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VIETNAM ELECTRICITY
TRUNG SON HYDROPOWER COMPANY LIMITED
TRUNG SON HYDROPOWER PROJECT
ENVIRONMENTAL
MANAGEMENT PLAN (Draft)
INFRASTRUCTURE CONSTRUCTION OF
RESETTLEMENTS
TRUNG SON HYDROPOWER PROJECT
Prepared by:
Thang Long Infrastructure Development JSC. (Infra-Thanglong)
Ha Noi, July 2013
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CONTENT
1. GENERAL INTRODUCTION 5
1.1 Background 5
1.2 EMP Purposes and Scope 6
2. SUB-PROJECT DESCRIPTION 7
2.1 Resettlement sites 7
2.2 Architectural Solutions 21
2.3 Progress of subproject 23
3. LEGISLATION BASIS 25
3.1 Vietnamese Legislation 25
3.2 Safeguard Policies of the World Bank 26
4. THE MAIN ENVIRONMENTAL IMPACTS 27
5. THE MITIGATION MEASURES 39
6. THE EMERGENCY ACTION PLANS 47
7. THE ENVIRONMENTAL MORNITORING PLAN 48
7.1 The monitoring plan in compliance with the mitigation measures 48
7.2 The environmental quality monitoring 51
8. EMP IMPLEMENTATION 53
9. REPORTING SYSTEM 55
10. CAPACITY BUILDING 56
11. ESTIMATED COST FOR EMP IMPLEMENTATION 56
12. COMMUNITY CONSULTATION AND INFORMATION DISCLOSURE 58
13. REFERENCES 59
14. ANNEX 59
14.1 Annex 1 – Location of disposal sites 60
14.2 Annex 2 - Minutes of community consultation 63
14.3 Annex 3 – TOR for Construction Supervision Consultant (CSC) 64
14.4 Annex 4 – Environmental Responsibilities of Contractor 66
3
LIST of TABLE
Table 1: Summary of impacts ................................................................................................................................ 27
Table 2: Environmental mitigation measure .......................................................................................................... 39
Table 3 : Chance finding procedure and emergency action plan ........................................................................... 47
Table 4: The mornitoring plan ............................................................................................................................... 48
Table 5 : The environmental sampling program .................................................................................................... 52
Table 6: The roles and responsibilities of the stakeholders in the EMP implementation progress ........................ 54
Table 7: Requirement of mornitoring report ......................................................................................................... 55
Table 8: Propsed training program on EMP .......................................................................................................... 56
Table 9: Estimated cost for EMP implementation ................................................................................................. 56
LIST of FIGURE
Figure 1 – Map of Resettlement Communes ........................................................................................................... 8
Figure 2 – Resettlement site No. 1 ........................................................................................................................ 11
Figure 3– Some existing photos of the resettlement site No. 1 ............................................................................. 12
Figure 4 – Resettlement site No. 2&3 ................................................................................................................... 15
Figure 5 – Some existing photos of the resettlement sites No. 2 &3 ..................................................................... 16
Figure 6 – Plan of Resettlement Site No. 4 ........................................................................................................... 18
Figure 7 –Some existing photos of the resettlement site No. 4 ............................................................................. 20
Figure 8 – Report and monitoring outline for EMP implementation ..................................................................... 53
4
ABBREVIATIONS
DONRE Department of Natural Resource and Environment
EPC Environmental Protection Commitment
EMP Environment Management Plan
EVN Vietnam Electricity
FS Feasibility Study
RCC Roller Compacted Concrete
TORs Terms of References
UXO Unexploded ordnance
WB the World Bank
PMU Project Management Unit
5
1. GENERAL INTRODUCTION
1.1 Background
Trung Son Hydropower project shall be built on Ma river, in territory of Trung Son
commune, Quan Hoa district, Thanh Hoa province with an installed capacity of 260MW and a
mean annual electricity of 1018.6GWh, which is a multi-purpose project providing power
generation and flood control benefits. Proposed dam is about 40km from Lao PDR
downstream, reservoir tail is about 10Km from the border. A roller compacted concrete
(RCC) dam is 84.5 m in height with 513 m crest length. Full supply level is 160m. Total
capacity of the reservoir is 348.50 million m3. Flood Control storage is 112 million m
3. The
reservoir covering an area of 13.175Km2 will inundate a mixture of forest and agricultural
land.
Total estimated cost is US$ 386 million, of which there is an estimation of US$2.9 million
for environment managing tasks (except for the tackled requirements which the bidders must
follow) and US$35.1 million for compensation, resettlement and livelihood restoration for
affected people. EVN has officially applied for a WB loan of USD330 million from IBRD.
At present estimation, there is a total of about 10,591 people belonging to 2,327
households to be affected by the project as a whole. About 533 households shall be displaced.
Of those, it is estimated that about 1,945 people of 486 households shall be affected by
construction of access road, 7,012 people of 1,516 households shall be affected by
construction of main dam and dam associated structures, reservoir, and reservoir upstream
and downstream impacts.
Households to be displaced due to the project impacts shall relocate to 4 planned
resettlement sites. Resettlement site No.1 – to be built in Trung Son commune, Quan Hoa
district, Thanh Hoa province; Resettlement site No.2 - to be built in Muong Ly and Tam
Chung communes, Muong Lat district, Thanh Hoa province; Resettlement Site No.3 – to be
built in Trung Ly commune, Muong Lat district, Thanh Hoa province; Resettlement Site No.4
– to be built in Tan Xuan commune, Moc Chau district, Son La province. The Basic Design of
such resettlement sites have been developed and approved by the Client. It is expected that
after the completion of the detailed design, the construction period of resettlement sites is 12
months.
An environmental screening was undertaken in line with the World Bank safeguards policy
requirements and it showed that the World Bank’s policies on Environmental Assessment –
6
Procedure/ Regulations (OP/BP 4.01), Natural Habitats (OP/BP 4.04), Involuntary
Resettlement (OP/BP 4.12) and Policy on Access to Information are triggered for the
subproject. The implementation of the subproject would cause both negative and positive
impacts to the subproject area. The negative impacts will occur during pre-construction,
construction, and operation. However, these impacts are not significant, temporary, localized,
and can be mitigated with available mitigation measures. The positive impacts will occur
mostly during operation. Positive impacts will likely be significant and positive due to their
long term nature at both the local and regional level. Therefore, the subproject is assessed as
B environmental category.
The Government’s regulation on environmental assessment requires submission of an
Environmental Protection Commitment (EPC) for the subproject. Three EPC reports were
prepared and submitted to the District People’s Committees of Quan Hoa, Muong Lat and
Moc Chau in April 2013. The EPC report for Resettlement Site No.1 was approved by the
People’s Committees of Quan Hoa District under Decision No.233/UBND-TNMT dated
27/05/2013. The EPC report for Resettlement Site No.2 & 3 was approved by the People’s
Committees of Muong Lat District under Decision No.305/UBND-TNMT dated 22/05/2013.
Regarding to resettlement site No.4 located in buffer zone of Xuan Nha natural reserved area,
environmental and ecological impacts generated from the land-use’s purpose changing and
resettlement construction will be detailedly analyzed in an independent EIA prepared by
another consultant. This report will be submitted to and approved by Appraisal Council of
MONRE (as stipulated in Environmental Protection Law of GoV). Consulting firm for this
assignment is being selected and the draft of report is intended to be completed by December,
2013. In addition to fulfilling the government requirements, an Environmental Management
Plan (EMP) that complies with the World Bank OP 4.01 needs to be prepared for this
subproject.
1.2 EMP Purposes and Scope
Main purposes of EMP:
(i) Present the mitigation measures to minimize the potential impacts generated during the
phases of a project.
(ii) Develop the environmental monitoring programs in order to control and evaluate the
efficiency of the mitigation measures;
(iii) Estimated cost to implement EMP.
7
EMP will also be in compliance with the Environmental Management Framework of the
Trung Son Project, which is included in Annex K of the EMP of Trung Son hydropower
project.
Scope of EMP:
This EMP is used to address impacts and mitigation measures to be implemented during
the pre-construction, construction, and operation phases of the resettlement sites, including
work items as follows:
(i) Ground leveling;
(ii) House construction;
(iii) Construction of public works: Community house, Kindergartens, Primary school and
houses for teachers; health care centre;
(iv) Construction of internal roads, suspension bridge, ferry;
(v) Construction of water supply system;
(vi) Construction of electricity system;
(vii) Construction of irrigation system;
(viii) Land reclamation.
2. SUB-PROJECT DESCRIPTION
2.1 Resettlement sites
Resettlement and Cultivation Areas No. 1, 2, 3 & 4 located in Trung Son commune of
Quan Hoa district and Trung Ly, Tam Chung and Muong Ly communes of Muong Lat
district, Thanh Hoa province and in Tan Xuan commune of Moc Chau district, Son La
province (see Figure 1 below).
8
Figure 1 – Map of Resettlement Communes
MA RIVER
DAMS
9
Resettlement site No. 1:
* Geographical coordinate
- Latitude: from20° 34' 52" to 20° 39' 01" North
- Longitude: from 104° 49' 24" to 104° 52' 10" East
* Geographical location
The resettlement site No.1 is bounded by Son La province to the North and West, by sub-area
No.14 and No.03 of Trung Son commune to the South and East.
The Resettlement site No. 1 is constructed for settlement of 235 relocated households
(including 27 spared land blocks for further demand up to 2014). As planned, the ground
leveling will be implemented for only 208 households in 5 resettlement points as follows:
- Co Pung village: 48 households;
- Pa Pua village: 29 households;
- Pom Chon village: 55 households;
- Keo Dam village: 44 households;
- To Xuoc village: 32 households;
Co Pung resettlement point: With an area of 5.98ha, this point is about 1km from the
existing Ta Ban village to the Northwest. Investment construction items in Co Pung
resettlement point include 48 family houses, 01 community house of 60m2, 01 kindergarten
with 02 classrooms, 01 primary school with 03 classrooms, 02 single rooms for teachers and
associated infrastructure system of internal road, water supply and electricity.
Pa Pua resettlement point: With an area of 3.04ha, this point is about 0.5km from the
existing Ta Ban village to the Northwest. Investment construction items in Pa Pua
resettlement point includes 29 family houses, 01 community house of 60m2, and other
associated infrastructures system. Requirement for social service is provided by new one
constructed in Co Pung resettlement point.
Keo Dam resettlement point: With an area of 4.73ha, this point is about 01km from the
existing Ta Ban village to the Southwest. Investment construction items in Keo Dam
resettlement point include 44 family houses, 01 community house of 60m2, 01 kindergarten
with 02 classrooms, 01 primary school with 03 classrooms, 03 single rooms for teachers, and
associated infrastructure system of internal road, water supply and electricity.
10
Pom Chon resettlement point: With an area of 7.19ha, this point is located on the hill top,
surrounded by Quanh stream and Ma river, about 1km from Pom Chon resettlement point to
the South. Investment construction items in Pom Chon resettlement point includes 55 houses,
01 community house of 60m2 and associated infrastructure system. Social services is provided
by new one system constructed in Keo Dam resettlement point.
To Xuoc resettlement site: With an area of 3.28ha, this point is about 1km from existing
Xuoc village to the Southwest. To Xuoc resettlement point includes 32 houses, 01 community
house of 60m2, 01 kindergarten with 01 classroom, 01 primary school with 02 classrooms,
and infrastructure system of internal road, water supply and electricity.
All the resettlement points are connected to the West Road of Thanh Hoa Province- a
provincial road of western districts, which is under construction and completed by 2014 (see
the details in Figure 2).
11
Figure 2 – Location of Resettlement site No. 1
West Thanh Hoa Road
Quanh Stream
Resettlement points
pppoint
Ma River
West Thanh Hoa Road
Quanh Stream
Resettlement points
pppoint
Ma River
West Thanh Hoa Road
Quanh Stream
Resettlement points
pppoint
Ma River
12
Figure 3– Some existing photos of the resettlement site No. 1
The existing condition of land use in the
resettlement sites
Bamboo, cassava in the resettlement sites
The existing road with high slope
The existing section of West Road not
constructed
Ta Ban Stream
Quanh Stream
13
Resettlement site No. 2:
* Geographical coordinate
- Latitude: 20° 32' 14" to 20° 34' 32" North
- Longitude: 104° 45' 39" to 104° 47' 13" East
* Geographical location
The resettlement site No.2 is bounded by Son La province to the North, by Ma river to the
South and on the East and the West by Muong Ly commune
The Resettlement site No. 2 is planned for 112 households (including 12 standby land
blocks for development by 2014. As planned, the ground leveling will be implemented for
100 households in 03 resettlement points as follows:
- Nang village: 54 households;
- Tai Chanh village: 35 households;
- Lat village: 11 households;
Nang village resettlement point: With an area of 6.23ha, this point is about 1.5km from
the existing Nang village to the higher position. Nang village resettlement point includes 54
houses, 01 comunity house of 100m2, 01 kindergarten with 02 classrooms, 01 primary school
with 8 classrooms, 04 rooms for teachers, 01 health care centre, water supply and electricity
system.
Tai Chanh village resettlement point: With an area of 3.69ha, this point is about 200m
from the former Tai Chanh village. Tai Chanh village resettlement point includes 35 houses,
01 comunity house of 60m2, 01 kindergarten with 02 classrooms, 01 primary school with 03
classrooms, 02 rooms for teachers, water supply and electricity system.
Lat village resettlement point: With an area of 1.43ha, this point is about 200m from the
former Lat village. Lat village resettlement point includes 11 houses, 01 new health care
centre, water supply and electricity system.
14
Resettlement site No. 3:
* Geographical coordinate
- Latitude: 20° 31' 07" to 20° 32' 27" North
- Longitude: 104° 45' 54" to 104° 47' 13" East
* Geographical location
The resettlement site No.3 is bounded by Sub-are No. 58 and 55 of Trung Ly commune to
the South and the East and on the West by sub-area No. 66 of Trung Ly commune, Muong
Lat distrist.
The Resettlement site No. 3 is planned for 41 households (including 6 standby land blocks
for development by 2014. As planned, the ground leveling will be implemented for 35
households in 02 resettlement points as follows:
- Lin village: 19 households;
- To Chieng village: 16 households;
Lin village resettlement point: With an area of 2.9ha, this point is about 1.5km from the
existing Lin village. Lin village resettlement point includes 21 houses, 01 community house
of 60m2, 01 kindergarten with 02 classrooms, 01 primary school with 03 classrooms, 02
rooms for teachers and water supply and electricity system,.
To Chieng village resettlement site: With an area of 1.44ha, this point is about 1km from
the existing To Chieng village. To Chieng resettlement point includes 19 houses, and other
social infrastructures to be shared with Lin resettlement point.
15
Figure 4 – Resettlement site No. 2&3
Resettlement sites
West Thanh Hoa Road Ma river
16
Figure 5 – Some existing photos of the resettlement sites No. 2 &3
The existing condition of land use in the
resettlement sites
Bamboo, cassava in the resettlement sites
Some locations with low density of
vegetation cover ( resettlement site No.2)
Existing school in Ban Nang Village
Medical Station- Ban Nang village Existing market of Ban Nang village
17
Resettlement site No.4:
* Geographical coordinate:
- Latitude: 20° 39' 0" North
- Longitude: 104° 39' 14" East
* Geographical location
The resettlement site No.4 is bounded to the North by Xuan Nha commune, Moc Chau
distrist, Son La province and by Trung Ly commune, Muong Lat distrist, Thanh Hoa
province to the South, by Trung Son commune to the East and to the West by Chieng Xuan
commune, Moc Chau distrist, Son La province.
The Resettlement site No. 4 is constructed for settlement of 186 relocated households
(including 16 spared land blocks for futher demand up to 2014), As planned, the ground
leveling will be implemented for 170 households at 03 resettlement points as follows:
- Tham Ton: 50 households;
- Pom Hien - Suoi Non 1: 68 households;
- Pom Hien - Suoi Non 2: 68 households;
Tham Ton resettlement point: With an area of 9ha, this resettlement point is located on the
right side of Tan Xuan road connecting Xuan Nha commune to Tan Xuan commune.
Invesment construction items in Tham Ton resettlement point include 50 family houses, 01
community house of 100m2, 01 kindergarten with 02 classrooms, 01 primary school with 03
classrooms, 02 single rooms for teachers and associated water supply and electricity and
internal road system.
Pom Hien - Suoi Non #1 resettlement point: With an area of 18.9ha, this point is located
in Dong Ta Lao village. Investment construction items in Pom Hien - Suoi Non #1
resettlement point include 68 family houses, 01 community house of 60m2, 01 kindergarten
with 02 classrooms, 01 primary school with 03 classrooms, 02 single rooms for teachers, and
assoicated water supply and electricity and internal road system.
Pom Hien - Suoi Non #2 resettlement point: With an area of 13.5ha, this point is located
in Tay Ta Lao village. Investment construction items in Pom Hien - Suoi Non #2 resettlement
point include 68 family houses, 01 community house of 60m2, 01 kindergarten with 02
classrooms, 01 primary school with 03 lassrooms, 04 single rooms for teachers and associated
water supply and electricity and internal road system.
18
Figure 6 – Plan of Resettlement Site No.
Resettlement poits
The planned reservoir bottom
19
4
20
Figure 7 –Some photos on existing condition of the resettlement site No. 4
The existing Tan Xuan road
Existing condition of Tham Ton resettlement
site
Existing vegetation coverage in defined
position of Pom Hiến – Non #2 Stream
The existing land use in Pom Hien- Non #1
Stream resettlement sites
The existing roads
Ta Lao Stream
21
2.2 Architectural Solutions
Residential land: the land blocks are arranged along the internal road. Each land block
contains an area of 700m2, including 250 – 300 m2 of ground leveled for house construction
and remains for garden land. Totally, there are 342 land blocks for relocated households
allocated to resettlement sites No. 01, 02 and 03) and 202 land blocks allocated to
resettlement site No. 04. Additionally, 61 spared land blocks are also prepared for future
demands up to 2014.
Living houses: Stilt house and one-floor house
modes are designed availably to selection of
relocated people. House is separated into two parts:
(i) The main space with living room and bedroom;
(ii) The auxiliary space is arranged to one side of
house with one separated entrance. The total area of
house alternatively is 25m² or 45m² or 65 m²
deepened on number of member of relocated
household.
Community house: The selected design is a
large stilt house with an auxiliary room under the
main floor.
Kindergartens: One shared space is arranged to
two ages of child. Classroom contains (i) A room
for kid activities, one dining room and one
bedroom; (ii) The auxiliary space with corridors
and one multi-purpose spare room and toilet and
kitchen.
22
Primary classrooms: An one-floor classroom is
designed with three separated rooms and associated
windows and doors (see picture).
Single room for teachers: One-foor mode is
designed close to schools. Each house contains
separated spaces included living room, bed room,
kitchen and toilet.
Health care centre: Functional areas is designed including (i) Emergency room; (ii) surgery
room; (iii) Patient room; (iv) Warehouse; (v) Management room.
Internal road, suspension bridge and ferry: The internal road system connected the
resettlement points to the external road is designed as the Grade-B Standards for rural road
with the total length of 7.69 km for resettlement sites No. 1, 2 &3 and 14.54 km for
resettlement site No. 4.
Suspension bridge is designed with the length of 111m and width of 2.5m and access road
in accordance with the standard for Grade B. Ferry is designed with the width of 3.5m and
working water level varied from 150m to 160m. These two construction items is only
prepared for resettlement point Suoi Non #1 (Resettlement site No 4).
Water supply system: In each resettlement points, the water from targeted streams is
conveyed to the centralized filter tank with capacity of 17m3/h. Treated water is delivered by
D34-D42 steel pipes along internal road's sides to 2m3 water tank of each household by PVC
D27 plastic pipes.
23
2.3 Progress of subproject
Subproject is divided to 08 packages with budgets and progress below:
No. Code of
package
Name of package Budget
(million
VNĐ)
Bidding
time
Constructi
on time
2013 2014 2015
10 11 12 1 2 3 4 5 6 7 8 9 10 11 12 1 2 3
1 W-RE-01 Construction of resettlement site No.1
Quan Hoa district, Thanh Hoa province
(ground leveling, internal road, public
house and living house)
55,704 4th Quarter
2013
12 months
2 W-RE-02 Construction of resettlement site No.2 & 3
Muong Lat district, Thanh Hoa province
(ground leveling, internal road, public
house and living house)
36,577 1st Quarter
2014
12 months
3 W-RE-20 Construction of resettlement site No.4
Moc Chau district, Son La province
(ground leveling, internal road, public
house and living house)
102,823 3rd Quarter
2013
12 months
4 W-RE-04 Construction of water supply system for
resettlement sites No.1, 2 & 3 Thanh Hoa
33,009 4th Quarter
2013
08 months
24
No. Code of
package
Name of package Budget
(million
VNĐ)
Bidding
time
Constructi
on time
2013 2014 2015
10 11 12 1 2 3 4 5 6 7 8 9 10 11 12 1 2 3
province
5 W-RE-21 Construction of water supply system for
resettlement site No.4 Son La province
17,639 3rd Quarter
2013
08 months
6 W-RE-03 Construction of 35/0.4KV power line and
substation and 0.4KV power line
38,066 3rd Quarter
2013
08 months
7 W-RE-05 Reclamation for agricultural cultivation
in Thanh Hoa province
3,263 1st Quarter
2014
12 months
8 W-RE-06 Reclamation for agricultural cultivation
in Son La province
1,430 3rd Quarter
2013
12 months
25
3. LEGISLATION BASIS
The EMP is prepared in compliance with the environmental regulation of GoV and the
environmental safeguard policy of the WB.
3.1 Vietnamese Legislation
o The Law on Environmental Protection approved by the National Assembly of the
Socialist Republic of Vietnam dated 29th November, 2005;
o Decree No.29/2011/ND-CP dated 18th April, 2011 of the Government on strategic
environmental assessment, environmental impact assessment and environmental
protection commitment;
o Circular No.26/2011/TT-BTNMT dated 18th July, 2011 of the Ministry of Natural
Resources and Environment, detailing a number of articles of the Government's
Decree No. 29/2011/ND-CP dated 18th April, 2011 on strategic environmental
assessment, environmental impact assessment and environmental protection
commitment;
o Decree No. 149/2004/NĐ-CP dated 27th July, 2004 of the Government on granting
license for water source utilization and operation, and use of water sources, discharge
of water into water sources;
o Decision No. 233/QĐ-TTg dated 18th October 2006 by Prime Minister approved the
National Program for the Protection of Labor, labor safety, labor hygiene in 2010.
Table 2.1: Vietnamese regulations on environmental
NO NAME OF REGULATION Code
1 Land quality – National technical regulation on the allowable
limits of heavy metals in the soils
QCVN 03:2008
2 Land quality – National technical regulation on the pesticide
residues in the soils
QCVN 15:2008
3 National technical regulation on domestic water quality QCVN 14:2009
4 Water quality - National technical regulation on surface water
quality
QCVN 08:2008
5 Water quality - National technical regulation on underground
water quality
QCVN 09:2008
6 National technical regulation on Industrial Wastewater QCVN 41:2011
7 Acoustic – National technical regulation on noise QCVN 26:2010
8 National technical regulation on Vibration QCVN 27:2010
26
NO NAME OF REGULATION Code
9 Air quality – National technical regulation on ambient air
quality
QCVN 05:2009
10 Air quality - National technical regulation on hazardous
substances in ambient air
QCVN 06:2009
11 Air quality - National Technical Regulation on Industrial
Emission of Inorganic Substances and Dusts
QCVN 19:2009
12 Air quality - National Technical Regulation on Industrial
Emission of Organic Substances
QCVN 20:2009
13 National technical regulation on the emission of health care
solid waste incinerators
QCVN 02:2008
14 Radiation safety-Basic signal related to ionization radiation TCVN 7468:2005
15 Requirement to set up radiation immunity areas TCVN 7515:2005
16 Guidance on radiation immunity areas TCVN 7516:2005
17 Definition of status of radiation TCVN 7517:2005
3.2 Safeguard Policies of the World Bank
The Bank Operation Policy (OP) and Bank Procedure (BP):
Environmental Assessment – Procedure/ Regulations (OP/BP 4.01)
Natural Habitats (OP/BP 4.04)
Involuntary Resettlement (OP/BP 4.12)
Policy on Access to Information.
27
4. THE MAIN ENVIRONMENTAL IMPACTS
An environmental impact assessment is an assessment of the possible positive or negative impact that a proposed project may have on the
environment, together consisting of the environmental, social and economic aspects. To identify and evaluate the impacts of any one project, there are
various methods commonly used for environmental impact assessment such as checklist method; matrix method; and cost-benefit analysis method.
In this part of report, the checklist method is applied which is widely used and generally sufficient for small-scale projects having Category B
classification. The construction of the subproject will mainly caused impacts on land acquisition, increased levels of dust, air pollution, and wastes.
However, these impacts are not significant, temporary and localized and can reduce by mitigation measures.
Table 1: Summary of impacts
No. Impacts Manigtude Duration Description of impact Impacts
assessment
Pre-construction stage
1 Land
acquisition
Medium Permanent As master plan, total area of resettlement sites is 4,357ha (see table). Of which, area for construction
of infrastructure and houses is 81.31 ha (1.86%), the land reclamation for agricultural cultivation is
140.04 ha (3.21%). Existing forest area assigned to household management is 4,135.65 ha
(94.93%).
The affected vegetation is mainly planted bamboos, distributed in Co Pung, Pa Pua, Pom Chon, Keo
Resettlement site Affected area (ha)
Site No.1 837.5
Site No.2&3 780.5
Site No.4 2,739
Total 4,357
Medium
and
mitigable
28
No. Impacts Manigtude Duration Description of impact Impacts
assessment
Dam points (Resettlement No. 1), Nang village point (site No.2), Tai Chanh, Lin villages (site No.3)
and Suoi Non (site No.4). Other areas are predominantly uncultivated land with shrubs and grasses.
2 Impact on
Subproject
affected
household
Medium Permanent The resettlement sites are constructed in agricultural and planted forest land. There is not any
household needs to be relocated and no resettlement is required. Number of affected households is
357. Compensation plan will be prepared and implemented by the project owner.
Resettlement site Numbers of affected households
Site No.1 126
Site No.2&3 123
Site No.4 108
Total 357
Medium
3 Accident
related to
UXO
None None Mine clearance was completed at all resettlement sites by Company No36 - Ministry of Defence
(through contract No 03/2013/HĐKT-TĐTS and No 04/2013/HĐKT-TĐTS);
None
4 Impact on
historical
and cultural
properties
None None The resettlement sites are selected to avoid crossing any historical and cultural properties such as
pagodas, churches. No cultural and historical site is affected by the sub-project. During soil
excavation, if there will be found any underground historical or cultural valuable object, the
contractor shall follow “Chance Find Procedures”
None
Construction stage
5 Loss of
vegetation
Medium Permanent The construction activities potentially created impact on vegetation coverage include site clearance
for agricultural cultivation (about 140 ha) and ground leveling for resettlement construction (81 ha).
Medium
and
mitigable
29
No. Impacts Manigtude Duration Description of impact Impacts
assessment
coverage
Resettlement site
Residential and infrastructural
area (ha) Land Reclamation Area (ha)
Site 1 24.22 13.86
Site 2&3 15.69 19.89
Site 4 41.4 106.29
Total 81.31 140.04
Affected vegetation is mainly planted bamboos and cassava, which have economic value rather than
ecological one. Normally, life cycle of bamboo from growing to cultivated time is about five years.
The newly developed areas are also used for bamboo planting and/or agricultural cultivation that
helps to compensate the loss of green coverage in each project area.
6 Threats to
flora and
fauna
minor temporary All resettlements sites are located in uncultivated land and/or planted forest (mainly bamboo) with
low bio-diversity but high vegetation coverage. Through community survey, there is only some
popular animals such as bird, rodent and reptiles that can be found in these areas. There is not any
sign of endangered species. Moreover, daily activities of local people such as transportation,
agricultural cultivation, bamboo planting and even hunting prohibit the widespread of these animals.
However, the construction activities such as site clearance, ground leveling and noise from
construction equipment and vehicles and the operation of worker’s camps can generate impacts to
the local habitats. The impact mainly happens in the beginning time of construction (about 3 months
from commencement) and needs to have suitable mitigation measures.
Minor
30
No. Impacts Manigtude Duration Description of impact Impacts
assessment
7 Dust Medium temporary Dust mainly sourced from (i) construction site and (ii) routes of transporting construction materials
(cement, sand, stone, steel, brick, etc.) and excavated soil and construction waste to disposal sites.
Most of the resettlement sites are separated to the existing residential areas with distance varied
from 1km to 3km. The existing green coverage is quite good. Dust mainly generates during the
ground leveling and road construction (about 3 months) and significantly reduces during house
construction.
For the transportation routes, based on assessment of construction material demand, the number of
truck mobilized is estimated as follow:
Resettlement site Material waste (basic design) Number of truck Time
Site No.1 9,900 tons 2-10 trucks/ day 12 months
Site No.2 6,000 tons 2-6 trucks/ day 12 months
Site No.3 7,800 tons 2-8 trucks/ day 12 months
Site No.4 10,000 tons 2-10 trucks/ day 12 months
With just around ten vehicle/truck predominantly operated in the first 3 months of construction
stage, the impact is evaluated as minor, temporary and mitigated by contractor’s measures.
However, 03 positions including Nang village and Tai Chanh Junior School (Site No.2) and Ta Lao
village (Site No.4) located on road sides are directly exposed to dust and needs to have effective
mitigation measures.
There is no new quarry and borrow pit required to be opened. All construction material will be
provided by local suppliers and/or from existing quarries/borrow pits that newly opened for the
medium
and
mitigable
31
No. Impacts Manigtude Duration Description of impact Impacts
assessment
Trung Son main project. All these quarries/borrow pits have to be licensed and strictly managed by
local authorities.
8 Noise and
Vibration
Medium Temporary Noise and vibration are mainly generated from the ground leveling, road construction and material
transportation.
All resettlement sites are quite isolated to existing residential areas. With only a few vehicles
operated daily, the impact is evaluated as minor, temporary and mitigated by contractor’s measures.
However, there are 02 sensitive points located along the transportation route including Tai Chanh
Junior School (Site No.2) and Ta Lao Junior School (Site No.4). Suitable mitigation measures are
required to be applied.
medium
and
mitigable
9 Erosion/lan
dslide
Minor Temporary Construction activities such as ground leveling on hill’s slope can create risk of landslide and/or
erosion, especially in rainy season; There are some key factors related to landslide/erosion
assessment, included:
Geological Characteristics:
Resettlement No.1 located on edQ layer with thickness varied from 0,5 to 3m strongly
weathered soil thickness >3m strongly weathered rock. Slope is greater than 25% and
groundwater is quite limited and stable geology .
Resettlement site No.2&3 located in granite stone and hard granite biotit. The slope is
higher than 25% and there is no sign of shallow groundwater presented.
Resettlement site No.4 located on the silt layer of high organic matter with thickness varied
from 0.3 to 0.5m and followed by layer of clay and limestone which are highly resistant to
water penetration.
minor
32
No. Impacts Manigtude Duration Description of impact Impacts
assessment
Climatic Characteristics
The rainy season usually begins from May to September. The rainfall is uneven with
monthly average rainfall is around 133mm;
Regarding to the resettlement site No.4, heavy rain occur from April to September with
monthly average rainfall is a little higher than other areas (around 200mm/month);
As natural condition of stable geological foundation and high vegetation coverage as well as
medium rainfall associated with the suitable design as GoV standard, impact related to
landslide/erosion is minor and mitigable.
10 Surface
water
pollution
Medium Temporary Pollution from construction sites
Run-off water from construction sites and/or waste water from worker camps possibly create impact
to the surrounding water sources (see in table below). The worker’s camps at one resettlement
points with around 30 people will be located close to construction site with minimum distance to the
water sources of 100m. With such a distance, solid waste and waste water still have chance to
entering into water bodies and have to be managed sufficiently.
Location Stream Name (width) Distance to the
construction site
Xuoc Village
(Site No. 1)
Unknown creek (<1m) Run through the
construction site
Nang Village
(Site No.2)
Nang Stream (6-8m) About 200m
Medium
and
mitigable
33
No. Impacts Manigtude Duration Description of impact Impacts
assessment
Ta Lao Village
(Site No.4)
Tà Lào Stream (6-8m)
Creek at Tà Lào Village(<1m)
About 100m
About 150m
Regarding to construction of resettlement site No.4, the suspension bridge and ferry are constructed
over the Quanh Stream with the width varied from 15 to 20m). This water of stream is quite
abundant and at good quality. The bridge abatement is build on land and there is no construction
activities conducted in the stream. The scope of work for ferry construction is also small. The
impact on water quality is evaluated as minor.
Pollution from material transportation routes
Most of the transportation routes such as West Road and Co Luong road located far from all water
sources. There is only one internal road of Nang village (resettlement site No.2) crossed Nang
stream at the connection point of Nang and Tai Chanh Village with no bridge and dam. Existing
stream has a high flow (with width of 6m) and good water quality and mainly used for irrigation
purpose. As estimated, about 02 to 05 vehicles are daily operated during construction. Chance for
material from transported vehicles dropping into stream is quite limited but still required to be
managed properly.
11 Solid waste
generated
Medium Temporary The estimate of excavated soil volume from ground leveling is presented as table below:
Location The estimated excavated soil (m3)
Resettlement Site No.1 34,876
Resettlement Site No.2 73,000
Resettlement Site No.3 18,438
Medium
and
mitigable
34
No. Impacts Manigtude Duration Description of impact Impacts
assessment
Resettlement Site No.4 68,600
Total 194,914
Design consultant, PMU and local authority have worked together to define suitable areas which
have average transportation distance of less than 1km and sufficient storing capacity. These disposal
sites can be used for agricultural cultivation after project completed. Some high slope position are
built stone embankment with a height of 1-2m to avoid erosion/landslide in rainy season.
Consequently, list below presents the selected sites:
For resettlement site No.1: 03 disposal sites located at Co Pung, Pa Pua and Pom Chon
resettlement point, along existing West Road.
For resettlement site No.2: 01 disposal site located between Nang and Tai Chanh Village
For resettlement site No.3: 01 disposal site located between To Chieng and Lin Village and
01 disposal site located at Lat village.
For resettlement site No.4: 06 disposal sites are located along the existing road
12 Domestic
waste
Medium Temporary The subproject is implemented in 12 months. The peak construction time lasts 8-9 months, and the
remaining time is reserved for ground leveling.
It is expected to have 80 workers involved in the construction of each resettlement site. These
workers will establish their camps on site. Workers can be locally selected, so each camp will have
about 30-40 workers.
In resettlement sites, auxiliary facilities such as sanitary bathrooms and toilets will be built for
workers.
Medium
and
mitigable
35
No. Impacts Manigtude Duration Description of impact Impacts
assessment
All waste discharged from camps is mainly domestic solid waste which can cause environmental
pollution. However, the discharged waste is mainly packing, leftover food, etc. with a small amount
(each camp will generate 40kg waste per day).
13 Impact on
current
infrastructu
re system
Minor Temporary The transportation of material to construction site and excavated soil to disposal site possibly create
impact to the existing technical infrastructure system of local people such as local road, electric
poles, water conveyed pipes of households.
Water pipes: the construction activities will not affect to existing water sources or
conveying system of local residents.
Electricity: Most of construction of resettlement areas are isolated to the existing residential
areas. However, there are some electric poles located right on the roadside that can be
impated during material transportation.
Road: New internal road will be constructed for resettlement points and then connected to
main roads such as West Thanh Hoa and Tan Xuan Roads (linked Tan Nha to Tan Xuan
communes). Currently, these main road is already asphalted with 6m in wide (Tan Xuan
road) or being constructed (West Thanh Hoa). The impact on road damage during
transportation is minor.
Minor
14 Conflict
between
constructio
n worker
and local
people
Minor Temporary The presence of immigrated workers possibly creates several social issues such as social vices (like
prostitution, gambling, Drugs etc.) and unhygienic situation around the worker's camp as well as
cultural conflict with local residents. Most of ethnic people at the resettlement sites are Thai,
Muong, H’Mong. They have the own cultural habit and customs, but not closed to surrounding
areas. Many construction activities are being implemented in project areas. The immigrated workers
are supposed to be easily integrated with local community. For manual work, the contractor can hire
Minor
36
No. Impacts Manigtude Duration Description of impact Impacts
assessment
the local labor (about 30-40% of construction labor). This impact is minor and temporary.
15 Health and
safety
Medium Temporary Labor accidents might happen during construction commencement stage if the safety issues are not
well considered. The leading safety hazards on site are falls from height, motor vehicle crashes,
excavation accidents, electrocution, machines, and being struck by falling objects. Some of the main
health hazards on site are asbestos, solvents, noise, and manual handling activities. Construction
work in these areas is not allowed under bad weather condition such as strong wind, mist, or
nighttime, etc.
Traffic accident can be happened when construction trucks/vehicle run through residential areas and
or crowed places like school, market.
Medium
and
mitigable
Operation stage
16 Impact to
habits and
customs of
local
people
Minor Temporary According to the public consultation, most of residents agreed with the design modes of
resettlement sites. Houses in new resettlement sites are designed with the same architectural
structure as the existing one. Additionally, with much better construction material, the new houses
are expected to withstand climate disasters such as high wind, heavy rain and storm. Along the road,
the similar house design contribute to create beautiful landscape of area. Besides, the sub-project
will also provide sufficient infrastructures such as electricity, water supply and hygienic toilets and
each resettlement point (30-50 households) will have a community house for public activities. It is
expected that it will takes short-time for relocated people being familiar with new location.
Minor
17 Dust, noise
and traffic
accident
Minor Permanent After project completed, the internal road will only be used by local people (mostly motorbike or
walking). All roads are concreted with the width of 2.5 to 3m and warning signs arranged around
sensitive points such as kindergarten, school, health care center in order to minimize risk of traffic
accidents.
Minor
37
No. Impacts Manigtude Duration Description of impact Impacts
assessment
Trade activities in resettlement area are still limited with only 01 or 02 trucks weekly come to
procure agricultural product and/or bamboo. Impact of dust and noise is not considerable.
18
Solid waste
and waste
water.
Minor Permanent
The maximum number of household in one resettlement point is 68. As practice, each household
will generate 2 kg solid waste per day. Annually, one resettlement site can generate around 50 ton of
domestic solid waste. Different to domestic waste from urban areas, waste in remote area is rich of
biodegradable matter that can be buried and/or used as natural fertilizer. As current customs of
ethnic group, solid waste are normally collected in digged hole in their own garden. In short-term,
this solution is acceptable. In future, centralized dumping site for each one resettlement point should
be considered for better management of domestic waste.
Waste water from household will be collected to small canals and to main drains along the road.
Sewage from toilet will be directly penetrated into soil. With very low density of population, this
method is environmentally acceptable and widely applied to almost all remote/mountainous areas.
Minor
19 Health and
Environme
ntal
Sanitation
Positive Permanent The positive change of environmental and living conditions of local people is presented in table
below:
Infrastructure Before the project After the project
Water supply - Simple pipe for collecting
water directly from
stream/creek to households
- The water storage is not
hygienic.
- Each household has its own water
tank.
- The centralized water storage with
filtering system for treatment.
Electricity - Small scale hydro-
generator for each
- Power is provided by national
electricity grid.
Positive
38
No. Impacts Manigtude Duration Description of impact Impacts
assessment
household.
- Unsafety and low capacity
of electricity.
- Safety and stable power system.
Drainage - Natural drainage. - Concreted canal/culvert system.
Toilet - Temporary, unsanitary. - Standard toilet
Traffic road - Mainly pathway - All concreted roads with traffic
signs.
20 Conflict in
water use
None None Irrigation water is required for new terraced paddy fields. Suitable water sources have been defined
through site survey and public consultation. Water from existing streams is collected and conveyed
to the field by pipe system. With very high vegetation cover on large catchment area, water is quite
abundant and sufficient for both irrigation and domestic uses purposes. As a result, there is no
conflict in water use.
None
39
5. THE MITIGATION MEASURES
Table 2: Environmental mitigation measure
No
.
Impacts
Mitigation Measures Implementation Unit
Pre-construction stage
1 Land acquisition Implement measures defined in the Subproject Resettlement Plan PMU
Construction stage
2 Loss vegetation
cover
+ All vegetation outside the limit of earthworks to be clearly marked and defined on-site by temporary
fencing or marking
+ Site clearance in a forested area is subject to permission from Department of Agriculture and Rural
Development.
+ The application of chemicals for vegetation clearing is not permitted.
+ Restore the vegetation in the reclaimed areas.
Contractor
3 Threats to flora and
fauna
+ Prohibition of hunting and fishing.
+ Burning for vegetation clearing is not permitted
+ No area of potential importance as an ecological resource should be disturbed unless there is prior
authorization from CSC, who should consult with PMUs, and the relevant local authorities. This could
include areas of breeding or feeding of birds or animals, fish spawning areas, or any area that is protected
as a green space.
Contractor
40
No
.
Impacts
Mitigation Measures Implementation Unit
4 Dust + Spray water on the road surface in case of high dust concentration or when complaint of residents raised.
+ At the project location route through residential areas (Nang village and Tai Chanh Junior School (Site
No.2) and Ta Lao village (Site No.4), it is required to have sprinkler regularly used before construction
vehicle passed.
+ Construction vehicles shall comply with speed and carried load limits
+ Material loads shall be suitably covered during transportation
+ Develop the suitable construction diagram and measures for reducing the construction time and plan
clearance for material gathering.
Contractor
5 Air pollution + All vehicles must comply with Vietnamese regulations controlling allowable emission limits of exhaust
gases.
+ Vehicles in Vietnam must undergo a regular emissions testing and get certified named: “Certificate of
conformity from inspection of quality, technical safety and environmental protection” following Decision
No. 35/2005/QD-BGTVT.
+ There should be no burning of waste or construction materials or cleared vegetation on site.
+ Cement processing plants should be located far from residential areas.
Contractor
6 Noise and vibration + Ensure the maintenance periodically of construction vehicles and equipment.
+ Avoid noises of construction equipment/vehicle during nonworking time.
+ Construction vehicles shall comply with speed and carried load limits
+ Community announcement about the details of construction plan.
Contractor
41
No
.
Impacts
Mitigation Measures Implementation Unit
7 Erosion/landslide + Abate the soil erosion and maintain the soil slope during excavation time.
+ Avoid clearing activities during the rainy season.
+ Installation waste-trapping screens in drainage ditches;
+ Storm building drains for the construction to avoid local inundation of water in heavy rain.
+ Dredging sediment and deposit.
Contractor
8 Water pollution + The Contractor must be responsible for compliance with the relevant Vietnamese legislation relevant to
wastewater discharges into watercourses.
+ Installation of the private toilets for worker camps including mobile and standard toilets.
+ Temporary drainage system for water drainage, bin for waste collection..
+ Waste water collection system with filter- tank.
+ Waste water storage for workers.
+ Prohibition of discharging waste into the residential and construction areas.
+ Regularly collect solid waste into the prescribed waste areas.
+ Before construction, all necessary wastewater disposal permits/licenses and/or wastewater disposal
contract have been obtained.
+ At completion of construction works, wastewater collection tanks and septic tanks shall be safely
disposed or effectively sealed off.
Contractor
9 Solid waste + Frequently tidy up dropped waste from the construction site to the disposal sites Contractor
42
No
.
Impacts
Mitigation Measures Implementation Unit
generated + Procurement of the waste collection equipment at the camps
+ With the hazardous waste, establish the collection system to store temporarily around the construction
sites, after that transport to the local hazardous waste treatment suppliers.
+ Build the hygienic toilets at each worker 's camp..
+ Negotiate with residents and local authority to arrange the comfortable accommodation for workers.
+ Regular collection and transportations of waste, garbage to the prescribed location.
+ Reuse non hazardous waste such as debris of cut trees, brick, rock etc.
10 Traffic
management
+ Prior to construction, carry out consultations meeting with local government and community
+ Installation of lighting at night must be done if this is necessary to ensure safe traffic circulation.
+ Place signs around the construction areas to facilitate traffic movement, provide directions to various
components of the works, and provide safety advice and warning.
+ Employing safe traffic control measures, including road/rivers/canal signs and flag persons to warn of
dangerous conditions (if necessary).
+ Avoid material transportation for construction during rush hour.
+ Signpost shall be installed appropriately in roads where necessary (especially 02 positions including Tai
Chanh Junior School (Site No.2) and Ta Lao Junior School (Site No.4) located along the transportation
route are more sensitive)
Contractor
11 Impact on public
social infrastructure
+ Awareness of machinery operator and supervise construction practice
+ Supervise excavation/leveling works to ensure that waste soil is transported to designated areas
Contractor
43
No
.
Impacts
Mitigation Measures Implementation Unit
+ Compensate for any damage of house, road and other social service system
+ Disclose construction plan and methods
12 Cultural/Social
conflicts,
increasing risk of
HIV/AIDs
+ Introduce environmental code of practice developed in the main project to regulate worker’s behavior.
+ Encourage contractor to hire local labor when possible
+ Extend the current communication campaigns on HIV/AIDs under the main project’s health program to
resettlement construction workers.
Contractor
13 Worker and public
Safety
+ Develop, apply and monitor the implementation of workplace safety regulations including safety
measures.
+ Provide protective equipment for workers and enforce the usage
+ Restrict unauthorized access to construction sites
+ Design bridges to ensure safe access at both ends
+ Ensure connection between the main road and roadside facilities to avoid accidents for vehicles,
particularly bicycles and motorbikes
+ Install and maintain lighting for use at night and signboards when carrying out construction works on
waterway
+ Set and implement limits on height of construction material loads on vehicles such as bricks, pipes
+ Worker allocation to site transportation or during loading/unloading of bulky materials and equipment
+ The contractor shall provide safety measures as installation of fences, barriers warning signs, lighting
system against traffic accidents as well as other risk to people and sensitive areas
Contractor
Contractor
44
No
.
Impacts
Mitigation Measures Implementation Unit
+ Blasting activities should be implemented within the designated time and local people shall be informed
prior to blasting.
+ Storage, transport, use and destroy of industrial explosive materials shall be strictly follow the guidelines
in Decree No 39/2009/NĐ dated on 23 April 2009 of the Govemment on Industrial Exploisive Materials
and the National Technical Regulation QCVN 02:2008/BCT on guidelines in storage, transport, use and
destroy of industrial explosive materials
14 Communication
with local
communities about
Subproject
environmental
issues
+ Maintain open communications with the local government and concerned communities;
+ Disseminate project information to affected parties (for example local authority, enterprises and affected
households, etc) through community meetings before construction commencement.
+ Provide a community relations contact from whom interested parties can receive information on site
activities, project status and project implementation results.
+ Provide technical documents and drawings to PC’s community, especially a sketch of the construction
area and the EMP of the construction site.
+ Notification boards shall be erected at all construction sites providing information about the project, as
well as contact information about the site managers, environmental staff, health and safety staff, telephone
numbers and other contact information so that any affected people can have the channel to voice their
concerns and suggestions.
Contractor
15 Workforce, camp
and site
management
+ Workers’ camps will be located at least 100 m away from schools and health care centers and not be
located on steep slopes. The workforce shall be provided with safe, suitable and comfortable
accommodations and safe portable water. They have to be maintained in clean and sanitary conditions.
+ Site offices, worker camps, mixing stations, and workshops shall be located NOT within 100m from any
Contractor
45
No
.
Impacts
Mitigation Measures Implementation Unit
water courses, 500 meters of existing residential area.
+ Engineers and workers shall register their temporary residence with the local authority.
+ Contractor should sign committeemen with local authorities on keeping of security and social safety on
subproject’s areas.
+ Allocate officer to be the Contractor‘s Workplace Safety and Environment Officer responsible for
environmental and safety issues including training for workers.
+ Septic tank toilets must be provided at all construction camp areas where there will be concentration of
labor.
+ First aid boxes shall be provided in each construction camp site.
Operation stage
16 Traffic accident - Maintain the traffic sign board system
- Conduct IEC campaign to local residents on traffic regulation
Local authority
17 Solid waste and
waste water
pollution
+ Set the collection bin for separating organic waste at each household
+ Control outlet of drain along road to avoid directly discharging into water bodies and/or cultivation
areas.
+ Conduct IEC campaign to raise awareness and practice of local residents on hygienic behaviors.
+ Operation and maintenance of drainage system, water supply system as well as toilet.
Local authority
18 Water use's conflict + Define the protected area of water sources Local authority
46
No
.
Impacts
Mitigation Measures Implementation Unit
management + Animal breeding, chemical pouring around water sources is not permitted
47
6. THE EMERGENCY ACTION PLANS
Table 3 : Chance finding procedure and emergency action plan
TT Risks Activities Responsibilities
1 Discover antiques during excavation time
- The contractor needs to protect the site and report to the CSC/PMU and local museum/culture management institution. - Bring them to the museum/culture management institution. Determine to continue the construction work or stop for investigation. The director of Cultural and Information Department and the director of the provincial museum have responsibility for the subsequent processing steps of the founded antiques in Article 21 of Decree No. 92/2002, guiding the implementation of the Law on Cultural Heritage
Contactor CSC Contractor Contractor Relevant institutions
2 Discover the place of historic interest during the excavation time
Protect the scene and report to the local authority. Determine who have responsibility, where and how to deal with and suggest the next action.
Contractor Relevant institutions.
3 The residents complain about the environmental problems from the construction activities
Handle the problems immediately if possible Record Discuss with the project owner/ local authority where the problem occurred
Contractor Contractor, PMU and local authority
4 Accident at work Perform first aid if possible and pick the victim up to the nearest hospital if necessary Protect the scene and make a sign Take the minutes of incident.
Workers/people who attend the scene Contractor Contractor and local community
5 Detect unexploded landmines
Protect the scene Report to the local authority Contact to the most suitable military unit for help
Contractor Contractor/ local authority.
48
7. THE ENVIRONMENTAL MORNITORING PLAN
7.1 The monitoring plan in compliance with the mitigation measures
Table 4: The mornitoring plan
Potential
impact
Monitoring
methods
Time Signs compliance Monitoring
Unit
1 Accident
related to
UXO
Check
documents
During the design
stage
Prior to the
contractor is
appointed to the
construction site
Sign the contract
Complete the work.
PMU
Independent
Monitoring
(6 months)
2 Destroy trees
and
vegetation
Observe the
vegetation and
tree covers
Before construction
site clearance
Weekly, during the
construction
clearance time
Agrarian floor.
Keep vegetation
far from the
construction site
-
PMU
Contractor
Construction
monitoring
The
independent
monitoring
(6 months)
3 Local
inundation
Observe the
actual drainage/
sewerage
process
After the heavy
rains
During the
extensive
excavation
Good surface
drainage
No stagnant water
on the construction
site
Construction
monitoring
Independent
monitoring
(6 months)
4. Generate
waste
Monitoring the
generated waste
and waste
treatment
weekly Clearance of
construction site
Cover waterproof
for the trash.
Prohibition of
disposing waste to
the construction
site
PMU
Construction
monitoring
Independent
monitoring
(6 months)
5 Noise and
dust
Interview
Monitoring dust
level in the
construction site
Monthly
Daily, during the
extensive
excavation,
concrete and
construction
Announce to the
local authority
Cover trucks
Limited dust level
on the construction
roads and site.
PMU
Construction
monitoring
Independent
monitoring
49
Potential
impact
Monitoring
methods
Time Signs compliance Monitoring
Unit
process
implementation
No complaint
about dust and
noise.
(6 months)
6 Water
pollution
Monitoring the
construction site,
surface drainage
in water storage
areas
Twice a week
Create the drainage
system and
draining hole/
sediment trap
Cover and embank
oil and fuel storage
areas
No trace of oil/fuel
leakage on the
ground.
Construction
monitoring
7 Cultural/soci
al conflict
Increased
risk of
HIV/AIDs
Interview
workers and
local residents.
Monitoring
workers in the
construction site
Monthly Communication
campaign to
prevent the risk of
HIV/AIDs for
workers at the
resettlement sites
Hire local workers
for manual
working
implementation
Construction
monitoring
Independent
monitoring
(6 months)
8 Increase the
threats of
hunting and
consuming
wild animals
Control the food
and worker
camps
Monitoring local
residents
Weekly, especially
weekend and
holiday
Not keeping wild
animals in camp
No hunting
equipment in camp
No report of wild
animal
consumption.
Construction
monitoring
Independent
monitoring
(6 months)
9 Protect the
cultural
resource
Monitoring During the
excavation
implementation
Application of
Revealed
Treatment Process
Construction
monitoring
Independent
monitoring
(6 months)
10 Landslide/
Erosion
Stability of
slope
Monitoring of
soil
transportation
and threats from
construction site,
especially from
excavation area.
Occurrence of
excavation process
Weekly at
construction site,
where vegetation is
not recovered
Prevent the slope
erosion during
excavation time
Cultivated lands at
construction sites
are re-planned.
Construction
monitoring
Independent
monitoring
(6 months)
50
Potential
impact
Monitoring
methods
Time Signs compliance Monitoring
Unit
11 Safety for
worker
Require labor
protection
clothing for
workers
Within 2 weeks,
since the contractor
has been mobilized
to the construction
site weekly
Develop the safety
rules at work
Workers with labor
protection clothing
such as gloves,
boots, hard hats,
etc at work
Construction
monitoring
Independent
monitoring
(6 months)
12 Safety for
community
monitoring the
construction site,
material and
stone pits,
during and after
implementation
of blasting work
Weekly during
construction time
Before and during
blasting time
Before the
implementation of
electric provided.
Set warning signs
at construction site
Guard before and
during the
exploded time
Including
construction
lighting system
Guider is available
for traffic when the
trucks go out or
loading and
unloading time
Training the safety
electric usage for
ethnic
Construction
monitoring
Independent
monitoring
(6 months)
13 Capacity to
approach of
users to the
infrastructur
e/ resource
monitoring the
impacts with the
infrastructure/
existing resource
Weekly The effected local
authority and
residents receive
the notice and
agree about water
supply progress for
construction and in
case of temporary
interruption.
Make more
driveways if
necessary.
Construction
monitoring
Independent
monitoring
(6 months)
14 Risk on fire monitoring fuel
and oil storage
areas
Daily Set warning fires at
the fuel and oil
storage areas
The combustible
source must be far
away from fuel and
oil storages at least
100m
Construction
monitoring
Independent
monitoring
(6 months)
15 Interrupted
the approach
or destroy
the
cultivated
monitoring the
cultivated land
around the
construction area
Weekly
After complete
excavation stage
Not allowed to
load/unload or
discharge waste,
building materials
at cultivated land
Construction
monitoring
Independent
monitoring
51
Potential
impact
Monitoring
methods
Time Signs compliance Monitoring
Unit
land area (6 months)
16 Health risk
related to
asbestos
cement
material
monitoring the
resettlement
activity.
During the
resettlement time
Residents wear the
face mask when
loading/unloading
roofs made by
asbestos cement.
Construction
monitoring
Independent
monitoring
(6 months)
17 Control the
transmissio
n of the
disease
Check the real
activity of
contractor about
the detail design.
During the
resettlement
construction time.
Construct the
sanitation and
drainage systems.
Set the lips and
holes for water
tanks.
PMU
Construction
monitoring
Independent
monitoring
(6 months)
7.2 The environmental quality monitoring
Beside mornitoring contractor's compliance on mitigation measures implementation, an
environmental quality monitoring/sampling will be implemented during project performance
(see table 5 below)
52
Table 5 : The environmental sampling program
No. Observation items Pre-construction Construction Operation
I Air quality
1. Parameter TSP, PM10, Noise
2. Frequency One time during 6
months after
construction
Per 6 months One time for the
first operation year.
3. Location
Resettlement site No. 1 2 points: on the planned West Thanh Hoa Road, near Co Pung
and To Xuoc Points
Resettlement site No. 2 3 points: Lat, Nang and Tai Chanh Village
Resettlement site No. 3 2 points: Lin and To Chieng Village
Resettlement site No. 4 3 points: Tham Ton, Suoi Non 1 and Suoi Non 2.
4. Applied Environmental
Standard
QCVN 05:2008/MONRE
QCVN 26:2010 / MONRE;
II Surface Water Quality
1. Parameter T°, pH, DO, TSS, BOD5, COD, oil and grease, Coliform
2. Frequency One time within 6
months prior to
construction
commencement
one time per six
months
One time within the
the first year of
pilot operation .
3. Location
Resettlement site No. 1 1 point: Tà Ban Stream
Resettlement site No. 2 1 point: Nang Stream
Resettlement site No. 3 1 point: To Chieng (Ta Buôn) Stream
Resettlement site No. 4 1 point: Quanh Stream
4. Applied Environmental
Standard
QCVN 08:2008/MONRE;
53
8. EMP IMPLEMENTATION
In order to ensure the EMP implementation operate effectively, environmental
management system is defined with involvement of related agencies (see figure 8).
monitoring
Report
Information interchange
Figure 8 – Organization chart of environmental management system (EMS)
During detailed design stage, EMP requirement have to be integrated into assignment..
During the bidding and contract negotiation process, contractors have to review all the
responsibilities and assigned task of contractor related to environmental mitigation measures
and make commitment to comply with the regulations. Cost estimate for mitigation measure
is encouraged to be done clearly.
In the construction phase, Construction Supervision Consultant (CSC) have
responsibility to conduct on-site monitoring on agreed mitigation measures implemented by
Contractors (see Terms of reference in Appendix 3)
The roles and responsibilities of the stakeholders during EMP implementation process are
summarized in the following table:
PMU
Trung Sơn
Construction monitoring
Contractor
WB
EVN
Community
Local authority
Independent Monitoring
Consultation
54
Table 6: The roles and responsibilities of the stakeholders in the EMP implementation
progress
Stakeholders Responsibilities Sub-project 's stage
1. Trung Son PMU
• Contracting with the consultant to conduct
the environmental screening and EMP
preparation for the sub-project.
• monitoring to ensure that the suitable
mitigation measures are applied for the
technical designs, bidding documents,
construction contracts and construction
monitoring.
• Arrange enough the resource including staffs
and budget for the EMP implementation and
monitoring of the sub-projects.
• The general monitoring to ensure the EMP
compliance.
FS preparation
Detailed design
Construction
Pilot operation
2. Feasible study
consultant
• Incorporation of mitigation measures on the
technical design documents and construction
contract and construction supervision.
• Cost estimate for environmental mitigation
measures.
FS preparation
3. Contractor • Ensure sufficient budget allocated to
implementation of environmental mitigation
measures by incorporated it into financial
proposal and contract.
• Implement all the mitigation measures as
agreed
Bidding and
construction
4. Construction
supervision
consultant (CSC)
• daily conduct on-site monitoring on health,
safety and environmental issues as defined in
EMP
5. Independent
monitoring
consultant
• Conduct monitoring on effectiveness of EMP
implementation
• Conduct sampling program
• Prepare report submitted to the WB and
relevant agencies
Construction
Pilot operation
55
6. The local
authorities
Facilitate to:
• Community consultation during the detailed
design (if available)
• Conduct community based monitoring system
on environmental impacts
Detailed design
Construction
7. The relocated
households
Participate in monitoring on environmental
issues generated from construction activities
-
9. REPORTING SYSTEM
Table 7: Requirement of mornitoring report
No. From To Report Frequency
1 The contractor PMU Monthly
2 Construction supervision
consultant
PMU Monthly
3 PMU Local authorities In required
4 Independent monitoring
consultant
PMU, WB Once per six months
5 PMU Trung Son Hydro Power
Company Limited
Once per six months
6 Trung Son Hydro Power
Company Limited
WB, EVN Once per six months
56
10. CAPACITY BUILDING
Table 8: Propsed training program on EMP
No. Contents Time Cost estimate
1 Training on labour safety and mitigation
measures for the construction workers
One time before
construction
commencement
Included in
construction
contract
2 Training on EMP implementation and
monitoring for staffs of PMU
Annually Included in training
program of main
project
3 Training on community based monitoring
for local authorities and representatives of
affected people of 5 communes
One time before
construction
commencement
35.000.000 VND
Total 35.000.000
11. ESTIMATED COST FOR EMP IMPLEMENTATION
Table 9: Estimated cost for EMP implementation
No. Items Before
construction
Construction Operation
1 The mitigation
measures
This cost is
counted in the
contract with the
design consultant
This cost is counted
in the contract with
the contractor
The local environmental
and sanitation management
cost.
2 Environmental
quality
monitoring of
CSC
Included in contract of CSC
3 Independent
monitoring
consultant
included
sampling
500.000.000 VND
57
program
3 Capacity
building cost
35.000.000 In general training fee of
Trung Son Hydropower
Project
AMOUNT: 535.000.000 VND
58
12. COMMUNITY CONSULTATION AND INFORMATION
DISCLOSURE
No. Location for
consultation
Day and
Time
Attended
members
List of participated local
authorities and
representatives of
households
Summarize the
issues as
discussed/mentioned
59
13. REFERENCES
1 Basic design for the resettlement sites of Trung Son Hydropower Project.
2 Approval of the basic design for the resettlement sites of Trung Son Hydropower
Project issued by Trung Son Hydropower Company Limited
3 Resettlement Plan report
4 EIA and EMP reports for Trung Son Hydropower Project (main project)
5 SESIA for Trung Son Hydropower Project.
14. ANNEX
60
14.1 Annex 1 – Location of disposal sites
The disposal location of
resettlement No. 1
61
The disposal location of resettlement site No. 2, 3
62
The disposal location of resettlement site No. 2, 3
63
14.2 Annex 2 - Minutes of community consultation
64
14.3 Annex 3 – TOR for Construction Supervision Consultant (CSC)
Overview:
CSC have responsibility to provide the specialized technical services (“Service”) to ensure the
effective EMPs implementation of the project.
Scope:
The general services that provided by CSC include controlling, monitoring the construction operation
to ensure that the approved mitigation measures in EMP have been implemented on the right track and
the negative effects to the environment have been mitigated.
On behalf of PMU, CSC intend to implement the following tasks:
- Frequently implement the site monitoring.
- Consider the implementation status of the environmental protection measures in EMP and
contract.
- Consider the effect of the environmental mitigation measures and environmental implementation
of the project.
- If necessary, consider acceptable in terms of environmental construction methods (for both the
temporary and permanent constructions), relevant design plans and submissions. As required, the
CSC find and recommend plans for the least impact on the environment in consultation with
designers, contractors and the PMU
- Verify the results of the investigation of any non-compliance with the implementation of
environmental quality and the effectiveness of the remedial measures; and
- Provide feedbacks of audit result to the Chief Engineer of the contractor under specific mitigation
measures in the site.
- Guidance for the Contractor to perform corrective actions within the provisions and
implementation of additional monitoring if required, following the request and the order of the
contract in case of non-compliance and complained states;
- Require the Contractor in undertaking actions to reduce the impact and compliance with the EMP
as required in the case of non-compliance/ inconsistent identification;
- Require the Contractor to stop the action causing harmful effects, and / or the Contractor fails to
implement the requirements of the EMP / conduct corrective actions
- For contracts that needed the Site Environmental Management Plan (SEMP), CSC must
consider the last time and give recommendations through all environmental planning in the site
that can affect the environment. This task includes, but is not limited to: dredging areas, temporary
material pits, disposal and camp areas. CSC will review and approve the SEMP submitted by the
Contractor. If the plan does not comply with the EMP, EIA or RAP, CSC must work with the
PMU and the Contractor to provide a solution or suitable overcome.
- Address the complaints: complaints from local people will be collected by the Contractor's site
staff about environmental violations such as noise, dust, traffic safety, etc. Head or Deputy Head
Consultant of Contractor and CSC are responsible for processing, handling and achieving
solutions to the received complaint. CSC have to provide a copy of the complaint and confirm that
these complaints are resolved by Contractor, similar as the relevant problems when examining the
site.
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- Verify monthly payment: CSC must confirm monthly payments for the relevant activities in term
of the environment made by the Contractor.
- Report: CSC are required to establish the following reports in documents:
o Report every two weeks about incompliance problems.
o The monthly summary report includes the main problems and discovers by checking
the construction operations.
o By the end of the project, CSC are required to establish the final report to summarize
the main findings of the assignment, the number of violations, solutions, etc as well as
consultation and instructions on how to perform the similar tasks in the future.
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14.4 Annex 4 – Environmental Responsibilities of Contractor
The Socialist Republic of Vietnam
Independence- Freedom- Happiness
-------------oOo-------------
DISCLOSURE FOR THE ENVIRONMENTAL OF CONTRACTOR
Legal representation of Contractor is required to read carefully this disclosure, fill information
in the form and sign it. This is an integral part of Bidding Documents, as well as an essential part of
the Installation and Construction Contract that signed with the Contractor, to confirm that the legal
representation of contractors have read and fully understood all environmental requirements that
mentioned in the Bidding Document for the installation packages of the following Items: Construction
of resettlement areas, Trung Son Hydropower Project.
1. Contractors confirm that the bid price included all necessary cost to ensure the
implementation of all mitigation measures in EMP of each item and in compliance with environmental
technical specifications in the Bidding Documents.
2. The contractor confirm that legal representation of contractors shall appoint
Mr/Mrs….……….……………………………………. to be the Safety and Environmental Officer
(SEO) for bidding package. This officer will be in charge of working full time at the sites to ensure in
compliance with environmental and safety requirements of the bidding package.
3. The contractors also confirm that all incompliance with these conditions might be punished.
THE LEGAL REPRESENTATIVE OF
CONTRACTOR
67
The environmental requirements of construction and installation in the resettlement areas has been
established and presented clearly by environmental consultant in EMP (detailed in section 3, EMP –
Environmental mitigation measures). The contractors need to careful read and fully understand all
requirements to be included into the contractor’s bid: Construction of resettlement areas, Trung Son
Hydropower project.
I. Overview
In order to avoid negative effects into the environment and local community, as well as minimizing
damaging impacts to the environment during the construction and operation stages of the resettlement
sites, Contractor and workers are required to observe the mitigation measures as mentioned below:
- “Environmental Management Plan for construction and equipment installation items of the
resettlement sites in Trung Son hydropower Company Limited”.
- The technical specifications, procedures and the most popular practices are presented in this
Annex.
II. Overall responsibilities of Contractor to the environment:
Contractor need to include, but not limited the following responsibilities:
- In compliance with the legal regulations about the current environment in Vietnam.
- Working in scope of requirements in the contract and the conditions in the bidding documents.
- Assign the representative of the construction team to participate in the site inspection operations by
the PMU, CSC or the DONRE as well as implement all corrective actions to overcome the
environmental issues as guidance provided by the Supervision Engineer;
- Provide and update information for PMU about activities, assignments that can contribute ỏ continue
to cause the significant harmful impacts into the environment.
- In case of instruction by the Supervision Engineer and PMU, the Contractor must stop the
construction activities that causes adverse impacts, also propose and conduct the environmental
remedial actions and implementation other construction methods (if required) to minimize the negative
environmental impacts.
- Establish and maintain an Environmental and Safety Board which consists of Construction team
leader or Vice- team leader and Safety and Environmental Officer (SEO) with the purpose of receiving
and dealing with the complaints, objections, argument and displeased of the local community caused
by the construction operation. SEO is responsible to record all of complaints, resolve methods and
results into the complained register. The register need to keep at the construction office and available
for review by the supervision engineer and PMU.
III. Responsibilities of Contractor in EMP implementation:
The construction contactor has responsibility in compliance with the technical specifications of EMP
of the resettlement site construction items, Trung Son Hydropower Plant and regulations about the
current environmental management of Vietnam, included but not limited the following items:
i) Application of the mitigation measures of the negative impacts into the environment is
presented in Section 3- The mitigation measures of environmental impacts and
68
Section 4- Emergency Action Plan of EMP for the resettlement sites and prepare budget
for implementing the mitigation measures.
ii) Based on EMP, Contractor developed the detail plan for implementing the environmental
management. The detail plan include the following components:
- Management Plan for worker camps.
- Management Plan of the overall construction operation.
- Plan for management and storage of construction materials (including the dangerously
chemicals)
- Solid waste and waste water management plan (including construction and household waste)
- Plan for management and mitigation of noise and dust.
- Plan for management and mitigation of impacts to vegetation and wild animals.
- Plan for environmental landscape restoration
- Healthy and safety ensuring plan at the construction.
- Erosion and soil aggrandizement controlling plan.
- Safety plan during the construction stage and training for workers about environmental
management and community relations.
- Rules and regulations about living activities of staffs and workers at the construction sites.
- Emergency Problem Treatment Plan.
- Management and Monitoring Plan for Report Process.
The detail measure of plan need to satisfy the following requirements: to implement the particular
mitigation measure: who implement (people, team, etc), how to implement ( labours, machines,
equipments…) and cost? (Contractor should choose the paragraphs and diagrams representation for
good application in the future). This plan shall be completed and submitted together with the
bidding document.
iii) Ensuring that at least one supervisor is available in compliance with EMP before and during
the construction time.
iv) Ensuring that all of the construction activities will be approved in document of the relevant
authorities.
v) Ensuring that all of staff and workers understand through their process and duties.
vi) In compliance with requirements about the environmental management monitoring and
reporting in EMP and inform to PMU about the difficulties and solutions.
vii) Inform to the local authority and PMU in case of environmental problems and co-ordinate
with the relevant institutions and stakeholders for resolving.
IV. Safety and Environmental Officer of Contractor:
Each contractor will nominate a Safety and Environmental Officer (SEO) to work full-time at the
construction site. Requirements for a SEO include a undergraduate degree in Environmental Major, at
69
least 3 years of working experience in environmental management, training and monitoring at the
infrastructure construction project. Additionally, SEO should have a good knowledge about
Vietnamese Environmental Legal Regulations and has participated to the labor safety and sanitation
training class that organized by Department of Labour- Invalids and Social Affairs and have the labor
safety and sanitation certificate.
SEO have the responsibilities for implementing and managing EMP of Contractor. Tasks of SEO will
include, but not limit the following activities:
- Training and developing environmental awareness for workers of Contractors within 2 weeks since
be mobilized, after that the training is repeating every six months. The additional trainings will be
implemented under the guidance of Environmental Supervision Engineer.
- Conduct the internal environmental monitoring at the site to check the construction activity
implementation of contractors, equipments and implementation methods to manage the environmental
pollution and evaluate the efficiency of the mitigation measures into the environmental impacts.
- Internal monitoring the implementation of environmental mitigation measures and in compliance of
contractors with the environmental protection measures to prevent and control pollution; the
committed requirements in the contract; guidelines of the contractor(s) on environmental
improvement, environmental awareness and also proactive measures to prevent pollution.
- Conduct an investigation and propose the mitigation measures for the contractor(s) in case of
incompliance/ infringe the EMP; monitoring and implementing the environmental mitigation
measures.
- Evaluate the success of the EMP implementation to estimate effectively the cost and adequacy of the
implemented mitigation measures.
- Survey after receiving the complaint, thence evaluate and select the corrective actions.
- Conduct the additional monitoring activities, based on the concrete guidelines of the monitoring
engineer and/ or PMU; and
- Contact and implement all activities under the co-ordination or guidance of the Contractor Leader,
Environmental Supervision Engineer, Supervision Engineer, PMU, representatives of the provincial
environmental management offices, local authority about all of environmental problems if necessary.
- Establish the regularly reports for the environmental implementation of package according to the
frequency as mentioned at Section 7- Contact information and report of the EMP for the
resettlement sites of Trung Son Hydropower Project.
- All of the internal monitoring as well as other activities of SEO should be minuted and updated
frequently into The environmental implementation monitoring diary of Contractor. This diary is
used for normally checking by the supervision engineer to evaluate the effect of SEO.
V. Monitoring the environmental implementation of Contractor:
Client will sign a contract with the Consultant to carry out the task of Supervision Engineer.
Consultant will apply the environmental and monitoring activities of the package. The environmental
monitoring engineer of construction/execution monitoring Consultant is responsible to monitor daily
the implementation of measures, in order to minimize environmental impact and safety of the
Contractor. The construction monitoring Consultant will carry out the following main tasks:
70
Before the construction stage, make sure that all of the compensation process for land,
works on land and relocation and/ or recovery/ donation of land as well as the clearance
of landmines and UXO have been completed.
Review and approve the detail plan for implementing the EMP by Contractor before the
construction operation.
During the construction process, monitoring closely the compliance with implementing
of the environmental and safety mitigation measures.
Confirm the compliance with the EMP of Contractor and check any negative effect or
damage caused by the contractor. If necessary, establish a request statement for
contractor to compensate/ restore the construction site, as provided in the contract. The
implementation of environmental management issues of the Contractor shall be
mentioned in the progress report of the sub-projects.
VI. Compliance Regime:
a. The contractors are not allowed to implement the construction activities, including preparation
of construction within the project scope in advance the detail plan of EMP are reviewed and
approved by the construction supervision consultant and environmental official of the Client.
b. The Client is mandatory the Contractor in compliance with the contract provision including
compliance with EMP and the detail implementation plan of EMP. In case of incompliance
with EMP, Client will require the Contractor to bring out the suitable measures.
c. In order to ensure in compliance with the environmental standards of the sub- project, Client is
allowed to hire the third party to solve the problems in case the Contractor could not
implement the remedies on time, leading to the negative effects into the environment, as
follow:
- For insignificant mistakes (such as minor impact/ damage, temporary and repairable),
Client or the representative of Client (Supervision Consultant) will notify the Contractor
to correct the problems as required in the EMP within 48 hours after receiving the official
report. If the mistakes are satisfactorily repaired during that time, no more action should
be undertaken. Supervision consultants have the right to extend more 24 hours in the
limited time for recovery, under the conditions that the Contractor has implemented
activities but not completed the prescribed time, due to irresistible conditions that
mentioned in the contract.
- For major violations, it is required about 72 hours for repairing, the Client through the
supervision consultant will announce the violation and require the Contractor to rectify
within the prescribed time by their budget. If the Contractor fails to complete corrective
work according to the specified time, they will be punished by financial punishment (cost
punishment is calculated by the cost of remedying damage)
- According to the evaluation of the Supervision Consultant, if the Contractor fails to
resolve the problems in environmental management or the contractor conduct reparing
unsatisfactorily within the specified period of time (48 hours or 72 hours), the investors
have the capacity to arrange for another contractor (third-party) to implement the suitable
measures and deduct money for this task from the contract with the contractor in the next
payment.