6995:2001 Air quality – Standards for organic substances from industrial emissions discharged in urban regions,

9. TCVN 6996:2001 Air quality – Standards for organic substances from industrial emissions discharged in rural and mountainous regions;

• standards concerning noise:

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1. TCVN 5948-1998 Acoustic – Noise emitted by accelerating road vehicles – Permitted maximum noise level,

2. TCVN 5949-1998 Acoustics – Noise in public and residential areas - Maximum permitted noise level;

• standards concerning water quality: 1. TCVN 5942-1995 Water quality – Surface water quality standards, 2. TCVN 5943-1995 Water quality – Coastal water quality standards,

3. TCVN 5944-1995 Water quality – Ground water quality standards, 4. TCVN 6772:2000 Water quality – Domestic wastewater standards,

5. TCVN 6773:2000 Water quality – Water quality guidelines for irrigation,

6. TCVN 6774:2000 Water quality – Fresh-water quality guidelines for protection of aquatic life,

7. TCVN 6980:2001 Water quality – Standards for industrial effluents discharged into rivers used for domestic water supply,

8. TCVN 6981:2001 Water quality – Standards for industrial effluents discharged into lakes used for domestic water supply,

9. TCVN 6982:2001 Water quality – Standards for industrial effluents discharged into rivers used for water sport and recreation,

10. TCVN 6983:2001 Water quality – Standards for industrial effluents discharged into lakes used for water sport and recreation,

11. TCVN 6984:2001 Water quality – Standards for industrial effluents discharged into rivers: for protection of aquatic life,

12. TCVN 6985:2001 Water quality – Standards for industrial effluents discharged into lakes: for protection of aquatic life,

13. TCVN 6986:2001 Water quality – Standards for industrial effluents discharged into coastal water used for protection of aquatic life,

14. TCVN 6987:2001 Water quality – Standards for industrial effluents discharged into coastal water: for water sport and recreation;

• The standards concerning soil quality: 1. TCVN 7209- 2002 Soil quality – maximum allowable limits of pesticide

residues in the soil; • The standards concerning the vibration, labour sanitation:

1. TCVN 6962:2001 Vibration emitted by construction works and factories – Maximum permitted levels in the environment of public and residential areas

• Technical documents: Feasibility Study of the Project. • The standards concerning hazardous wastes

1. TCVN 6706-2000 Classification of hazardous wastes; 2. TCVN 6707: 2000 Warning and precautionary sign of hazardous wastes; 3. TCVN 7629:2007 Hazardous waste thresholds 4. TCXDVN 320:2004 Hazardous solid waste landfills - Design standard

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Environmental Impact Assessment: content and procedure

5HSRUWLQJ�VWUXFWXUH�DQG�FRQWHQW�The recommended EIA structure according to Vietnamese law includes:

INTRODUCTION 1. Project profile 2. Legal and technical basis for environmental impact assessment (EIA) 3. EIA Methodology 4. Organization of E.I.A. implementation Chapter 1: BRIEF DESCRIPTION OF PROJECT 1.1. Name of project 1.2. Project owner 1.3. Location of project

• 1.4. Main contents of project Chapter 2: NATURAL, ENVIRONMENTAL, ECONOMIC AND SOCIAL CONDITION 2.1. Natural and environmental condition: ��*HRJUDSKLFDO�DQG�JHRORJLFDO�FRQGLWLRQ ��0HWHRURORJLFDO�DQG�K\GURJUDSKLFDO�FRQGLWLRQ ��&XUUHQW�FRQGLWLRQ�RI�QDWXUDO�HQYLURQPHQWDO�IDFWRUV

• 2.2. Economic and social condition: ��(FRQRPLF�FRQGLWLRQ ��6RFLDO�FRQGLWLRQ Chapter 3: ASSESSMENT OF ENVIRONMENTAL IMPACTS 3.1 Assessment of impacts ��,PSDFWV�WKDW�UHODWH�WR�ZDVWH��,PSDFWV�WKDW�GR�QRW�UHODWH�WR�ZDVWHV - )RUHFDVWLQJ�HQYLURQPHQWDO�ULVNV�WKDW�SURMHFW�PD\�WDNH 3.2. Evaluation on detail level and reliability of assessment Chapter 4: SOLUTIONS AND MEASURES TO MINIMIZE NEGATIVE IMPACTS, TO PREVENT AND COPE WITH ENVIRONMENTAL PROBELMS 4.1. For Negative impacts 4.2. For environmental problems Chapter 5: ENVIRONMENTAL MANAGEMENT AND MONITORING PROGRAMS 51. Environmental management program 5.2. Environmental monitoring program Chapter 6: COMMUNITY CONSULTATION 6.1. Consultation with communal level People’s Committees 6.2. Consultation with communal level National Father Front Committees 6.3. Responses and commitments of project owners to the opinions raised in consultation process CONCLUSION, RECOMMENDATION, AND COMMITMENT 1. Conclusion 2. Recommendation 3. Commitment ANNEXES

A detailed explanation about the content of each of the above indicated chapters is indicated in the attachment of the Circular No. 05/2008/TT-BTNMT of the Ministry of Natural Resources and Environment providing guidance on strategic environmental assessment, environmental impacts assessment and environmental protection commitment.

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&RQVXOWDWLRQ�QHHGV�As required in Article 6a (Decree 21/2008/ND-CP dated on February 28, 2008) consultation of commune, ward or township, People’s Committees and community representatives should be organized in the process of making environmental impact assessment reports.

• Commune, ward or township Fatherland Front Committees shall represent communities in contributing opinions in the process of making environmental impact assessment reports of investment projects in their localities.

• The project owner shall send a document on the project's major investment items, environmental issues and environmental protection measures and request the commune-level People's Committee and Fatherland Front Committee of the place where the project is to be executed to give opinions.

• Within fifteen (15) working days after receiving a written request for opinions, commune-level People's Committee and Fatherland Front Committee shall give their opinions in writing and make them public to local people.

• Past this time limit, if they issue no written replies, the commune-level People's Committees and community representatives shall considered having agreed with the project owner.

$SSURYDO�SURFHGXUH��According to Article 11 of Decree 21/2008/ND-CP on appraisal of EIA reports, heads or leaders of agencies stipulated in Clause 7 of Article 17 of Law on Environmental Protection shall make decisions on the establishment of Appraisal Councils for EIA reports of the projects. Based on the technological, technical and environmental complexity of the projects, the heads or leaders of agencies stipulated in Clause 7 of Article 17 of Law on Environmental Protection make decisions on the selection of appraisal form through the Appraisal Council or Appraisal Service Providers. The Appraisal Council or Appraisal Service Providers have the functions of providing consulting services for competent agencies to consider and evaluate the quality of EIA reports as background for considering and approving in accordance with the regulations. In necessary circumstances, before official meetings of the Appraisal Council, the responsible agencies can exercise supporting appraisal modalities as follows:

• Survey on the project implementation site and surrounding location; • Taking samples for reference analysis; • Collecting opinions of communities surrounding the project implementation site; • Collecting critical opinions from experts outside the Appraisal Council, relevant scientific and

technological agencies, social and vocational organizations, and non-governmental organizations; • Organizing appraisal meetings on specific topics.

The Appraisal Council and Appraisal Service Providers on EIA reports operate in accordance with regulations issued by Minister of Natural Resources and Environment. The duration for appraisal of projects under the competence authority of making decision and approval of the National Assembly, the Government, the Prime Minister as well as inter-sectoral and inter-provincial projects is 45 working days, starting on the date of receiving valid application dossiers. For projects that are not in the scope of Clause 1 of article 12 of Decree 21/2008/ND-CP, duration for appraisal is 30 working days since the date of receiving valid application dossiers. In case EIA reports are not approved and must be re-appraised, duration for re-appraising is determined in Clauses 1 and 2 of article 12. The approval procedure in the scope of the EIA project including the different steps and responsible parties throughout the different project phases is presented in Figure 3-2.

Figure 0-3: Presentation of EIA approval procedure

Ministry of Planning and Investment

Ministry of Natural Resources and Environment

Investor Phase 1

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Submit EIA report

Add information

Not approve/ require additional information 45 days Phase 2

Construction and installation EP facilities

Monitoring mitigation measures Evaluate EA report

Report

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Environmental Protection Commitment: content and procedure

5HSRUWLQJ�VWUXFWXUH�DQG�FRQWHQW�Proposed structure and requirements of an environmental protection commitment according to Vietnamese law is as follows:

I. GENERAL INFORMATION 1.1. Project name: (exact name as in feasible study report or investment report) 1.2. Name of agency, project owner: 1.3. Contact address of agency, project owner: 1.4. Head of agency, company owned project: 1.5. Facilities for contact with agency, company owned project: (telephone number, Fax, E-mail...). II. PROJECT EXECUTING SITE III. SCALE OF PRODUCTION, BUSINESS IV. DEMAND FOR ENERGY AND FUEL V. ENVIRONMENTAL IMPACTS 5.1. Arisen wastes 5.2. Other impacts VI. MEASURES FOR MINIMIZING NEGATIVE IMPACTS 6.1. Waste treatment 6.2. Minimizing other impacts VII. ENVIRONMENTAL TREATMENT PLANS; ENVIRONMENTAL MONITORING PROGRAMS VIII. IMPLEMENTATION COMMITMENT Commitment on Implementation of wastes treatment, minimization of other impacts raised in environmental impact assessment report; commitment of following current standards on environment; commitment of implementing other environmental protection methods as regulated by Vietnamese law.

Further details on the content of an EPC is presented in annexes attached with Circular No.05/2008/TT-BTNMT by Ministry of Natural Resources and Environment guiding on strategic environmental assessment, environmental impact assessment and environmental protection commitment

(ODERUDWLRQ�RI�HQYLURQPHQWDO�SURWHFWLRQ�FRPPLWPHQWV��In case the preparation of an EPC is due, LEP 2005 specifies that after receiving valid EPC dossiers within time duration as stipulated in Clause 2 of Article 26 of Law on Environmental Protection, the People’s Committees at district or communal levels are authorized to issue certificates to those objects who register environmental protection commitments. According to the Circular 05/2008-TT-BTNMT of the Ministry of Natural Resources and Environment, the project owners have responsibility to send the dossier registering for environmental protection commitment (EPC) to the People’s Committee at the district level or authorized People Committee at commune level where the project is executed. In case the project is belonging to two or more districts, towns, cities … , the project owners choose one People Committee at district level belonging to a province to send a dossier registering for environmental protection commitment. The content and form of the dossier registering environmental protection commitment are regulated as stipulated in Annnex 26 of the Circular 05/2008-TT-BTNMT- Guideline for strategic environmental assessment, environmental impact assessment and environmental protection committment.

SCREENING PROCEDURE AND GUIDANCE ON CONTENT ACCORDING TO WORLD BANK AND VIETNAMESE RULES ON ENVIRONMENTAL IMPACT ASSESSMENTS Based on the EIA rules defined in the Vietnamese legislation and the World Bank safeguard policies, a guidance is provided on the appropriate EA procedures which need to be followed.

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Table 0-1 illustrating the procedure to be followed based on above described World Bank rules and Vietnamese legislation.

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Table 0-1: Guidance on screening procedure and disciplines covered in site specific impact assessments on PCB management, disposal and remediation

IMPACT ASSESSMENT SCREENING PROCEDURE FOR SITE SPECIFIC IMPACT ASSESSMENT PROJECTS

1. LOCATION

World Bank Vietnamese legislation

Projects using part or the whole land area represented by nature conservation zones, national parks, historical-cultural relic areas, world heritages, biosphere reserves, and famous scenic places which are protected under decisions of provincial/municipal People’s Committees

Cat A EIA

2. TYPE OF PROJECT

PCB Management Project or Sub-Project PCB Treatment and Disposal Project or Sub-project

Site Remediation Project or Sub-project

Subtasks World Bank Vietnamese

legislation Subtasks World Bank Vietnamese

legislation Subtasks World Bank Vietnamese

legislation

Testing equipment Cat B EPC

Treatment based on

destruction by reduction

Cat A EIA Soil excavation and transportation

Cat A EIA

Handling oils, materials and

waste including packaging,

labelling and transport

Cat B EPC Treatment based on

oxidation treatment

Cat A EIA Soil washing (excavated

contaminated soil)

Cat A EIA

Replacement, retrofilling and

recycling

Cat B EPC Treatment based on

combustion/incineration

Cat A EIA Thermally enhanced soil

vapour extraction

Cat A EIA

Construction of temporary

storage place

Cat B EPC Construction of final storage

place or/and disposal at

landfills for HW

Cat A EIA In-situ soil flushing

Cat A EIA

In situ vitrification Cat A EPC

TiO2 enhanced

photocatalysis

Cat A EPC

IMPACT DISCIPLINES TO BE COVERED IN SITE SPECIFIC IMPACT ASSESSMENT PROJECTS In general following disciplines should be covered in an impact assessment, including both Cat A and B projects according to the World Bank Safeguard rules and EIA and EPCs according to Vietnamese legislation.


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• Water and aquatic resources: • Ground water contamination • Surface water contamination • Soil and waste: • Soil contamination • Waste production • Climate, air and noise: • Air emissions of POPs • Dust formation • Noise production • Ecosystems: • Loss of ecological valuable areas • Ecotoxicity to terrestrial life • Ecotoxicity to aquatic life

• Land use: • Land use change • Loss of sites with archaeological, historical and cultural value • Man and his socio-economic living environment: • Direct health risks (direct exposure) • Indirect health risks • Nuisance (dust, noise) • Social effects (resettlement) • Social effects (employment) • Social effects (other)

• Depending on the type of project, some disciplines may be excluded from the impact assessment. Based on the scoping results, only those disciplines for which potential environmental impacts “x” and potential environmental impact not likely to occur “(x)” are indicated should be included in an impact assessment: PCB Management Project or Sub-Project PCB Treatment and Disposal Project or Sub-project Site Remediation Project or Sub-project

For each of the specified subtask, see Table 0-1 For each of the specified subtask, seeTable 0-2


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3.4. SCREENING PROCEDURE FOR SITE SPECIFIC PROJECTS AND INVOLVEMENT OF DIFFERENT PARTIES

Figure 3-4: Screening procedure for site specific projects

World Bank: As category B project, all site specific projects will require an EIA to meet with the bank requirements. The facilities owner will need to prepare EIA in English and submit to the Bank for their internal approval. The PMU is responsible for proposing scope and TOR of

VEA MOIT EVN People’s Committee

(PC)

WB

PMUs inform the WB the disclosure

situation

WB issues No Objection

No No

VEA PMU / EVN PMU

Facility owner and independent consultant develop EIA to comply

with the WB’s requirement

Facility owner develop EPC to comply with the

government’s requirement

Submit to the WB

Submit to the PC

Review of WB Review of PC

Review satisfactory?

Review satisfactory?

Approved EIA Approved EPC

Disclosure by facility owner

YES YES

PMUs supervise

all activities of the process


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EIA, which must be agreed by the WB later on. In the framework of the PCB Management Demonstration Project, this EIA will include an EMP. When TOR is developed, the facilities owner may consider hiring an independent consultant to develop an EIA based on this EA framework. If the EIA report is not acceptable to the WB, the bank will send it back to the facilities owner for revision. In case that EIA is approved by the WB, the facilities will be responsible for translating it into Vietnamese and for disclosing it on the location of the project and on the website of VEA. The disclosure information will be sent to the WB, including where and when the EIA report was disclosed. Vietnam: As mentioned in previous sections, all subprojects under current design would not fall into listed projects which require EIA according to Vietnam regulations. Instead, the project owner needs to prepare an EPC to meet with requirements of government regulations. All necessary steps to comply with requirements specified in LEP 2005, Decree 80/2006/ND-CP, Decree 21/2008/ND-CP and the Circular 05/2008-TT-BTNMT are described below: The facilities owner will prepare an EPC dossier in Vietnamese and submit to the People’s Committee at the district level or authorized People’s Committee at commune level where the project is executed. The EPC dossier consists of:

��01 copy of recommendation form for certifying EPC according to Annex 25 of the Circular 05/2008-TT-BTNMT

��05 copies of EPC with the structure and content according to the Annex 24 and Annex 26 of the Circular 05/2008-TT-BTNMT of the Ministry of Natural Resources and Environment. Since the content of EPC can be made based on the information of EIA submitted to the bank. The PMU will take the responsibility of translation and adapt to make the required EPC.

��01 copy of project document.

The time for registration of EPC for certification is before applying for construction permits. In case it does not require construction permits, it should be submitted before commencing the projects.

In case of a qualified dossier, the People’s Committee at district or commune level is authorized to certify, register the environmental protection commitment of the project owner according to a structure as stipulated in Annex 27 of Circular 05/2008-TT-BTNMT. In case of registering and certifying at district level, the People Committee at district level sends one certified dossier of environmental protection commitment together with the certificate document to the project owner for implementation. When the EPC dossier is approved by the People’s Committee, the PMU is responsible for informing the WB about the situation. It will help the bank in making decision to issue the No Objection for the project. It should be noted that there are differences between projects implemented in EVN and non EVN – sites. While in EVN sites, the PMU of EVN will take the responsibilities of helping facility owner in drafting and submitting of EIA for the Bank requirements as well as EPC dossier for Vietnam government, the PMU of VEA and MOIT will takes that responsibilities for project undertaken in non EVN sites.


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Project description

OVERALL PROJECT OVERVIEW: PCB MANAGEMENT DEMONSTRATION PROJECT The project aims to assist Vietnam to establish a sound PCB management system that would minimize potential environmental and health risks from unmanaged PCB oils and equipment. In so doing, the project is designed to establish a sound PCB management in the country. This would entail significant investment in PCB management infrastructure and strengthening of limited technical and management capacity of all key stakeholders including the public and private sectors in Vietnam. The project will develop a National Action Plan for sound PCB management and initiate implementation of the first phase of the Action Plan. Recognizing the need for better understanding of PCB situation in Vietnam, the project will give priority to the development of a comprehensive PCB inventory and reporting system, strengthening of PCB regulatory, institutional framework, analytical capacity, good practices for operating, handling, labelling, transporting, maintenance, and storage of PCB equipment and wastes. Site-specific PCB management systems including a reporting framework consistent with the policies and regulations to be established as part of this Project will be tested in selected facilities in 10 demonstration provinces. Experience and lessons learned from these specific facilities would be used to refine the Vietnam sound PCB management system before the system is applied nationwide on a mandatory basis. One of the elements in the site-specific PCB management system includes development of a maintenance and retirement schedule for PCB equipment. The maintenance and retirement schedule will take into account Vietnam’s obligations under the Stockholm Convention and any PCB oil and equipment phase-out policies to be recommended by this Project. This information would provide Vietnam with an estimate of waste matrices and waste stream. This improved understanding of PCB equipment and wastes along with the country’s overall plan for hazardous waste management, would enable Vietnam to determine cost-effective and environmental friendly treatment and disposal options for the next phase of the sound PCB Management Action Plan. The Project consists of five components:

1. PCB Management Framework and Action Plan; 2. PCB Management Demonstration; 3. Institutional Strengthening; 4. Monitoring and Evaluation; 5. Project Management.

The project components with potential environmental and social impacts include: • Component 1: “Development of PCB management framework”: This assessment has been completed

satisfactorily under TF1 “$VVHVVPHQW�RI�SROLF\��UHJXODWRU\�DQG�OHJDO�IUDPHZRUN�IRU�3&%�PDQDJHPHQW”. The executive summary of the policy assessment report is given in chapter 0.

• Component 2: “Demonstration of PCB management”, which will support in the demonstration provinces:

- physical improvement of existing storage facilities; - identify, label, maintain, and service in-use PCB equipments; - transport and storage of retired PCB equipment and oils, and wastes;

Component 3, 4 and 5 also have an indirect impact on environmental and social conditions but are not subject to environmental and social impact assessment according to Vietnamese and World Bank rules. However, in case tasks as described in component 3, 4 and 5 appear in site


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specific PCB management projects, they will be covered as one integrated part in the impact assessment. The second component, “PCB Management Demonstration project”, proposes to conduct implementation of PCB management activities from identification to safe storage of PCB oils, equipment, and wastes for final disposal. Procedures for implementing these activities will strictly follow the regulations and guidelines developed under the component 1 (PCB Management Framework and Action Plan) of this project. Pilot implementation of these PCB management activities would be conducted at 9 selected facilities within the eleven demonstration provinces: • Ha Noi; • Hai Phong; • Hai Duong; • Quang Ninh; • Nam Dinh; • Ho Chi Minh City; • Dong Nai; • Ba Ria – Vung Tau; • Can Tho; • Lam Dong - Da Lat; • De Nang. In the framework of the PCB management and disposal project, different activities may be carried out that imply environmental impacts. It concerns all kinds of activities related to PCB management on the one hand and activities related to (pre)treatment, disposal and remediation of PCBs on the other hand.

PROJECT ACTIVITIES RELATED TO PCB MANAGEMENT PCB management activities with an environmental impact potential include all activities: • related to the identification and inventory of PCBs and PCB containing products or equipment, like

testing of equipment, sampling and analysing oils, proper labelling of PCB-free and PCB-containing equipment,

• related to the proper handling of PCBs, PCB-containing products or equipment and PCB-waste, like packaging, collection and transportation, temporary storage at the place of origin of the waste preceding collection, temporary storage preceding final disposal operations or final storage,

• related to reuse and recycling of PCBs and/or equipment, including decontamination techniques, recycling of equipment and of oils, retrofilling, maintenance on PCB-containing equipment.

Issues related to PCB treatment and disposal operations are described in chapter 0. Up to date PCB management in Vietnam is in its initial phase. Through the Ministry of Natural Resources and the Environment (MONRE) a “Vietnam National Implementation Plan for Stockholm Convention on Persistent Organic Pollutants Toward 2020” has been developed, approved and submitted (NIP, 2006). In this plan it is outlined how POPs will be managed, reduced and eventually eliminated. Today an initial inventory has been conducted in Vietnam which indicated that approximately 1,800 capacitors and 10,000 transformers contain PCB’s. The quantity of estimated oil amounts up to 7,000 tonnes. It should be stressed however that the inventory is not complete so that the PCB contaminated oil will be substantially higher i.e. estimate of 13,000 tonnes (SNC-Lavalin, 2007).


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In the framework of the “PCB management and disposal project” Venitco is actually further inventorizing and analysing PCB containing equipment, in particular capacitors and transformers. Other management practices are for the moment not developed in Vietnam. From site visits it indeed appeared that storage conditions are far from ideal, transformers in some cases being stored on bare soil without protection and being exposed to weather conditions. Recycling activities are carried out without much care and sensibilisation of the works as such leading to potential exposure.

Identification of PCB-containing products and equipment An effective policy on PCB management and disposal starts with a thorough identification of PCB containing equipment and wastes. A distinction between PCB-containing and PCB-free materials can be difficult, for following main reasons: • PCBs can be present in waste from old ‘open’ applications, dating from a period where the use of

PCBs in specific applications was common practice, but for which the use has stopped or has been forbidden for a longer time. E.g. PCBs have been used in paints and glues used between 1960 and 1980, and they will still be found occasionally in construction and demolition waste as it precipitated into concrete. It is however very difficult to screen all construction and demolition waste on the presence of PCBs.

• PCBs can be found in recycled oil products, where non PCB-containing oils and PCB-containing oils have been recycled together and a dilution of PCBs has been taken place.

When confronted with this problem on identification of PCB-containing waste, a choice can be made based on a risk assessment between two approaches • The application of the precautionary principle, with the treatment of the whole waste fraction under a

worst case scenario, as if it contained PCBs. This can be advised for high risk waste streams for which treatment under a worst case scenario could turn out more economically than testing all individual wastes. It should be examined if this is an appropriate approach for waste oils.

• A follow up with random spot checks to manage the probability and the risk of encountering PCB-containing wastes. This might be an appropriate approach for wastes possibly contaminated by ‘open’ use of PCBs.

PCB can be mainly found in following ‘closed’ applications: • Electrical transformers, in which PCB containing oil is deliberately applied as a dielectric fluid. An

identification plate can sometimes identify these transformers. Well known mark names for PCB-containing fluids are: askarel, pyraleen, chlophen, …;

• Electrical transformers, in which no PCB containing oil is applied deliberately, but where the oil might be contaminated with PCBs during maintenance works. An identification plate will not exclude the presence of PCBs. Testing might be necessary;

• Industrial electrical capacitors with more than 1 litre of PCB-containing oils; • Small scale capacitors in older electrical household equipment; • Other electrical components like fluorescent tube ballasts, voltage regulators, electromagnets,

switches, circuit breakers, rectifiers, vacuum pumps, liquid filled electrical cables,…; • Hydraulic systems and heat transfer systems. PCBs can also be found in ‘open’ applications like lubricants, plasticizer and flame retardants, paints, printing inks, varnish, wax, glues, fill mortar, wood conservation agents, chlorine bleached paper … .


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Testing PCB content of products and oils When the PCB content cannot be derived from the age or nature of the waste or equipment, testing on PCB content can be useful to determine the PCB content. The Stockholm Convention considers an upper limit value of 0.005 % of PCBs in liquids (Stockholm Convention annex A points (d) and (e)). The USA has not yet implemented the Convention. The European POPs Regulation 850/2004, implementing the Convention, considers a waste as PCB-containing if it contains more than 15 µg/kg. The limit is calculated as PCDD and PCDF according to the following toxic equivalency factors (TEFs):

TEF PCDD 2,3,7,8-TeCDD 1 1,2,3,7,8-PeCDD 1 1,2,3,4,7,8-HxCDD 0.1 1,2,3,6,7,8-HxCDD 0.1 1,2,3,7,8,9-HxCDD 0.1 1,2,3,4,6,7,8-HpCDD 0.01 OCDD 0.0001 PCDF 2,3,7,8-TeCDF 0.1 1,2,3,7,8-PeCDF 0.05 2,3,4,7,8-PeCDF 0.5 1,2,3,4,7,8-HxCDF 0.1 1,2,3,6,7,8-HxCDF 0.1 1,2,3,7,8,9-HxCDF 0.1 2,3,4,6,7,8-HxCDF 0.1 1,2,3,4,6,7,8-HpCDF 0.01 1,2,3,4,7,8,9-HpCDF 0.01 OCDF 0.0001

6DPSOLQJ�Usually sampling of PCB oils in transformers is a non destructive technique that can be combined with maintenance of the equipment. Sampling on other electrical equipment can be combined with the process of dismantling and decontamination. Sampling on PCBs from open applications usually includes the collection of a representative amount of well chosen waste fractions.

7HVWLQJ�WHFKQLTXHV�Following standards can be used for the testing of PCB content in oils: • For PCBs in insulating liquids in transformators, capacitors…: EN61619; • For PCBs in oil waste and petrochemical products: EN12766-1 and prEN12766-2. The total amount is the sum of all identifiable and quantifiable congeners. Oil samples are diluted in hexane and analysed using gas chromatography with a mass spectrometric detector or an electron capture detector ECD, after cleaning the sample using silica/H2SO4 silica NaOH, or using silica/sulphate silica/benzene sulphonic acid.


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Labelling of PCB-free and PCB-containing equipment and waste The labelling of PCB-containing equipment or tested PCB-free equipment needs to be reliable in order to achieve a correct waste treatment chain. All actors involved, generators, collectors, waste sorting facilities, waste pre-treatment- recycling- or disposal facilities should at every moment be able to make a distinction between PCB-containing equipment and PCB-free equipment based on reliable labels. This will be useful to avoid mixing the waste or the waste oils in the decontamination and treatment phases.

Packaging and collection of PCB-waste Packaging of PCB-containing waste can serve two purposes. It can be useful to separate PCB-containing waste from non PCB-containing waste, and it can be necessary to avoid leaching or dispersion of PCBs in the environment during the waste storage and treatment chain. Depending on the nature of the waste, different packaging strategies can be used. When liquid waste is packed, reusable drums can be used. It should be guarded that they are not reused to pack non PCB-containing materials except if they have gone through a proper decontamination operation, like solvent washing with proper treatment of the PCB-containing solvents (see paragraph 0). When non reusable packaging is used, it can be necessary to treat them as PCB-containing waste if they have made contact with the PCB in the packed waste. Collection of PCB-waste is preferable performed by professional companies or organisations experienced in waste handling and handling of hazardous substances. A call system seems appropriate, because PCB-containing waste is generated occasionally by taking equipment out of use. It is not a regular waste fit for a periodical collection (weekly, monthly collection). Potentially PCB-containing waste from households can be collected through a bring system e.g. for electrical equipment or for private construction and demolition waste.

Transportation of PCB-waste

*HQHUDO�FRQGLWLRQV�Key elements that have to be taken into account when shipping hazardous substances relate to: • Requested or useful documentation and safety sheets that should accompany the transport; • Technical equipment of the transport means, avoiding or limiting damage by precipitation of the

hazardous substance in the environment and avoiding health risks for the driver and the society, in case on normal use and in case of an accident;

• Adequate packaging; • Labelling; • Safe and stable loading conditions; • Level of expertise and training of the driver and the loaders; • Transfrontier shipment. As described in paragraph 0, transfrontier shipment, mainly to incineration plants in industrialised countries, can be a valuable alternative for local waste treatment. Vietnam is member of the Basel Convention since 13.03.1995, but no export of hazardous waste has been reported under the procedures of the Convention. According to the Convention article 4.2: ”Each Party shall take the appropriate measures to (e) Not allow the export of hazardous wastes or other wastes to a State or group of States belonging to an economic and/or political integration organization that are Parties, particularly developing countries, which have prohibited by their legislation all imports, or if it has reason to believe that the wastes in question will not be managed in an environmentally sound manner, according to criteria to be decided on by the Parties at their first meeting.” Export of hazardous


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waste, if acceptable, should always be accompanied by a procedure of consent of the involved parties as regulated by the Basel convention. Vietnam has not yet ratified the Ban-amendment, adopted at the Second Conference of the Parties to the Basel Convention (COP2), 25 March 1994 in Geneva in which the parties decided: • to prohibit immediately all transboundary movements of hazardous wastes which are destined for

final disposal from OECD to non-OECD States; • to phase out by 31 December 1997, and prohibit as of that date, all transboundary movements of

hazardous wastes which are destined for recycling or recovery operations from OECD to non-OECD States.

Transfrontier shipment of PCB-waste entering Vietnam from an OECD-country could be avoided, although the Ban amendment has not yet entered into force. Export of PCB-containing waste is legally allowed to all countries that under the Basel convention gave permission on import, but sustainable waste management practices could, under application of article 4.2 and in line with the idea of the Basel-ban, limit this export to OECD-countries.

Temporary storage of PCB-waste Temporary storage of PCB-containing waste takes place at two different moments in the waste treatment chain. Before the waste is collected and after collection before the waste is properly treated.

%HIRUH�FROOHFWLRQ�Temporary storage takes place at the premises and under the responsibility of the generator of the waste. Decommissioned PCB-containing equipment, mainly transformers or industrial capacitors, sometimes stay at the place where they were used, and will only be disposed of at the moment of demolition. In Vietnam however, decommissioned transformers and capacitors are in general stored in storage yards in various provinces (i.e. Nam Dinh, Ho Chi Minh City, Da Nang, …). Storage conditions may however in some cases be quite poor. Other PCB-containing waste can be temporarily stored with the other waste waiting for a periodical industrial waste collection or waiting for proper transport to a waste treatment or disposal facility. The quantities of stored waste will be rather limited and will only include the locally generated waste. The quality of waste storage depends upon the management. In optimal conditions waste should be stored in a sheltered and guarded place with an impermeable floor and equipped with technical measures to remediate accidental spills or leakage of liquids. The temporary storage should be limited in time, and should be managed in a way that avoids environmental damage and that avoids the mixing of waste.

%HIRUH�GLVSRVDO�Waste can be temporarily stored after collection when the waste treatment capacity is not able to immediately treat an accidental higher supply of waste. Temporary storage is necessary for all processes where the waste is generated or collected in a discontinuous way, e.g. when equipment is deactivated or when a collection campaign has taken place, and the waste treatment technique is a continuous process treating smaller amounts at the time. A balance is needed between the temporary storage and the waste treatment, avoiding that the temporary storage is growing above the yearly treatment capacity. On the other hand temporary storage can be necessary to collect an amount of waste that makes treatment technically feasible or economically acceptable. This is necessary when the waste generation or collection is a continuous process where very regularly small amounts of waste are collected (e.g. from a lot of different SMEs) and the treatment process is operating discontinuously, treating larger batches of waste.


35

Temporary storage can take place under the responsibility of the waste collector or the waste treatment centre. The same precautionary measures as described above will be necessary, but on a larger scale. Waste streams from different producers will be combined in the temporary storage, which requires a well managed supervision not to allow unfavourable mixtures of waste of a different nature. When appropriate waste treatment capacity is not yet available, temporary storage can be a solution to wait for planned investments in final disposal infrastructure to become operational. The European Commission uses in its Landfill Directive 1999/31/EC a threshold value on three year allowable temporary storage for non hazardous waste and one year temporary storage for hazardous waste. If the temporary storage of waste is longer than these thresholds, the installation is considered to be a landfill and it has to fulfil all more stringent exploitation conditions of a landfill. The US (Code of Federal Regulation: 40 CFR Parts 264 and 265, on http://www.ega.gov/osw/inforesources/pubs/orientat/rom35.pdf) defines storage as “holding hazardous waste for a temporary period, after which the hazardous waste is treated, disposed of, or stored elsewhere temporary. The temporary period is not limited in time. If transporter storage at a transfer facility exceeds 10 days, the transfer facility becomes a storage facility. Temporary storage is in both approaches only acceptable if a final disposal operation will be realised within a limited timeframe. If final disposal is not foreseen or if final disposal will only be realised at an undefined moment in future, solutions other than temporary storage (e.g. export) will have to be found in a transitional period.

Recycling

5HF\FOLQJ�3&%V�DV�3&%�As the use of PCBs is forbidden under the Stockholm Convention (article 3: parties should prohibit and/or take the legal and administrative measures necessary to eliminate the production and use of PCB), recycling of PCBs is not allowed. However this recycling prohibition is refined in part II (d) of Annex I (d) of the Convention: “Except for maintenance and servicing operations, not to allow recovery for the purpose of reuse in other equipment of liquids with polychlorinated biphenyls content above 0.005 per cent”. Recycled PCB may be applied for the maintenance and servicing operations on equipment that can operate until 2025. Recycling of PCBs should therefore be very well regulated and limited to the quantities needed for the purpose of maintenance and servicing.

5HF\FOLQJ�PDWHULDOV�FRQWDPLQDWHG�ZLWK�3&%V�PCBs can be fully removed from equipment; • by disassembly of electrical equipment (see paragraph 0); • by applying a preparatory activity based on media transfer technologies like thermal desorption,

solvent washing or adsorption/absorption techniques (see paragraphs 0, 0 and 0). Once these operations have been performed, the remaining metals or materials can be fit for reuse or recycling. Also residues from a PCB disposal operation can be fit for recycling. Because of the high value of metal scrap, shredding and recycling transformers and other electrical equipment becomes economically attractive. Therefore is should be avoided that non decontaminated equipment enters into the recycling circuit.

5HWURILOOLQJ�Reuse on decontaminated transformers can be achieved by applying retrofilling techniques. Since the production of PCB-containing fluids was discontinued, several dielectric fluid options have emerged. Replacement fluids should perform well in the field of electrical properties,


36

physical traits, use with switching operations, maintenance and environmental fate. They need to have similar dielectric properties, similar stability, similar fire safety and should be less toxic or persistent. The four predominant synthetic and natural materials that lend themselves to fire-resistant dielectric applications are organic polyol esters, silicone-based fluids, less flammable petroleum oils, and synthetic hydrocarbons. Mineral oils and silicones are categorised as a ‘less flammable’ substitute and are widely used in transformers. ‘Non-flammable’ substitutes are: • Perchloroethylene (PCE) which is the most common PCB substitute but which still has many of the

properties that caused PCBs to be banned. • Trichlorobenzene (TCB) which is slightly less popular than PCE and which can create dioxins under

arcing conditions. • Tetrachloroethylene under the trade mane of Wecosol. This product is used for over 50 years and

remains stable. The basic steps in a retrofil operation are: • Perform electrical tests; • Check for any necessary gasket or bushing replacements; • Flush with new, PCB-free mineral oil dielectric fluid; • Fill with new PCB-free mineral oil dielectric fluid; • Test for residual PCBs. The decision to retrofil can be based on following considerations: • Cost; • Equipment usage; • Effectiveness of retrofilling process; • Disposal options for PCB liquids; • Liability; • Public perception; • Equipment downtime; • Viability of the replacement fluid; • Availability of PCB substitutes.

PROJECT ACTIVITIES RELATED TO PCB TREATMENT AND DISPOSAL PCB treatment and disposal activities with an environmental impact potential include activities likely to be operated in Vietnam, as identified by SNC-Lavalin (2007), that can be performed on-site or more likely off-site in specialised treatment facilities, disregarding the nature of the PCB-containing waste that has to be treated. The evaluation of SNC-Lavalin is recapitulated and added in this chapter. The recommendations of SNC-Lavalin have been taken into consideration; only treatment techniques are described that are likely to be applied for in Vietnam. Other techniques will not be subject of an EIA in Vietnam.

Pre-treatment techniques The treatment of hazardous waste usually can be described as a chain of different process steps, where the waste is pre-treated to give it the appropriate physicochemical properties, (size, state of aggregation, water content, concentration or solution, acidity, calorific value, …), next the waste is handed over for its actual disposal operation and hereafter the disposal residues can be submitted to another waste treatment installation. These subsequent treatment steps can take place either in one plant or in several spatially separated installations.


37

The pre-treatment techniques described below can be combined with the disposal operations described in the next paragraphs, depending on the nature of the waste.

Table 0-1: Matrix of pre-treatment and treatment techniques

Alka

li re

duct

ion

inclu

ding

so

dium

Base

ca

talys

ed

deco

mpo

sitio

n pr

oces

s (B

CD)

Cem

ent k

iln c

o-pr

oces

sing

Gas

Phas

e Ch

emica

l re

duct

ion

(GPC

R)

Plas

ma

arc

deco

mpo

sitio

n

Wet

air

oxid

atio

n

Dewatering X X X Electrical equipment disassembly

X X X X X X

Shredding X X X X X Screening X X X X X Oil/water separation X X X pH adjustment X X Soil washing X X X X X Thermal desorption X X X X Solvent washing X X X X Adsorption/absorption X X X Depending on the size of the required installation and the complexity of the applied technique some pre-treatment techniques can be applied on the spot where the PCB-containing waste or soils originate from, while other techniques are strictly connected to or integrated with a treatment or recycling technique off-site. Most techniques are fit for both an on-site or off-site configuration.

'HZDWHULQJ�Dewatering is a pre-treatment approach that partially removes water from the wastes to be treated. Dewatering can be employed for destruction technologies which are not suitable for aqueous wastes (e.g. molten sodium), for which dewatering can serve to augment the calorific value, for which dewatering is an interesting technique to reduce size and quantity of the waste to be treated or to change the state of aggregation (e.g. solid versus liquid). Both resulting waste streams, the soil/solids and the water/liquids, will likely require treatment after separation. There is wide-variety of dewatering techniques that depend on the matrices being treated. Soil de-watering techniques include plate-and-frame filter presses, drum filters, vacuum filters, centrifuges and many other systems. Selecting the systems for remediation is dependent on the characteristics of the waste to be treated (water content, particle size and distribution, through-put, end-point conditions, etc.). Thermal systems commonly called driers can also be used for dewatering. These technologies are well-developed and commercialized. The most important potential source of pollution from dewatering is the waste water stream. Improper removal of waste water might cause surface water contamination and as a consequence ecotoxicity to aquatic life and indirect health risk to man.


38

(OHFWULFDO�HTXLSPHQW�GLVDVVHPEO\�Large and medium-sized liquid-filled transformers comprise steel vessels, containing the dielectric fluid, windings and supports (lumber and paper). Once the oil has been drained, the transformers can be broken down. Lumber and paper can be separated and contained for destruction. The cores have proven resistant to solvent washing and also require a multi-stage pretreatment approach which includes shredding, as well as the application of a direct destruction technology (i.e. incineration). The steel vessels, often referred to as hulks or carcasses, can be solvent washed (see 0) or subject to a destruction technology. Other, smaller scale electrical equipment can contain PCBs in quantities less than 1 litre PCB-containing oils. Mainly small sized capacitors in fridges, washing machines, fluorescent lighting ballasts, public lighting armatures, industrial applications like power-current compensating capacitors for electrical installations, UPS emergency power supply on batteries, small one-phase motors for pumps or fans with a fixed capacitor, larger thyristor rectifiers (filter capacitors). Most small PCB containing household equipment has an age of above 20 years as production ceased long time ago. However, hazardous components, including PCB-containing capacitors, should be removed from electrical and electronic waste before further treatment. Small capacitors in fluorescent lighting ballasts can be broken down with the objective of size reduction. Mobile trailers have been specifically designed for the disassembly of fluorescent lighting ballasts. As long as electrical equipment disassembly is executed on an impermeable surface, no major pollution sources are expected from this pre-treatment technique.

6KUHGGLQJ�Some technologies are only able to process wastes within a certain size limit. For example, some will handle PCB contaminated solid wastes only if less than 200 microns in diameter. Shredding can be used in these situations to reduce the waste components to a defined diameter. By reducing particle size, shredding creates more surface area, increases exposure to treatment chemicals or systems (heat, light, etc.). Small solid parts, such as capacitor pans from fluorescent lighting ballasts, are more accessible to treatment after they have been shredded as the oil is no longer encased in metal. Shredding can be a pre-treatment method for all solid PCB-containing waste. Next to the electrical equipment and its components it can be applied to open applications. PCBs used to have a broad field of application, not only as an isolating fluid in capacitors and transformers, but also as a hydraulic oil, coolant, lubricant, plasticizer in plastics, as a composing element in paints, inks, varnish, glue and adhesives. If shredding takes place on a hardened surface, no major pollution sources are expected. If not, this technique can cause soil and groundwater pollution. In badly insulated conditions, noise production can be relevant.

6FUHHQLQJ�Screening as a pre-treatment step can be used to remove debris from the waste stream or for technologies that may not be suitable for both soils and solid wastes. There are several screening technologies commercially proven and developed including grizzly screens, drum screens and vibratory screens amongst others. Such screening systems are widely available and commonly used in waste management and remediation operations. No major pollution sources are expected from this pre-treatment technique.

2LO�ZDWHU�VHSDUDWLRQ�Oil/water separation is necessary for those treatment processes which are not suitable for aqueous wastes (e.g. molten sodium) or which are not suitable for oily wastes. Both the water


39

and the oily phase may be contaminated after the separation and both may require a specific treatment. PCBs are lipophylic/hydrophobic. They tend to partition to oils and fats and away from water, which makes oil-water separation technology an interesting pre-treatment technique in the treatment chain to concentrate the PCBs. Oil/water separation is an old technology with many commercially proven and developed options. The selection of specific systems depends on material and sizing characteristics. Common oil/water separation systems include baffled gravity separators, skimmers and far more complicated systems such as centrifuges. Chemical treatment may be required to remove soluble oils or disperse colloids. The most important potential source of pollution from the oil/water separation pre-treatment technique is improper removal of the water or oily phase. This might lead to surface water contamination, ecotoxicity to aquatic life and even indirect health effects.

S+�DGMXVWPHQW�Some treatment technologies are most effective in a defined pH range and in these situations, caustic, acid or CO2 are often used to control pH levels. Some technologies may also require pH adjustment as a post-treatment step. As PCBs are neither basic nor acidic, their presence does not influence the pH itself, but other components in a wastewater stream may do so, particularly for such technologies as sodium reduction. No relevant pollution sources are expected from this pre-treatment technique.

/RZ�WHPSHUDWXUH�WKHUPDO�GHVRUSWLRQ��/77'��Low-Temperature Thermal Desorption (LTTD) is a media transfer technology, also known as low-temperature thermal volatilization, thermal stripping or soil roasting. It is used as an ex-situ remediation technology that uses heat to physically separate volatile and semi-volatile compounds and elements (most commonly petroleum hydrocarbons) from contaminated media (most commonly excavated soils). The same techniques can also be used for the decontamination of non-porous surfaces of electrical equipment such as transformer carcasses that formerly housed PCB-containing dielectric fluids. For soil, two common thermal desorption designs operating as continuous process are rotary dryers and thermal screws. Rotary dryers are horizontal cylinders that can be indirectly or directly-fired and are usually fuelled by natural gas or fuel oil. The dryer is normally inclined and rotated to ensure good mixing of the material being treated. In thermal screw units, hollow augers known as screw conveyors, transport soil through an enclosed trough. Hot oil or steam is circulated through the auger to indirectly heat the soil. For electrical equipment, batch desorbers are used. The difference between thermal desorption units and incinerators is the end point objective which determines the temperature to which the material is raised. LTTD only volatilizes contaminants, hence, has lower temperatures than incinerators. Although the solid phase, whether soil or electrical equipment would no longer be considered “contaminated”, the vapour stream requires further treatment as all contaminants have been transferred to this phase. The method of treatment is dependent on the nature of the contaminant, concentration and other physical factors. For PCBs, vapours are commonly incinerated at high temperatures, although absorption by activated carbon is possible for low concentration vapours. If the gas phase is subject to condensation or scrubbing, further treatment of the concentrated liquid state by a non-combustion technology is possible. Potential pollution sources for this pre-treatment technique are the vapour phase, which has to be treated properly, and in some cases concentrated liquids.


40

6ROYHQW�ZDVKLQJ�Electrical equipment such as capacitors and transformers are difficult to treat, but if PCBs are removed by solvent, the contaminated solvent has many disposal options. This technology has also been used successfully for the treatment of contaminated soil. It is fit for PCB removal from containers (i.e. drums) and electrical equipment (i.e. transformer carcases, capacitors, etc…). Although occasionally adequate for casings, the internal components of the transformers (core and windings) fail to meet objectives when a traditional technique of soaking the equipment with solvents is used. Autoclaving is a batch process using solvent to extract PCBs from electrical equipment. The system works in cycles. After loading the waste to be cleaned, a vacuum is applied and solvent charged. The chamber is heated to drive off water. The solvent, containing PCBs, is drained and distilled to produce clean solvent for re-use and PCB wastes for further treatment (generally high temperature incineration or alkali reduction). The techniques of solvent washing have problems to compete with less laborious techniques with higher efficiency like waste incineration which can cope with the entire equipment, possibly after shredding. The most important pollution source of solvent washing is the contaminated solvent. In case the solvent is not treated well, it might cause surface water pollution, ecotoxicity to aquatic organisms and indirect health effects.

$GVRUSWLRQ�DEVRUSWLRQ�Sorption is the general expression for both absorption and adsorption processes. Sorption is a pre-treatment method that uses solids for removing substances from gaseous or liquid solutions. Adsorption involves the separation of a substance (liquid, oil) from one phase and its accumulation at the surface of another (zeolite, silica, etc.). In the case of absorption a material is transferred from one phase to another, interpenetrates the second phase to form a solution (e.g. organic compounds such as PCBs transferred from liquid or vapour phase into activated carbon). The sorbent then requires treatment to destroy the contaminant. For activated carbon contaminated with PCBs, incineration is commonly used. These pre-treatment technologies may be used to concentrate contaminants and separate them from aqueous wastes. The concentrate and the adsorbent or absorbent will require destruction treatment. Sorption pre-treatments should produce wastewater which meets discharge criteria if initial concentrations are low. There are several sorption technologies commercially proven and developed. Potential pollution sources are improper removal of sorbents and wastewater. Removal of sorbents might cause soil and groundwater pollution. Discharging of untreated wastewater can be the cause of surface water pollution, ecotoxicity to aquatic organisms and indirect health effects.

Alkali reduction including sodium Sodium reduction technology is a technique applicable mainly for PCB removal from oil transformers. It is a variant of a technique where sodium ions are solvated in ammonia, but here no ammonia is used and the sodium ions are solvated in the oil itself. The solvated electrons in the solution act as powerful reducing agents removing the halogens (primarily chlorine) from the PCB molecules. The sodium reacts with the chlorine atoms in the PCBs to form non-toxic salt and biphenyls. The solvated electron reaction is highly exothermic. In application, contaminated oil is placed into a sealed treatment vessel and mixed at room temperature, and brought into contact with the solvated electrons. Depending on the matrices treated, pre-treatment and/or post-treatment may be required. Possible pre-treatments are water removal, crushing, screening and washing. Possible post-treatments include pH adjustment. Most of this processed oil can be resold as reclaimed oil and return to service.


41

Treatment systems using this technology are both transportable and fixed. A mobile system in operation has a capacity of 15,000 litres of oil per day. The process is patented and has a destruction efficiency estimated by SNC Lavalin of 95 % to 99 %. A similar approach is the dechlorination of organic compounds in mineral oils which can be undertaken by alkalis other than sodium. The use of potassium tert-butoxide (t-BuOK) has been commercialized in Japan since 2004. There is one operating plant treating 36,000 l/day. Destruction efficiencies of 99.98 % to 99.99 % were reported. Sodium is a hazardous, reactive element and it is a challenge to manage the reagents involved in the treatment process safely. Potential impacts related to alkali reduction (reduction destruction method) are summarised in Table 5-2.

Base catalysed decomposition process (BCD) The Base Catalyzed Decomposition process treats liquid and solid wastes in the presence of a reagent mixture consisting of a high boiling point hydrocarbon, an alkali (sodium hydroxide or sodium bicarbonate) and a proprietary catalyst. When heated (315 to 500 ºC), the reagent produces highly reactive atomic hydrogen, which reacts with organochlorines and other wastes. The residues produced from decomposition are an inert carbon residue and sodium salts. After the reaction, solid residues are separated from the residual oil by gravity or centrifugation. The oil and catalyst may be recovered for reuse. The operation of this process can be either on a continuous basis or by batch. In practice, the contaminated liquid is pumped into a heated reactor containing the hydrocarbon oil, sodium hydroxide and the catalyst. The reaction is rapid. For solid waste treatment, the waste needs to be premixed with the catalyst and fed into a heated thermal desorption unit. Depending on the pollutant concentration in the feed, some can be collected from the thermal desorption condensate. If the contaminant level is high and the decomposition is not complete, then the resulting condensate is treated in a liquid BCD reactor. Some pre-treatment may be required depending on the waste to be treated. The possible pre-treatment steps include premixing, shredding, screening and dewatering. The destruction efficiency of this proven technology is very high (99.9999 %). The process can treat 100 kg/h to 20 t solid waste /h on a continuous basis and 1 to 5 t solids/batch with 2 to 4 batches a day. For liquid waste, the capacity is typically 4,500 to 9,000 l with 2 to 4 batches a day. Higher concentrations in the waste require longer reaction time. The possible configuration of the technology ranges from modular to transportable units as well as fixed plants. The technology requires the use of chemical products in large quantities, which requires skilled operators and well-defined safety procedures. Further analysis of the material could be required since the condensate has to be treated if concentrated in the contaminants. There was a measurable discharge of dioxins and organochlorines to the atmosphere for the older plants but this problem has been addressed by the replacement of the old hydrogen donor with the hydrocarbon oils now in use. The air emissions are as low as monitoring equipment can detect and ancillary liquid and gas scrubbing units further minimize pollution risks. Potential impacts related to the base catalysed decomposition process, are summarised in Table 5-2 (reduction destruction method).

Gas Phase Chemical reduction (GPCR) The GPCR process is a two-stage process, beginning with heating the waste in the absence of oxygen to temperatures around 600 ºC, causing organic compounds to desorb to the gas phase. The solid or liquid phase of the waste is treated and cooled for non-hazardous disposal. In the second stage, a gas-phase thermo-chemical reaction of hydrogen with organic compounds occurs at a high temperature (approx. 850 °C) in a reaction vessel. The organic compounds are reduced by the hydrogen to methane, hydrogen chloride and minor amounts of low molecular weight


42

hydrocarbons in the GPCR reactor. The reduced gases are then scrubbed to remove the particulates and acid before being stored for reuse as a fuel. The process can also operate without any external hydrogen supply if the methane produced, is converted back to hydrogen. As this reduction reaction occurs in the gas phase, pre-treatment is required for liquid and solid wastes These pre-treatments (vaporizer, thermal desorption batch processor (TRBP), TORBED Reactor Systems and liquid waste pre-heater systems (LWPS)) are part of the GPCR technology. The water and aqueous solutions could be evaporated using a steam heated vaporizer and then fed into the process. The bulk solid wastes are processed via a Thermal Reduction Batch Processor (TRBP) or thermal desorption, which is an oven-type chamber where the contaminants are volatilised. The organic vapours are then sent to the GPCR reactor. Contaminated soils/sediments can be pre-treated with the TORBED reactor, which allows higher throughput. Dewatering of waste material is not required. Measured destruction efficiencies are 99.9999 % for PCBs. This process is flexible and can be applicable to bulk solids, contaminated soils/sediments and liquids including oils. Some limitations are identified. For example, the pre-treatment can be limiting in the case of large equipment to be decontaminated. The treatment of waste containing arsenic as well as mercury produces highly toxic arsenic and mercury compounds. Even though mobile units are available, this technology remains mainly as large fixed plants. The capacity of mobile units is limited by the necessary ancillary equipment. The size and complexity of this ancillary equipment is significant. The benefits of this technology are the high efficiency of the process (low emissions) and the range of matrices and contaminants that can be treated. All PCB wastes, including transformers, capacitors and oils can be treated using this system. On the other hand, its limited capacity can be a disadvantage depending on the amount of waste to be treated and some by-products are generated which need to be disposed of (used liquor and solid residues). This technology could be considered as ‘high tech’ meaning that some skilled operators would be required to operate such a plant. The principal raw materials and ancillaries required for this process are electricity, hydrogen (at least during start-up), water and caustic. The use of hydrogen at high temperatures is a significant risk and comprehensive fire safety and security measures are required for its management. GPCR technology is recommended for low and high concentration POP destruction, in the described matrices, for industrial regions. GPCR is also recommended for use in remote locations. Access to fuel, spare parts and properly trained maintenance personnel would be required, but hydrogen and electricity could be generated locally. Potential impacts related to the gas phase chemical reduction (reduction destruction method) are summarised in Table 5-2.

Cement kiln co-processing Combustion technologies suffer from poor public perception. There is a strong belief amongst the public that such technologies generate harmful dioxins and furans (PCDD/F) and release them to the atmosphere. Regulatory controls on emission rates need to be installed to address these concerns. The European Union requires a temperature greater than 850 ºC to be maintained for at least two seconds to destroy PCDD/F and to avoid precursors, and in case of more than 1 % of halogenated organic substances, expressed as chlorine, the temperature has to be raised to at least 1,100 ºC. The US-EPA requires a 2 second residence time at 1,200 ºC and 3% excess oxygen or 1.5 second resident time at 1,600 ºC and 2 % excess oxygen in the stake gas. Unlike other currently applied incineration processes with a two stage incineration process, cement kiln co-processing is an single stage process. Temperatures reach 1,450 °C in a cement kiln and the combustion gases stay above 1,200 °C for five to six seconds destroying most POPs in the process. The cement kiln is an oven that rotates to expose limestone, sand and clay evenly to make cement clinker. The clinker process includes a large quantity of lime (in excess) that


43

will neutralize any traces of sulphur and chlorine. Mineral elements are fixed in the crystalline pattern of the clinker. Dust is produced, collected and reintroduced into the process. The cement kiln does not produce any liquid or solid waste. The use of hazardous waste as fuel, including chlorinated solvents such as PCBs, has proven to have no impact on the quality of the cement product. Furthermore, the use of the cement as a building material has shown no long term environmental or safety consequences. The lack of solid residues after treatment is a distinct advantage over other incineration technologies. SNC Lavalin (2007) quotes a demonstrated destruction efficiency ranging between 99.95% and 99.999999 % and they reach a emission limit of 0.1 ng TEQ/Nm³ and a maximum concentration of 0.4 g/Nm³ of PCBs in cement. The technology will destroy POP-contaminated liquid, non aqueous waste, powder, sludge and soil. Pre-treatment may be required to create the physical conditions for entering the waste into the kiln. Liquid hazardous waste is either injected separately or blended with a primary fuel or a sorbent. Solid waste is mixed and burned along with the primary fuel. Wastes must be blended with a fuel suited to the cement process itself. Under proper conditions, the risk to the environment and humans can be minimal. Irregularities in the process may cause incomplete combustion resulting in polluting emissions. Highly qualified technical personnel are necessary to operate the system. Considering the process technology, there is medium potential for exposure. Formerly, Cement kiln disposal (co-processing) was not an accepted technology by the Basel Convention because there is insufficient evidence that the process is “dioxin-free” (GEG, 2004). As more data are provided on emissions which prove that the technology meets appropriate standards (such as those of the EU), this was be reconsidered and cement kiln co-processing is now included on the list of acceptable destruction technologies for POPs and PCBs. The environmental benefits of co-processing waste and hazardous waste in cement kilns can be summarized as follows:

• decrease the combustion of virgin fuels; • decrease the need to extract and refine virgin fuels; • decrease the need to construct alternate treatment facilities (cement kilns are already

constructed); • decrease the use of non-combustible raw materials (i.e. replacing some limestone and other

precursors with slag and ash); • decrease the need to quarry and transport the non-combustible raw materials; • decrease the need to transport hazardous waste over long distances (the economics of the

cement industry mean that kilns are generally within 200 to 300 km of their customers, due to transportation costs, and are thus widely distributed over every country);

• decrease the need to dispose of non-hazardous waste in landfills (no solid waste generated, solid residues are incorporated into the cement clinker); and

• decrease the need for treating or disposing of hazardous non-combustible waste. As with many developing countries, the cement kilns in Vietnam are a combination of old, out-dated plants and new, state-of-the-art, facilities. Only the most modern plants should be considered for hazardous waste destruction (including PCBs and other POPs). The technology should only be used in cement plants that can demonstrate competent waste management systems and good kiln temperature control, in accordance with the guidance documents elaborated by the World Business Council for Sustainable Development and the cement industry. These documents provide insight into the regulatory control of plants, waste selection, air emission control and monitoring amongst other elements (http://www.wbcsdcement.org). It is important that cement kilns, when active in the field of waste incineration, respect the same emission limits as imposed on waste incineration plants, and take measures to avoid


44

environmental impacts. The most frequent environmental complaints are related to dust, fine-dust PM10, odour and noise. Potential impacts related to cement kiln co-processing (combustion/incineration) are summarised in Table 5-2.

Plasma arc decomposition The principles of plasma arc decomposition are that an electrical arc is struck between two electrodes. Chlorinated organic compounds are transformed into their elemental states and recombined into mineral gases. The plasma arc technology directs an electric current through a low pressure gas to create a plasma. The waste is injected into the plasma at a temperature that can reach 3,000 to 15,000 °C. Plasma arc decomposition is available in three processes. Although the main goal of the technology is the destruction of PCBs, it is worthwhile to investigate the energy balance of the energy consuming plasma arc process and the valorisation of the obtained gasses. Safe waste and Power (www. Safewasteandpower.com) suggests a net energy production, but this largely depends upon the nature of the waste fed to the system. The technology is used for energy recovery from a large scale of carbon based substances, like PCB-containing oils. These three processes however do not include energy recovery but do include extensive gas treatment. The three processes are the pact process, the Plasma Converter System and the Plascon process. Since the application possibility in Vietnam seems limited, these thermal non-combustion methods are not fully described. The most important potential source of pollution from this technique is improper treatment of the obtained gasses, possibly leading to air pollution.

Wet air oxidation (WAO) WAO is the oxidation of soluble or suspended components in an aqueous environment using air as oxidant. It can treat liquid waste and sludges with high organic contents. The process oxidizes and hydrolyzes organic contaminants in water at temperature of 150 to 320 °C and pressures of 10 to 210 bars, which is below the critical temperature and pressure of water. At these elevated temperatures and pressures, the solubility of oxygen in water is dramatically increased, providing a strong driving force for oxidation. With residence times between 60 to 120 minutes, the technology converts organics into CO2, H2O, and short chain biodegradable compounds such as acetic and formaldehyde. Depending upon waste characteristics, bioremediation as a post-treatment may be required. Wastewater with low pH may cause corrosion damage to the metals used in the WAO. PH adjustment as pre-treatment may be required. Post-treatment evaluation for the potential products of incomplete oxidation must be considered prior to implementing this technology. WAO is a mature technology with more than 300 units installed worldwide. Capacities of Zimpro WAO installations are between 0.5 and 66 m³/h. However it is not clear how effective the technology is in treating PCBs. Tests on the actual contaminated waste should be conducted to evaluate its suitability. It could possibly be used for the destruction of low concentration of PCBs depending on test results. The WAO process does not always achieve complete oxidation of the organic compounds. By-products to the environment will be produced with this technology, but can be eliminated with further treatment like activated carbon for vapours and biotreatment for liquid. High levels of electricity are required, although heat energy can be recovered. Some concentrated wastes might require pure or enriched oxygen. Titanium, expensive and not easily available, is recommended to prevent corrosion. There is low risk to the environment and humans. The technology is intrinsically safe with regards to the risk of runaway reactions. In the presence of chloride and high temperature, the process requires high performance construction materials and preventive maintenance is very important. Qualified


45

technical personnel are necessary to operate the system. Considering the process technology, there is high potential risk for worker exposure. This technology is available on compact skids and on large scale static installations. Potential impacts related to wet air oxidation (combustion/incineration) are summarised in Table 5-2.

Other techniques All techniques described above are considered by SNC-Lavalin as applicable in Vietnam, in one way or another. Technology is either already present (cement kilns) or companies have been found interested in importing the technology and applying it in a local Vietnamese context. However, treatment of PCBs and PCB-containing waste can be performed abroad when transfrontier movement of the waste and treatment in e.g. Australia, Japan or Europe would be environmentally and economically more feasible or desirable than treatment at the place of origin of the waste. Techniques that are used abroad and that are fit for PCB destruction, apart from the techniques mentioned above, are mainly different types of waste incineration:

• Rotary kiln incinerator with after burner and various air pollution devices; • Fluidized bed incinerator; • Static incinerator.

These incinerators are only found in industrialized countries because of their capital costs and also because highly trained personnel are required. Regular maintenance and services, intensive control procedures including analytical facilities are also necessary. A continuous supply of fresh water, large quantities of chemicals for the scrubber and a reliable supply of electricity and fuel are needed. It should also be recognized that gas scrubbers are required with a good control/treatment of the other residues like ashes and so forth. Potential impacts related to these kinds of incineration techniques (combustion/incineration) are summarised in Table 5-2.

PROJECT ACTIVITIES RELATED TO SITE REMEDIATION PCB site remediation activities include in-situ activities on PCB pollution in soil or groundwater. Treatment of excavated and transported soils is not mentioned when this is covered by the techniques discussed in paragraph 0. Hereafter the techniques like soil washing, thermally enhanced soil vapour extraction and soil flushing, as final treatment methods for in situ soils are explained. Potential impacts related to site remediation activities (site remediation) are summarised in Table 5-2.

Soil washing Soil washing is a volume reduction technology for excavated contaminated soil. Soil comprises varying sized particles, from fines to boulders. As contaminants are only adsorbed onto the smaller particles, separating the particles by size allows for more economical and efficient treatment. Soil washing comprises a multi-stage sizing procedure, beginning with the removal of large particles (stones, cobbles, boulders, etc.) by mechanical screening and then mixing the soil with water to form a slurry which is then separated by a variety of methods, most developed for mining ore extraction techniques. The fines generated contain the majority of contaminants. The stones, cobbles and boulders, once washed clean of fines, are generally-contaminant-free and can be used as fill. The concentrated fines are less expensive to transport, store, treat or destroy, whichever management strategy is selected. Soil washing can be performed in large static installations or in small scale mobile installations, with comparable results.


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Thermally enhanced soil vapour extraction (SVE) Under this approach for in situ treatment, heating is used to increase the volatilization rate of semi-volatiles and facilitate extraction. Once extracted the contaminants need to undergo a further off-site treatment as described in chapter 0. Heating can be realised by steam/hot air injection or electrical resistance/ electromagnetic/fiberoptic/ radio frequency heating. The system is designed to treat some PCB congeners. After application of this process, subsurface conditions are excellent for biodegradation of residual contaminants. The following factors may limit the applicability and effectiveness of the process:

• Debris or other large objects buried in the media can cause operating difficulties; • Performance in extracting certain contaminants varies depending upon the maximum temperature

achieved in the process selected; • Soil that is tight or has a high moisture content has a reduced permeability to air, hindering the

operation of thermally enhanced SVE and requiring more energy input to increase vacuum and temperature;

• Soil with highly variable permeabilities may result in uneven delivery of gas flow to the contaminated regions;

• Air emissions may need to be regulated to eliminate possible harm to the public and the environment. Air treatment (and permitting) will increase project costs;

• Residual liquids and spent activated carbon may require further treatment; • Thermally enhanced SVE is not effective in the saturated zone, however, lowering the aquifer can

expose more media to SVE (this may address concerns regarding light non-aqueous phase liquids);

• Hot air injection has limitations due to the low heat capacity of air. Remediation projects using thermally enhanced SVE systems are highly dependent upon the specific soil and chemical properties of the contaminated media. This technology may be suitable for some specific sites and should be evaluated on a case by case basis.

Soil flushing For soil flushing methods water, or water containing an additive to enhance contaminant solubility, is applied to the soil or injected into the groundwater to raise the water table into the contaminated soil zone. Contaminants are leached into the groundwater, which is then extracted and treated by one or more methods as described above in chapter 0. The target contaminant group for soil flushing is inorganic wastes including radioactive contaminants. The technology can be used to treat PCBs but it may be less cost-effective than alternative technologies for this type of contamination. There has been very little commercial success with this technology. The addition of environmentally compatible surfactants may be used to increase the effective solubility of some organic compounds, however, the flushing solution may alter the physical/chemical properties of the soil system. The technology can mobilize a wide range of organic and inorganic contaminants from coarse-grained soils. Factors that may limit the applicability and effectiveness of this process include:

• Low permeability or heterogeneous soils are difficult to treat; • Surfactants can adhere to soil and reduce effective soil porosity; • Reactions of flushing fluids with soil can reduce contaminant mobility; • The potential of washing the contaminant beyond the capture zone and the introduction of

surfactants to the subsurface concerns regulators. The technology should only be used where flushed contaminants and soil flushing fluid can be contained and recaptured;

• Above ground separation and treatment costs for recovered fluids can impact the economics of the process.


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In situ vitrification In-situ vitrification uses electricity to melt contaminated soil or wastes at high temperature. The organic pollutants are destroyed by pyrolysis and inorganic compounds are immobilized within the vitrified glass. Large graphite electrodes are inserted into the soil. Electricity arcs from one electrode to another through the soil. Temperatures reached vary from 1,400 to 2,000 °C. The heat reduces the soil into a molten form. The electrodes move deeper as the ground liquefies and continue to melt the soil until the maximum depth is reached. The estimated achievable depth is 9 meter. The electricity is then shut off and the soil solidifies into glass. The organic pollutants are reduced into gases that are collected and transported for treatment. When the vitrification process is completed, the fused glass block can be left in place. The blocks can weigh as much as 1,400 tons and are not subject to breakdown or other decomposition from the environment. The in-situ vitrification technology is commercially available (Geomelt, Geosafe). The technology is suitable for a wide range of soil, dewatered sludge, sediment, and wastes. Permeability and density tests should be performed for each site. The soil should have sufficient amount of glass-forming materials (silicon, aluminium oxides) and metals. The technology has been applied on matrices contaminated with PCBs. Destruction efficiencies have been reported between 90 and 99.99 %. The vitrification process is limited by the availability of power. Volatile organic compounds and combustion products can escape from the off-gas treatment system. The soil should be dried prior to melting to prevent the release of dangerous gases. Electrodes, a transformer, off-gas collection hood, off-gas treatment system and water are the required materials. A mobile skid is available. SNC Lavalin estimates that there is low risk to the environment and humans, considering that the off-gas treatment system is designed in a way to prevent leaks. Considering the process technology, there is low potential for worker exposure. The technique is expensive and therefore useful for highly contaminated and mixed waste sites.

TiO2 enhanced photocatalysis Organic compounds, such as PCBs, can be completely degraded in an aqueous environment by UV irradiation in the presence of oxygen and TiO2 based photocatalysts. The solution is placed into the reactor with TiO2 as a photocatalyst. The photocatalyst is made out of titanium dioxide (0.1 to 0.5 % by weight) on glass micro-spheres, which are immobilized on a fixed support or on the reactor wall for easy separation once the reaction is completed. If not, the reactor has to be supplemented by liquid-solid separation as a post-treatment step. Skimming could be a separation method used since the TiO2 micro-spheres float on the water surface due to their low bulk density. Once the solution to be treated is into the reactor with the catalyst, the irradiation process starts with an UV source between 300 to 360 nm and contaminants are degraded. This process is usually rapid. This technology is commercially available (Purifics Photo-Cat). It can reduce PCBs in soil, water and aqueous solutions and sludge to acceptable discharge standards. Destruction efficiency mounts up to 99.99 % for PCBs. No by-products to the environment can be produced with this technology. The technology requires electricity. It is available on skids and the installations are compact. Considering the process technology, there is low potential for worker exposure. The technology is fit only for small scale treatment (groundwater), as this technology is not ideal for scale-up to larger operations. It can be used as part of a treatment train for cleaning an aqueous wastewater or treating contaminated groundwater.


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Analysis of potential impacts (scoping) In this section, impact identification is carried out. The aim of this scoping is to identify all impacts which appear to be of potential importance at this stage. The list of impacts is not exhaustive for the following reasons:

• A number of projects elements are only in the planning phase so that their characteristics and as a result the exact importance of their environmental impact cannot be assessed;

• It is necessary to limit the assessment to a manageable number of relevant impacts that are selected by the expert team.

The scoping exercise is provided under the form of activity/impact matrices (Table 0-1, Table 0-2). For clarity reasons the PCB management and disposal projects have being analysed in two different tables. The first table includes all management issues until final storage. In the second table the different treatment techniques are taken into consideration. Furthermore the different activities/projects likely to be carried out when managing and/or disposing PCB’s have been grouped as a function of their potential environmental impacts. For each of the different treatment, disposal and remediation methods, dismantling associated pre-treatment and post treatment techniques have also been taken into account. It should also be noted that when identifying potential effects also impact linked to construction activities are taken into consideration. Further on, in the impact assessment section, the origin/cause of the impacts will be discussed. The assessment will be based to a maximal extent on quantitative criteria. The assessment criteria which will be outlined and discussed in each separate chapter and will primarily be based on environmental quality objectives, basic values and limits from the legislation of Vietnam whenever available. Given the importance of the project, however, the assessment will also be carried out in relation to international quality objectives and guidelines. Reference will be made in particular to the World Bank’s Operational Policies and Directives. Other assessment criteria which will be applied are e.g. surface loss, modifications expressed as percentage, increase of diminution, etc. The assessment output will be based on the following criteria:

• Magnitude: referring to the quantum of change to be experienced; • Extent: referring to the area which will be affected; • Significance: referring to the importance of the magnitude considering the present situation; • Special sensitivity: referring to region specific situations of sensitivity e.g. protected habitats.

For the assessment of the importance of impacts other factors such as reversibility and duration will also be taken into account. Both direct and indirect effects will be considered.


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Table 0-1: Scoping for potential impacts related to presence, management, transportation and storage of PCB containing materials


Testing equipment




Transportation

Water and aquatic resources Ground water contamination X2 (X)3 X X X (X) Surface water contamination X (X) (X) X X (X) Soil and waste Soil contamination X (X) X X X (X) Waste production X X X Climate, air and noise Air emissions of POPs X X (X) Dust formation (X) (X) Noise production (X) Ecosystems Loss of ecol. valuable areas X (X) Ecotoxicity to terrestrial life X X X X Ecotoxicity to aquatic life X (X) X X Land use Land use change X Losses of sites with archaeological, historical and cultural value

X


2 Potential environmental impact 3 Potential environmental impact not likely to occur


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Testing equipment




Transportation

Direct health risks (direct exposure)

X (X) X X X (X)

Indirect health risk X X X X Nuisance (dust, noise) (X) Social effects (resettlement) X X X Social effects (employment) X (X)


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Table 0-2: Scoping for potential impacts related to treatment, disposal and site remediation.


Oxidation treatment Combustion/ incineration

Site Remediation

Water and aquatic resources Ground water contamination (ground)water use

X X

(X) X

X X

Surface water contamination X X X X Soil and waste Soil contamination, X (X) X Waste production (X) X X (X) Climate air and noise Air emissions X X X X Dust formation (X) (X) X (X) Noise production X X X (X) Smell (X) X X Ecosystems Loss of ecol. valuable areas X (X) X Ecotoxicity to terrestrial life X X X (X) Ecotoxicity to aquatic life X X X X Land use Land use change X (X) X (X) Landscape alteration X X X Losses of sites with archaeological, historical and cultural value

(X) (X) X


Direct health risks (direct exposure) X X X (X)


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Oxidation treatment Combustion/ incineration

Site Remediation

Indirect health risk X X X (X) Nuisance (noise, visual effects, traffic,…)

X X X (X)

Social effects (resettlement) (X) (X) X Social effects (economic/employment) (X) X X Social effects (transport) X X X Social effects (use of resources) (X) X X (X)

Below a description of the “typical effects” to be expected from the PCB project is provided. The activities are subdivided in accordance to the subdivision made in the scoping tables.


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PRESENCE, MANAGEMENT, TRANSPORTATION AND STORAGE A typical environmental impact likely to occur in relation to the presence and further handling until storage of PCB containing materials is pollution of soil and consequently groundwater as a result of leakage or accidents. The presence of PCB containing materials may already have led to soil and groundwater contamination. This should be investigated. Further on improper handling, transport, and storage may also provoke leaks. When in connection to water bodies the leaks may lead to further dispersion of PCBs and may result into a pollution of surface water. Indirectly these effects may give rise to exotoxicological effects both for terrestric fauna and flora and for aquatic biota. As a result fauna and flora may undergo an impact from PCB handling, transport and storage activities. The management of PCBs may also result in to production of wastes (possibly contaminated). These should be managed in a proper way. Noise production resulting from management, transportation and storage of PCBs in expected to be minimal. Only the construction of a storage facility or transport activities may produce some noise. Direct effects on ecosystems, sites with archeological, historical or cultural value are not likely to occur; only in case storage facilities are build, some loss with respect to these areas can be noted. Risk to man can be the result of direct exposure and/or the consequence of exposure upon dispersion of PCBs. Direct exposure can occur to workers being exposed directly to fumes or through contact with PCBs during handling or as a result of leaks. Inhabitants living nearby the project site and workers can also be exposed to PCBs through air pollution, soil pollution or pollution of groundwater. In an extreme case impacts can occur from eating foodstuff in which PCBs from leaks have been accumulated. It should be stressed here that proper management should improve the health situation and minimize burden to man. Nuisance impacts from PCB management activities will be limited to some increased traffic due to transport and maybe some noise and dust from traffic. Social and economic effects will probably also be limited. Some impacts may however occur with respect to the income of people active in PCB recycling. Resettlement will only be of any importance in case of the construction of storage facilities.

TREATMENT, DISPOSAL AND REMEDIATION The likelihood of impacts to occur as well as the importance of the impacts related to treatment, disposal and site remediation will be higher as compared to the handling, storage and transportation. The different treatment and disposal methods, exception made for site remediation, generally have both a construction phase and a phase of operation (possibly followed by dismantling). The construction phase provokes some typical activities leading to environmental impacts. These may include:

• The pumping of ground water to allow the construction activity; • The clearance of the site: removal of vegetation and in some instances removal of the top soil

layer; • A lot of transportation activities resulting from the construction works; • The settlement of workers accompanied by the production of waste and waste water; • The need of recourses e.g. water, energy.

For each of the treatment and disposal methods involving construction activities, potential environmental impacts are:

• Lowering of the ground water table;


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• Increase in the noise level; • Air emissions and air pollution from transport: i.e. dust, NOx, TSP; • Direct loss of ecotopes and fauna and flora; • Change in the land use pattern; • Loss of sites with archaeological, cultural or historical value; • Nuisance to man: noise, dust and traffic; • The use of recourses (e.g. water) which may be scarce; • Needs for resettlements: movements of the population; • Littering with waste.

The treatment techniques (including the associated pre-treatment needs) are possibly leading to a number of typical impacts. Several of the pre-treatment and treatment techniques including soil remediation are responsible for the discharge of waste water. Water pollution is thus another potential typical environmental impact. Next to this, also other aspects of the water balance may be impaired due to the need for water and in a few cases for cooling water. Pre-treatment, in particular shredding, but also treatment techniques may have a high sound power level. These activities may thus result in a noise impact. Although PCB treatment and disposal aims at minimizing dangerous wastes, some waste products are still resulting from the processes. This asks for a further proper waste management. Contamination of soil and as a consequence ground water should be prevented at the treatment plants. Nevertheless it is not to be excluded and deserves the necessary preventive measures. Site remediation however is aiming at improving the quality of soil and groundwater. As already indicated in the section on the impacts of the construction activities, the treatment and disposal activities may also during operation lead to a direct loss of ecological valuable sites and sites of archaeological, cultural or historical value. The erection of plants will also have an impact on land use and on the structure of the landscape. This will be in particular the case for the larger combustion/incineration plants. For the smaller oxidation treatment units this will not be the case. The typical effects on man may be significant and varying in nature and intensity. The impacts most likely to occur are:

• Direct health effects on workers when coming into contact with PCB wastes; • A multitude of indirect effects (workers and inhabitants) resulting from exposure to PCBs through

inhalation of polluted air, drinking of polluted groundwater or surface water, and consuming foodstuffs enriched with PCBs;

• Nuisance impacts of different nature: ∼ Stress, sleeplessness and other impacts from noise, ∼ Traffic and dust nuisance, ∼ Odour, ∼ Visual discomfort resulting from landscape changes.

It should be stressed that the treatment and disposal as well as remediation activities generally should lead to minimize the health risk for the population of Vietnam. The operation of a plant for treatment and disposal of PCB’s may also bring along a number of socio- economic impacts. These may directly affect the population and provoke some resettlements. It may also be that some employment opportunities are created and that the income of some people may increase. On the other hand the recyclers may loose business. The implantation of the treatment facility may provoke some environmental pressure (i.e. waste) on the local population; on the other hand it may lead to further development of a region due to indirect employment, the attraction of people, the need for more roads,…


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Finally the presence of a treatment and disposal unit will lead to a higher demand of resources, i.e. water and energy and as such a disequilibrium may be created if the carrying capacity is surpassed.


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Environmental and social impact assessment methodology

INTRODUCTION In this chapter a methodology is described allowing to prepare an EIA for the different projects to be planned and implemented in the framework of the overall PCB management and disposal project. In the first place attention will be paid to the information needs for the project description. Indeed, in order to be able to prepare a valuable EIA, the project compounds have to be known and described with a sufficient degree of detail. This is the case for each technical alternative. Thereupon the various disciplines for which potential environmental impacts have been delineated at the occasion of the scoping will be dealt with. For each discipline the following issues will consecutively be provided: • The information needed and the information sources for:

- the baseline description, - the assessment of the impacts;

• The assessment methodology and the criteria to be used for the assessment. Before going into more detail on the information needs and impact methodology for each discipline, the following remarks of a more general nature are useful at this stage: • The geographical area to be covered for each EIA will depend on the size of each individual project

and on the distribution/dispersion potential for the different pollutants and the area potentially to be affected. Apart from some transportation effects the effect of PCB management and disposal will mainly be restricted to a distance of maximally a few km from the site of operation. In case of management activities it is likely that all activities take place within the borders of the site of operation. Since expected emissions and discharges will be negligible or low, their impact is not expected to reach beyond a distance of 1 km to 2 km from the border of the operation site. In case of treatment, project emissions may be more significant and also social impacts may be expected. Based upon expert experience with EIA’s on treatment plants for hazardous substances, the dispersion of relevant levels of air, water or groundwater pollution will not reach further than some 2 to 5 km from the site of operation. Further effects on fauna, flora and man will also be limited to that area. Experience with EIA’s has learned us that for waste treatment facilities a study area with a diameter of 5 to 10 km is largely sufficient. Only in the case there would already be a significant pollution problem of soil and (ground)water impact may cover a larger area. This will have to be verified for each individual project. The study area has to be demarcated for each location alternative to be studied.

• In case considerable construction activities take place in order to carry out the project (i.e. new treatment plant) also effects during the construction phase and eventually the dismantling phase have to be assessed;

• The baseline environmental situation In this framework report no description of the baseline environmental situation is given since the baseline situation is always project-specific. However the topics to be treated, the data needed for the description of the baseline situation and the information sources that exist for gathering data in the baseline situation are described. This is not done in a separate chapter but it is integrated in this chapter; it is provided separately for each discipline to be studied.

• The description of the baseline situation will primarily be based on existing studies and on most recent information and data available from the respective public services and agencies, on national and international scientific literature data and on a field recognition trip. The degree of detail for the description should mainly be based on the following two questions that are related to one another:

- Which environmental characteristics can possibly be influenced by the project elements?


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- Which area characteristics can possibly play a role in the prediction of the effect? This means that it is of no use to provide a comprehensive description of a wide range of characteristics that cannot be affected by the project and do not provide any added value in the impact assessment. For the framework “Environmental and Social assessment Report” however the information needs for the description of the baseline situation will be comprehensive so that all elements are covered. For the EIA of each project the issues of relevance will have to be selected from the list taking into account the potential effects predicted.

• For the description and assessment of the impacts, the following scheme is applied: - Description of the baseline situation; - Evaluation of the actual situation in relation to the assessment criteria; - Determination of the contribution of the project to the environmental quality - Prediction and description of the environmental situation to be expected in the presence of

the project; - Evaluation of the importance of the environmental impact to be expected.

PROJECT DESCRIPTION In order to be able to carry out an environmental impact assessment of a specific project, sufficient information of an acceptable quality has to be available on the characteristics of the project. The information needed is different in nature. It concerns the following issues:

• The general situation of the project in the study area; • All issues related to the construction phase; • The different project components during the phase of operation; • Facilities and activities related to the project.

In this chapter a comprehensive overview will be provided on the information needs and as a result on the information to be provided in an EIA related to the management of PCBs. Since this document is aiming at providing a framework for different specific projects, the information needs outlined will cover the feeds for the full spectrum of PCB management and disposal issues. It should be stressed that, apart from some information on specific aspects of the general situation of the project, the bulk of information in the project characteristics should be provided by the project initiator. Moreover it should be clear that the more detail is given on the project characteristics, the higher the quality of the EIA can be.

General situation of the project in the study area In this section some information of general nature should be gathered to provide a general description of the location and the physical and geographical situation of the project. The information needed here includes: • A geographical map (at least 1/10,000) showing the exact location of the project and the exact

project area; • A general description of the surroundings of the project; • A description and map of the topography of the surroundings; • The administrative situation (owner, available permits); • The on-site infrastructure proposed. As indicated above, most information should be provided by the project initiator. Other information sources are: • For the geographic map and data: National Hydrogeological Union;


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• For the topographic data: MONRE Service Centre for Land and House Management.

The pre-construction and construction phase The description of the construction phase involves: • An overview of the different phases and the timing of the project; • A description of the consecutive activities during construction:

- Preparation works i.e. excavation, pumping of groundwater, removal of soil, - The building activities, - The transport needs for the construction, - The development of temporary settlements,

• The use of resources and waste production to be expected.

The phase of operation The components to be described for the operation phase within the framework of the PCB management and disposal project will vary widely according to the type of the site specific project for which an EIA has to be prepared. It speaks for itself that the description of a management project involving retrofilling will vary widely form the information to be provided for a PCB incineration project. A selection should thus be made of the information needs provided below. The following comprehensive overview of the information needs can be provided: • Description of the PCB containing equipment to be managed or treated (kind of equipment, volume

of PCB content, type and concentration of PCB’s); • Description of historic experiences concerning the PCB equipment: leakages, other accidents; • Description of the operations and handling foreseen on the location (i.e. sampling, labelling,

packaging, recycling, retro filling) and description of the way the operations will be carried out; • Description of the (preventive) measures already foreseen to prevent pollution; • Description of the way transport will be carried out: type of trucks, packaging, preventive measures

foreseen, quantity to be transported; • Description of the storage facilities: type of construction, storage conditions, preventive measures

foreseen, quantity to be stored, packaging; • Description of the pre-treatment techniques used: process description, capacity foreseen per day and

per year, operation time schedule, acceptation procedure for PCB equipment; • Description of the treatment and/or disposal techniques: process description, treatment/disposal

capacity, regime (continuous flow versus batch), operation time, acceptance procedure; • Presence of groundwater extraction on site and in the immediate surroundings (number of wells,

depth of extraction well, results regarding water quality, capacity, …); • Kind of surface covering, presences of impermeable paving, …; • Existing procedures in the case of the occurrence of accidents, spill procedures;

• Transport activities linked to (pre) treatment and disposal: transportation needs (quantities) and mode, numbers of vehicles per day and per year;

• Utilities linked to treatment and disposal units: description of energy supply, description of equipment or measures to prevent/treat possible environmental pollution: water treatment unit, air purification equipment;

• The sound power level and the use pattern of equipment and utilities to be used for (pre) treatment; • Description of the storage needs associated with the treatment and disposal units: storage capacities

needed for each type of product; storage quantities per year; description of the storage facilities: size, measures foreseen to prevent pollution, storage conditions;


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• Quantification and description of the origin and use of resources: water supply (groundwater, surface water, …) energy supply (including energy carrier: gas, coal, …);

• Quantification of the use of materials and chemicals; • Estimation of the waste production: description of the quantities of different types of waste expected

to be produced, description of the storage facilities for waste, the waste management and the final fate of each of the different types of waste;

• Description of the different sources for emissions and waste water production: expected and maximum allowed flow rate, temperature and composition of the off gasses; characteristics of the emission point (stack) i.e. height, diameter; flow rate and characteristics of the waste water (i.e. temp, COD, BOD, N, P, SS, …).

When it is foreseen that operation will only be temporarily, the EIA should also provide some insight in the impacts related to the termination of the project. In general, however, little is known to allow predicting effects. In any case the subject should be touched by providing an idea on the actual insight in the demolition and decommissioning phase of the project.

The actual environmental performance of the facility When the project is carried out in an existing facility an overview should be provided on the overall environmental performance of this facility before the project is implemented. This overview should provide general information on: • The general lay out of the facility; • The (production) capacity of the plant; • The global man power and the man power of the environmental and/or safety and health

department; • The existence of an environmental management system and/or emergency plans; • Mean measures already taken and equipment in operation for environmental protection; • The existence of an environmental monitoring plan

With respect to the emissions to the different compartments and/or the pollution in the different compartments we refer to the data and information needs described in the sections 6.3 up to 6.5 of this report. Specific information needed with respect to the actual situation on PCB management should include:

• The number and the characteristics of the PCB containing equipment (name of manufactures, power

rating, PCB content) • The actual condition of the equipment; • The maintenance situation of the equipment • The operational situation of the equipment • The existing status for management of PCB’s and PCB containing equipment: procedures, people

involved, preventive measures. • … For transformer servicing facilities further specific data should be gathered on: • The procedures for servicing; • The existing safety and health protection procedures; • The training organized for the staff; • The protective clothing and other protective materials available; • The monitoring carried out.


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The data on the environmental performance of the facility can be obtained from the owner of the plant and the staff involved. To that aim a questionnaire should be established and discussed with the project initiator.

AIR, CLIMATE AND NOISE Air, climate and noise include a variety of impacts of physical and chemical nature. The impacts on air are in general resulting from the production of emissions into the air from processes, combustion, energy supply or traffic. Certain air pollutants may further lead to smell effects, depletion of ozone, climate change or acid deposition. In the context of PCB management however, this is not expected. The importance of climate conditions finds its origin in its role for predicting distribution of air pollutants. Noise may be produced during construction activities and transport. In treatment facilities, equipment such as compressors, ventilators, etc may also result in noise. In general impacts may be air pollution with different compounds and smell. The presence of PCB containing materials as well as their handling leads to emissions into the air. These emissions are not likely to be high but anyway an impact on air quality may occur. This may also be the case due to dust formation when constructing a storage or treatment facility or as a result from transport by truck. An important potential environmental impact from the treatment and disposal techniques is air pollution. This is in particular the case for combustion and incineration techniques. Reduction destruction methods may also lead to air pollution. Next to the stack emissions also diffuse emissions into air may occur. This is in particular the case during pre-treatment i.e. shredding and screening. PCB’s are the mayor component to be taken into account for air pollution. Next to this, attention should also be focused on dust and smell (i.e. cement kiln) and dust produced by traffic. The potential impacts in case of PCB management and disposal are further summarized in the Table 0-1 and in the Table 0-2. Air pollution and noise may further lead to impacts on human health (exposure and toxicity of airborne pollutants, hearing impairment) or to nuisance (annoyance from noise, dust, smell).

Data and information needed • Emission data:

- Measured emissions from actual situation in plant or emission factors for power plant for relevant components: NOx, SO2, PM10, CO2, CO;

- All emission sources from the project likely to produce relevant emissions to air; - Emission factors for the different emission sources i.e. PCB containing materials, emissions

due to traffic (NOx, PM10) handling and treatment of PCBs; - For the emissions of PCB, measurements do not appear to be of relevance since emissions

are diffuse in nature; - General noise emission factors (sound power level) for the use of (pre)treatment equipment.

• Data on baseline situation: - Data on general climatological situation at the nearest station: monthly mean temperature,

monthly mean precipitation, yearly average and monthly data on wind direction, windspeed, cloudiness and humidity;

- Actual air quality monitoring data (according to availability) and/or description of major sources; no air quality monitoring for project purposes is needed;

- Actual noise situation: description of major sources; no measurements needed for project. • Assessment criteria:


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- Standards and guidelines for ambient air quality: SO2, NOx, PM10, CO, PCB, chlorinated hydrocarbons (if relevant);

- Standards for noise.

Information sources The emission data originating from measurements at the existing plants should be provided by the owner of the plant. The emission sources related to the project should either be provided by the project initiator or be determined by the EIA expert. If no measured emission data can be obtained from the owner of the plant, the data which are relevant for the impact assessment, should be generated by the EIA expert based upon the technical characteristics of the processes and the characteristics of the off gas production on the one hand and existing emission factors from EPA or the EU (CITEPA, 2001; US EPA, 1995; Bush et al. 2005; EEA, 2007; Emissieregistratie Nederland, 2008;) on the other hand. PCBs emission factors (air and noise) are to be provided by the EIA expert (see tables 0 and 1.6). Data on the climatological characteristics are to be obtained from the Centre for Hydrometereology from North and South Vietnam. Actual air quality monitoring data are provided by the DONREs, the National Environmental Monitoring stations. Monitoring data can be obtained from operators in case a monitoring plan on air quality is due. Specifically for PCBs no monitoring data will be available. Exception made for situations where substantial PCB leaks are noted, no air quality monitoring of PCBs will be needed. It can be assumed that air concentration of PCBs will be zero. In case substantial leaks are recorded, air quality should be monitored for 24 h on the spot of the leak at 1 m height and respectively 500 m and 1000 m off wind of the leak. Data on noise emissions is also provided via existing monitoring plans or should be determined by the EIA expert. Standards and guidelines are given in the Vietnamese legislation. Besides this, also World Health Organisation and EU standards and guidelines are gathered.

Assessment methodology and criteria Firstly the climate conditions, the reference situation concerning air quality (for the relevant parameters, i.e. SO2, NOx, PM10, CO and PCBs and the noise situation are described. The actual situation is related to the standards and guidelines for air quality. For noise a qualitative description will be given. The standard and guidelines to be applied are summarized in following tables.

Table 0-1: Standards and guidelines for air quality (WHO, 2000, TCVN 5937,2005)

Parameter Vietnam International WHO

guideline EU standard

CO (µg/m³) 10000 (8hr) 30000 (1hr)

10000 (max)

NOx (µg/m³) 40 (year) 200 (hr)

40 (year) 40 (year) 200 (hr)4

SO2 (µg/m³) 50 (year) 125 (24 hr) 20 (year)5

4 NOx: EU standard for ecosystem protection: 30 µg/m³ (year)


63

125 (24 hr) 350 (1 hr)

125 (24 hr)

PM10 (µg/m³) 150 (24 hr) 50 (year) 300 (1hr)

706 (24 hr) 50 (24 hr) 40 (year)

PCB (mg/m³) 0.57

Table 0-2: Guideline values for community noise in specific environments (WHO, 1995)

Specific Environment Critical health effect(s) LAeq [dB(A)] Time base [hours]

LAmax fast [dB]

Outdoor living area Serious annoyance, daytime and evening Moderate annoyance, daytime and evening

55 50

16 16

- -

Dwelling, indoors Inside bedrooms

Speech intelligibility & moderate annoyance, daytime and evening Sleep disturbance, night-time

35 30

16 8

45

Outside bedrooms Sleep disturbance, window open (outdoor values)

45 8 60

School class rooms & pre-schools, indoors

Speech intelligibility, disturbance of information extraction, message communication

35 during class

-

Pre-school bedrooms, indoor

Sleep disturbance 30 sleeping time

45

School, playground outdoor

Annoyance (external source) 55 during play

-

Hospital, ward rooms, indoors

Sleep disturbance, night time Sleep disturbance, daytime and evenings

30 30

8 16

40 -

Hospitals, treatment rooms, indoors

Interference with rest and recovery #1

Industrial commercial shopping and traffic areas, indoors and outdoors

Hearing impairment 70 24 110

Ceremonies, festivals and entertainment events

Hearing impairment (patrons: <5 times/year)

100 4 110

Public addresses, indoors and outdoors

Hearing impairment 85 1 110

Music and other sounds trough head-

Hearing impairment (free-field value) 85#2 1 110

5 For ecosystem protection 6 WHO prescribed exposure effect analysis 7 TCL (Baars et al., 2001)


64

Specific Environment Critical health effect(s) LAeq [dB(A)] Time base [hours]

LAmax fast [dB]

sounds trough head-phones/ earphones Impulse sounds from toys, fireworks and firearms

Hearing impairment (adults) Hearing impairment (children)

- -

- -

140 #2 120 #2

Outdoors in parkland and conservations areas

Disruption of tranquillity #3

#1: As low as possible #2: Peak sound pressure (not LAF, max) measured 100 mm from the ear.

In a second phase the relevant sources of air pollution will be identified. For all relevant pollution sources emissions will be calculated using emission factors. The majority of emissions of PCBs arise from leaks from electrical transformers and capacitors which contain PCBs and are in poor condition. General emission factors for PCBs are presented in Table 0-3. It should be noted that PCB emissions from transformers and capacitors during normal operation are negligible. There are limited data available on emissions of PCBs from electrical equipment (European Environment Agency, 2000; USEPA 1987). In order to obtain an idea of PCB emissions, emission estimates are calculated based upon the evaporation process for different activities. When PCB containing oils are removed from transformers, a very small part of the PCBs will evaporate. This will lead to either releases of PCBs in the ambient air or accumulation of PCBs in the workplace atmosphere. Emissions from removing PCB containing oils from transformers can be estimated using the following formula:

T

MPLs 0083144.0

.=

Whereby: Ls specific loss (g/m³) P vapour pressure (kPa) M molecular weight (g/mol) T temperature (K)

Molecular weight and vapour pressure are congener dependent. Taking into account the ranges of vapour pressures cited in the literature for various congeners, maximum specific losses of 1 – 40 mg/m³ are calculated for liquids consisting of pure PCBs:

Molecular Maximumweight specific loss(g/mol) (mg/m³)

Monochlorobiphenyls 188,65Dichlorobiphenyls 233,1 5,1E-05 - 4,2E-04 4,8E-03 - 4,0E-02 40Trichlorobiphenyls 257,54 1,5E-05 - 1,1E-04 1,6E-03 - 1,1E-02 11Tetrachlorobiphenyls 291,99 1,4E-06 - 9,0E-05 1,6E-04 - 1,1E-02 11Pentachlorobiphenyls 326,43 1,4E-06 - 1,7E-05 1,9E-04 - 2,2E-03 3Hexachlorobiphenyls 360,88 9,8E-08 - 7,0E-06 1,4E-05 - 1,0E-03 1Heptachlorobiphenyls 395,32Octachlorobiphenyls 429,77Nonachlorobiphenyls 464,21Decachlorobiphenyls 498,66

Vapor pressure (kPa) Specific loss (g/m³)


65

If the congener composition of the PCBs is unknown, the value of 11 mg/m³ is advised because tri- and tetrachlorobiphenyls have been the most widely used in transformer applications. The specific losses from oils containing only a fraction of PCBs can be obtained by multiplying the maximum specific losses for pure PCBs with the weight fraction of PCBs in the mixture:

• Western PCB based transformer oils contain 60 – 70 wt% of PCBs: multiply by 0.65 • Soviet PCB based transformer oils (Sovtol-10) contains 90 wt% of PCB’s: multiply by 0.90 • PCB contaminated transformer oils containing 500 ppm of PCBs: multiply by 0.0005

An estimate of total loss is obtained by multiplying the maximum specific loss, corrected for the PCB content of the mixture, with the total amount of PCB holding transformer oils handled. Evaporation from spills can be calculated by Sutton’s formula:

−

+= −

wt

wt

PP

P

T

PMxum 1ln

3144.8002.0" 11.078.0

Whereby: m” evaporation rate (kg/m²/s) u wind speed (m/s) x characteristic length of spill (m) – spill diameter M molecular weight (g/mol) Pt atmospheric pressure (Pa) Pw vapour pressure (Pa) T temperature (K)

Using a standard wind speed op 0.1 m/s for inside spills and a spill diameter of 1 m, evaporation rate of pure PCB’s amounts to:

Molecular Maximumweight evaporation rate(g/mol) (g/m²/hr)

Monochlorobiphenyls 188,65Dichlorobiphenyls 233,1 5,1E-02 - 4,2E-01 1,6E-06 - 1,3E-05 47,6Trichlorobiphenyls 257,54 1,5E-02 - 1,1E-01 5,2E-07 - 3,8E-06 13,7Tetrachlorobiphenyls 291,99 1,4E-03 - 9,0E-02 5,5E-08 - 3,5E-06 12,7Pentachlorobiphenyls 326,43 1,4E-03 - 1,7E-02 6,2E-08 - 7,4E-07 2,7Hexachlorobiphenyls 360,88 9,8E-05 - 7,0E-03 4,7E-09 - 3,4E-07 1,2Heptachlorobiphenyls 395,32Octachlorobiphenyls 429,77Nonachlorobiphenyls 464,21Decachlorobiphenyls 498,66

Vapor pressure (Pa) Evaporation rate (kg/m²/s)

If the congener composition of the PCBs is unknown, the value of 13,2 g/m²/hr is advised because tri- and tetrachlorobiphenyls have been the most widely used in transformer applications. When room volume and air refreshment rata are known, then wind speed can be calculated from these values and substituted into Sutton’s formula. The specific losses from oils containing only a fraction of PCBs can be obtained by multiplying the maximum specific losses for pure PCBs with the weight fraction of PCBs in the mixture:

• Western PCB based transformer oils contain 60 – 70 wt% of PCBs: multiply by 0.65; • Soviet PCB based transformer oils (Sovtol-10) contains 90 wt% of PCBs: multiply by 0.90; • PCB contaminated transformer oils containing 500 ppm of PCBs: multiply by 0.0005.

Table 0-3: Emission factors for PCB emissions (Annema et al, 1995)

Source PCB emission to air (%/year) PCB emission to soil and water (%/year)

Transformerr 0.006 0.054 Capacitors 0.16 1.44 The emission factors related to traffic are summarized in Table 0-4.


66

Table 0-4: Emission factors for traffic and construction activities (g/km) (USEPA, 1995)

Parameter NOx CO TSP VOC Automobiles 3.8 5.7 0.06 1.0 Heavy dirty trucks (>15 tonnes, diesel)

25 2 2.5 2.5

Excavation 2.69(1) (1) total dust in kg/Ha/month For specific treatment facilities, emission with depend on the specifications of the processes. The specific noise contribution of the project will be determined for the construction phase and the operation phase. For each phase the relevant noise sources are identified and the emission related sound power lever will be determined. For general noise sources ‘typical’ sound power levels are summarized in table 6.5. For specific installations it is expected that the levels will be provided by the initiator and his engineering company.

Table 0-5: Sound power levels LW for different noise sounds

Machine/noise source LW (db (A)) Excavator 104 Dumper 104 Bulldozer 104 Levelling machine 104 Truck 105-110 Shredder 126

For all relevant air emission parameters the contribution to the ground level air concentration will be calculated using a bi-Gaussian distribution model taking into account the climatological data. Receptor areas will be defined. Based upon the sound power levels, the specific noise contribution from the project components will be calculated using the IMMI model. Based on the results of the dispersion modelling, the potential impacts on the ambient air quality will be assessed. To that aim the contribution to air quality will be compared to the national and international air quality standards and guidelines (see above). The assessment for noise will be based on the level of the noise contribution in the surroundings of the project and the comparison of the expected levels with the guideline values (see table 6-2).

SOIL AND GROUNDWATER Impacts on soil and groundwater concern the whole range of alterations related to quality of soil and groundwater on the one hand and characteristics of soil and groundwater on the other hand. These characteristics may include geological, hydro geological or pedological features related to structure and composition of soil or related to groundwater flow or vulnerability. In this section also the production and the management of waste is considered. In the Table 0-1 and in the Table 0-2 the potential impact from the PCB management and disposal project is summarized. Impacts on soil and groundwater quality may further lead to direct exposure for humans or fauna and flora. Furthermore indirect exposure resulting from bioaccumulation of pollutants in cultured food may also occur. Changes in groundwater hydrology may lead to changes of the water balance and as such affect flora or limit groundwater use for fauna and men.


67

Data and information needed • Data on the baseline situation:

- Pedological characteristics at the site (description of the upper 1.5 m of the soil, soil types); - Geological description (overview of present layers in the underground, illustrated by one or

more geological cross-section); - Hydrological description (groundwater vulnerability overview and characteristics of relevant

aquifers, aquitards, impermeable layers: permeability, groundwater velocity, direction groundwater flow, …);

- Overview sources of potential soil contamination (situated on a plan): ∼ a description of the different steps of the process, ∼ the locations on the site which are considered critical to soil pollution, for instance

location of PCB containing equipment, disposal sites, storage of hazardous components, presence of underground pipes, sewage, …,

∼ general management regarding accidents, handling of hazardous components, …; - Overview of accidents resulting in a potential soil pollution (+ undertaken actions); - Quality data regarding soil and groundwater;

• Assessment criteria: - Background values, - soil sanitation values used in Vietnam to assess soil and groundwater contamination.

Information sources For the description of the baseline situation following information sources can be used: • Data on pedagogical, geological and/or hydrogeological archives, soil maps, drilling logs, etc.:

1DWLRQDO�+\GURJHRORJLFDO�8QLRQ�DQG�GDWD�REWDLQHG�IURP�WKH�RSHUDWRU�RQ�LQYHVWLJDWLRQV�LQ�WKH�VFRSH�RI�SUHSDUDWRU\�ZRUNV�RI�FRQVWUXFWLRQ�DFWLYLWLHV;

• Data on ground and groundwater quality, groundwater flow direction and groundwater vulnerability, presence of extraction wells, etc.: 1DWLRQDO�+\GURJHRORJLFDO�8QLRQ;

• Results of soil contamination studies: GDWD�WR�EH�SURYLGHG�E\�WKH�RSHUDWRU�RI�WKH�SODQW��,I�QR�GDWD�DUH�DYDLODEOH��PRQLWRULQJ�VKRXOG�EH�FDUULHG�RXW�DV�RXWOLQHG�IXUWKHU�LQ��

• Existing Vietnamese legislation relevant for soil and groundwater; • Field information (photos of the site, of locations where soil pollution occurs (visual or organoleptic),

where PCB-containing equipment is situated, etc). This information is needed to define the places where soil samples could be taken.

Assessment methodology and criteria

&KDUDFWHULVWLFV�RI�3&%V�UHOHYDQW�IRU�VRLO�DQG�JURXQGZDWHU�Mobility If released into soil, PCBs experience tight adsorption. The adsorption is generally increasing with the degree of chlorination of the PCB. They generally do not leach significantly in aqueous soil systems. The higher chlorinated congeners have a lower tendency to leach than the lower chlorinated congeners. In the presence of organic solvents, PCBs may leach quite rapidly through soil. Degradation PCBs are mixtures of different congeners of chlorobiphenyl. The relative importance of the environmental fate mechanisms generally depends on the degree of chlorination. In general, the persistence of PCBs increases with an increase in the degree of chlorination. Mono-, di- and


68

trichlorinated biphenyls biodegrade relatively rapidly, tetrachlorinated biphenyls biodegrade slowly, and higher chlorinated biphenyls are resistant to biodegradation. Although the biodegradation of higher chlorinated congeners may occur very slowly on an environmental basis, no other degradation mechanisms have been shown to be important in natural water and soil systems. Therefore, biodegradation may be the ultimate degradation process in water and soil. Polychlorinated biphenyls degrade into less-chlorinated PCBs. When released into water, adsorption to sediment and suspended matter is an important process; PCB concentrations in sediment and suspended matter have been shown to be greater than in the associated water column. Although adsorption can immobilize PCBs (especially the higher chlorinated congeners) for relatively long periods of time, eventual re-solution into the water column has been shown to occur. The PCB composition in the water is enriched by the lower chlorinated PCBs because of their greater water solubility, and the least water soluble PCBs (highest chlorine content) remain adsorbed. Volatilization/evaporation Vapour loss of PCBs from soil surfaces appears to be an important fate mechanism, with the rate of volatilization decreasing with increasing chlorination. Although the volatilization rate may be low, the total loss by volatilization over time may be significant because of the persistence and stability of PCBs. In the absence of adsorption, PCBs volatilize from water relatively rapidly. However, strong PCB adsorption to sediment significantly competes with volatilization, with the higher chlorinated PCBs having a longer half-life than the lower chlorinated PCBs. Although the resulting volatilization rate may be low, the total loss by volatilization over time may be significant because of the persistence and stability of the PCBs. Bioaccumulation PCBs have been shown to bioconcentrate significantly in aquatic organisms. Accumulation increases with the more highly chlorinated congeners.

Parameters (http://www.fao.org/DOCREP/003/X2570E/X2570E08.htm)

3URSHUW\� 3DUDPHWHU� 8QLW� 9DOXH� &RQFOXVLRQ�Melting point °C -

Vapour pressure mPa

Density g/cm3

Degradation DT50soil Years Very slightly degradable

Solubility Sw mg/l <0.1 Not soluble

Mobility Log KOC >3.4 Slightly mobile

ADI mg/kg/day 9.00E-5

Human:

Direct contact mg/kg dm soil 45

Consumption of vegetables mg/kg dm soil 6

Permissible Concentrations

Consumption of drinking-water g/l 1.8

$VVHVVPHQW�PHWKRGRORJ\�For the construction phase as well as the exploitation phase following impacts could be relevant:


69

• Alterations in soil use (f.e. increase of paved surface), increase of area which is in use for the project; • Alteration of the soil profile due to construction (removal of soil, foundations, …); • Alteration in soil structure and soil stability due to f.e. setting of soil (impact of storage, movement of

trucks, …); • Change in soil and groundwater quality due to exploitation, storage, good practices; • Erosion due to impact of wind and water (removal of vegetation, borders, …); • Changes in groundwater pattern (f.e. extraction wells), hydraulic parameters, height of groundwater

table, infiltration, … . These impacts are considered for the study area which is in the case of soil equal to the project area. For groundwater the boundaries of the study area are function of the impact on groundwater, f.e. influence of a possible extraction well. Especially the impact on soil and groundwater quality is relevant. Soil can become contaminated with PCBs through accidents involving the removal and maintenance of transformers and capacitors or through improper disposal of PCB containing substances. Accurate determination of the PCB content of soils suspected to be contaminated is necessary for the responsible parties to make the appropriate decisions regarding site clean up and remediation. To detect a potential contamination with PCBs, it is important to do at least one drilling in each zone which is identified as a risk location. If the PCB holding equipment is located on an impermeable surface however, no sampling is required. If the impermeable surface is not bordered by a curb preventing liquid substances to be washed off, the areas around the impermeable surface will have to be sampled if there are any signs/possibilities that oil/liquid wastes may have penetrated the soil. As the contamination spreads from the surface it is always important to take a sample of the upper soil and 2 samples at greater depth (for example: 0.5 to 0.75 m and 1 tot 1.25 m). Not only the concentration of PCBs but also the organic matter and clay content must be analysed. If the upper soil sample is contaminated a deeper sample can be analysed. If also this sample gives a concentration above the sanitation value it is necessary to sample and analyse the groundwater. For the project only soil samples will be taken. Locations where no hard surface is present or where the surface is characterised by a number of cracks will be chosen above the areas where an impermeable surface is present. The number of drillings performed at one location will be function of the area of the risk zone. The impact evaluation results in an overview of relevant mitigation measures. In this case the mitigation will primarily exist out of monitoring needs and periodical soil investigation to ensure no pollution of the soil occurs. In the case of accidents where PCB’s could come into the environment a spill procedure will be needed to make it possible to intervene immediately.

&ULWHULD�The concentration of PCBs in the soil above which some action should be considered will depend primarily on the exposure estimated in the baseline risk assessment based on current and potential future land use. Other factors include the impact the residual concentration will have on groundwater and potential environmental impacts. An overview of existing criteria8 is given in Table 6-6 and Table 6-7. No criteria for assessment of PCB contamination in soil exist in Vietnam.

8 Derivation methods of soil screening values in Europe. A review and evaluation of national procedures towards harmonisation, Carlon C. et al., JRC Scientific and technical reports (EUR 22805 EN), 2007, 306p


70

Table 0-6: Assessment criteria relevant for soil

mg/kg d.w. Screening values for negligible risk

Screening values for intermediate (warning) risk (residential use)

Screening values for potentially unacceptable risk (residential use)

Screening values for potentially unacceptable risk (industrial use)

Netherlands 0.02 1 Germany 0.8 Sweden 4 Belgium (Brussels) 0.9 10.4 Belgium (Flanders) 0.011 0.033

Table 0-7: Assessment criteria relevant for groundwater

µg/l Screening values for negligible risk

Screening values for intermediate (warning) risk

Screening values for potentially unacceptable risk

Netherlands 0.01 0.01 Belgium (Brussels) 0.1 Austria 0.06 0.1

WATER AND AQUATIC RESOURCES Knowledge of PCB behavior in an aquatic environment is important to determine information requirements and assessment methodology. PCBs in water are transported by diffusion and currents. PCBs in surface water essentially exist in three phases: dissolved, particulate and colloid associated. The heavier and less soluble congeners in the water column are the more likely to be associated with particulates and colloids and the smaller the risk that they freely exchange into the vapor phase. The more soluble, lower chlorinated (and ortho-rich) congeners are predominantly in the dissolved state in the water column and can readily partition into the vapor phase. In general, PCB-solubility is low. Experimental and monitoring data have shown that PCB concentrations in sediment and suspended matter are often higher than in the associated water column, but the opposite has been shown as well. Apparently, the partitioning behavior of PCBs in the water tends to be location specific. PCBs leave the water column by partitioning onto sediments and suspended particulates, and by volatilization at the air/water interface. PCBs can be immobilized for relatively long periods of time in aquatic sediments. The adsorption of dissolved PCBs onto solids is greatest for solids composed primarily of organic matter and clay. The more highly chlorinated component (and ortho-poor) PCBs, which have lower water solubility and higher octanol-water partition coefficient (Kow), do have a greater tendency to bind to solids as a result of strong hydrophobic interactions. In contrast, the low molecular weight PCBs, which have higher water solubility and lower Kows, sorb to al lesser extent on solids and remain largely into the water column. PCB input into aquatic reservoirs is predominantly from wet and dry deposition and from the recycling of sediment-sorbed PCBs into the water column. Recycling of PCBs, due to volatilization of PCBs from the water column and subsequent release of PCBs from sediments, occurs when atmospheric inputs decrease. The rate of re-dissolution of PCBs from sediment to water increases in warmer periods because of more rapid volatilization of PCBs from water with higher temperatures. Environmental redistribution of PCBs from


71

aquatic sediment is most significant for the top layers, while PCBs in the lower layers may be effectively sequestered from redistribution.

Data and information needed • Data on baseline situation:

- Inventory of all water bodies and aquatic resources that might be affected by the project; - Data on actual use of water bodies and aquatic resources (domestic water supply, irrigation

purposes, bathing, fishing, aquatic breeding and cultivation, …) - Data on hydrographical and hydraulic characteristics; - Data on flow characteristics ; - Data on water quality; - Data on sediment composition (organic matter, clay); - Data on sediment quality.

• Emission data: - Inventory of all possible sources of contamination:

∼ Direct discharge into surface waters: e.g. waste water from electrical industry, waste water contaminated by leakage of hydraulic fluids, …;

∼ Indirect discharge into surface waters: e.g. runoff of water from accidental spillage of PCB-containing hydraulic fluids, disposal of waste oils into street drains, runoff from farmland to which PCB containing sludge has been applied;

∼ Atmospheric deposition of PCBs; - Characterisation of contamination sources: overview of relevant pollutants, e.g. in case of

PCBs it is important to know weather it concerns higher or lower chlorinated PCB-congeners; - Quantification of possible contamination: e.g. calculation based on pollutant concentration

and waste stream flow, deposition factors. • Assessment criteria:

- Water quality standards and guidelines; - Background values.

Information sources The information sources for water and aquatic resources impact assessment may be multiple: • Vietnamese legislative acts on water conservation; • Monitoring data on water quality and characteristics of water emissions: 9($�DQG� WKH�RSHUDWRUV� RI�

SODQWV�� LQ�FDVH�QR� LQIRUPDWLRQ�FDQ�EH�REWDLQHG� IURP�H[LVWLQJ� LQIRUPDWLRQ�VRXUFHV��RQ�VLWH�PRQLWRULQJ�VKRXOG�EH�FDUULHG�RXW�E\�WKH�(,$�H[SHUW��

• Data on hydrologic and hydrographic characteristics of rivers, i.e. width, depth, flow rate of water: &HQWUH�IRU�+\GURPHWHRURORJ\;

• International literature on water quality standards, e.g. :+2�SXEOLFDWLRQV��(3$�SXEOLFDWLRQV; • Field survey; • Water and sediment sampling; • Etc.


72

Assessment methodology and criteria

$VVHVVPHQW�PHWKRG�At first a baseline study will be conducted. All relevant water bodies and aquatic resources that might be affected by the project are listed. Hydrographical, hydraulic and flow characteristics are described, as well as quality characteristics and actual use. The depth of this baseline study depends on information available. If no information on water and sediment quality of relevant water bodies is available, two water samples and two sediment samples upstream and downstream the project impact have to be taken and analysed on general parameters (pH, temperature, suspended solids, …) and relevant pollutants (PCBs, …). Clay and organic matter content of sediment samples has to be determined as well. Actual water and sediment quality are compared to available standards and guidelines as given in Table 0-8. Next, possible impacts during construction and operational phase are determined, described and assessed: • Possible impacts during construction phase:

- Alteration of hydrographical characteristics due to construction works: description based on actual characteristics and scope of planned interventions (e.g. length of dikes to be filled up);

- Influencing of water quality due to accidental spillage during construction: qualitative description based on an estimation of used equipment.

• Most likely impacts during operational phase: - Influencing of water and sediment quality due to direct or indirect discharging and

atmospheric deposition: description based on identification, characterisation and quantification of pollution sources. In case of discharge of waste water, quantities of pollutants discharged and contribution to pollutant quantities in receiving surface waters are calculated if sufficient data are available. For PCBs in particular, partitioning between water column and sediment has to be studied. Assessment of impacts is related to the extent of pollution and possible exceeding of quality standards. If no information on waste water streams is available, at least one sample should be taken and analysed;

- Influencing of water quantity due to discharge of waste water and rainwater from hardened surfaces: description based on waste water flow, rainfall, hardened surface and receiving surface water flow.

If the impact assessment results in important negative impacts on water or aquatic resources, measures will be proposed to avoid or mitigate expected impacts.

&ULWHULD�Relevant criteria in the assessment of potential impact on water and aquatic resources are given in the tables 6-8 and 6-9.

Table 0-8: Water quality standards and guidelines

Organisation Standard/guideline US Environmental Protection Agency (EPA)

Maximum contaminant level for community water systems and non-transient non-community water systems for PCBs

5 µg/l

US Environmental Protection Agency (EPA)

Maximum contaminant level goal for PCBs in water

0 µg/l

US Clean Water Act PCB criterion to protect freshwater aquatic life

0.014 ng/l as a 24 hr average

US Clean Water Act PCB criterion to protect saltwater aquatic life

0.030 ng/l as a 24 hr average


73

Organisation Standard/guideline aquatic life

Belgium (Flanders) Quality standard surface water, median for total PCBs

� 7 ng/l

Table 0-9: Industrial waste water: Vietnamese limits of Parameters and Maximum Allowable Concentrations of Pollutants

Parameters and substances Unit A B C Temperature °C 40 40 45 pH 6-9 5,5-9 5-9 Odour - ND ND - Colour (at pH=7) Co-Pt 20 50 - BOD5 (20°C) mg/l 30 50 100 COD mg/l 50 80 400 Suspended solids mg/l 50 100 200 Arsenic mg/l 0.05 0.1 0.5 Mercury mg/l 0.005 0.01 0.01 Lead mg/l 0.1 0.5 1 Cadmium mg/l 0.005 0.01 0.01 Chromium (VI) mg/l 0.05 0.1 0.5 Chromium (III) mg/l 0.2 1 2 Copper mg/l 2 2 5 Zinc mg/l 3 3 5 Nickel mg/l 0.2 0.5 2 Manganese mg/l 0.5 1 5 Iron mg/l 1 5 10 Tin mg/l 0.2 1 5 Cyanide mg/l 0.07 0.1 0.2 Phenol mg/l 0.1 0.5 1 Mineral oil and fat mg/l 5 5 10 Animal-vegetable fat and oil mg/l 10 20 30 Residual chlorine mg/l 1 2 - PCBs mg/l 0.003 0.01 0.05 Chemical for vegetable protection: organic phosphorus

mg/l 0.3 1 -

Chemical for vegetable protection: organic chloride

mg/l 0.1 0.1 -

Sulphide mg/l 0.2 0.5 1 Fluoride mg/l 5 10 15 Chloride mg/l 500 600 1,000 Ammonia (as N) mg/l 5 10 15


74

Parameters and substances Unit A B C Total nitrogen mg/l 15 30 60 Total phosphorus mg/l 4 6 8 Coliform MPN/100 ml 3,000 5,000 - Bioassay 90% fish alive after 96 hr. in WW Gross alpha activity Bq/l 0.1 0.1 - Gross beta activity Bq/l 1.0 1.0 -

A: Industrial waste waters containing the values of parameters and concentrations of substances which are equal to or lower than the values specified in the column A may be discharged into the water bodies used for sources of domestic water supply B: Industrial waste waters containing the values of parameters and concentrations of substances which are lower than or equal to the values specified in the column B may be discharged only into the water bodies used for navigation, irrigation purposes or for bathing, aquatic breeding and cultivation, etc. C: Industrial waste waters containing the values of parameters and concentrations of substances which are greater than the values specified in the column C may be discharged into specific water bodies permitted by authority agencies ND: not detectable

1.6 FAUNA AND FLORA The discipline “Fauna and Flora” includes all potential impacts on terrestrial and aquatic ecosystems. It may concern either the direct loss of valuable or protected biotopes or species or the deterioration of biotopes or organisms as a result of ecotoxicity through air, water or soil or changing conditions of soil, groundwater or water supply. The potential impacts of PCB management concern both the above mentioned effects, including:

• Direct loss of biotope resulting from the construction of a storage facility or treatment facility; • Deterioration of aquatic/terrestrial biotopes or species due to eco-toxicity resulting from pollution

with PCBs.

Data and information needed • Data on the baseline situation

- An overview of the protected areas (and their protection status) in the study area; - A description of the biotopes; - An identification of rare species; - A photo impression.

• Assessment criteria - Ecotoxicological no effect levels.

Information sources The information sources for fauna and flora impact assessment may be multiple. In particular the following sources are needed: • Legislative acts on nature conservation and identification and delineation of protected areas: 9LHWQDP��

(QYLURQPHQW�$GPLQLVWUDWLRQ��9($�; • ,QWHUQDWLRQDO�FRQYHQWLRQV i.e. the Ramsar Convention on Wetlands (1971), the Bern convention, the

convention on Biological Diversity and the convention on the Protection of the World Cultural and Natural Heritage;

• Local university departments on nature conservation;


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• International literature on ecotoxicology i.e. WHO publications; • Field verification by the EIA expert.

Assessment methodology and criteria The description of the baseline situation starts with a general description of the surroundings on a macro level. There upon the protection status of the study area is provided and the ecologically valuable areas are identified. All special protected areas in the study area are described into more detail based upon literature information and field recognition. The description includes:

• The characterization of the different terrestrial and aquatic biotopes; • The identification of rare species; • The evaluation of the protection status, the health status and the vulnerability of the biotopes; • A visual overview of the biotopes in the study area.

The methodology and criteria for the assessment of the impacts will vary accordingly to the type of effect to be expected. The first group of effects is related to • The loss or deterioration of protected areas or nature reserves or in particular ecologically valuable

areas or rare and/or valuable plant communities; • The loss of biotopes as a result of construction activities: construction of storage and other facilities; • The deterioration or drastic change of terrestrial biotopes as a result of soil/ or groundwater

pollution: ecological valuable biotopes, rare or valuable plant communities; • Gain of biotopes as a result of the remediation of the site. These effects can be quantitatively assessed by inventorying and calculating the area surface for which the alterations are expected. This will be coupled to the ecological value of the biotopes affected. A second group of effects concerns the potential disturbance of fauna and flora as a result of noise, dust, traffic,… . Again the assessment criteria will be the surface of the area expected to be disturbed. Indirect ecotoxicological effects on fauna and flora resulting form leaks, emissions and discharges is a next effect group of effects which is potentially relevant. To assess these effects ecotoxicological criteria will be used i.e. the no effect level for acute and chronic ecotoxicity for different groups of organisms versus the expected exposure. It should be noted that these effects may also be positive due to a reduction of the risk as a result of the management plan. Ecotoxicological data for PCBs are summarized in Table 6-6.

Table 0-10: Geometric mean values for the 50 % effect concentration (L(E)C50), for the lowest observed effect concentration (LOEC) for the No Observed effect concentration

(NOEC) for PCBs in the aquatic environment (Callebaut and Vanhaecke, 2000)

L(E)C50 µg/l NOEC µg/l LOEC µg/l

Micture of PCB’s Crustaceans 22 1.7 Fish 55 PCB 77 – fish 250,000 PCB 81 – fish 15,600 PCB 101 – crustaceans 510 PCB 126 – fish 219 219


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L(E)C50 µg/l NOEC µg/l LOEC µg/l

Mixture of 5 PCB’s fish 25 Arochlor9 1254 Crustaceans 0.94 Fish 0.32 Arochlor 1242 Crustaceans 10 Fish 1 Arochlor 1248 Crustaceans 52 Fish 3.4 Arochlor 1221 – fish 500 Arochlor 1232 – fish 30 Arochlor 1260 – fish 51

The predicted no effect concentration from a mixture op PCBs to aquatic organism was calculated to be 34 ng/l according to the EU Technical Guidance Document (Callebaut and Vanhaecke, 2000) Ecotoxicological no observed effect concentrations for birds and mammals are very rare. The following data could be recorded: • NOEC for the bird Gallus domestics: 2-400 mg/kg food (McKinney et al, 1976, Romijn et al 1991); • NOEC for mammals (PCB 153): 1mg/kg food (Romijn et al 1991).

9 Arochlor: technical polychlorinated biphenyl mixture with different percentage of chlorine


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Comparison of alternatives In an environmental and social impact assessment, the possible alternatives should be evaluated. The following types of alternatives should be considered:

• The zero alternative: this is the evolution of the present situation without the PCB project being implemented;

• The alternative with the planned situation if the project is carried out. • For the latter several alternatives or scenarios may be studied i.e.: • Location alternatives: comparison of different possible locations for the project to be carried out; • Technical alternatives: comparison of different techniques/processes/methodologies to carry out

the project. The alternatives may be of different origin:

• They may originate from a feasibility study in which an (economic viable) solution is aimed at to conduct a management or disposal project;

• They may be asked for by the different governmental or other agencies involved in the EIA procedure, or during the first public consultation round;

• They may be proposed as a result of a study on “Best Available Technologies not Entailing Excessive Costs” (BATNEEC) for a certain project.

For each of the alternatives a full project description should be given (see chapter 0). If, however, when carrying out the scoping it already appears that an alternative will have a very high environmental and social impact in comparison to the other alternatives to be studied or when an alternative appears not to be realistic, it can be argued in the EIA report not to elaborate this alternative in the EIA process. In this case no full project description is needed for this alternative. It should be clear that for all alternatives all impact categories indicated in the scoping process should be studied in detail (see Table 0-1 and Table 0-2). In order to be able to compare the different alternatives studied the principles of multi-criteria analysis have to be applied. To that aim – for standardisation and comparison reasons - all impacts are classified according to the following schedule:

0 No effect + Slight positive effect: this is an improvement of the existing situation for a specific impact

with limited magnitude, extent and significance ++ Moderate positive effect: this is a significant improvement of the existing situation for a

specific impact leading to surpassing the criteria used and characterised by a clear magnitude or extent

+++ Highly positive effect: this is a significant effect with an important magnitude and extent - Slight negative effect: this is a deterioration of the situation for a specific impact without

surpassing the criteria set; the impact can generally by mitigated and is reversible or limited in extent and magnitude

-- Moderate negative effect: this is a deterioration of the situation for a specific impact giving raise to surpassing the criteria used: it is characterised by a clear magnitude or extent, however mitigation may lower the effect

--- Highly significant negative effect: this is a significant deterioration of the situation for a specific impact characterised by a large magnitude and extent

---- Very important negative effect: this is a significant deterioration of the situation for a specific impact characterised by a large magnitude and extent and irreversible in nature without mitigation possibilities.


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In that way the impacts from different nature are brought into one scale which will allow inter-comparison. In a next step it will be necessary to establish an acceptable methodology for valuation and rating of the environmental resources of different nature. This valuation depends on the specific importance given to each environmental component or resource, taking into account the local situation and in particular specific sensitivities. In order to evaluate the relative importance given to the different environmental issues, valuation factors are proposed. This may be agreed upon between the group of experts involved in carrying out the EIA. It is to be advised however that the major stakeholders are involved in valuating the environmental issues since they are supposed to be well aware of the project and local sensitivities. In the particular case of the PCB project it is proposed that EVN, DONRE, VEA and one NGO are involved in participation to the evaluation. Once the valuation factors have been attributed, the impact assessment score has to be multiplied by the valuation factor for each impact. The valuated scores obtained in the way are to be added up to come to a total environmental score. The alternative with the lowest (negative) score is then ranked to be the alternative having the smallest environmental effect. However, the comparison also has to be subject of a qualitative discussion and interpretation.


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Environmental and social Management and Monitoring plan

LEGAL FRAMEWORK Both the Vietnam Government and the WB requires mitigation measures to be recommended as an integral output of the EA process. The WB requires that this information is presented in a particular format within an ”Environmental Management Plan” (EMP). Doing so, it represents good practice in EA reporting and also facilitates more effective and practical implementation of recommended measures. Meanwhile, the Vietnam Government request the contents of an EMP must be in two Chapters of EIA report which will be reviewed and approved in a Central Appraisal Committee or a Provincial Appraisal Committee respectively.

The following are legal documents related to rules of EMP contents:

• the World Bank’s OP 4.01

• the Circular No 05/2008/TT-BTNMT of the Ministry of Resource & Environment issued December 08, 2008 on guiding to implement SEA, EIA and EPC

In general, the EMP should list all requirements to ensure effective mitigation of every potential environmental impact identified within the EA; even those that are already assumed to be part of the design. In this way, the EMP becomes a transparent summary of all the commitments made in the EA and how those commitments will be delivered. This is critically important during implementation, as it enables PMUs, the Borrower, the WB and regulatory authorities to implement (or track) project commitments.

EMP FRAMEWORK The EMP must include the following information:

• Summary of typical environmental impacts that could occur as a result of project activities

• Identification of feasible mitigation measures including responsibilities and cost for implementation

• Identification of suggested monitoring indicators including responsibilities and cost for implementation;

• Institutional arrangements: human resources to implement the EMP;

• Capacity development and training;

• Implementation schedule;

• Reporting procedures.

Mitigation The EMP identifies feasible and cost-effective measures that may reduce potentially significant adverse environmental impacts to acceptable levels. The plan includes compensatory measures if mitigation measures are not feasible, cost-effective, or sufficient. The EMP includes following activities:

• It identifies and summarizes all anticipated significant adverse environmental impacts; • It describes each mitigation measure, including the type of impact to which it relates and the

conditions under which it is required (e.g. continuously, in the event of contingencies), together with designs, equipment descriptions, and operating procedures;


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• It estimates any potential environmental impacts of these measures; and • It provides linkage with any other mitigation plans if required for the project.

The following strategies were employed for an EMP (in order of priority): • Avoid the impact. To “avoid” means to be able to change some aspect of the project

design, construction, or operation such that the impact no longer occurs (e.g., changing the alignment of a road so it avoids a national park).

• Minimize the impact. To “minimize” means to implement measures that will reduce impacts to acceptable levels (e.g., ensuring that construction equipment meets TCVN industrial emission standards).

• Rectify the impact. To “rectify” means to allow an impact to occur, then afterwards take measures to rehabilitate the environment to a level whereby the impact is within acceptable limits (e.g., filling in used limed pits as part of construction clean-up).

• Compensate for the impact. To “compensate” means to allow the impact to occur, then afterwards provide non-monetary compensation (first priority) or monetary compensation (second priority) for losses created by the impact (e.g., if a farmer must be resettled, the first compensation priority is to provide replacement land and housing. If replacement land and housing cannot be provided, the replacement value of losses should be calculated and provided to the farmer.).

The mitigation measures will be elaborated as a table with the following possible structure:

Issue Description of typical impacts

Typical mitigation measures

Monitoring indicators

Responsible

Timing Cost

Construction phase Air Soil

Operational phase Surface water

Air

Soil

Monitoring Environmental monitoring during project implementation provides information about key environmental aspects of the project, particularly the environmental impacts of the project and the effectiveness of mitigation measures. Such information allows corrective action to be taken when needed. Therefore, the EMP identifies monitoring objectives and specifies the type of monitoring, with linkages to the impacts assessed in the EIA report and the mitigation measures described in the EMP. The monitoring section of the EMP provides:

• a specific description and technical details of monitoring measures including: • the parameters to be measured; • methods to be used; • sampling locations; • frequency of measurements; • detection limits (where appropriate); • definition of thresholds that will signal the need for corrective actions; and


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• monitoring and reporting procedures to ensure early detection of conditions that necessitate particular mitigation measures, and furnish information on the progress and results of mitigation.

The monitoring needs will be worked out in a table which will be similar to the table containing the mitigation plan. Following structure may be used.

Parameter of concern

Frequency Methodology Example location

Assessment criteria (quoted Vietnamese standard)

Investment cost

Recurring cost (annually)

Wastewater, for example

Flow rate Random check or monthly

Open channel related device with known relation water height – flow rate

BOD Random check or monthly

Winkler method or O2-specific electrode

...

Soil, for example

PCBs Periodically (every 5 years)

….

To ensure that the mitigation and monitoring is performed, it will be necessary to elaborate a number of operational procedures. For example:

• What to do in the case of accidents; • Visual control of the state of for example impermeable floors; • …

Institutional arrangements Experience on other projects has found that there is substantial benefit in assigning one person in each management unit to take responsibility for implementing their respective duties in the EMP. In the case of the PCB project, the following recommendations are made:

• Assign one person to PMU as Environmental Safeguards Specialist.

• Assign one person for each PMU of demo-project (sub-PMU) as Environmental Officer.

• Retain at least one Safeguards Independent Monitoring Consultant to review and monitor EMP implementation.

The environmental safeguard specialist/environmental officer positions will be part-time posts held by regular staff within the PMUs and sub-PMUs. It is expected that environmental officers will hold other posts within sub-PMU (social safeguards, engineering, etc);

The Environmental Officer is responsible for ensuring that the registration and updating of all relevant EMP documentation is carried out. It is the responsibility of the Project Manager to ensure that all personnel are performing according to the requirements of this procedure and to


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initiate the revision of controlled documents, when required by changes in process, operating procedures, legislation, specifications, audit findings or any other circumstances, by informing the Environmental Officer of the changes. A controlled document is official only if the issue/revision has been approved. The Environmental Officer and Project Manager are responsible for ensuring that the latest versions of documents are used to conduct tasks which may impact on the project environment.

The safeguard independent monitoring position will be on contract with PMUs.

Capacity Development and Training To support timely and effective implementation of environmental project components and mitigation measures, the EMP defines who is responsible for carrying out the mitigation and monitoring measures. For example for operation this includes responsible persons for supervision, enforcement, monitoring of implementation, remedial action, financing, reporting, and staff training. If necessary, the EMP recommends the establishment or expansion of such units, and the training of staff, to allow implementation of EA recommendations. The relevant Vietnamese institutions will be defined and the capacity requirements for the involved institutions will be evaluated but also the capacity requirements of the operator will be discussed.

Implementation Schedule and Cost Estimates For all three aspects (mitigation, monitoring and capacity development), the EMP also provides:

• an implementation schedule for measures that must be carried out as part of the project, showing phasing and coordination with overall project implementation plans;

• the capital and recurrent cost estimates and sources of funds for implementing the EMP. These figures are also integrated into the total project cost tables.

For these two last elements it is important that insight is given in the plans and organizational structure of the project owner or organizer.

Reporting procedures It is vital that an appropriate document handling and retrieval system be developed for all EMP documentation. This will ensure that there is adequate EMP documentation control and will facilitate easy document access and evaluation. EMP documentation should include:

• EMP implementation activity specifications;

• training records;

• site inspection reports;

• monitoring reports; and

• auditing reports. Responsibilities must be assigned to relevant personnel for ensuring that the EMP documentation system is maintained and that document control is ensured through access by, and distribution to, identified personnel. The following environmental monitoring and reporting framework will apply to the project:

- Each construction contractor will provide monthly reports to PMUs on the implementation of the requirements contained in the relevant demo-project EMP and the results of the environmental performance monitoring outlined in the EMP.

- During construction, for each demo-project, sub-PMUs will engage an independent organization to conduct periodical environmental monitoring and prepare reports for submission to the PMUs, DONRE and WB. The timing and frequency of these reports will vary depending on the sub-projects and will be defined in the sub-project EMP.

- During operation, for each demo-project, sub-PMUs will engage an independent organization to conduct periodical environmental monitoring for at least the first 2 years


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of operation and reports to PMUs, DONRE and WB. The timing, frequency and duration of these reports will vary depending on the demo-projects and will be defined in the demo-project EMP.

Document control is important for the effective functioning of an EMP. A document handling system must be established to ensure adequate control of updating and availability of all documents required for the effective functioning of the EMP. This procedure applies to the EMP as well as procedures and policies relating to the EMP, which must be controlled (i.e. identified, registered and changes recorded).

The EMP and procedure documents must be controlled and only distributed according to a distribution list compiled by the Environmental Officer. Documents should be numbered and controlled according to the distribution list. These documents shall be marked “controlled copy”. Holders of controlled documents shall sign the distribution list when they receive a new or revised document and must destroy the old version. Whole documents should not be reprinted and older versions destroyed when only a few pages are affected by the revision.

OVERVIEW OF POTENTIAL ENVIRONMENTAL AND SOCIAL MITIGATION MEASURES

Mitigation measures for activities related to PCB management As discussed in Chapter 4.2, PCB management activities can be divided into different kind of processes: • identification and labelling of PCB-containing products and equipment (including the testing to

determine the PCB content); • transportation of PCB containing products/waste; • PCB (temporary) storage; • Decontamination of PCB containing equipment and retro-filling activity. The implementation of mitigation measures is, for certain, relevant with respect to the three last processes. In fact the mitigation measures can be subdivided into 3 groups. Into the first group belong the measures which are related to infrastructure, the second group are measures which are process related, the third group exists of measures which are related to codes of good practice and management principles. For each of the measures, mentioned in Table 0-1, following items are described (if relevant):

• the first column (issue) gives the type of measures (infrastructural, process or management related);

• the second column (target) indicates if the measure is applicable for a location within the plant, a process step or concerns a management aspect;

• the third and fourth column (indicator) give some more information regarding the mitigation measure itself;

• the fifth column gives an idea how regular the application of the measurement must checked. The occurrence of spills and accidents is related to each of these processes. Spill management is important and is, therefore, worked out as a separate item. Also environmental monitoring is considered to be a separate process step.


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Table 0-1: Overview of typical mitigation measures and monitoring for activities related to PCB management

Issue Target Description Indicator Timing Transportation of PCB containing products/waste Infrastructural needs Loading/unloading area preferably

an impermeable floor a separate collection system for contaminated surface water curbs to prevent spreading of PCB containing products in the case of a spill

Presence of containment equipment, absorbents if spills do occur

Monthly control

Loading/unloading mechanism

Well maintained equipment Enough place to operate

Lack of deficiencies Monthly control

Transportation means airtight containers, drums, plastic bags with measures to prevent leakage

emergency equipment on vehicles communication equipment for emergencies

Monthly control

Process needs Registration and labelling of transported product/waste

Including information regarding characteristics of PCB’s like condition, origin, quantity, type of packaging container, …

Each transport

Cleaning up by using surfactant Discharged water to specialized disposal installation

After each transport

Management needs Trained personnel (drivers

and loaders) Regular training sessions regarding

characteristics and background knowledge of PCBs Packing and transporting of PCBs Accidents and emergency response measures

Every 6 months

Procedures/codes of good practice

Transportation plan (planning of route and agenda, accommodation and fuel

necessary documents must be in order Each transport


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Issue Target Description Indicator Timing accommodation and fuel charging, measures for addressing troubles or breakdown of vehicles, …)

Acceptance guidelines Checking the transported load, the labelling and note abnormalities into register

Each transport

PCB storage (temporary) Infrastructural needs Storage area Anti-seepage:

Impermeable floor Leachate collection system Preferably covered (inside)

Visual inspection Materials used: must be incompatible with PCBs, resistant to erosion, corrosion Absence of any kind of openings (floor drains, sewers, …) Absence of cracks No visible signs of contamination

Monthly control

Storage facilities Separate storage in function of type of PCB product or waste (applicable for all kind of hazardous products) – PCBs with similar properties may be stored together Storage areas separated by curbs, different rooms Transport alleys must be present Air tight drums and containers

Volume of the curbed area must be able to contain 1/5 of the total storage Check labeling Presence of equipment to retain the spill (absorbents), personal protection equipment and tools, communication equipment, fire fighting facilities, air cleaning system

Weekly inspection If any breakage or damage occurs, cleaning up and replacement of package must be undertaken

Handling equipment loading/unloading equipment f.e. lifting hook and handling space

Check for mechanism failure of the handling equipment Check the available free space

Monthly control When problems are observed, immediate


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Issue Target Description Indicator Timing action must be taken

Adequate ventilation Fans (portable) Lack of deficiencies Process needs Registration and labelling of

stored product/waste Including characteristics of PCB’s like condition, origin, quantity, type of packaging container, storage date, position in storage facility, …

Weekly check

Cleaning up by using surfactant surface, walls and equipment

Discharged water to specialized disposal installation

Periodical and after closure

PCB contaminated material (in airtight drums)

must be brought to specialized disposal site Periodical and after closure

Management needs Trained personnel Regular training sessions Regarding characteristics and background

knowledge of PCBs, receiving and storing of PCBs Keeping the facility in good working conditions Checking of mechanism failure Accidents and emergency response measures

Every 6 months

Decontamination of PCB containing equipment and retrofill activity Infrastructural needs Closed loop dehalogenation

technology Generation of solid waste within the reactor

Analysis of waste Monthly inspection and analysis

No production of off-gas Monitoring of transformer oil PCB’s concentration At the end of

the decontamination


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Issue Target Description Indicator Timing Adequate ventilation Fans when integrated ventilation

is not foreseen Suitable filtration to prevent air emissions

Important to ensure that air is supplied at a higher lever than it is extracted Presence of filters which exist out of 2 parts: electrostatic filter to remove aerosol and activated carbon filter to remove vapour

Periodical inspection

Process needs Cleaning up by using surfactant

surface, walls and equipment Discharged water to specialized disposal installation

Periodical and after closure

PCB contaminated material (in airtight drums)

must be brought to specialized disposal site Periodical and after closure

Management needs Trained personnel Regular training sessions Regarding characteristics and background

knowledge of PCBs, replacement liquids Decontamination PCB containing equipment / retrofilling Keeping the facility in good working conditions Checking of mechanism failure Accidents and emergency response measures

Every 6 months

PCB Treatment plan Explaining the detailed activities, the risks of the different handling actions, …

Check if transformer is approved for retrofilling, dependant of age of equipment, condition of transformer, is necessary technology available, are suitable replacement fluids available, …

yearly update

Check required characteristics of PCB replacement oils: electrical characteristics, fire resistance properties, density, coefficient of thermal expansion, viscosity, flash point and flammability, combustion by-products, …

yearly update

Protect personnel Provide protective clothing like Replace periodically Every 6 months


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Issue Target Description Indicator Timing One piece chemical resistant suit Chemical resistant gloves Boots, or disposable covers for shoes Approved face breathing mask

months

Safety Inspect working of fire equipment Replace periodically Every 6 months

Spill management Management needs Elaborate a spill response

plan

Identifying Reporting requirements (names, phone numbers of appropriate agencies) Immediate response procedures Information on containers, labelling, disposal requirements for cleanup debris Methods for determining spill boundaries Decontamination procedures for different PCB use areas Required records Post-cleanup sampling requirements

Yearly update

Avoid spreading Avoid spills from running out Containment equipment and absorbents at all relevant areas

Weekly inspection

Spill control Absorptive material should be spread on the contaminated area and should be left in place for at least one hour or longer to ensure that all PCB fluid have been absorbed

immediately


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Issue Target Description Indicator Timing Removal of contaminated soil if PCB contamination cannot be determined

visually at least 15 cm of soil depth must be excavated

Within 24 hours

Removal of absorptive material after use and contaminated soil, also exposed clothing, boots, …

In steel containers

All equipment in exposure area should be washed down with solvent

Within the week

Prevent emission of PCBs to the atmosphere

Pump out the air with air pump whose outlet is fixed with carbon fiber absorber Use plastic cloth to cover surface of polluted spot to diminish the vaporization of PCB’s

Within 24 hours

Training sessions Exercise every available spill which may occur

periodically

Protect personnel Provide personal protective clothing and equipment (see higher)

Protect surrounding Inform responsible authorities Within 24 hours

Prevent pedestrians and vehicles entering

Placement of barricades around the contaminated area

immediately

Safeguard personnel When exposed, medical attention must be organized

immediately

Inspiration of PCBs Move exposed people to ventilation room Give artificial respiration In function of seriousness hospitalization will be necessary

Dermal contact with PCBs Swab skin with soap or neutral detergent Take contaminated cloths of and clean


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Issue Target Description Indicator Timing In function of seriousness send to hospital

Eye contact with PCBs Rinse eye with water In function of seriousness send to hospital

Ingestion of PCBs Send to hospital at once When conscious use syrup of insert finger to induce vomiting

Evacuation of personnel and, if necessary, people present in the immediate surroundings

Foresee room for care and support

Environmental monitoring PCB Detection of potential

pollution Visual inspection for leaks at storage facility

Leak detected Weekly

PCB in soil (mg/kg) and groundwater (µg/l)

Define background level Soil investigation (drillings and piezometers) 1 drilling / area <20 m² 1 piezometer / area < 50m²

Concentrations in soil (top soil and soil immediately under top soil) and groundwater of <1 mg/kg dw soil <0,1 µg/l groundwater

Start of activity In case of spills or storage on soil.

Follow-up potential pollution in soil and groundwater

Regular investigation at spots defined as critical

If the soil/groundwater conditions poses risk for the current or future use of the site remediation is necessary

Periodically (f.e. every 10 years) and after closure of the facility

PCB in air (µg/m³) Define background level Start of activity Weekly check

at relevant spots

Monitor ambient air quality Measure PCB content and hydrocarbon content in emission gas

Concentration < 0.5 mg/m³ Every 6 months and after closure of


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Issue Target Description Indicator Timing gas facility

Monitor air discharge Measure PCB content and hydrocarbon content in emission gas

Concentration < 0.5 mg/m³ Every 4 months

Detection of air pollution Monitor air quality in (storage) facility in case of leak

Concentration in air <0.5 mg/m³ Ad hoc


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Mitigation measures related to PCB treatment and disposal For the PCB treatment and disposal a number of pre-treatment and treatment techniques exist. The possible mitigation measures are elaborated in a way which is different from the concept which is chosen for the activities related to PCB-management. Here the mitigation measures are given in relation to the impact group as there is less difference in the impacts for the different techniques. One of the impacts which are considered is the impact on the social environment. The social environment refers to how people and communities behave, their relationships, education and occupation, and the conditions in which they live. For example increased levels of unemployment could be due to poor living conditions. Levels of education and employment directly influence the social environment, especially the rate of social development. Low levels of education limit people’s access to employment opportunities as well as constraining the growth of the economy. Economic growth and global competitiveness in turn can be constrained by a lack of appropriately skilled people. Poor levels of public health place also immense pressure on human well-being.


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Table 0-2 Overview of typical mitigation measures and monitoring related to PCB treatment and disposal

Issue Target Description Indicator Timing Water Ameliorate water run off Foresee drainage, containments,

with slight slope

Reduce discharge of industrial wastewater

Use separate discharge systems for household wastewater, rain and industrial wastewater

Buffering of wastewater before treatment

To get more homogenous composition of waste water before treatment

Purification of industrial wastewater

Foresee the necessary waste water treatment installation At least sedimentation basin and oil trap

Concentrations in treated waste water must be less than those determined in the environmental permit

Monthly control

Optimisation of nutrient dosage

Efficiency of wastewater treatment installation

Soil, groundwater and waste Protect groundwater

resources Limit use of groundwater as industrial water

Avoid soil and groundwater contamination

Store chemicals, fuels/oils in covered areas with concrete (impermeable) floors and curbs to prevent spreading

Check for visual spots of contamination or signs of cracks in the floor

weekly

Handle chemicals, … with the greatest care

throughout

Ensure prompt clean-up of any spills

Immediately, followed by corrective actions within


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Issue Target Description Indicator Timing the months

Waste disposal Construct isolated and fenced temporary disposal areas weekly clear and transport waste to accredited waste treatment installations No disposal of waste in direct surrounding of surface water

waste management plan Describing the different waste streams (solid, fluid, hazardous, …) identification of temporary disposal sites on map destination of the different disposal streams monitor requirements (register, …)

Air and noise Minor emissions from

vehicles and equipment Cover vehicles carrying dispersible materials Minimize size and duration of exposed areas Keep vehicles and equipment well maintained Cover temporary stockpiles

Reduction of dust formation Sprinkling or brushing of roads Wheel washing Establishing and enforcement of speed limits


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Issue Target Description Indicator Timing Prevention of unnecessary

emission of gasses Use of machinery complying with BAT(NEEC)

Limit noise impact for workers

Provide noise protection equipment

At places where an excess of noise regularly occur f.e. by poorly working machines

Periodical check

Limit noise generation for surroundings

Keep equipment well maintained Replace old noisy equipment by new more silent ones (BATNEEC) Avoid nightly acitivities Use acoustic shields or place noise reducing equipment at very noisy activities

Equipment with excess of noise Regular check Take into account in the yearly made investing plan

Ecosystem Aquatic ecosystem Changes to water quality may

affect aquatic ecosystems Ensure quality of discharged wastewater in surface water

Periodical inspection

Vegetation and habitat Dust generation, air pollution and adverse effects on water quality may affect growth of vegetation

Foresee cleaning of site Check air purification systems

periodically

Protected areas Avoid impact or foresee compensation

In function of growth activity

Man and his social economic living environment Changes to economic

activities and production Employment opportunities Impact on number of employees In function of

growth of changes in activity

Changes to traffic volumes and traffic safety

Changes to accessibility Schedule works to be completed in efficient and timely manner

Effects on public health Elaborate procedures which must be followed in case of incidents

Cooperate with local authorities


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Issue Target Description Indicator Timing Land use changes Elaborate a dossier explaining

what will be realised and evaluate possible impacts Implement compensation if necessary

Cooperate with local/national authorities In function of growth activity

Effects on physical or cultural heritage

If effect occurs possible compensation must be studied

Maximal integration in existing landscape

Effect on landscape Reduce visual impact f.e. adequate plantation programme in and around the project site

• Monitoring

• Parameter of concern

• Target • Description (collection, handling, analysis

• Indicator • Timing

• Soil and groundwater (see table 8.1)

• • • •

• Waste water (typical components)

• • • •

• Flow rate (m³/hour) • Determination of flow rate

• Open .channel calibrated device (venturi) with known relation

• - • Continuous

• BOD (mgO2/l) • Detection of pollution • O2 concentration measurement before and after incubation

• <50 • Monthly:

• COD (mg O2/l) • Detection of pollution • Potassium dichromate method • <80 • • Chlorinated

hydrocarbons (µg/l) • Detection of pollution • Gas chromatographic method

after extraction with adapted sovent

• < 1000 • Monthly

• PCB’s (µg/l) • Detection of pollution • Gas chromatographic method after extraction with adapted

• 3-50 (depending on receiving water body – see table 6-9)

• Monthly


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• Monitoring

after extraction with adapted solvent

– see table 6-9)

• pH • Detection of pollution • Electrometric method (pH electrode)

• 5,5-9 • Continuous

• Salinity (mg/l) • Detection of pollution • Colorimetric method (electrode)

• < 1000 • Monthly

• Air pollution (typical components)

• • • •

• TSP (PM10) emission (µg/m³ or mg/m³)

• Detection of emission • Isokinetic sampling 24h device.

• <4 • 2x/year •

• PCB emission (µg/m³)

• Detection of emission • Isokinetic sampling 24h device • Gaschromatography

• <0,5 • 2x/year •

• Dioxines/furanes emission (ùg/m²)

• Detection of emission • Isokinetic sampling 24h device • Gaschromatography

• < 0,5 • 2x/year

• PCB + dioxin deposition pg/d

• Air quality • Air quality monitoring point to be set up 0,5, 1 and 2 km direction of predominant offwind – one month

• 3 Bergeroff deposition bottles per sampling point

• Toxic equivalents (TEQ) • 1-4 pg/kg.d.

• 2x/year


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ROLES AND RESPONSIBILITIES OF STAKEHOLDERS The roles and responsibilities of the different Ministries and Agencies at both the national and provincial levels have been reviewed by Breeze and Associates Inc (2007b) and are summarized in section 2.1 of this report. In this section 2.1 an overview is provided of the authorities involved in the different aspects of the PCB management. Furthermore the findings of Breeze and Associates Inc (2007b) on the needs for improvement are summarized in the same section. This overview provides the basis for the implementation of the environmental management and monitoring plan. For this implementation there will always be a key role for the project initiator who will be the main responsible for carrying out the mitigation measures and monitoring. This project initiator may either be EVN or another (private) company involved in the management of PCB’s, i.e.:

• Owners/developers of storage facilities for PCB’s • Owners/developers of refilling /recycling stations for PCB’s • PCB transport organizers • Owners of PCB treatment facilities • Responsible for power plants

For each project the environmental management plan has to be implemented in close collaboration and under the supervision of the respective Government Agencies (see 2.1.1.). Most likely (since it concerns local projects) the environmental management plan will be implemented by the project initiator (plant owner) in close collaboration and under control of a steering committee with representatives of:

• DONRE/VEA: for ensuring data collection is carried out properly, for assessing monitoring data and for control that prescribed measures are carried out

• Provincial Peoples Committees: to ensure that all directives from the environmental management plan are implemented

Other Ministries are to be part of the steering committee when the environmental management plan is related to projects that fall within their competences (i.e. Ministry of transportation for PCB transport projects) or when effects may occur that are related to their responsibility (i.e. Ministry of Health when health effects are important). In case mitigation measures encompass the level of individual projects and are more general in nature a major responsibility should be taken by VEA, together with MONRE to arrange for these measures to be implemented ( in the framework of the PCB management project). This will be the case for the following types of measures:

• Development of material for sensibilisation of workers and citizens in general; • Setting up of training on characteristics of PCB’s, preventive measures for packing and

transporting PCB’s • Development and organisation of training on emergency response • Setting up of a monitoring program for transformer oil


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results public consultation meetings

LEGAL FRAMEWORK Vietnam requirements

• The Circular number 05/2008/TT-BTNMT of the Ministry of Resource & Environment issued December 08, 2008 guiding to implement SEA, EIA and EPC:

- The project proponent send to the Commune People Committee and the Commune Fatherland Front Committee a formal information of project description, including environmental and social potential impacts; mitigation measures; and other related problems;

- The Commune People Committee and the Commune Fatherland Front Committee open public announcement of information of project or arrange a public meeting if necessary;

- The Commune People Committee and the Commune Fatherland Front Committee give their opinions in writing to the project proponent. The opinion shall be added to EIA report to submit to Appraisal Committee.

• The Decision No 80/2005/QD-TTg of The Prime Minister issued April 18, 2005 promulgating the Regulations on public supervision for investment projects:

- Community has a right to supervise all activities of investment projects, including environmental impacts and mitigation measures;

- Public supervision shall implement through the local Fatherland Front Committee.

Bank Requirements For all Category A and B projects proposed for World Bank (IBRD or IDA) financing, during the impact assessment process, the borrower (VEPA and EVN) consults project-affected groups and local nongovernmental organizations (NGOs) about the project’s environmental aspects and takes their views into account. The borrower initiates such consultations as early as possible. As indicated in chapter 0, the borrower consults these groups at least twice for Category A projects:

• shortly after environmental screening and before the terms of reference for the EA are finalized; and

• once a draft EA report is prepared. In addition, the borrower consults with such groups throughout project implementation as necessary to address EA-related issues that affect them. The primary purpose of the public consultations provision in the World Bank rules (Operational Directive (OD) 4.01and OP/BP/G 4.0) and EIA rules in Vietnam is to protect the interests of affected communities, especially the poor and vulnerable. Experience has shown a strong link between project sustainability and effective public consultation. Stakeholder group’s benefits from public consultation may include for example:

• Fewer conflicts and delays translate into improved profitability for investors; • Governments improve decision making and secure greater transparency and accountability; • Public agencies and NGOs may gain credibility and further understanding of their mission; • Affected people can influence the project to reduce adverse impacts, maximize ancillary benefits

and ensure that they receive appropriate compensation; • Additional opportunities will arise during project design to ensure that vulnerable groups are given

special attention, that equity issues are considered and that the needs of the poor receive priority; • Environmental and Social Management Plans which result from the EA process are more effective.


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The objectives for consultation at each stage and some methods on how this can be done are summarized in the following table.

Table 0-1: Public Consultation during the EA Process

EA Stage

Objectives Example Methods

Scoping Identify key stakeholders; - Introduce the project; - Understand the value of environmental parameters; - Understand how land is currently used and learn whether there are elements of the baseline previously unknown.

Individual meetings with key stakeholders e.g. local government, NGOs, select number of locally affected people; - Questionnaires; - Scoping workshop.

Completion of Draft EIA Report

Report and discuss results of EIA; - Obtain feedback and acceptance of results.

Disclosure of EIA report or its summary, inviting feedback; - Organize public meeting, focus groups, workshops or seminars.

Following disclosure and consultation on the draft EIA report, the proponent / Project owner is responsible for revising the EIA report to reflect the comments and views obtained during consultation. Responsibility The Project owner is responsible for ensuring that project affected people and local NGOs are appropriately informed during the EA process. The Project owner must also organize the disclosure of the EIA report (or its summary) to locally affected populations and then organize meaningful consultation with these. The Project owner must also ensure that the views of affected people and local NGOs are taken into consideration in project design and implementation. A mechanism for continuing consultation with these stakeholders must be included in the EMP and carried out throughout project implementation to address any issues or impacts that may arise. Consultation Techniques and reporting The public participation process can be broken down into four key stages, each of which is a prerequisite for the next:

¾�,QIRUPDWLRQ�JDWKHULQJ��collection of baseline data from the public to feed into impact prediction; ¾�,QIRUPDWLRQ�GLVVHPLQDWLRQ��stakeholders are informed about the project; ¾�&RQVXOWDWLRQ��stakeholders are given the opportunity to voice their views about the project; and ¾�3DUWLFLSDWLRQ�� an extension of consultation, where stakeholders become joint partners in the

design and implementation of projects and take part in decision-making. Different techniques can be used for each stage as described in following Table. Information Gathering

Information Dissemination

Consultation Participation

Questionnaires/ surveys/ polls.

Media (radio, TV, newspapers).

Focus groups/workshops.

Village committees.


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Key informant interviews.

Displays, exhibits.

Conferences/ seminars.

Round tables.

A report on public consultation can be developed with content as following 1. Introduction - Background and Objective of Project.

- Purpose of Consultation in EIA Preparation.

- Requirement for Consultation (of WB and of the goverment). - Identification of Project Affected Groups.

- Outline of Consultation Report.

2. Summary of consultation activities undertaken - Overview of how consultation undertaken, when, by whom.

- Summary of persons consulted.

3. Result of consultation during project scoping - Issues Identified by Stakeholders. - How these issues were taken into account.

4. Result of consultation on draft EIA report - Issues Identified by Stakeholders. - How these issues were taken into account.

5. Recommendations for ongoing consultation Annexes - Summary of Project (should provide project description in brief,

potential impact of project, and mitigation measures for some

significant impact). - Detail proceedings / minutes for each consultation activity.

- Complete List of Participants for each consultation activity.

If the report is included in the EIA report however it can focuss on the results of the consultation meetings and on the way how the input is taken into account in the EIA.

• Public consultation for the PCB management Project • For the projects to be carried out within the framework of the PCB Management Project it is

recommended to organize two consultation meetings in case an EIA is due or in case a EIA is prepared (see also section 3.3).

• The stakeholders that should be invited are those who have an interest or a stake in the Project including ‘those who are likely to be affected by the project as well as those who may have an influence over the project’.

• The following stakeholder groups have been identified by the consultant for being invited to the consultation meetings for projects implemented within the framework of the PCB management projects:

• Donor: World Bank • Project implementing agency: EVN • Lead agency for the country’s National Implementation Plan for the Stockholm Convention:

MONRE • Implementing agency for POP activities: VEPA • Department of National Resources and Environment of the Province: DONRE • Provincial Peoples Committee ensuring that national directives are implemented in the provinces

and their local (district) representatives from the villages that may be affected • Local community representatives/leaders from the villages that may be affected


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• Local citizens that may be affected • Non governmental organizations which are organized in the Provinces in which the project is

proposed • Other organized interest groups like associations of industrial sectors • Representatives from (Provincial Departments of) Ministries with responsibilities related to the

project: ¾�Ministry of Health ¾�Ministry of Industry and Trade ¾�Ministry of Construction ¾�Ministry of Science and Technology

• The stakeholders have to be invited at least two weeks before the consultation meeting takes place. Invitations should be addressed by the project initiator either by

• An invitation letter: to all representatives from Ministries and Government Departments • A publication in a local newspaper: for the public • An announcement at the entrance of the site of the project • Comments can be made in different ways: • Spoken comments during the meeting • Written comments up to a maximum of two weeks after the meeting • All comments should be summarized in the minutes of the meeting to be completed with the list

of attendants and with an addendum of the written comments. • The comments should be taken into account in preparing respectively the draft and final EIA.

Comments not taken into account should be addressed separately by providing responses to the comments in the chapter on public consultation of the EIA.

PUBLIC CONSULTATION FRAMEWORK All subprojects require at least one public consultation and the results of the consultation require documentation in the EMP. The public consultation can be conducted either prior to preparing a draft EMP in order to discuss key environmental issues and proposed management actions to be included in the EMP, or after a draft EMP is completed to act as a basis of discussion and to elicit any additional environmental issues that may be of concern to affected groups. In either case, early consultation is preferred. If a public consultation is being conducted to address social aspects of the subproject, EMP public consultation may be combined with it to discuss environmental and social aspects in an integrated manner. This should reduce the time and expense in preparing for and conducting the consultation. The developer is responsible for organizing, conducting and documenting public consultations. Public consultation should introduce the subproject to the local residents and determine if there are any particular subproject concerns. Consultations should also include representatives of local government (Commune’s People Committee) and local organizations (for example Fatherland Front, Women's Union, and concerned local NGOs). Documentation of the public consultation should include the following information: • Manner in which notification of the public consultation was announced: media used, date(s),

description or copy of the announcement; • Date(s) consultation(s) was (were) held; • Location(s) consultation(s) was (were) held; • Who was invited


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o Name, Organization or Occupation, Telephone/Fax/e-mail number/address (home and/or office);

o Who attended o Name, Organization or Occupation, Telephone/Fax/e-mail number/address (home and/or

office); • Meeting Program/Schedule, including what was presented and by whom; • Summary Meeting Minutes (Comments, Questions and Response by Presenters), especially including

issues raised by the local residents; • Decisions reached and actions agreed upon to address issue raised, including schedules to implement

agreed actions, deadlines, and responsibilities for the actions; and • Any signed agreements arising as a result of consultation.

• The documentation should reflect all comments, whether or not the developer agrees or disagrees. The minutes should also have signatures (name, title) of the chairman of the dialogue.

Stakeholder analysis The stakeholders are defined as those who have an interest, or a stake in the Project, including “those who are likely to be affected by the project as well as those who may have an influence over the project”10. Based on the review of the secondary data, fieldwork, and formal and informal meetings/consultations, the following stakeholder groups has been identified , and their characteristics, interests, and influence are summarized in the table below:

Table 9.2. Stakeholder analysis

Stakeholder categories

Relevant Stakeholders

Characteristics Social situation, Location, Size, Organizational Capability

Interests Commitment to Status Quo vs. Openness to Change

Influence High, Medium, or Low

Donor World Bank (WB)

Large international development organization with focus on environmental pollution prevention.

Interest in developing project that will help HW and PCB management development in Vietnam

High

Government policymakers

MONRE, MOIT

Borrower. Responsible for HW management.

Strong interest in improvement of policy framework on sound PCB management

High

Implementing agencies

VEA, EVN, ISEA

Responsible for overall implementation of PCB Management Demonstration Project.

Strong interest in successfully implementing PCB Management Demonstration Project as designated implementing agency.

High

10 Social Analysis Sourcebook: Incorporating Social Dimensions into Bank-supported Projects, World Bank, 2003. P.10.


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EPD Under MOPS, responsible for investigation, dealing with legal violations of HW management.

Interest in implementing PCB Management Demonstration Project, development of legal requirements.

Medium

MOC Responsibilities for settting the sector standards for the construction of all HW transportation systems and facilities in Vietnam. Moreover, MOC can direct PPCs in planning for the construction of hazardous waste facilities

Interest in implementing PCB Management Demonstration Project

Medium

MOH Responsibilities for overseeing the management of medical wastes at health care facilities and, in coordination with MOC and MONRE, for planning, selecting technologies and establishing medical waste incinerators

Interest in implementing PCB Management Demonstration Project and development of the legal requirements.

Medium

MOLISA Responsibilities for workers’ safety and occupational health, including providing guidelines and PCB good practices for workers who may be working with PCB equipment

Interest in implementing PCB Management Demonstration Project and technical guildelines

Medium

Provincial People’s Committees (PPCs)

In charge of socio-economic development planning in local level

Strong interests in development of PCB storages.

Medium

DONREs In charge of provincial environmental management.

Strong interest in PCB management

High

Other interested authorities

District Authorities

Responsible for working with sub-PMUs to carry out bulding and operating PCB storages

Strong interest in building and operating PCB storages in their respective districts.

Medium


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Workers Working with PCB contaminated equipments

Strong interest in bulding and operating PCB storages

High Intended beneficiaries, but also adversely affected persons

Local Communities

Living near PCB storages Strong interest in bulding and operating PCB storages

Medium

Overview of Project-Level Public Consultation Activities The Demo-projects must involve as many stakeholder groups as possible in the process of implementation. Table 9.3 summarizes a consultation process for demo-project.

Table 9.3 Summary consultation process for demo-project Activity Type of Participation

Stakeholder Groups* Timing & Duration Output Constraints

Project Identification

Donor (WB); Government policymakers (MONRE, MOIT – Borrower); Implementing agencies (VEA, EVN)

Up to signing contract. Project Contract.

-

Public Consultations

Donor (WB); Government Policymakers (MONRE, MOIT – Borrower); Implementing agencies (VEA, EVN, ISEA); Other interested authorities; Private sector firms; & NGOs.

Formal Consultation Workshops (3 workshops during Consultancy Services – Inception, Interim, & Final)

Formal workshop minutes; incorporation of feedback into Project design and into related reports

Those mentioned above, plus District and Commune PCs; Local communities in general

Informal Consultations – throughout Consultancy Services.

Difficulty of full coverage and definitional issues of all project affected communes.

Fea

sibi

lity

and

Pre

limin

ary

Des

ign

Preparation of Project Implementation Plan (PIP)

WB; VEA, EVN, ISEA. Following identification of Project components and by WB disclosure date.

PIP. Time constraints.


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Activity Type of Participation Stakeholder Groups* Timing & Duration Output Constraints

Preparation of EIA & EMP

PMUs (Prepared under separate contract by another Consultant.)

Commenced during latter half of Feasibility and Preliminary Design Consulting Services and expected to be completed by WB disclosure date.

EIA & EMP Time and resource constraints. Difficulty of coordination because EIA is under separate contract from all other components.

Project Implementation, Supervision & Monitoring

Project implementation done by PMUs and sub-PMUs with assistance from VEA, EVN, ISEA and DONREs Intended beneficiaries (Local Communities); Other affected & interested groups.

Entire implementation period. Information dissemination on details of project for respective Project area populations significantly in advance of commencement Continuous consultations during Project implementation so that it minimizes anticipated as well as unexpected negative impacts during implementation

Improved Transport Network in Mekong Delta.

Time and resource constraints. Difficulty of full coverage and definitional issues of all Project-affected areas and groups. Limited expertise on social issues and M&E in implementing agencies.

Project M&E

VEA, EVN, ISEA; PMUs; DONREs; DIONREs; Local communities in general; Other interested groups.

Group discussions with local communities and other affected persons.

M&E Report.

Time and resource constraints. Difficulty of full coverage and definitional issues of all Project-affected areas and groups

* Only lists main stakeholder groups to be involved, and this does not mean the participation is limited to the listed stakeholder groups.

PUBLIC CONSULTATIONS ORGANISED IN THE SCOPE OF THE FRAMEWORK EA & SA PREPARATION PROCESS In the scope of the preparation of the Framework Environmental and Social Impact Assessment, two public consultation meetings have been organised by EVN on the aim of the project and the first draft report of the Framework EA & SA:

• on 24th of June 2008 in Hanoi • on 26th of June 2008 in Ho Chi Minh City.

By this, both northern and southern demonstration provinces are covered.


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The aim of the consultations was to inform future stakeholders on the planned project and to give them the possibility to provide input and remarks on the first draft report on the framework EA & SA for ARCADIS to improve the report. Minutes of both public consultations and a list of people who attended the consultations are provided in appendix 1 At the moment of the consultation meetings a first draft of the environmental and social framework report had been prepared. The results of this draft report were presented to the participants of the consultation meetings. Several remarks were made by the participants. Apart from some detail remarks that are reported in the minutes (appendix 1), the following major issues resulted from the remarks of the participants at the meetings:

- The need to provide recommendations on how to apply the EIA legislation in Vietnam with respect to the PCB management project, taking also into consideration the World Bank Policy: this comment has been addressed in the report by providing a clear overview of the World Bank and Vietnamese EIA regulations and procedures and by providing a guidance on the screening procedure and disciplines covered in site specific impact assessments on PCB management, disposal and remediation. The analysis of the local situation was taken into account; as a result it is recommended to expand the need for a full EIA to facilities for storage, retrofilling, replacement and recycling of PCB containing equipment. In this section the instruction for assessment of environmental and social impacts was also taken into consideration in finalizing the report.

- During the course of the drafting of the framework report on environmental and social impact assessment, the ‘ PCB management project’ has been classified in cat. B instead of cat. A: the consultant has taken into account this change.

- There appeared to be a need to also focus on the potential social impacts of the PCB management project: in the final report the social aspects received more attention from the consultant.

- In an environmental impact assessment report effects should be quantified to a maximal extend: the consultant agreed with this statement and has put additional effort in quantifying potential effects: i.e. emissions, discharges,…

- In the draft report the mitigation and monitoring measures were rather limited and not fully adapted to the local situation; an emergency plan was lacking: an additional search for monitoring and mitigation measures was carried out in international literature; this has been completed with data obtained from the local consultant

- The sources of data should be clearly indicated and both Vietnamese and international standards should be applied: together with the local consultant all sources of data have been identified; moreover all the international standards in the report have been complemented with specific Vietnamese standards


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Knowledge gaps and uncertainties in assessment If the description of the project elements is not complete or is not available in a sufficient degree of detail this will lead to a higher degree of uncertainty in assessment. As a result the assessment will become more general without possibilities to quantify the impacts. The same applies when the baseline situation cannot be described due to a lack of data on the actual situation of the environment. Therefore the major gaps in knowledge and uncertainties in assessment for each of the environmental issues studied will be listed. In a further stage this list can also be used for identifying monitoring needs.

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References Annema, J.A., Beurskens, J.E.M, Bodar, C.W.M. (ecls) (1995) Evaluations of PCB fluxes in the environment. RIVM report 601014011 Bilthoven, The Netherlands.

Assessment Requirements - Practices and Lessons Learned in East and Southeast Asia Baars, A.J.; Theilen, T.M.C, Janssen, P.J.C.M., Hesse, J.M., Van Apeldoorn, M.E., Heijerinck, M.E.M, Verdam, L, Zechmaker, M.J. (2001). Re-evaluation of human toxicological maximum permissible risk levels, Bilthoven, Netherlands RIVM Report 711701025

Breeze and Associates Inc. (2007a). Assessment of the policy, regulatory and legislative framework – Final Report. GEF PCB Waste Management and Disposal Demonstration Project (P099460) Breeze and Associates Inc. (2007b). Assessment of the policy, regulatory and legislative framework – Supplementary Report. GEF PCB Waste Management and Disposal Demonstration Project (P099460) Bush, T. King K., Passant N., Tsagatakis I (2005). NAEI UK Emission Mapping Methodology. Information available on following website: http://www.naei.org.uk/data_warehouse.php. Callebaut K., Vanhaecke P. (2000) Development of a framework based on quality criteria for licensing the dumping of dredged material into the waters of the Maritime zone according to the Paris Convention. Report for the Flemish Government 125pp. CITEPA (2001). Calculating emissions into the air: general methodological descriptions. Report for the “Centre Interprofessionnel Technique de la Pollution Atmosphérique”. Dang P. N. (2004). Introducing Strategic Environmental Assessment into Vietnam Laws. ECD (2008): Capacity assessment on supervision and enforcement of PCB management Emissieregistratie Nederland (2008). Methodologies used for the PRTR (Pollutant Release and Transfer Register) in the Netherlands. Documents available on following website: http://www.emissieregistratie;nl/erpubliek/misc/documents.aspx. ERM (1998). Hazardous Waste Management Strategy for Vietnam European Environment Agency (2000): Emission inventory guidebook, Electrical equipment containing PCB’s European Environment Agency (2007). Emep + Corinair Emission Inventory Guidebook. 2007 Hazardous substances databank: http://www.toxnet.nlm.nih.gov Mc Kinney J.D., Chae K., Gupter B.D., Moore J.A., Goldstein J.A. (1976). Toxicological assessment of the hexachlorobisfenyl isomers and 2, 3, 7, 8-tetrachlorodebenzofurain in chicks. 1. Relation of chemical parameters: Toxicol. Appl. Pharmacol. 36, 65-80 MONRE (2006): Vietnam National Implementation Plan of the Stockholm Convention Obbard J. P., Lai Y.C. and Briffett C. (2004) Environmental Assessment in Vietnam: Theory and Practice, Journal of Environmental Assessment Policy and Management. 4(3), p: 267- 295 Romijn (A.), Luttik R., van de Meent D., Sloof W., Canton of H (1991): Presentation and analysis of a general algoritm for risk assessment on secondary poisoning. RIVM Report nr 619-102-002 SNC-Lavalin (2007): PCB Management and Disposal Demonstration Project - Analysis of PCB Treatment & Disposal Options for the Socialist Republic of Vietnam. Draft Report to The World Bank, July 2007. Tan Alan K.J. (2000) APCEL Report: Environmental Law (ASEAN-10). Faculty of Law, National University of Singapore (http://sunsite.nus.edu.sg). The Center for Environmental Research and Community Development (2008). Final report on CS4 - Capacity Assessment on Supervision and Enforcement of PCB Management.

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Preparation of Vietnam PCB Management and Disposal Demonstration Project (Grant # TF057892) Tieu Chiran Vietnam (TCVN 5937, 2005) Air quality – ambient air quality standards. US Department of Health and Human Services. Public Health Service. Agency for Toxic Substances and Disease Registry (2000): Toxicological profile for polychlorinated biphenyls (PCBs)

USEPA 1987. Locating and Estimating Air Emissions from Sources of Polychlorinated Biphenyls (PCB). USEPA – 450/4-84.007

US EPA (1995) AP 42: Compilation of air pollutant Emission factors, volume 1, Chapter 13

WHO (1995) Bergland, B., Lindwall, T., Schwela, D.H. Guideline for Community Noise, WHO Geneva

WHO (2000) Air Quality guidelines for Europe, WHO regional publications. European series no 91

World Bank - GEF (2007). GEF PCB Waste Management and Disposal Demonstration Project. Annex 4 – Detailed Project Description World Bank (2006). Environmental Impact Assessment Regulations and Strategic Environmental

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APPENDICES

1. Minutes of the consultation meetings and list of people attending the public consultation rounds

2. Policy Needs Assessment 3. Environmental Management Plan Template for demonstration sites.


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ANNEX 1. MINUTES OF THE CONSULTATION MEETINGS AND LIST OF PEOPLE ATTENDING THE PUBLIC COLSULTATION ROUNDS

Vietnam Environment Administration The World Bank

PCB Management Demonstration Project (PDF-B)

CS6 – Environmental Impact Assessment

MINUTES OF CONSULTATION WORKSHOP 24 June, 2008

Time: 13:30 – 16:30 Place: Berner Hall, Vietnam Electricity, 18 Tran Nguyen Han, Hanoi Subject: Workshop on Public Consultation for EIA framework of CS6 Chair: Ms. Le Thi Ngoc Quynh – Deputy Director of Science, Technology and

Environment Department, Vietnam Electricity (EVN) Participants:

1. From Government Agencies: Vietnam Environment Administration (VEA), Technical Safety and Industrial Environment Agency;

2. From Provincial Departments: Department of Natural Resources and Environment (DONRE) Nam Dinh, DONRE Hanoi, Department of Industry and Trade (DOIT) Hai Phong, DOIT Quang Ninh;

3. From EVN: Department of Science-Technology & Environment, Department of International Cooperation, Office of EVN; PC 1, PC Hai Duong, Nam Dinh, Quang Ninh, Hai Phong, Hanoi, Pha Lai JSC, and Electricity Transmission Companies of Ninh Binh, Quang Ninh, Hai Phong;

4. From Institutes/Centers/Universities: University of Civil Engineering, University of Natural Science, Research Centre for Environmental Technology and Sustainable Development (CETASD), Centre for Environmental Engineering of Towns and Industrial Areas (CEETIA), Centre for Environmental Change & Sustainability (CECS), Institute of Industrial Chemistry;

5. From Project Office of PCB-WB Project and Consultants Arcadis-Vidaneco. Main Content A – Opening 1. Ms. Le Thi Ngoc Quynh welcomed participants and stated the objectives of the consultation workshop. 2. On behalf of Consultant of component CS6, Mr. Stijn Vermoote and Mr. Paul Vanhaecke – ARCADIS Belgium presented the draft report of EIA framework. B – Discussion 3. Mr. Pham Manh Hoai – CETASD – asked about the methodology applied by Arcadis to assess the PCB’s impacts to human and environment through PCB storage and transportation. 4. Answer from Arcadis: the methodology was mainly based on the exposure risks from PCB oil and PCB-contaminated transformers. Each stage (e.g. storage, transportation) has different emission and exposure limits. Quantitative method is applied to calculate potential impacts. When implementing the project, e.g. at the transportation stage, if preventive solutions


116

(e.g. to prevent spills and leaks) are provided and well practiced, potential adverse impacts will be avoided. 5. Mr. Do Thanh Bai - Institute of Industrial Chemistry – suggested Consultant add more inputs for quantification of pollution to calculate potential impacts in PCB management, treatment and disposal activities. 6. Answer from Arcadis: In general, in order to quantify a pollution load, there are common calculating methods to define pollution level (e.g. in air, water). Arcadis is now further studying the database of the U.S Environmental Protection Agency about emission factors and other relevant information. 7. Ms. Nguyen Anh Thu – Independent Consultant said, the report presented an EIA framework; however, suggestions for minimizing these impacts were not provided yet. Ms. Thu suggested, in case Consultant Arcadis did not have sufficient practical experience in Vietnam, international experience are welcomed to be used to reduce impacts. It was also suggested that Arcadis consult with local experts to come up with reduction measures appropriate with current situation of Vietnam. 8. Answer from ARCADIS: Vidaneco is the local consulting company of Arcadis in Vietnam, which has experienced domestic experts. For Ms. Thu’s suggestion, as reduction measures must base on specific and practical impacts, moreover, the report offered framework for common assessment only, it is very difficult to bring out specific measures. However, Arcadis would supplement into the report typical impacts and their respective specific reduction measures (e.g. exposure, emergency responses). 9. Mr. Nguyen Ba Yem – Nam Dinh PC: for risks and occupational safety related to handling PCB-contaminated equipment, materials and PCB wastes, Nam Dinh PC is implementing EVN’s guideline for safe handling with electrical equipment. However, there still lack standards and guidelines for proper handling with PCB-containing or PCB- contaminated materials (clouts, paper…). He suggested relevant authorities should issue regulations and safety instructions in near future, so that they have a base to follow to avoid exposure and cross-contamination risks. 10. Mr. Nguyen Anh Tuan - Project coordinator remarked that the report presented quite good and adequate methodology on EIA. The targeted subjects to this activity include: (i) those who know well about EIA but little about PCBs, thus objective of CS6 is to provide an EIA framework which will serve as a guide, and (ii) those who directly execute the project, then help them understand potential impacts and preventive measures. Up to now, Pha Lai is the only site selected as the demonstration site for the project, other sites in other provinces havenot been determined yet. Therefore, the responsibility of CS6 Consultant is to establish an EIA framework at Pha Lai to serve as a model and a detailed guideline to be applied in other sites. Based on report of CS6 Consultant, Mr. Tuan gave following comments:

- Legal/policy framework which has been assessed in the report should extend to analysis of EIA in Vietnam regarding PCB;

- When developing the TOR, the World Bank required the EIA framework should be used not only as a frame instruction for other demonstration sites of the project (not for Pha Lai only), but also for other similar projects in the future in Vietnam;

- The Ministry of Natural Resources & Environment has issued EIA and social impacts assessment instruction, Consultants could refer to this document;

- Apart from EIA, the World Bank also required this report to assess social impacts; however, this content in the report was still vague, Consultants should supplement and focus more on this part.


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11. Answer from ARCADIS: Arcadis would acknowledge Mr. Tuan’s suggestion on assessment of legal frame and social impacts. About referring to instruction of MONRE, Arcadis found that this document would be difficultly used by the project, for demonstration sites of this project are scatteredly located in 15 different provinces. 12. Ms. Le Thi Ngoc Quynh – EVN highly appreciated the overview and multiple aspects assessed in Arcadis’ EIA content; however, Ms. Quynh recommended that Consultants should focus only on issues directly related to the project (e.g. exposure). Consultants had the responsibility to report to WB on the real situation in Pha Lai. Pha Lai is relatively isolated with surrounding areas, so environmental impacts would also be limited (e.g. no impacts on historical, archaeological values, fauna and flora) 13. Mr. Do Tien Doan – Project officer spoke: the report of Consultants consisted of 2 sections: (i) WB’s safeguards policy and (ii) Vietnam’s EIA process; thus, Mr. Doan suggested Consultants Arcadis should have a combined section which meet both WB and Vietnam requirements. On the other hand, in a recent meeting between CS6 Consultant and WB, WB informed that this project was no longer classified in Category A project but Cat. B (because it involved in management only, not disposal as original approach), thus Consultants should recheck with WB and then adapt the report accordingly. 14. Answer from ARCADIS: report content was divided into 2 activities (management and disposal), so it would be easy to change according to WB’s new requirements. C – Closing 15. On behalf of EVN – the leading of CS6, Ms. Le Thi Ngoc Quynh acknowledged suggestions and comments from participants and EVN would work with Consultant to complete EIA report.


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PCB Management Demonstration Project (PDF-B) Consulting Service 6 – Environmental Impact Assessment

Public consultation meeting minutes

June 26, 2008 Time: 8:30 – 11:30 Location: Meeting room of Power Company No 2, 72 Hai Ba Trung, Ho Chi Minh city Subject: Public consultation on EIA framework of CS6 component Lead by: Ms. Le Thi Ngoc Quynh – Vice director of Division on Science, technology and

Environment, Vietnam Electricity (EVN) Participants:

1. Representatives of VEA and Sub-branch of VEA in the East-South 2. Representatives of Provincial Departments: Department of Natural Resources and

Environment (DONRE) Can Tho and Ho Chi Minh, Department of Industry and Trade (DOIT) Ho chi Minh city.

3. From EVN: Department of Science-Technology & Environment, PC 2, PC Ho Chi Minh city, Lâm ng, ng Nai, C n Th , Bà R a-V ng Tàu, Thu Duc Thermal Electricity Company, Can Tho Thermal Electricity Company, Phu My Thermal Electricity Company, Eastern Electricity Transmission Company, Western Electricity Transmission Company, Electricity Transmission Company No. 4.

4. From Institutes/Centers/Universities: University of Civil Engineering, Institute for Resources and Environment in Ho Chi Minh city, VENETCO

5. From Project Office of PCB-WB Project and Consultants Arcadis-Vidaneco. Major contents A – Opening

6. Ms. Le Thi Ngoc Quynh welcomed participants and presented the objectives of the meeting as well as general information of the project and CS6.

7. Representative of the consulting firm ARCADIS Belgium, Mr. Stijn Vermoote and Mr. Paul Vanhaecke – presented the draft report on EIA framework

B – Discussion

8. Mr. Nguyen Hung – Phu My Thermal Electricity Company wonders the reason that the Pha Lai Themral Electricity Company is replacing 19 PCB containing transformers is due to PCB or due to their expiration. On the other hand, he wonders if PCB could be generated during the operation process. If so, is there any measure to reduce PCB concentration?

9. Ms. Le Thi Ngoc Quynh – EVN answers: Replacement of 19 transformers in Pha Lai is followed the company’s plan. However, it matches with the activities and objectives of the PCB Management Demonstration Project so that the project will support the company to build up a storage facility for these transformers and other potential PCB containing equipments. On the other hands, PCB is not generated during the operation process but due to intentionally added into oil.


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10. Ms. Anh Xuan – Sub-branch of VEA in the East-South comments: the report on EIA

framework is quite good but is not detailed enough when describes the impact level of project activities.

11. ARCADIS answers: The report is just an EIA framework to which any specific EIA report can follow so that it can only be in a general form.

12. Ms. Le Thi Bich Thuy – VENETCO has following comments:

¾�The report on EIA framework does not include the task of screening to see if the project falls into category 1 or 2 in order to comply with Vietnamese regulations.

¾�The report on EIA framework does not mentions the reporting systems in order to comply with Vietnamese regulations (decree 21)

¾�The report lacks of social plan ¾�The report lacks of pre-construction phase ¾�Due to Vietnam situations, the potential impacts of project activities may be more

than those indicated in the report. It is guessed that those impacts were indicated based on the knowledge of foreign consultants who lives and works in more developed countries. Therefore, the Arcadis may need to consult more with local consultants to have a deeper analysis in this issue.

13. ARCADIS answers: ¾�Agree to include in the EIA framework the task of screening to see if the project falls

into category 1 or 2 to comply with Vietnamese regulations ¾�Will review again the requirement of Vietnamese regulations on the reporting systems ¾�Agree to include in the EIA framework the analysis and plan on social issue ¾�The pre-construction phase is already in the report but is emerged in the construction

phase ¾�Will analyzed deeper on the potential impacts taking into account the real situation of

Vietnam

14. Mr. Thanh – Institute for Resources and Environment in Ho Chi Minh City asks: The project does not have the disposal component, why does the EIA framework report also include this component?

15. Ms. Le Thi Ngoc Quynh - EVN: The report include disposal component for the follow up project.

16. Ms. Anh Xuan – Sub-branch of VEA in the East-South comments: The EIA framework should also include the mitigation measure and emergency plan.

17. ARCADIS answers: Since it is just a framework, a detail mitigation measure can not be included. However, it is agreed that a general mitigation and emergency plan will be considered.

C – Conclusion

18. On behalf of EVN – the leading of CS6, Ms. Le Thi Ngoc Quynh acknowledged suggestions and comments from participants and EVN would work with Consultant to complete EIA report.


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Consultation meeting Hanoi 24/06/08


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Consultation meeting Ho Chi Minh City, 26/06/2008


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ANNEX 2. POLICY NEEDS ASSESSMENT

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Table 0-1: Policy Needs Assessment - Summary Table (Breeze and Associates, 2007a) Vietnam Current Practice Best Practice Gap Recommendations Policy Framework 27 policies “Life cycle” policy frameworks

Integrating regulation(s) Economic instruments / technical support Clear definitions

Life cycle gaps Inconsistent Overlap Limited support Limited compliance

1) Develop a “life cycle” policy framework 2) Develop integrating regulations with • economic instruments • technical support 3) Provide clear definitions • PCB equipment • PCB materials

Establishing Priorities

No formal priorities Different priorities established: Priority 1 > 100,000 mg/kg > 500 mg/kg Priority 2 > 50 mg/kg Priority 3 > 2 mg/kg > 5 mg/kg PCB free < 2 mg/kg < 5 mg/kg

Priorities not yet established 4) Develop a practical, staged plan based on analysis of capacity 5) Plan should have: • Thresholds for high risks • Definitions for sensitive sites • Set a balanced pace - 16 years • Be reviewed in 5 years 6) As a starting point for discussion • Priority 1 - > 500mg/kg • Priority 2 > 50 mg/kg • Priority 3 > 5 mg/kg • PCB Free < 5 mg/kg

Priorities – Sensitive Sites No definition for sensitive sites for PCBs Long list of sensitive sites:

• Hospitals • Schools • Food and feed • Senior’s • Drinking water • Potable water • Aquatic spawning • Endangered species

Sensitive sites not defined for PCBs 7) Develop a list of sensitive sites to meet Vietnam’s needs based on: • Analysis of capacity • National considerations

Phase Out - Timelines


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Vietnam Current Practice Best Practice Gap Recommendations No formal timelines Phase out timelines range from 10 to

20+ years Increments for each priority range from 3 to 10 years

Timelines not yet set 7) Establish timelines starting with high concentrations / sensitive sites 7) Move incrementally from high to low with completion target of 2020 or 2025 7) As a starting point for discussion • Priority 1 (S) – 5 yrs • Priority 1 (Not S) – 9 yrs • Priority 2 (S) – 13 yrs • Remaining – 17 yrs (2025)

Disposal Deadlines

NIP sets disposal deadline as 2028 End of storage deadlines range from 1 to 2 years

No deadlines 8) As a starting point for discussion • 2 years for PCBs in storage when disposal facilities

established • 1 year for PCBs coming out of service after disposal facilities

available

Restrictions and Bans

Restrictions: • Import • Export • Municipal landfilling • Direct releases • Mixing / diluting

Bans: • Manufacture • Import • Mixing / diluting • Reuse / recycling • Dust suppression • Discharges to environment Restrictions: • Export • Municipal landfilling (solids >

50 or liquids > 5)

No bans: • Import • Manufacture • Dust suppression No restrictions: • Reuse / recycling • Mixing / dilution (5 to 50 mg/kg) • Liquids in landfills (5 to 50 mg/kg)

9) As a starting point for discussion Bans: • Manufacture • Imports (except for labs) • Dust suppression Restrictions: • Export (with PIC) • Mixing / diluting (>5 mg/kg) • Reuse / recycling (>5 mg/kg) • Municipal landfilling (> 5 mg/kg for liquids)

In-Service Equipment

Several chemical regulations on: • Chemical identification

All regulate in-service equipment. • Registration

Unclear how or when the chemical regulations apply to PCBs

10) Require registration 11) Require annual updates 12) Establish operating standards


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Vietnam Current Practice Best Practice Gap Recommendations • Registration / declaration • Chemical safety • Inspection and reporting

• Routine reporting • Repair / retrofilling • Storage • Worker safety • Monitoring / inspection

13) Establish worker safety practices in technical guidelines 14) Establish standards for on-site storage 15) Develop two guidelines to support in-service regulations

PCB Waste Management

Dec. 155, Dec. 23 and Cir. 12 in place “Cradle to grave” HW requirements

Integrated HW and waste PCB “cradle to grave” requirements Supportive technical guidelines Financial guarantees for HW facilities

Inconsistency between Dec. 155 and Dec 23 / Cir.12 Few supporting guidelines Placarding / labeling inconsistent No financial guarantees for private facilities

16) Amend HW Reg’s to ensure consistency 17) Define “out of service” as HW 18) Develop technical guidelines: • Generator registration • Transfer, transportation and storage • Decontamination of transformers 19) Amend technical guidelines: • Dec. 60/2002, MOSTE • TCXDVN 320-2004, MOC • HW in Cement Kilns 20) Require financial guarantees

Contaminated Sites LEP commitments • Site ID • Measures to stop at source • Rehab • Compensation NIP commitments • Site ID • Clean-up of POP hot spots

Comprehensive site ID and clean-up policies and programs Requirements for notification and rapid response

Few formal activities in place for site ID and clean-up No implementing provisions for rapid response and clean-up responsibility

21) Assign responsibility to owners: • Notification • Studies • Leaking equipment • Action to stop discharges and clean-up • Compensation for effected parties 22) Coordinate a PCB clean-up program with NIP POP commitments

Policy Compliance


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Vietnam Current Practice Best Practice Gap Recommendations Some inspection and enforcement efforts for HW Some technical support for: • Industry • DONREs Some resources New sanctions

Clear PCB regulations Technical guidelines for industry Visible inspection and enforcement Significant sanctions Protocols for inspection staff

Inconsistent regulations Limited technical support Limited resources / inspections Sanctions will not promote compliance

23) Develop outreach program • Brochures • Ad’s • Presentations 24) Develop technical guidelines (See Rec. 18) 25) Develop inspection protocols and enforcement mechanisms 26) Provide necessary resources 27) Assess cost of compliance and increase sanctions to provide disincentives

Environmental Monitoring More than a dozen monitoring initiatives undertaken NIP (PP #10) commits to building laboratory capacity VN with Korea on POPs database

Environmental monitoring programs for POPs and PCBs National monitoring programs for receiving environments

No formal program in place No formal database Uncertain laboratory capacity

28) Establish national program coordinated with NIP PP #10 and Korean initiative • First round sampling in two years • Coordinate with ASEAN nations

National Inventories HW data beginning to be collected Several one time PCB inventories undertaken Most extensive underway by EVN / Experco

Annual inventories: • In-service • Phased out • Storage • Disposal Annual analysis and submission of results

No routine submissions of “life cycle” data (see Rec. 10 and 11) No national “life cycle” inventory Limited analysis

29) Require tabulated reports by DONRE for submission to VEA biannually 30) Require VEA to consolidate and analyze for submission to PM, Minister and public

Public Involvement

LEP confers rights to individuals: • EIA reports • Registered commitments • Lists of chemicals • Degraded sites • Waste plans

Access to: • Information • Decision making • Justice Data available: • Inventory reports • Monitoring reports • Reports from owners Applications for new facilities /

Limited individual access to data collected Limited individual access to the decision making Limited individual access to justice

31) Develop communications program for POPs / PCBs 32) Require all reports available using on-line register 33) Require applications be available for comment 34) Develop guidelines for disadvantaged groups 35) Prepare outreach guidelines aimed at small sources


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Vietnam Current Practice Best Practice Gap Recommendations opportunities for involvement

Capacity Building and Training

Initial training provided at national and in selected provinces by VEA through VCEP

Integrated HW and PCB training provided to all government staff involved in implementing the PCB regulations

Limited training provided for HW and no training for PCBs

36) Develop training for national / provincial levels as part of HW training: • Training for all Ministries with PCB responsibility • Training for VEA in:

- Engineering assessment / licensing - Inspection / enforcement

• Training for DONRE in: - Generator registers - Engineering assessment / licensing - Inspection and enforcement - Monitoring

Cost Recovery Mechanisms


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Vietnam Current Practice Best Practice Gap Recommendations LEP - Polluters responsible for remediation, compensation VEF mobilizes funding from national and donor

Polluter pays principle is a core element No implementing regulation for LEP principles 37) Establish a process to set: • User fees for storage transportation, treatment and disposal • Administration fees for government costs 38) Develop cost allocation formula 39) Put the following economic instruments in place to make: • Owners responsible for mgt • Owners responsible for site clean-up • Electrical utilities responsible for system survey / mgt

Roles and Responsibilities Line Ministries responsible for key aspects: • HW • Chemical programs

Environment agencies responsible Overlapping responsibilities Inconsistent interpretations and compliance

1) In short term, give MONRE uniform State management for PCBs 2) In short term, give MONRE provisions proposed for new PCB regulation 3) In long term, consider a transition plan towards clear environmental responsibilities

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ANNEX 3: ENVIRONMENTAL MANAGEMENT PLAN TEMPLATE The following is a suggested template that PMU and facility owner can use to develop an environmental management plan.

1. Introduction (Recommended 1-2 pages) a. Subproject Background b. General information of the site and the owner c. Objectives

2. Subproject Description and Setting (Recommended 2-3 pages) Provide a brief summary of the subproject and its setting, including a map showing local and regional characteristics. This information will be extracted from the EIA approved by the WB and from EPC approved by the government of Vietnam.

a. Subproject Map – a map of the subproject area and its regional context should be provided showing subproject components the affected subproject area.

b. Subproject Summary – only key project details should be included such as what activities will be carried out, area of the storage sites, height of the store (if applicable), capacity of the store, etc.

c. Environmental Setting - The environmental setting should describe major environmental features.

3. Key Environmental and Social Issues (Recommended 2-3 pages) Using the subproject EIA/EPC, a summary of key environmental impacts arising from each subproject phase (construction and operation) should be provided. The list of impacts will be used to describe specific environmental mitigation and management actions to reduce and/or eliminate subproject impacts.

a. Key Environmental Issues b. Key Social Issues (if any)

4. Key Mitigation and Management Actions The EMP should describe mitigation and/or management actions that facility’s owner will implement to reduce and/or eliminate subproject impacts to an acceptable level as determined by Vietnamese regulatory authorities and to ensure compliance with World Bank Safeguards. These mitigation and management actions will form part of No Objection conditions. While it recognized that the extent and magnitude of these mitigation and management actions will vary with subproject characteristics, a generic mitigation and management action template is provided Table 8.1. The mitigation plan wil include:

a. Identifies and summarizes all adverse environmental impacts. b. Describes, with technical details each mitigation action for each type of impact. c. Describes indicator and timing. d. Provides linkages to other plans.

5. Supervision, Follow-up and Monitoring The EMP describes measures for supervision of facility’s owner to ensure that the subproject is being constructed in compliance with environmental and social commitments and suggested mitigation measures. Specifically supervision describes the following:

a. Structure and function of the environmental supervision unit b. Types of data that will be collected to measure EMP compliance

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c. Types of action taken in the event of non-compliance d. Reporting mechanisms

Environmental monitoring during subproject implementation provides information about key environmental aspects of the subproject, particularly environmental impacts and the effectiveness of mitigation measures. The EMP identifies monitoring objectives and specifies the type of monitoring, with linkages to the impacts assessed in the EA report and the mitigation measures described in the EMP. Specifically, the monitoring section of the EMP provides the following:

a. Specific description and technical details of monitoring measures to be implemented including parameters to be measures, methods, sampling locations, frequency, analyses, and definition of thresholds for corrective action.

b. Monitoring and reporting procedures.

6. EMP Timeline and Costs The EMP should provide an implementation schedules and capital and recurrent costs of implementation. 7. Public Consultation and Disclosure All subprojects require at least one public consultation and the results of the consultation documented in the EMP. The public consultation can be conducted either prior to preparing a draft EMP in order to establish key environmental issues to be included in the EMP, or after a draft EMP is completed to act as a basis of discussion and to elicit any additional environmental issues that may be of concern to affected groups. 8. Suggestions for EMP Preparation and Review The focus of the EMP is to describe, in a clear and concise manner, how mitigation and management actions will be implemented to reduce subproject impacts to acceptable levels; it is not intended to replicate the subproject EIA or EPC, although this information shall form the basis of the EMP. • The subproject description should only summarize those design aspects that could result

in an environmental impact requiring a mitigation or management action; it is not necessary to describe the subproject in detail and provide unnecessary textual description, tables or drawings;

• The EMP should include a map that clearly indicates the area affected by the subproject and also a regional context to allow for easy location;

• The EMP should only summarize the environmental and social setting of the subproject; • The EMP should only summarize key issues or impacts of the EIA/EPC; it is not

necessary to repeat them in detail; • The EMP should provide clear and detailed mitigation or management commitments on

behalf of the PMU for each and every key impact of concern, including responsibility and timeline for implementation;

• The EMP should include a detailed description of costs as these will form part of subproject financing.

• The developer should ensure that adequate public consultation is completed. • The WB should review the EMP and ensure that all key subproject impacts have a specific

management or mitigation action to reduce the impact to an acceptable level; • Costs of the EMP should be tallied and included as part of subproject financing costs; • The WB should verify that adequate consultation has been completed and that there are no

outstanding issues on behalf of subproject stakeholders, local organizations or government regulators.

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