Viet Nam: Ha Noi Metro Rail System Project (Line 3: Nhon – Ha Noi ... · Viet Nam: Ha Noi Metro...

Environmental Monitoring Report

Annual ReportJanuary to December 2016

Viet Nam: Ha Noi Metro Rail System Project(Line 3: Nhon – Ha Noi Station section)

Prepared by Ha Noi Metropolitan Railway Management Board for the AsianDevelopment Bank.

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CURRENCY EQUIVALENTS(as of 31December 2016)

Currency Unit – Viet Nam Dong (VND)VND1.00 = $ 0.000046

$1.00 = VND 22,642

ABBREVIATIONSADB - Asian Development BankAFD - Agence Francaise DevelopmentCEMP - Contractor Environmental Management PlanCENMA - Hanoi Centre for Environmental and Natural Resource

Monitoring and AnalysisDGTresco - French TreasuryDEALIM - DAELIM industrial Co., LTDCP - Construction PackageCO - carbon monoxideEATC - Environmental Analyzing and Technique JSCEIAB - European Investment BankEIA - Environmental Impact AssessmentERB - Emergency Response PlanFFEM - Fonds Français pour l'Environnement MondialHANCOR - Hanoi Construction CorporationHPC - Hanoi Peoples’ CommitteeMONRE - Ministry of Natural Resource and EnvironmentMOT - Ministry of TransportMRB - Hanoi Metropolitan Railway Management BroadNO2 - nitrogen dioxideGOV - GovernmentGRM - Grievance Redress MechanismQCVN - Vietnam National Environmental StandardsPIC - Project Implementation ConsultantPMU1 - Project Management Unit 1PPE - Personal Protective EquipmentSO2 - sulfur dioxideSPS - Safeguard Policy StatementTIC - Total Installed CostTOR - Terms of referencesURENCO - Urban Environmental Company

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WEIGHTS AND MEASURESdB(A) – Decibel (weighted average)

ha – hectarekg/d – kilogram per daykm – kilometerkm2 – square kilometerm – meterm2 – square meterm3 – cubic meter

m3/d – cubic meters per daym3/s – cubic meters per second

mg/m3 – milligrams per cubic metermm – millimeter

NOTE(i) In this report, "$" refers to US dollars.

This environmental monitoring report is a document of the borrower. The viewsexpressed herein do not necessarily represent those of ADB's Board of Directors,Management, or staff, and may be preliminary in nature.

In preparing any country program or strategy, financing any project, or by making anydesignation of or reference to a particular territory or geographic area in thisdocument, the Asian Development Bank does not intend to make any judgments asto the legal or other status of any territory or area.

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TABLE OF CONTENT

I. INTRODUCTION 6A. Project background 6B. Project Implementation Progress 8

II. INSTITUTIONAL SETUP AND RESPONSIBILITIES FOR EMPIMPLEMENTATION AND SUPERVISION 10

A. Institutional responsibilities for environmental management 10B. Incorporation of Environmental Requirements into Project ContractualArrangements 17

III. COMPLIANCE WITH ENVIRONMENT RELATED PROJECT COVENANTS 17

IV. ENVIRONMENTAL MITIGATIONS MEASURES IMPLEMENTED IN THEREPORTING PERIOD 21

V. ENVIRONMENTAL EFFECTS MONITORING 33A. Monitoring plan and responsibilities 33B. Environmental quality targets, sampling and analytical methods 35C. Monitoring results 36

VI. PUBLIC CONSULTATION, GRIEVANCE REDRESS MECHANISM 38A. Public consultation and EMP information dissemination 38B. Grivence Redress Mechanism (GRM) 40

VII. INSTITUTIONAL STRENGTHENING AND TRAINING 42

VIII. KEY ENVIRONMENTAL ISSUES 43A. Key Issues Identified, Actions Taken, Additional Actions Required 43

IX. CONCLUSION AND RECOMMENDATION 45A. Overall Progress of Implementation of Environmental ManagementMeasures 45B. Actions Recommended 46

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List of tablesTable 1. Scope of construction packages.................................................................. 8Table 2. Work Progress as of December 2016.......................................................... 9Table 3. Institutional responsibilities for environmental management ...................... 10Table 4. Project environmental reporting system assessment ................................. 14Table 5. List of main persons specifically in charge on environmental and safety

issues............................................................................................................... 16Table 6. The status of CEMP .................................................................................. 17Table 7. Status of Compliance with ADB Loan Covenants ...................................... 17Table 8. Environmental and Safety monitoring activities.......................................... 21Table 9. Findings during the site inspections........................................................... 22Table 10.EMP implementation assessment............................................................. 31Table 11. The monitoring program undertaken from Jan to Dec 2016 ..................... 33Table 12. Analyzing Method for Air Quality.............................................................. 35Table 13. Analyzing Method for Noise and Vibration ............................................... 35Table 14. Analyzing Method for Surface Water Quality ........................................... 35Table 15. Monitoring the implementation of public involvement activities ................ 39Table 18. Environmental key issues ........................................................................ 43

List of FiguresFigure 1. The project map ......................................................................................... 7

Figure 2. Environmental and safety monitoring structure......................................... 14

Figure 3. Current reporting process......................................................................... 16

Figure 4. Noise levels measured during Jan to Dec 2016........................................ 36

Figure 5.Vibration levels measured during Jan to Dec 2016.................................... 37

Figure 6. Concentration TSP and PM10 at three project stations ............................ 38

Figure 7. Current process for resolving complaint ................................................... 41

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I. INTRODUCTION

A. Project background1. Hanoi Pilot Urban Railway line No.3 (Nhon – Hanoi Railway Station) Projectis the first piloted project in developing the Mass Transit Model in urban area ofHanoi. The project comprises 12.4 km long section that goes from Nhon along theNational Road 32 and into the urban area of Hanoi. The evaluated section has a totallength of 8.4km with 8 stations, whereas the underground section has a length of 3.5km including 4 underground stations, plus a 500 m long transition section.

2. The project is divided into nine construction packages (CP-01 to CP-09). Thefirst five are mainly related to the execution of the civil works (CP-01: Evaluatedsection- line; CP-02: Evaluated stations; CP-03: Underground section and stations;CP-04: Depot infrastructure and CP-05: Depot architectural works) and the other four(CP-06 - CP-09) cover the supply and installation of the power supply, tracks, rollingstock, equipment, etc. The Project is co-financed by loans of, respectively, 250million euros (EUR) from the French Treasury (DGTresor), 220 million EUR from theAsian Development Bank (ADB), 110 million EUR from the Agency Franҫoise deDevelopment (AFD) and 73 million EUR from the European Investment Bank EIB.The counterpart financed by the Hanoi People Committee (HPC) is equivalent to 130million EUR. These figures sum 783 million EUR that was the original totalinvestment cost based on the feasibility study of 2009. The last Total InvestmentCost (TIC) of the Project was calculated in an amount of 1,176 million EUR in 2011,and approved by the HPC in June 2013 with 900 million EUR coming from OfficialDevelopment Assistance (ODA) source and 276 million EUR being the Vietnamesecounterpart funds. It has to be noted that the donors are undertaking the proceduresto increase the financing of the Project in an approximate amount of up to 70 millionEUR from each DGT, AFD and EIB, and in 140 million USD in the case of the ADB.

3. Socially the project will be a benefit to the population in the project area. Thepopulation, located in the western area of Ha Noi will, by using the metro, avoidtraffic congestion and reduce traffic safety hazards (especially traffic accidents);reduce health-related problems (especially respiratory problems) due to air pollutionand dust; and save time and benefit from a good transportation alternative to go toHa Noi Centre.

4. Beside the benefits, the project also has potential negative impacts on thelocal environment during both construction and operation stages. The updatedEnvironmental Impact Assessment (EIA) was cleared in 2013, which included theEnvironmental Management Plan (EMP). Four mobilized contractors (CP-01, CP-02,CP-04 and CP- 05) were required to prepare Contractor’s EMP (CEMP) for detailingtheir mitigation action plans to address construction impacts specific to siteconditions. The CEMPs of CP-01, CP-02, CP-04 and CP-05 were approved.

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Figure 1. The project map

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5. This environment monitoring report is in line with the TOR for theenvironmental consultant for the transition period. 1 The report documents theimplementation of Environmental Impact Assessment (EIA) and ContractorEnvironmental Management Plans (CEMP) of three civil work packages. The reportwas prepared through reviewing the monthly reports of all relevant stakeholders suchas IDOM (environmental consultant from June to August 2015), SYSTRA (projectimplementation consultant), Hanoi Metropolitan Railway Management Board (MRB,the implementing agency), and three ongoing contractors. This report presents theresults of the environmental management performance and internal monitoringactivities for period of January to December 2016. The report covers the following:

Status of compliance with ADB environmental loan covenants and with theenvironmental requirements of the Government of Vietnam during the reportperiod;

Status of implementation of the environmental mitigation measures during thereport period based on the EIA and CEMPs, including documentation ofcomplaints received and corresponding action/resolution; and

Results of the environmental monitoring of air quality, noise, vibration andsurface water quality conducted by the three contractors.

B. Project Implementation ProgressOn-going Site Works6. The environmental monitoring mission only focuses on the constructionpackages of the Project as CP01 – Elevated section- Line; CP02 – Elevation Station;CP03 – Underground Works, line and station; CP04 – Depot Infrastructure; andCP05 – Depot Building. The scope of each contract package is summarized in Table1.

Table 1. Scope of construction packages

Package Scope of work Contractor Start Date Duration ofcontract

CP01 Elevated rail section: comprises the constructionof elevated viaduct structure from the Depot tothe National Road 32, Ho Tung Mau, XuanThuy, Cau Giay and interfaces with theunderground section at the beginning of Kim Mastreet

DEALIM 04/7/2014 30 months

CP02 Elevated station: The package comprises 8elevated stations which are arranged basicallyequally along the elevated rail line section ofMetro line 3, each station shall constitute acomponent under this package, which included:civil work and structure; steel structurearchitecture and finisher; low voltage andplumbing and drainage

POSCO 27/05/2014 57 months

1The contract of the environmental monitoring consultant (IDOM) ended in September 2015, and thenew Project Management Consultant is planned to be mobilized in the third quarter of 2017. During theperiod from November 2015 to December 2016 environmental monitoring activities of the Project havebeen conducted with the assistance of ADB.

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Package Scope of work Contractor Start Date Duration ofcontract

CP03 Tunnel and underground stations: it comprisesall the underground works that contain 2 paralleltunnels and 4 stations

HYUDAI &GHELLA

N/A N/A

CP04 Infrastructure of Depot: it involves completeunderground and basic infrastructure of Depot

VINCONEX 2 22/10/2010 Finished

CP05 Architecture works of Depot, it comprisesconstructing all buildings in the Depot

HANCORP 12/01/2013 61 months

7. Works on packages CP01 (elevated section-Line) and CP02 (elevationstations) have been implemented in a rather satisfactory manner with the assessedphysical progress being around 60% for CP01 and 29% for CP02 as of November,2016. Delays in the utilities removal are affecting the CP01 and CP02 worksschedule. Works on depot package CP05 are now moving forward and discussionsare underway between MRB, related co-financiers and contractors regarding thetransfer of the CP04 remaining tasks to CP5. Due to the absence of re-mobilizationof CP04 contractor, AFD in principle agreed to the transfer. The CP03 contract(tunnel and underground stations) was signed on 30th October 2015, with contractduration of 49 months, but start date has not finalized.

8. The progress of three ongoing civil work packages (CP01, CP02 and CP05)up to December 2016 are summarized in the table below:

Table 2. Work Progress as of December 2016

Contractor

Progressas of 31October

2016

Construction activitiesIn Nov, Dec 2016

Location of construction

CP01 – Elevated section – Line

DAELIM 60 %

- Bored pile - section after station S8, ramp tounderground (Ngoc Khanh Ward)

- Substructure activity - section after station S8, ramp tounderground

- U Girder erection - P184 – P194 (Dich Vong Ward);

CP02 – Elevated section – Station

POSCO 28.60 %

- Construction of Pier Cap (Casting,Pre-stressing, grouting)- Cast in Place Beams

- Station 1 to station 7 (Minh Khai,Phuc Dien, Phu Dien, Mai Dich,Dich Vong Hau, Dich Vong andQuan Hoa Wards)

- Pile cap casting and construction- Shored excavation and pile head

- Station 8 (Ngoc Khanh Ward)

CP04 – Depot infrastructure

VC 2 - Construction activity has finished - The Depot (Tay Tuu Ward)

CP05 – DEPOT building

HANCORP 37.32% - Foundation of Building 28-29- Above grade (Superstructure) of

- The Depot (Tay Tuu Ward)

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OCC building- Construction of Building No6.- No major work items were done inNovember.

Construction Activities during the Previous Reporting Period9. Construction activities during the past months covered by the third semi-annual monitoring (June to December 2015) included Bored pile of CP01, Bored pileand construction of pier cap of CP02, construction of Depot infrastructure andbuildings of CP04 & CP05.

Planned Construction Activities for the Next Reporting Period10. In next six months, the construction will focus on U girder erection,substructure activity of CP01, construction and casting of Pile cap of CP02, andconstruction of buildings of CP05. Construction of the tunnel under CP03 is notanticipated to start in the next 6 months.

II. INSTITUTIONAL SETUP AND RESPONSIBILITIES FOR EMPIMPLEMENTATION AND SUPERVISION

A. Institutional responsibilities for environmental management11. The roles and responsibilities of the different institutions in EMPimplementation and monitoring are described in Table 3.

Table 3. Institutional responsibilities for environmental management

Organization EMP Responsibility committed in aproved EIA Current Implementationstatus

HPC/MRB

Project owner with overall responsibility for projectconstruction and operation.

Ensure that sufficient funds are available to properlyimplement the EMP.

Ensure that EMP provisions are implemented for theentire Project regardless of financing source.

Ensure that Project implementation complies with theGOV and ADB's environmental policy principles andrequirements

Being complied with

Project implementing agency with designated overallresponsibility for project construction and operationincluding environmental performance.Submit semi-annual monitoring reports on EMPimplementation to ADB and MONRE.Engage external expert(s) to undertake annualindependent verification of monitoring informationsubmitted to ADB and to determine if various EMPprovisions are being implemented in thorough andtimely manner and in accordance with budgetidentified within the EMP. Submit annual external environmental monitoringreports to ADB.Ensure that tender and contract documents include the

Partly complied withSubmission of the semi-annual report for Jan-Jun2016 was delayed.

No external environmentalmonitoring report wassubmitted for 2015.

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EMP.Liaison with Department of Defense and VietnameseArmy on UXO issues.Ensure that EMP provisions are strictly implementedduring pre- construction, construction and operationphases of the project.

Establish a grievance redress mechanism asdescribed in the EIA.Establish an Environmental Management Unit (EMU)staffed by qualified and experienced environmentalofficer and occupational health and safety officer

Partly complied with.

The GRM is not yet fullyoperational. A task force isyet to be established.No EMU was established atMRB.Corrective action plansdeveloped (Refer to chapterIV).

Undertake monitoring of the implementation of theEMP (mitigation and monitoring measures) withassistance from PIC.

Not complied withThere is no evidence thatMRB conducted routine EMPimplementation supervision.

ProjectImplementationConsultant (PIC)– SYSTRA

Undertake environmental effects monitoring duringpre-construction and construction phases for depot,viaduct and tunnel components

Complied withThere is a change in actualcontract of PIC. Based onthe contract, PIC does nottake responsibility toimplement the monitoringprogram.CENMA conducted thismonitoring from 2012 to Feb2015. From 2015 to June2016, contractors of CP01,02 and 05 have beenconducting theenvironmental qualitymonitoring.

Undertake environmental training for EMU, HRB/PMUstaff as required in the EMP

Partly complied withThere is a change in actualcontract of PIC. Based onthe contract, PIC does nottake responsibility to conductenvironmental trainings.IDOM (PMSC) conductedtrainings in 1st and 2nd July2013. No training wasconducted since then.

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Monitor the environmental performance of contractorsin terms of implementation of mitigation measures forpre-construction and construction phase as specifiedin the EMP.Monitor over-all implementation of various EMPprovisions.Review and approve the specific environmentalmanagement plans (e.g., Spoils Disposal Plan, DustControl Plan, Noise Control Plan, etc.) to be preparedby contractors as specified in the EMP

Complied withPIC carries out daily siteinspection in term ofcontractor’s mitigationmeasures implementation,reviews and revisescontractor’s monthly internalmonitoring reportsincorporated with a checkliston EMP implementation.PIC also has reviewed andissued “No objection” for 05CEMPs to submit MRB andADB.

Prepare monthly environmental monitoring reports onEMP implementation.

Not complied with.Corrective action plansdeveloped (Refer to table 8)

ProjectManagementSupportConsultant(PMSC) - IDOM

Ensure that the PIC is implementing its responsibilitiesspecified in the EMP such as conduct of environmentaleffects monitoring; monitoring of environmentalperformance of contractors; implementation ofenvironmental training for EMU, HRB/PMU staff; over-all monitoring of EMP implementation; and preparationof monthly environmental monitoring reports forsubmission to HRB Assist HRB/PMU/EMU in preparing semi-annualenvironmental monitoring reports for submission toADB. The semi-annual reports shall be based on themonthly reports prepared by the PIC as well asPMSC’s own observations/inspections to assessprogress of EMP implementation during pre-construction andconstruction phases.

Complied with up to Sep2015 (in view that thecontract of PMSC wasended.ADB is providing support tobridge the gap until thePMSC Phase 2 is mobilized.

Review and approval of specific environmentalmanagement plans prepared by contractors prior tocommencement of site works.

Complied withThe PIC has takenresponsibility on these tasks.

Contractors:CP01:DAELIM;CP02: POSCO;CP03:CP04:VINACONEXCP05:HANCORP

Appoint and environment, health and safety officer tooversee timely and proper implementation of mitigationand monitoring measures specified in the EMP Implement and provide sufficient funding and humanresources for proper and timely implementation ofrequired mitigation measures in the EMP for pre-construction and construction phases Prior to start of site works, prepare environmentalmanagement action plans in the form of specificmanagement plans (Dust and Noise Control Plan,Spoils Disposal Plan, Traffic Management Plan, etc.)specified in the EMP. Such plans shall be submitted tothe PSC for approval.

Complied with

Undertake land subsidence and settlement monitoringprogram specified in the EMP during the pre-construction and construction phase (TBM contractoronly) and submit monthly reports to PIC andHRB/PMU/EMU

Not yet due.CP03 (Joint Venture ofHyundai and Ghella) workshave not started yet.

External Expert Undertake independent annual reviews to verify the Partly complied with

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Responsibilities of Parties in Environmental Monitoring and Supervision12. The current organizational structure for the implementation of environmentalmonitoring and supervision is presented in Figure 1.

monitoring information submitted by HPC/HRB to ADBon the implementation of the environmentalmanagement plan (EMP). The external expert shallalso assess if various EMP provisions are beingimplemented as required. Review and verify the accuracy, breadth, depth, andrelevance of information provided by HRB to ADB withregard to EMP implementation Determine if EMP provisions (mitigation, monitoring,reporting, etc.) are being conducted in thorough andtimely manner and in accordance with budgetidentified within the EMP. Submit environmental monitoring report to ADB andHPC.

An external monitoring reportwas prepared in February2015 for 2014;The external monitoringreport for 2015 has not besubmitted yet.

MONRE

Approval of GOV EIA in accordance with Law onEnvironment Protection 2005

Complied with

Environmental monitoring and supervision duringconstruction and operation

Not complied with.No environmental inspectionwas conducted by MONREfrom the constructioncommencement to June2016.

Ha Noi DONRE

Monitoring environmental performance of projectthroughout construction and operationParticipate in resolution of community complaints onenvironmental impacts of the project duringconstruction and operation

Not complied with.No environmental inspectionwas conducted by Ha NoiDONRE from theconstruction commencementto June 2016

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Figure 2. Environmental and safety monitoring structure

Environmental Reporting System13. In accordance with the approved EMP, monthly, semi-annual and annualmonitoring reports on EMP compliance as well as quarterly environmental qualitymonitoring reports have to be prepared by relevant stakeholders. The detail status ofcurrent reporting is described in Table 4. The reporting process is illustrated in Figure3.

Table 4. Project environmental reporting system assessmentAgency Required reports in

approved EIATo

WhomCurrent status of Reportage

PIC(Systra)

Monthly environmentalmonitoring reports onenvironmentalperformance ofcontractors.

MRB Not complied withAn ADB consultant prepared 03 monthly reports fromJanuary to March 2016.There are no more monthly reports for thesucceeding months up to current time.PIC prepares monthly reports on Project quality andprogress in which a short section on health, safetyenvironment is included. However, the section doesnot include any substantive information. Systraagreed to include a more comprehensive section onEMP implementation until the PMS Phase 2Consultant is mobilized.

Quarterly reports onresults of environmental

MRB Partly complied withCENMA prepared quarterly environmental quality

PSMCIDOM

HPC ADB

MRB

PMU1

PICSYSTRA

DONRE

ContractorsCP01, CP02, CP03, CP04 and CP05

Current Monitoring Activities

Ended Monitoring ActivitiesTemporary Monitoring Activities

Weekly

DailyMonthly

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quality monitoring monitoring reports from Sep 2012 to Feb 2015.Since November 2015, contractors have beenpreparing semi-annual environmental qualitymonitoring reports.

PMSC(IDOM)

Assist MRB to preparesemi-annualenvironmentalmonitoring reports(SEMR)

MRB Complied withConsultancy services of IDOM ended in September2015. Since then, SEMRs have beentemporarilyprepared by ADB consultants.

MRB Semi-annualenvironmentalmonitoring reports(SEMR)

ADB Complied withSEMR for July to December 2015 was prepared andapproved by ADB. This report covers Jan-Jun andJul-Dec 2016.

Annual externalenvironmentalmonitoring report

ADB Not complied withThe external monitoring report for the year of 2014was prepared and approved by ADB in February2015;No report for 2015 was submitted to ADB.

Contractors N/a MRB Preparing monthly internal environmental and safetymonitoring reports and semi-annual environmentalquality monitoring reports, reviewed by PIC and thensubmitted to MRB.The last monthly reports was for November 2016.The last semi-annual reports was submitted in June2016

Contractor’s reports afterrevision and review by PIC

MRB ADB

PMU1

G 1

G 2

G 3

PICSystra

ContractorsCP01,02, 03, 04 and 05

Internal monthly environmentalmonitoring reports

Semi-annual environmentalquality monitoring reports

Monthly reports on Projectquality and progress includinga section of Health, SafetyEnvironment.

Semi annual EMRAnnual External EMR

Report to Document storage and exchange

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Figure 3. Current reporting process

Note: under PMU1, groups have been established to manage all packages of theproject such as a group in charge of CP01, another in charge of CP02, etc. andthese groups have responsibility of storing documents, resolving problems relatedthe contractors or consultants under their management.

Staff resources for EMP implementation14. Contractors. During the reporting period, the contractors have establishedHSE management units in charge of environment and safety to ensureimplementation of the CEMP. Site inspections for safety issues are conducted dailyby safety engineers of contractors, the contractors have always at least one safetyengineer at site during construction time. All environmental and safety staffs ofcontractors have been trained on a HSE course and have certificates on laboursafety supervision issued by authorized agencies.

15. Project Implementation Consultant (PIC).The PIC has assigned oneinternational HSE specialist that has continually been providing support to the MRBthrough close inspection of implementation of the environmental and safetycompliance at site. However, in view of large and long construction site (about 12km) and very strict requirements on safety, the specialist’s focus has been on safetyissues mainly, with little attention to EMP compliance monitoring.

16. MRB. Aside from assigning groups of technical staff for each package, MRBhas also requested the group leaders in charge of monitoring the EMPimplementation parallel with monitoring package quality, progress and disbursement.Due to so much works related to management of package quality, progress andpayment, little time and attention is given to EMP compliance monitoring.

17. A list of persons in charge of environmental and safety activities ofstakeholders also is provided as in the succeeding table:

Table 5. List of main persons specifically in charge on environmental and safetyissues

Name Position BackgroundCP02 contractor – Posco

Pak Deok Do Safety Manager Civil EngineerNghiem XuanDuc

HSE Manager Labor safety Engineer

Nghiem XuanAnh

Environmental staff Master in Environmental Science

04 staffs Safety Engineers Different backgrounds but all were trained on HSEmonitoring on construction sites.

CP01 contractor – DaelimVu Van Thuy HSE Manager Civil EngineerNguyen Thi Thu HSE document control Bachelor in EconomyTran MinhQuang

HSE Nurse Doctor

Do Minh Chien HSE night shiftmanager

Safety Engineer

12 staffs Safety Engineers Different backgrounds but all were trained on HSEmonitoring on construction sites.

CP05 – HancorpNguyen ThanhSon

HSE Engineer Civil Engineer

Project Implementation Consultant (PIC)Benoit ST-LAURENT

Safety Engineer HSE Engineer

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Name Position BackgroundMRB – PMU1

Bui Quang Anh Safety Engineer Marine and bridge construction

B. Incorporation of Environmental Requirements into Project ContractualArrangements

18. The updated EMP (2013) was incorporated in the bidding documents of civilworks during the procurement stage. The contractors were required to consider therequirements of the EMP when submitting their bids. The contractors also wererequired to prepare their own construction EMP (CEMPs). These CEMPs werereviewed and revised by PIC and MRB, and submitted to ADB for clearance andapproval. The status of CEMP approval is presented in Table6.

Table 6. The status of CEMP

No Status CP01 CP02 CP03 CP04 CP05

1 Send PIC for review 06/092014 13/01/2014 N/a 15/12/2013 21/02/2013

2 Issue No objection byPIC

10/09/2014 05/02/2014 N/a 28/12/2013 07/03/2013

3 MRB Review and agreeto submit CEMP to ADBfor clearance andapproval

4/6/2016 02/04/2014 N/a 22/01/2014 08/04/2013

4 ADB’s receipt

1st comments2nd comments3rd comments4th comments

20/10/2014

18/12/201423/01/201401/06/2016N/A

03/04/2014

30/06/201415/10/201421/10/201415/12/2014

N/a 19/01/2013

01/02/2013

08/04/2013

5 ADB’s approval NOT YET Approved Approved Approved

19. The CEMP of CP03 contractor has not been prepared yet because thecontractor was not yet mobilized. The CEMP of CP01 was re-submitted to ADB on22 June 2016 and cleared by ADB on 31 December 2016.

III. COMPLIANCE WITH ENVIRONMENT RELATED PROJECT COVENANTS

20. Table 7 shows the status of compliance with ADB’s loan covenants relating toenvironment, health and safety during this report period.

Table 7. Status of Compliance with ADB Loan Covenants

Schedule Para No. DescriptionRemarks/Issues

(Status of Compliance)

Schedule5

3 Capacity Support for HRB. The Borrowershall ensure that the capacitydevelopment program for strengtheningHRB's capacity is implemented in time toensure the timely and successfulimplementation of the Project. It isexpected that the said capacity buildingprogram will be financed under a

Partially complied with.

The PMS Phase 1 consultantwas mobilized 1 April 2014.Capacity building coursescommenced in May 2014.MRB’s capacity has increasedthrough several training courses

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separate cover. completed on FIDIC, contractmanagement, safeguards, ODAmanagement and gender.

The PMS Phase 1 contract hasended and the consultantdemobilized. The PMS Phase 2consultant is expected to bemobilized in Q2 2017. ADB hasfinanced individual consultantsto fill the gap between PMSPhase 1 and Phase2 to ensurecontinuous project managementsupport to MRB, especially onsocial and environmentalsafeguards. MRB is evaluatingthe EOIs and preparing theshortlist for the PMS Phase 2consultant. Mobilization of thePhase 2 consultant is expectedin August 2017.

Schedule5

6 Governance and Anticorruption. HPCshall, cause HRB to, ensure that duringthe project implementation: (a) relevantprovisions of ADB's Anticorruption Policy(1998, as amended to date) are includedin all bidding documents for the project;(b) contracts, financed under the project,include provisions specifying the right ofADB to audit and examine the recordsand accounts of HRB, contractors,suppliers, consultants, and other serviceproviders as they relate to the project; (c)period inspection of contractors isundertaken to ensure that fund withdrawaland settlement procedures are followed;and (d) a Project website is establishedwithin 12 months of the effective date,accessible by the general public, todisclose information about variousmatters concerning the project, includinggeneral project information, procurement,project progress, and contact details inthe English and Vietnamese languages.The website will also provide a link toADB's Integrity Unit for reporting to ADBany grievances or allegations of corruptpractices arising out of the project andproject activities. With regard toprocurement, the website shall includeinformation on the list of participatingbidders, name of the winning bidder,basic details on bidding proceduresadopted, amount of contract awarded,and the list of goods and works procured.


A project website wasestablished, but informationdisclosure needs improving,especially on the project’supdated progress and the GRM,to provide the stakeholders,including the affected peoplewith clearer picture of theproject.This need is highlighted giventhe persistent resettlementgrievances at depot and recentclaims from an environmentalgroup called Green Trees HaNoi on tree removal along theproject’s corridor.A communications strategy hasbeen formulated for the project.ADB has mobilizedcommunications consultants toprovide support to MRB / HMCto implement the strategy,including improving the projectwebsite and strengthencommunications on the project’son-going construction work,social and environmentalsafeguards.

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Schedule5

7 Grievance Redress Mechanism. HPCshall ensure that within 60 days from theeffective date, a complaint and problemmanagement task force, acceptable toADB, is established and functioningeffectively to: (a) review and documenteligible complaints of project stakeholder;(b) proactively address grievances; (c)provide the complainants with notice ofthe chosen mechanism/action; and (d)prepare periodic reports to summarize thenumber of complaints received andresolved, and final outcomes of thegrievances and chosen actions and makethese reports available to ADB uponrequest. Eligible complaints include thoserelated to the project, any of the serviceproviders, any person responsible forcarrying out the project, complaints onmisuse of funds and other irregularities,and grievances due to any safeguardissues, including resettlement,environment, ethnic minorities, andgender.


Grievance redress mechanisms(GRM) based on existing legalprovisions has been developedto facilitate resolution ofcomplaints regarding theproject’s resettlement impacts.The GRM for environment relieson the government's system ofpetitions and complaints, with noproject level coordination. Acomplaint and problemmanagement task force,acceptable to ADB, is yet to beestablished.

A request to establish a GRMworking group will be submittedto HPC. The working group shalldevelop a simple yet effectiveand efficient mechanism forproject affected people toexpress concerns, and achievesolutions that will promote aconstructive relationshipbetween the government, projectstaff, and affectedcommunities.(Refer to chapterIV)

Schedule5

8 Environment. HPC shall, and shall causeHRB to, ensure that: (a) the project isdesigned, constructed, and operated inaccordance with the environmental lawsand regulations of the Borrower, SPS,EIA, and EMP; if there is any discrepancybetween the Borrower's laws andregulations, and SPS, then SPS shallapply; (b) the institutional arrangementsfor effective implementation ofenvironmental safeguards including thegrievance redress mechanism (asdescribed in EIA) are in place beforecommencement of works construction; (c)environmental approvals are submitted toADB; (d) works contracts are supervisedand monitored in accordance with EMP;(e) the mitigation measures as specifiedin EIA and EMP, are fully implemented ina timely manner and are incorporated intothe bidding documents and workscontracts, and compliance of contractorsto the provisions of the EMP is ensured;(f) if any unanticipated environmentalimpacts become apparent during project


(a) Complied with.

(b) Partially complied with.Contractors and the PIC haveassigned qualified environmentand safety staff. MRB has notyet established anEnvironmental Management Unit(EMU) as required in EIA. Theproject GRM is not working forenvironment related grievancesand needs strengthening.

(c) Complied with.

(d) Partially complied with. Siteinspections are being conducteddaily by PIC. Each contractorhas their own internalenvironmental and safetysupervision staff. ADB hasfinanced the recruitment ofindividual consultants for internalmonitoring to bridge the gapbetween PMS-1 and PMS-2.

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implementation, a corrective action plan isprepared and approved by ADB; (g) theEMP is implemented in full to address theenvironmental aspects during theconstruction of the project, includingactions to be taken for auditing,measuring and monitoring theenvironment and safety conditions of thework, and responding to breaches inenvironmental or safety requirement; (h) ifthere are any additional components orchanges in the project resulting inadverse environmental impacts and arenot within the scope of EIA, new orsupplementary environment assessmentreport, consistent with the SPS, isprepared and approved by the relevantagencies of the Borrower and ADB; (i)semiannual reports on implementation ofthe EMP are submitted to ADB on atimely basis; (j) project components to befunded by the Borrower and otherfinanciers adopt the provisions of EIA andEMP and comply with SPS; and (k) HPCengages and retain qualified andexperienced external experts, acceptableto ADB, to review and verify theenvironmental monitoring informationprovided by HPC or HRB to ADB withregard to EMP implementation. Theexternal experts shall not be involved inday-to-day supervision of the project.Monitoring shall be undertaken annuallyand corresponding report shall besubmitted to ADB on a timely basis.

(e) – (h) Complied with.

(i) Partially complied with. 04semi-annual environmentalmonitoring reports weresubmitted to ADB until Jul-Dec2015. Report for Jan-Jun 2016 isstill pending.

(j) Complied with.

(k) Partially complied with. Anexternal expert has beenrecruited by ADB to prepare theannual external EMR. An annualEMR for the year of 2014 wasprepared and approved by ADB,but the report for 2015 is stilldue.

Schedule5

10 Applicability of ADB's Safeguard Policy toEntire Project. The Borrower shall ensurethat the portions of the project to befinanced by EIB, DGT, and AFD abide byall the requirements under SPS.

Being complied with.

Schedule5

12 Health risks. In coordination with the localhealth bureaus, HPC shall, and shallcause HRB to, ensure that (a) theHIV/AIDS prevention plan is implementedin accordance with its terms; (b) theworks contractors disseminateinformation and conduct awarenesstraining on the risks and preventionmeasures of HIV/AIDS and othercommunicable diseases to theiremployees, temporary laborers and familymembers, and subcontractors duringproject implementation; (c) measures toprevent other communicable diseases are


Relevant clauses have beenincluded in the biddingdocuments, works contracts andconsulting services contracts.

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implemented within the construction sites,as specified in the EMP, and (d) theserequirements are included in the workscontracts, monitored and reportedsemiannually to ADB through HPC.

Schedule5

13 Labor Standards. HPC shall, and shallcause HRB to, ensure that theconstruction contractors (a) provide timelypayment of wages and safe workingconditions to all workers; (b) pay equalwages to the women and makeemployees for equivalent labor; (c) do notemploy child labor as required by therelevant laws and regulations of theBorrower; (d) the contractors involved inthe project implementation maximize theemployment of local people, particularlywomen and ethnic minorities, who meetthe job and efficiency requirements forproject construction, operation andmaintenance; and (e) such workers areprovided with adequate on-the-jobtraining and safety training.


Relevant clauses have beenincluded in the biddingdocuments, works contracts andconsulting services contracts. Allworkers are provided withadequate safety training.

IV. ENVIRONMENTAL MITIGATIONS MEASURES IMPLEMENTED IN THEREPORTING PERIOD

Monitoring of Compliance with the EMP21. The inspection methodology utilized involved the visual inspection of the workareas and relevant sites, the conduct of formal and informal interviews with workers,residents, stakeholders and affected persons (APs), and field observationssupplemented with photographic documentation.

Schedule of Environmental Monitoring22. The site inspections for CEMP compliance are conducted daily by PIC(Systra), joint meetings among MRB, PIC and Contractors have been organizedwhenever the environmental and safety issues were identified and corrective actionswere requested. The compliance inspections of main contractors on subcontractorsalso have been conducted through internal meetings and daily site inspections byenvironmental and safety staffs. The monitoring activities relating to environment andsafety are shown in Table 8.

Table 8. Environmental and Safety monitoring activities

Mission/task Date Location of site visits Conducted by Whom

Monitoring onContractor’s CEMPcompliance

Daily All sites of CP01, CP02and CP05

Safety Engineers ofPIC

Monitoring onSubcontractor’s

Daily All sites of CP01, CP02 Environmental andSafety Engineers of

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CEMP compliance and CP05 Contractors

Monitoring on EMPimplementation andcompliance forAnnualenvironmental report

21st to 23rd

November 2016On-going sites of CP01,all stations of CP02 andthe Depot of CP05

ADB EnvironmentalConsultant

Monitoring on EMPimplementation andcompliance for ADBreview mission inDec 2016

6th December2016

Some of ongoing sitesof CP01, CP02 and theDepot of CP05

ADB SeniorEnvironmental Officer

ADB EnvironmentalConsultant from ADB

Monitoring on EMPimplementation andcompliance forAnnualenvironmental report

19st to 21st

December 2016A night site visits forongoing sites of CP01,all stations of CP02 andthe Depot of CP05

ADB EnvironmentalConsultant from ADB

23. During the period from 21st to 23rd November 2016, site inspections wereconducted by the national environmental consultant (NES) to validate and monitorthe implementation of the works. The site visits were made together with the PIC(except for CP01) and the concerned Contractors. The site-visits suggested that theconstruction sites are generally tidy (except for some sites of CP01 which areconstructing bore piles) and well organized. All construction sites are fenced aroundby durable metal sheets, some places at the turning points or crossroads, the metalsheets are replaced by expanded metal fence to assure a clear view for all trafficmeans. All the sites at height are equipped with façade netting, safety net fan and railguard. The use of personnel protective equipment is satisfactory. Toilets/portablesand garbage bins are provided at the construction areas. There are proper provisionsfor hazardous materials such as fuel and oil.

24. During the period from 19th to 21st December 2016, the site visits were madetogether with the safety engineers of concerned Contractors. To monitoring CEMPimplementation for construction activities at night, a night site inspection for U-Girdererection of P192 and P193 and other construction sites of CP01 was carried out atthe night of 21st December 2016. This night site visit suggested that the contractorhas complied well with the CEMP in view of obtaining official permit for streetblocking before construction, having traffic management plan with traffic staffs andthe assistance of DOT’s staffs; providing sufficient instruction boards, fence, flashinglights at the ongoing sites; the light for construction activities was satisfactory as well.

25. However, there are some minor environmental and safety issues which thecontractors could pay more attention to fully comply with the approved CEMPs, asindicated in Table 9.

Table 9. Findings during the site inspectionsIssues/Concerns/Findings Pictures

CP01 – Elevated section – LineContractor: DAELIM

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Issues/Concerns/Findings PicturesTitle of issue: information disclosure

Description: The contractor’s contactsincluding the hotline on constructioninformation boards at the gates ofconstruction sites are faded. Localpeople could not read this type ofinformation and they would not knowthe best and fastest way they send theircomplaints or queries related toconstruction activities (if any).

Location: at gates of the sites for Pier365 – P364 and P337 - P340

Time: November 22nd2016

Title of issue: Dust and communityhealth

Description: on most of the sites,heaps of unused fine materials such assoil or sand were scattered withoutcover and the contractor did not haveany measures to prevent dustspreading from these heaps as regularwatering or hauling off the unusedmaterials to the designated disposalsites.

Location: at the sites for Pier 365 –P364, P347 – P350, P337 - P340 andP229 - P232


Written information on theboard was faded and could

not be read

An unused heap of sand onthe site

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not be read


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not be read


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Issues/Concerns/Findings Pictures

Title of issue: Solid wastesmanagement

Description: there were some clothssticking with oil grease thrown away onthe site and out of garbage bin

Location: at the site for Pier 229 - P232


An other heap of soil on othersite

Cloths sticking withoil grease was

supposed to be in agarbage bin

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Issues/Concerns/Findings PicturesTitle of issue: Pollution of public road

Description: to sites under boring piles,the activities mostly involved earthworksand generated a large volume ofexcavated materials required to behauled to designated disposal sites.Under wet condition, soil becomessticky that easily is left out of the sitesand post a risk of polluting the roadways.

Location: at the site for Pier 365– P364


Title of issue: Construction sitesecurity

Description: some idle constructionsites were not locked, and had nosecurity guards that posed risks ofunauthorized access into constructionsites. These sites still have thepossibility of causing harm or injury topeople such as deep excavation holes,scaffoldings. It could be possible thatdrunk people would access these sitesand getinjured or killedthemselves byfalling into excavation holes or climbingup scaffolding and falling down.

Location: at the site for P 220 and P 50

Time: December 21st 2016

A Site of worksinvolved mostly with

earthwork

Natural soil ground

The gate of an idle site left open at nightwithout sercurity guard

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earthwork

Natural soil ground


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earthwork

Natural soil ground


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Issues/Concerns/Findings PicturesTitle of issue: Construction at night

Description: Some pictures illustratedfor U-Girder erection of CP01. Beforecommencement, safety engineers had abrief talk at the site on the comingconstruction activities and related safetyconcerns/issues for all of workers.

With the assistance of DOC’s staffs,traffic staffs of contractor, firstly, usedhard traffic marks to divide an existingtraffic lane into two temporary lanes,secondly blocked the other existing lanefor construction site at the time (10hPM) registered in the trafficmanagement permit.

Provided hard fences with instructionboards, flashing lights and traffic staffsto instruct traffic vehicles to go into thetemporary lane.

As completing construction, the fences,instruction boards, had traffic markswere removed to return the road asbefore construction. This task wasfinished before the time for ending roadblocking (5h A.M) registered in thepermit.

Location: at the site of P192 - 193


Arranging temporary lanes

Fences, flashing lights and traffic staffs

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CP02 – Elevated section – StationContractor: POSCO

Title of issue: Pollution of public road

Description: Two sites under boringpiles, the activities mostly involvedearthworks and generated a largevolume of excavated materials requiredto be hauled to designated disposalsites. Under wet condition, soilbecomes sticky that easily is leaved outof the sites and post a risk of pollutingthe road ways.

Location: at the site for station number8

Time: November 21st2016

An U-girder of 150 tons was lifted up onpile caps by two cranes

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Issues/Concerns/Findings PicturesTitle of issue: Dust and communityhealth

Description: Surrounding the gate ofstation 3 has much soil, sand and smallsubstances that were needed to cleanup to avoid raising dust to ambient air.

Location: at the gate of station 3

Time: December 20th 2016

Title of issue: Construction sitesanitation and management

Description: the site of station 7surrounded by 40 cm high concreteledge to prevent run-off water goingin/out the site. A short section (about ameter)of the ledge was broken thatcaused slits between surrounding fenceand road surface. At the time of siteinspection, garbages from outside,flowing run-off water, went into the site.

Location: in the station No7




A short broken ledge and garbages

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Issues/Concerns/Findings PicturesTitle of issue: not complied with SEMP

Description: the contractor for CP04has already finished the constructionworks and removed their facilities suchas site office, storing houses… out ofthe site. But on the area on which thesefacilities was located, there is evidenceof waste burning that is prohibited. Inaddition, also on this area, garbage anddebris still needed to be cleaned anddisposed of.

Location: at the site for Depot

CP05 – Depot building

Ash left from burningwastes at former siteoffice of contractor fo

CP04

Garbages and debris needto be all cleaned

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CP04


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CP04


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Issues/Concerns/Findings PicturesTitle of issue: Construction safety

Description: construction site at heightwas not secured by rail hand guard orproper fences.

Workers did not use personal safetybelt as working at height.

Location: in the site of a building at theDepot


26. Table 10 summarizes the environmental measures that were implemented bythe contractors and the environmental issues that were noted from January toDecember 2016. The assessment of effectiveness of the environmental managementmeasures being implemented by the contractors based on degree of compliance withthe environmental management measures in approved CEMPs reflects theenvironmental conditions in various construction sites during the reporting period.

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Table 10.EMP implementation assessment

EMP/CEMPrequirement

Assessment on Compliance with EMP/CEMPs

CP01 CP02 CP05

Dust controlPlan

Partly CompliedSome small heaps ofunused materials likely toproduce dust was nothauled to the designateddisposal sites. They are lefton the sites without cover.The contractor also did notspray water on these heapsfor dust control. There weresigns of dust at the sites.There was no washingstation at the site for P365 –P364.The contractor hasconducted ambient airquality monitoring programscomplied with the CEMP.

Being CompliedMitigation measureshave been carried out onthe sites such as duringthe dry days, periodicallywatering constructionsites has beenundertaken for dustcontrol, all vehiclestransported constructionmaterials (sand, clay,cement, stones, etc.)have been covered toprevent dust dispersion .No signs of dust orcomplaints on air qualityissues were recorded.The contractor hasconducted ambient airquality monitoringprograms complied withthe approved CEMP

Being CompliedMitigation measures havebeen carried out on thesites such as trucks will betightly covered with suitablematerial such as tarpaulin,construction spoils arestored in tanks to preventdust dispersion. No signs ofdust or complaints on airquality issues wererecorded.The contractor hasconducted ambient airquality monitoring programscomplied with the approvedCEMP.

Noise controlplan

Being CompliedMitigation measures weretaken on the sites followingthe CEMP;Several mitigationmeasures were NotApplicable due to the siteconditions.No complaints on noise andvibration issues wererecorded.The contractor hasconducted noise andvibration monitoringprograms complying withthe CEMP.

Being CompliedMitigation measureswere taken on the sitesfollowing the CEMP;Several mitigationmeasures were NotApplicable due to thesite conditions.No complaints on noiseand vibration issueswere recorded.The contractor hasconducted noise andvibration monitoringprograms complying withthe CEMP.

Being CompliedMitigation measures weretaken place on the site;No complaints on noise andvibration issues wererecorded.The contractor hasconducted noise andvibration monitoringprograms complying withthe CEMP.

Spoils disposalplan

Partly compliedSome small heaps ofexcavation material stillwere left on the sites thatshould be hauled to thedesignated disposal site.DAELIM signed a contractwith Hanoi URENCO andEnvironmental andEcological TechnologyCompany to disposal

Being compliedMitigation measureswere taken place on thesites followed theapprovedCEMPPOSCO signed acontract with HanoiURENCO andEnvironmental andEcological Technology

Being compliedMitigation measures weretaken place on the sitesfollowed the approved CEMPHANCORP signed acontract with Ha noiURENCO to haul anddispose spoils duringconstruction phase.

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EMP/CEMPrequirement


CP01 CP02 CP05excavation in two landfillsites in Vinh Quynh andDong Anh

Company to disposalexcavation in two landfillsites in Vinh Quynh andDong Anh

Spillmanagementplan

Being CompliedAll petroleum products arestored on the designatedareas with concrete/steelsheet floor, roof and firewarning signsNo signs of oil spillage onthe sites

Being CompliedAll petroleum productsare stored on thedesignated areas withconcrete/steel sheetfloor, roof and firewarning signsNo signs of oil spillageon the sites

Being CompliedAll petroleum products arestored on the designatedareas with concrete/steelsheet floor, roof and firewarning signsNo signs of oil spillage onthe sites

Trafficmanagementplan

Being compliedAll required permits issuedby DOT for trafficmanagement plan haveobtained before thecommencement ofconstructionContractor has beencomplying with the plan inview of assigning trafficstaffs and no trafficaccidents related toconstruction activities

Being compliedAll required permitsissued by DOT for trafficmanagement plan haveobtained before thecommencement ofconstructionContractor has beencomplying with the planin view of assigningtraffic staffs and notraffic accidents relatedto construction activities

Not applicable

Occupationaland Communityhealth andsafety plan

Being compliedAll construction sites arefenced around by durablemetal sheets, some placesat the turning points orcrossroads, the metalsheets are replaced byexpanded metal fence toassure an clear view for alltraffic means. All the sites atheight are equipped withfaçade netting, safety netfan and rail guard. The useof personnel protectiveequipment is satisfactory.No significant accidentsrecorded during thereporting period

Being compliedAll construction sites arefenced around bydurable metal sheets,some places at theturning points orcrossroads, the metalsheets are replaced byexpanded metal fence toassure an clear view forall traffic means. All thesites at height areequipped with façadenetting, safety net fanand rail guard. The useof personnel protectiveequipment is satisfactoryNo significant accidentsrecorded during thereporting period

Partly compliedAll construction sites arefenced around by durablemetal sheets, some places.A site at height was notequipped with façadenetting, safety net fan andrail guard. Some workersstill did not use personalsafety belt as working atheight.No significant accidentsrecorded during thereporting period

EmergencyResponse Plan

Being compliedA hotline for emergencycases has been provided oninformation board at thegates of construction sites.An emergency response

Being compliedA hotline for emergencycases has beenprovided on informationboard at the gates ofconstruction sites.

Being compliedA hotline for emergencycases has been providedon information board at thegates of construction sites.No emergency cases

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EMP/CEMPrequirement


CP01 CP02 CP05process was establishedwith safety staffsNo emergency casesrecorded during thereporting period

An emergency responseprocess was establishedwith safety staffsNo emergency casesrecorded during thereporting period

recorded during thereporting period

V. ENVIRONMENTAL EFFECT MONITORING

A. Monitoring plan and responsibilities

27. As described in the EIA, the responsibility for undertaking environmentaleffects monitoring during pre-construction and construction phases for depot, viaductand tunnel components would belong to the PIC but there is a change in actualcontract of PIC. Based on the contract, PIC does not take responsibility to implementthe monitoring program, instead of CENMA which had conducted this monitoringfrom 2012 to Feb 2015 and then from 2015 to June 2016, contractors of CP01, 02and 05 have been conducting the environmental quality monitoring. The monitoringprograms undertaken by the contractors from Jan to Dec 2016 are presented in thesucceeding table.

Table 11. The monitoring program undertaken from Jan to Dec 2016Package Parameters Location Time Conducted

by

CP01

- Air quality (NO2, SO2, CO)- Noise and vibration

Pier 10, 100, 180, 280 and 366 Jan2016

DEALIM


Pier 10, 100, 180, 280 and 366

Mar2016

- Surface water quality(Temperature, pH, DO,turbidity, Cr6+, Cr3+, TSS,NO2

-, NO3- NH4

+,totalPhosphorus, total Nitrogen, Cl-, F-, COD, BOD5, Fe,Cu, Hg,Cd, Zn, Ni, As, Pb, totalphenol, Total oil and grease,Coliform, E.coli)

NM1: at abutment No10MN2: Nhue River at Dien BridgeNM3: Mai Dich Lake, oppositeMai Dich cemeteryNM4: Mai Dich Lake near MaiDich bridgeNM5: To Lich river near CauGiay bridgeNM6: Thu Le Lake, oppositeAIA building near abutmentNo336


Pier 10, 100, 180, 280 and 366

May2016


-, NO3- NH4

+,totalPhosphorus, total Nitrogen, Cl-

, F-, COD, BOD5, Fe,Cu, Hg,Cd, Zn, Ni, As, Pb, totalphenol, Total oil and grease,Coliform, E.coli)


- Underground water quality NN1: Well of residential area

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Package Parameters Location Time Conductedby

(all parameters in QCVN09-MT:2015/BTNMT)

near abutment No10NN2: Well at the shop of DaMinh Ngoc, Ho Tung Mau streetNN3: Well at Salon Auto 370Cau Giay Street


Pier 10, 100, 180, 280 and 366 July2016


Pier 10, 100, 180, 280 and 366

Sep2016


-, NO3- NH4




CP02

- Air quality (NO2, SO2, CO,PM10 and TSP)- Noise and vibration- Wastwater quality (SO4

2-,TSS, COD, BOD5, Zn, Cr3+, oiland total coliform)

Station 1 (Nhon), Station 6(National University) andStation 8 (Cau Giay)

June2016

POSCO- Air quality (NO2, SO2, CO,PM10 and TSP)- Noise and vibration- Wastewater quality (SO4

2-,TSS, COD, BOD5, Zn, Cr3+, oiland total coliform)

Station 1 (Nhon), Station 6(National University) andStation 8 (Cau Giay) Expecte

d in Dec2016

CP05

- Air quality (NO2, SO2, CO,PM10 and TSP)- Noise and vibration

K1: at gate located atResidential area along RoadNo.70K2: Near Dormitory of HNIndustry University

June2016

HANCORP


-, NO3- NH4

+,totalPhosphorus, total Nitrogen, Cl-, F-, COD, BOD5, Fe,Cu, Hg,Cd, Zn, Ni, As, Pb, totalphenol, Total oil and grease,Coliform, E.coli)

Pont in the Depot area.

- Air quality (NO2, SO2, CO,PM10 and TSP)- Noise and vibration

K1: at gate located atResidential area along RoadNo.70K2: Near Dormitory of HNIndustry University

November 2016

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-, NO3- NH4




B. Environmental quality targets, sampling and analytical methods

28. The monitoring content included: (i) air quality; (ii) noise and vibration; (iii)surface water quality and (iv) underground water. The monitoring methodologies aresummarised below:

Table 12. Analyzing Method for Air QualityNo Item Method Standard

Compared1 Temperature TCVN 3752:2000 (ISO 8756:1994)

QCVN05:2013/BTN MT

2 Humidity TCVN 3752:2000 (ISO 8756:1994)3 Wind speed TCVN 3752:2000 (ISO 8756:1994)4 Pressure TCVN 3752:2000 (ISO 8756:1994)5 Wind direction TCVN 3752:2000 (ISO 8756:1994)6 SO2 (sulfur dioxide) TCVN 5971:1995 (ISO 6767:1990)7 NO2 (Nitrogen dioxide) TCVN 6137:2009 (ISO 6768:1998)8 CO (Carbon monoxide) TCVN 7725:2007 (ISO 4224:2000)9 Dust PM10 (particular matter

less than 10 microns)TCVN 5067:1995

10 Dust TSP (total suspendedparticulate)

TCVN 7241:2003

Table 13. Analyzing Method for Noise and VibrationNo Item Method Standard

Compared1 Noise, Leq TCVN 7878 - 2:2008 (ISO 1996-2:2003) QCVN

26:2010/BTNMT2 Vibration acceleration TCVN 6963:2001 QCVN

27:2010/BTNMT

Table 14. Analyzing Method for Surface Water QualityNo Item Method Standard

Compared1 Temperature EATC - PPNB - 02

QCVN 08:2008/BTNMT, B forsurface water

quality

2 pH TCVN 6492:19993 DO TCVN 7325:20054 Turbidity SMEWW 2130 B 20125 Cr6

+ HACH Method 80236 Cr3

+ SMEWW 3111B:20127 TSS SMEWW 2540 D 20128 NO2 SMEWW 4500 NO2- B 20129 NO3

- TCVN 6180:199610 NH4

+ SMEWW 4500 NH3 F 2012

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-, NO3- NH4








QCVN05:2013/BTN MT




TCVN 7241:2003




27:2010/BTNMT




quality




- TCVN 6180:199610 NH4

+ SMEWW 4500 NH3 F 2012

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-, NO3- NH4








QCVN05:2013/BTN MT




TCVN 7241:2003




27:2010/BTNMT




quality




- TCVN 6180:199610 NH4

+ SMEWW 4500 NH3 F 2012

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11 Total Phosphorus SMEWW 4500 P BE 201212 Total Nitrogen TCVN 6638:200013 Cl- SMEWW 4500 Cl- B 201214 F- HACH Method 802915 COD SMEWW 5220 C 201216 BOD5 TCVN 6001-1:200817 Fe SMEWW 3500 Fe B 201218 Cu SMEWW 3111B:201219 Hg SMEWW 3112B:201220 Cd SMEWW 3111B:201221 Zn SMEWW 3111B:201222 Ni SMEWW 3111B:201223 As SMEWW 3113B:201224 Pd SMEWW 3111B:201225 Total Phenol HACH Method 8047

29. Analyzing Method for ground water quality applies the National technicalregulation on ground water quality – QCVN09-MT:2015/BTNMT. The results alsoshall be compared with this standard to assess construction’s impacts on groundwells adjacent to construction sites of the Project.

C. Monitoring results

Results of ambient noise sampling

30. Noise measurement time was from 8.00 to 22.00. All the noise monitoringresults shall be compared with National Specification of Vietnam QCVN 26: 2010 /BTNMT for common area from 6.00 to 21.00. Most of the data measured at thelocations are higher than the level stipulated in the specification due to numerousvehicles on the roads. Figure 3 illustrates the results of monitoring noise level duringJan to Dec 2016.

Figure 4. Noise levels measured during Jan to Dec 2016

31. As the results from the monitoring programs during Jan to Dec 2016, themetro line can be divided in two sections, the first one from the Deport to P20 withinlow population density areas of Tay Tuu and Phu Dien wards, generally has noise

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level lower than the applied standard and the second one from P20 to the station 8,within very crowded areas, has noise level higher than the standard even during lowtraffic time from 6h to 7h. It is assumed that the high noise lever mostly comes frompublic traffic not from construction activities. The noise has not significantly changedamong the programs from Jan to Sep 2016.

Results of ambient vibration sampling

32. According to specifications, vibration level mustnot be higher than 75dB or0.055 m/s2 from 6.00 to 21.00 for common area and baseline at night. So, all thedata from the monitoring programs in table 10 reveal that the maximum vibrationlevel was lower than the level stipulated in the specification (QCVN27:2010/BTNMT). Figure 4 illustrates the results of monitoring vibration level duringJan to Dec 2016.

Figure 5.Vibration levels measured during Jan to Dec 2016

Result of ambient dust sampling33. Only the contractor of CP02 conducted a monitoring program on dustincluding PM10 and TSP level for 24h. This program was carried out in June 2016 atthree locations (station 1 – Nhon (Minh Khai Ward); Station 6 – National University(Dich Vong Hau Ward) and Station 8 – Cau Giay (Ngoc Khanh Ward)). Dustmeasurement time was from 8.00 to 22.00. All the dust monitoring results shall becompared with National Specification of Vietnam QCVN 05: 2013 / BTNMT. Most ofthe data measured at the locations are much higher (from 2.65 times to 7.5 times)than the level stipulated in the specification.

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Figure 6. Concentration TSP and PM10 at three project stations

34. The most significant reason for high dust concentration is the stations to belocated on the main roads (National Road 32, Xuan Thuy and Cau Giay streets) formaterial transportation to many ongoing projects in Ha Noi. And it is assumed thatthe earthwork activities of the Project also contributed to high dust concentration.

Result of ambient air quality sampling35. The monitoring data from the sampling programs of contractors (CP01,02 and03) also showed that all parameters of air quality monitored were much lower thanacceptable levels stipulated in the QCVN 05:2013/BTNMT and the air qualityadjacent to the project construction sites had only minor changes from last year 2015(Refer to appendix 2 for more detail)

Result of ambient surface water sampling36. The results from sampling programs conduced in Mar, May and Sep 2016 ofCP01 contractor showed that the parameters of NH4+, COD, BOD5 and Coliform ofnatural surface water sources (To Lich, Nhue Rivers, Thu Le and Mai Dich Lakes)higher than the current standard (QCVN 08:2015/BTNMT) meanwhile otherparameters (metals, oil, Phenol…) lower than the standards. This surface waterpollution is recently general for water sources within Ha Noi city as domesticwastewater has still been discharged directly to natural resources without treatment.The quality of surface water samples taken in the sites at abutments of pier showedthat the construction activities did not affect the water quality as all the parameters ofthese samples were lower than the standard (Refer to Appendix 2 for more detail).

VI. PUBLIC CONSULTATION, GRIEVANCE REDRESS MECHANISM

A. Public consultation and EMP information dissemination

37. Information relevant to the construction packages were disseminated through(i) the ceremony of work commencement (involving representatives of city, district,wards, journalists and other relevant agencies); (ii) sending documents to wardpeople committee; and (iii) the information boards at the gates or on the fencingsystem of construction sites. These kinds of information disseminated by (i) and (ii)only focused on technical description of the packages, project progress etc. but withno information related to EMP implementation. The information boards only providename, address, contact and hotline of contractors. GRM is not specifically disclosed.

38. As a requirement of updated EIA approved by ADB in August 2013, publicinvolvement activities to disseminate project information should be carried out duringpre-construction; construction and operation. A framework for these activities wasestablished as the commitment of MRB for ensuring public involvement in the project

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implementation phase. The status for implementing public involvement activities ispresented in the succeeding table.

Table 15. Monitoring the implementation of public involvement activities

Activity Purpose Participants Status ofimplementation

Newsletter/Fact Sheets

To broadly disseminate projectinformation to a wideaudience. Newsletters / FactSheets will be distributed toresidences and businesses inthe project area and oncommunity notice boards.

Residents and businessesin project area

Project information wasdisseminated byceremonies of workcommencement withidentified participants butdid not include residentsand businesses inproject area.

Mass mediacommunications

To broadly disseminate projectinformation to a wideaudience. Mass media toolswould include loudspeakers,radio, newspaper andtelevision.

Throughout project areaand more broadlythroughout Ha Noi.

Only traffic managementwas broadcast on radioand television.Tree relocation plan forKim Ma Street wasdisseminated throughpress conference.HIV programs have usedward loudspeakers forinformationdissemination.

Open publicmeetings

To provide stakeholders anopportunity to seek moredetailed information on theproject and provide directfeedback to the project team.

By open invitation tocommunity members andby invitation to keystakeholders such as wardand district officials, GOVagencies, NGOs etc.

Done. Key stakeholderssuch as ward and districtofficials and localresident were invited tomeeting before relocatethe tree.

Focus groups To allow detailed and focuseddiscussion on addressingproject- related issues such aswater use, land use andbusiness changes, use ofsystem by different passengergroups and amenity effectsduring construction

Community members, GOVauthorities and otherstakeholders formed intointerest groups to addressspecific issues – examplesof issues around whichfocus groups may bedeveloped include heritageissues, business operators,road user / public transportuser and operator groups,residents etc.

Done by social andresettlement consultantsduring their missions onresettlement monitoring.

Stakeholdermeetings

To allow discussion andinformation gathering onspecific issues relevant toenvironmental issues relatedto the project

GOV agencies, projectconsultants, NGOs etc.

Focus group meetingsconducted in Octoberand December 2016relating to tree relocationalong Kim Ma Street andpotential impacts oftunnel works on culturalresources.

39. Information dissemination to public is very important for projectimplementation as it gives some benefits for MRB operation consisting of (i)

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enhancing community’s support for project by project’s positive objectives for bothenvironment and society; (ii) obtaining precious feedbacks from community onunanticipated impacts; and (iii) avoiding unreasonable complaints due to the lack ofinformation. In view of these benefits and to comply with the EIA, the publicinvolvement activities should be scheduled in detail continuously.

B. Grievance Redress Mechanism (GRM)

40. The existing process for resolving complaints of the project is described in thesucceeding figure.

41. Currently, there are two ways that community members can file a complainton adverse impacts of project:

First way, Community or project affected people can make verbal complaintsdirectly to contractors through contractor’s hotline posted on information boardsat sites. These complaints shall be checked and resolved by contractors followingeach contractor’s processes and reported to the Engineer (Systra) forsupervision. In case the complaints cannot be resolved by contractors,community or affected people shall be guided to use the second way.

Second way, community or project affected people shall make written complaintswith or without the verification of ward people committee (WPC) and send themto MRB at the address of MRB Administration Department (this address is publicon the official website of MRB) and all complaints related to MRB activities aredocumented by this Department. The Department has responsibility to classifywhich metro line the complaint relates to. If the complaint relates to the project,they will be sent to the director of MRB and copied to the director of PMU1 incharge of the project. The MRB director shall send his request to resolve thecomplaint and report the results to the director of PMU1 attached with hisadvices, instructions, and comments. The director of PMU1 after receiving therequest, shall identify which construction packages (CPs) are involved with thecomplaints and continuously send the complaints to group leaders who are incharge of the involved CPs for explanation, corrective actions and feedbacks.Feedbacks for the complaints from the group leaders are submitted to thedirector of PMU1, then after revised and approved by PMU1 director, they aresubmitted to MRB director for clearance and approval before sending to theAdministration Department to respond to the community or affected people. Allfeedbacks for complaints also are documented by Administration Department.

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Figure 7. Current process for resolving complaint

42. Interviews conducted during site inspections in February and November 2016by independent environment specialists revealed that no interviewee had heard ofthe grievance redress mechanism (GRM) and were not aware of how to access it.The absence of a well-defined GRM that is easily accessible and known bypotentially affected people was a critical lapse that needed urgent attention.

43. A workshop was conducted on 7 December 2016 by ADB with participantsfrom MRB, the co-financiers, ward and district PC representatives, and contractors toidentify: (i) current weaknesses of grievance redress procedures for safeguardrelated matters, and (ii) measures to strengthen the GRM. The workshop concludedthat the GRM needed to be strengthened to: (i) clearly spell out the GRM’s mandate;(ii) define a simple and transparent GRM structure with a transparent, credible andpredictable grievance redress process and procedures; (iii) identify GRMcoordination responsibilities with dedicated and trained staff that can make decisions;and (iv) ensure the GRM is disseminated widely to potentially affected people (e.g.through an awareness raising campaign, distribution of GRM booklets, and an onlineplatform).

44. It was agreed that a working group would be established to develop a GRMthat incorporates the items above. The improved GRM must be in compliance withthe GoV legal framework and the co-financiers safeguard requirements. The workinggroup will include members of MRB, ADB, district authorities, the PIC andcontractors and will meet in January 2017. A paper is currently being prepared byADB to provide the working group with a clear context and background of the currentGRM, GoV regulatory framework, and proposal for improvements. The status of theGRM will be reviewed in the next semi-annual environment monitoring report.

45. Complaint by Green Trees Ha Noi. In the period from March to December2016, the project’s co-financiers received eight letters from Green Trees Ha Noi(GTH). GTH is an unregistered, informal group of concerned citizens established in

Director of MRB

Director ofPMU1

MRBAdministration

Department

G1

G2

G3

Ward Peoplecommittee

CommunityContractors

PICSystra

Complaint line Reporting line Feedback line

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2015 and operating through social media (Facebook). GTH consists of 30 foundingmembers and some 11,000 Facebook followers, which the Group classifies asmembers. In October 2016, and as a result of MRB’s written response to GTH dated17 October 2016, the Group split into two sub-groups with diverging positions andagendas. One hard core remains fundamentally opposed to the project design andthe relocation of trees.

46. The hard core of GTH is fundamentally opposed to the relocation of treesalong the Right Of Way of the Metro Line 3 corridor, and urges MRB and the co-financiers to re-consider the project design. They further claim that (i) theenvironmental impact assessment (EIA, 2010; updated in 2013) was not conductedin compliance with international good practice and deliberately omitted to documentthe project’s impact on legally protected trees and physical cultural resources; (ii)public consultation (in the framework of the EIA and the tree relocation planning) wasnot meaningful; (iii) tree trimming and relocation is being conducted without thenecessary approvals; (iv) transparency and accountability are not guaranteed; (v)ADB staff at HQ and VRM did not properly appraise the EIA, and do not adequatelysupervise project implementation.

47. ADB has acknowledged receipt of all letters within 5 working days, and hassystematically reminded HPC/MRB of their responsibility to address the complaint,improve the project GRM, and ensure meaningful consultation throughout projectimplementation.2 Two comprehensive letters responding to the complainant’s claimswere sent to GTH on 12 May 2016 and 14 October 2016, respectively. Meetingswere held with GTH representatives on 13 October 2016 and 22 December 2016.Regular meetings were convened with MRB.3 Several information requests were sentto MRB and the Ha Noi Department of Construction (DOC), and a temporarysuspension of tree relocation works was issued on 13 October 2016. MRB has beengenerally responsive to ADB’s requests for information and meetings. MRB alsohosted a meeting with two representatives of GTH on 13 October 2016, and provideda written response to the representatives’ request on 17 October 2016. The projectteam reviewed the updated EIA (2013); reviewed the GoV’s laws and decrees thatregulate petitions and grievances; inspected tree trimming and relocation works; andprovided advice to MRB and DOC on how to better align tree relocation methodologyto international good practice. The project team has sought advice from DOC, the HaNoi Department of Forestry and the IUCN4 to confirm the legality of ongoing andplanned tree relocation works.5

48. This issue shall be updated continuously in the next report (the first semi-annual monitoring report from Jan to Jun of 2017).

VII. INSTITUTIONAL STRENGTHENING AND TRAINING

49. As mentioned in the updated EIA, to strengthen the knowledge base of theEMU and PMU/HRB staff, a series of training activities shall be implemented by the

2 During the co-financiers’ joint review mission on 22 April 2016, the cofinanciers highlighted the issue toHPC Chairman and Vice Chairman, and the need for HPC/MRB to take ownership in responding toGTH. HPC was responsive to the complaint and the cofinancier’s request. The tree felling/relocationapproach was adjusted in April 2016 following the HPC Chairman’s Notification No. 95/TB-UBND to shiftfrom tree cutting to tree relocation.3 Meetings with MRB were held on 30 March, 24 August, 5 October, 1 November, 4 November, 14November, 21 November 2016. Agence Française de Développement(AFD) participated in the first twomeetings.4 The International Union for Conservation of Nature (IUCN) confirmed that the relocation of urban treeslisted on the red list of endangered species was acceptable if these are relocated to a more naturalhabitat.5 MOC is the agency in charge of issuing tree relocation permits and supervising tree relocation works.

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Project Supervision Consultant (PSC). The international specialist of PSC shallprepare a training program and materials based on the results of the assessment.Therefore, the environmental monitoring & assessment (EMA) training course wasorganized as a part of the Tasks 2.1. and 2.3 of the contract of PSC (IDOM) that wascarried out from 01 to 02 July, 2013. This course is to provide PMU-1 & MRB’s staffswith a comprehensive understanding of environmental safety management and todevelop their capacity on environmental monitoring & assessment.

50. Main objectives of environmental monitoring training course consisted of theunderstanding of environmental safeguard policy and EMP, how to implement,supervise EMP, how to prepare CEMP. There were about 23 MRB’s staffsparticipating in this course. This training course was received the special attention ofPMU-1’s staffs working at the Construction & Supervision Department (30%), theEngineering Department (13%), the Planning & Financial Department (4%) and theTechnical Assistance & Land Preparation Department (4%). The participating staffscame from MRB’s Divisions including the Financial & Accounting Division (4%),Technical Assistance & Investment Preparation Division (30%), the Planning &Investment Division (9%), and Technical Division (4%).

VIII. KEY ENVIRONMENTAL ISSUES

A. Key Issues Identified, Actions Taken, Additional Actions Required

51. Based on the assessment mentioned in previous chapters, Keyenvironmental outstanding issues identified during this monitoring period arepresented in table 18 with respective corrective actions, implementation responsibilityand timeframe.

Table 16. Environmental key issues

No Key issues Corrective actions Supervisedby

Schedule

MRB

1 The lack of awell-definedGRM

Refer to chapter VI MRB/ADB Afterparticipatingthe workinggroup onGRM,expected inMarch 2017

2 The lack ofEMU in MRB

Establish an EMU to oversee implementation ofEMP requirements for the entire project withassistance from the PIC.The EMU would be under the direction of theProject Management Unit 1(PMU1) within MRBThe EMU, shall be initially staffed by at least, anenvironmental engineer and an occupationalhealth and safety officer

MRB/ADB Expected inMarch 2017

3 The lack ofmonthlyenvironmentalmonitoringreports on EMPimplementation

Request the assistance of PIC to prepare themonthly reports.

MRB/ADB December2016

Establishing an EMU, and the EMU hasresponsibility to prepare monthly reports


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Schedule

4 Missing of EMPdisseminationactivities

Establishing an EMU, and the EMU hasresponsibility to conduct public disclosure ofproject information.


CP01 – DEALIM

5 Informationdisclosure

An information board with adequate and detailcontacts (name, position, tel) of relevantstakeholders (representative of MRB, PIC,contractors and hotline) should be provided atevery gates of construction site.

PIC and MRB February 2017

7 Dust controland communityhealth

- Conducting watering sprays at leat every 2hours during construction time for the heapsof unused fine materials.- Cleaning unused materials off the sites byhauling to the designated disposal sites.

PIC and MRB Daily

8 Solid wastemanagement

Providing bins specifically for the solid wastessticking with petroleum products, these binsshould be placed within the areas for storingpetroleum products.

PIC and MRB Daily

9 Pollution ofpublic road

A wheel washing station should be established atthe gate of the site for Pier 365 – 364 and in themanner the wastewater generated from thestation shall run off into the site. The stationshould also is provided with steel sheets forvehicle parking during wheel washing process.

PIC and MRB Dailywhenevervehicles out ofthe site

10 Constructionsite security

Provide locks for all construction gates andassure that all the gates are locked when thesites do not have any construction activities

Provide security guards at the sites on which stillhave excavation holes or scaffoldings


CP02 – POSCO

11 Pollution ofpublic road

A wheel washing station should be established atthe gate of the site of station 8 and in the mannerthe wastewater generated from the station shallrun off into the site. The station should also isprovided with steel sheets for vehicle parkingduring wheel washing process.


12 Air pollutionand communityhealth

Clean soil, sand and small substances aroundthe gates of the stations

Spray water on these areas to reduce dustbefore cleaning

PIC and MRB Daily

13 Constructionsite sanitationandmanagement

Rehabilitate the broken concrete ledge of the siteof station 7

Clean all the garbages within the site

PIC and MRB Jan 2017

CP04 – VC2

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Schedule

14 Not compliedwith SEMP

VC 2 contractor is requested to clean up the areaon which VC2 office is formerly located

PIC and MRB In Dec 2016

CP05 – HANCOR

15 Constructionsafety

Establish rail hand guard and fences systemfor the sites at height

Assure all workers to be equiped with properpersonal protective equipment while working

PIC and MRB In Dec 2016

IX. CONCLUSION AND RECOMMENDATIONA. Overall Progress of Implementation of Environmental Management

Measures52. Environmental supervision arrangements are not yet fully satisfactory. MRBshould urgently establish an Environment Management Unit (EMU) staffed with aqualified and experienced environmental, occupational health and safety officer, asspecified in the loan agreement and the updated EIA (2013) to coordinateenvironmental aspects of the project, including regular EMP implementationsupervision, public consultation and GRM coordination, and reporting to ADB.

53. The contractors’ compliance with environmental supervision and reportingrequirements is satisfactory (monthly environmental compliance reports aresubmitted to the PIC and MRB), but contractors should be requested to includesections on community participation, communication, grievances and health andsafety in forthcoming monitoring reports.

54. The PIC should include a more detailed section on the contractors’environmental management activities and performance in future monthly progressreports until the PMS Phase 2 Consultant is mobilized.

55. Contractors CP01, CP02 and CP05 have contracted licensed monitoringinstitutes to conduct environment effect monitoring (covering air and surface waterquality, noise, vibration) in accordance with their construction EMPs (last monitoringconducted in November 2016). This is considered acceptable as temporarymonitoring arrangement, but MRB should (i) accelerate recruitment of the PMSPhase 2 consultant; and (ii) ensure that monitoring results of the contractors aredocumented in the semi-annual environment monitoring reports.

56. Construction sites are generally tidy and organized. Information boards aredisplayed at construction sites. Sturdy metal sheet fences were installed around allconstruction sites. Security personnel are assigned at the construction siteingress/egress and the public are not allowed access to the area. Construction safetyis exemplary. General housekeeping is satisfactory. There are proper provisions forhazardous materials such as fuel, oil and gas. No major environmental issues wereobserved during the site inspections. CP04 contractor should be requested to cleanup the site of their decommissioned site office before contract termination.Information boards that disclose project schedule, contact information of thecontractor, Systra and MRB, as well as the project GRM, should be disclosed at allconstruction sites. The new information boards of CP01 are considered goodpractice and should be adopted by other contractors.

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B. Actions Recommended57. Outstanding issues during this report period and corrective action arepresented in Table 17. MRB needs to allocate adequate resources to carry outeffectively these actions. An environmental specialist is very necessary in projectmanagement system of MRB, and this position should be filled in early 2017.

APPENDIX 1–Environmental Monitoring Report No 12 prepared in Sep 2016 byDaelim and approved by Systra.

APPENDIX 2 – Monthly Environmental Compliance Report for Oct 2016 prepared byPosco and approved by Systra.

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