TIN NGHIA CORPORATION NHON TRACH 3 INDUSTRIAL PARK COMPANY LIMITED

VIETNAM INDUSTRIAL POLLUTION MANAGEMENT PROJECT IN DONG NAI, NHUE-DAY RIVER BASINS

ENVIRONMENTAL IMPACT ASSESSMENT Of Project

"CONSTRUCT CENTRALIZED WASTE WATER TREATMENT SYSTEM WITH CAPACITY 2.000 M3/DAY AT NHON TRACH 3 INDUSTRIAL PARK - PHASE 2 (MODULE 2)"

DONG NAI, 07/2012TIN NGHIA CORPORATION NHON TRACH 3 INDUSTRIAL PARK COMPANY LIMITED

VIETNAM INDUSTRIAL POLLUTION MANAGEMENT PROJECT IN DONG NAI, NHUE-DAY RIVER BASINS

ENVIRONMENTAL IMPACT ASSESSMENT Of Sub-Project

"CONSTRUCTION OF CENTRALIZED WASTE WATER TREATMENT SYSTEM WITH CAPACITY 2,000 M3/DAY AT NHON TRACH 3 INDUSTRIAL PARK - PHASE 2 (MODULE 2)"

PROJECT'S OWNER CONSULTANT DONG NAI, 07/2012 TABLE OF CONTENTS

5 IONS

BOD : Biochemical oxygen demand CEPT : Common Effluent Treatment Plant COD : Chemical Oxygen Demand DIZA : Dong Nai Industrial zone Authority DO : Dissolved Oxygen DONRE : Department of Natural Resources and Environments EIA : Environmental impact Assessment EMP : Environmental Management Plan ENTEC : Environmental Technology Center IP : Industrial Park IZA : Industrial Zone Anthority Ltd. Co : Limitted Company MONRE : Ministry of Natural Resources and Environments NT3IP : Nhon Trach 3 Industrial park – Phase 2 QCVN : Vietnam National Regulation TSS : Total Suspended Solid VACNE :Vietnam Association for Conservation of Nature and Environment

6

LIST OF TABLES

7 SUMMARY OF THE ENVIRONMENTAL IMPACT ASSESSMENT

Nhon Trach 3 IP One member Affiliated Co., Ltd is authorised by Tin Nghia Corporation to manage the infrastructures of the IP; hence is also responsible for the implementation of the CETP (Module 2), capacity 2,000 m3/day in Nhon Trach 3 IP. This EMP is constructed by the Environmental Technology Center (ENTEC), part of Vietnam Association for Conservation of Nature and Environment (VACNE). The contents of the plan is as below

1. PROJECT CONTENTS

1. Description Aim: to satisfy the increasing in number of firms within the IP and the arisen demand of wastewater treatment through the development of Module 2 CETP ,capacity of 2,000 m3/day” (the total capacity of two modules is 4,000 m3/day and night) Project Owners: Nhon Trach 3 IP One member Affiliated Co., Ltd Site Location: Road No. 2, Nhon Trach Industrial Park No. 1, Phase II, Nhon Trach District, Dong Nai Province. The Module 1 centralised wastewater treatment system have original capacity of is 2,000 m3/day the system ahs been receiving and treating wastewater of operating industries in the industrial park. Currently the average wastewater volume is 780 m3/day; nd peaked at 1,169 m3/day. By November 2012, the total wastewater volume of Nhon Trach 3 IP, Phase 2 will increase to around 3,000 m3/day. To properly collect and treat this wastewater, Tin Nghia has been developing the second module to expand the total capacity of the wastewater treatment facility of Nhon Trach 3 IP, Phase 2 to 4,000 m3/day.

2. CETP treatment technology Wastewater from Nhon Trach 3 IP, phase 2 is treated by two steps as follows:

1st Step (facilities own treatment): the wastewater from private companies will be treated preliminarily, to meet the influent standard of IP centralised treatment plant. 2nd Step (centralised treatment): Preliminarily treated wastewater is collected into the centralised treatment facility of the industrial park for further treatment ( and meet the QCVN 40:2011/BTNMT – National Technical Regulation on Industrial Wastewater, Column B, Kf=1.0, Kq=1.1) prior discharging into the environment Module 2 technology for Nhon Trach 3 IP CETP can be described as below:

Preliminary and Primary Treatment: + Removal of wastewater constituents (rags, sticks, floatables, grits…). + Chemical treatment (mixing and flocculation). + Removed floating oils and greases.

8 Secondary treatment (remove biodegradable organics): + Aerobic treatment to removal biodegradable nutrients, BOD, COD. Tertiary treatment: + Advanced treatment by remove residual suspended solid and dissolved materials. + Disinfection. Sludge treatment: + Dewater and compact the dried sludge.

3. CETP characteristics The effluent after treatment will be flown through the open ditches B4000, then closed pipes B3000 before being directed along the upper stream of Lo Ren canal (along regional slopes toward southeast), and finally being discharged into Thi Vai River. The discharge schedule is 24 hours a day. Discharge flow rate is 84 m3/hr (or up to 2000 m3/day)

4. CETP implementation schedules June/ July 2012: Finished legal works Aug-Dec 2012: Start the construction Jan 2013: Implement equipments, pipeline networks. Feb 2013: Pilot Run Mar- Apr 2013: Technology and system transfering

2. CHARACTERISTICS OF WASTEWATER RECEIVING BODY BASIN

1. Discharge points

Discharge point: Lo Ren Culvert (near Lo ren Bridge) and at coordinates (VN2000): X: 1.184.745 m; Y: 413.438 m.

2. Current environmental status Air quality: The analysed sampling results from nearby air quality samples showed all parameters met QCVN 05:2009/BTNMT, QCVN 26:2010/BTNMT, and QCVN 06:2009/BTNM Surface Water quality: The analysed sampling results from nearby surface water quality samples comparing to QCVN 08:2008/BTNMT, column B1 showed parameters like COD, BOD and TSS over the standards. Soil quality: The analysed sampling results from soil samples showed no heavy metal pollution

9 3. Characteristics of wastewater receiving body

Thi Vai River is the wastewater receiving body for all of Nhon Trach 3 wastewater and currently is heavily polluted due to wastewaters from nearby sources. River flowrate mixed with flood is peaked at 3,400 m3/s, with river with tide reverse flow peaked with tide at 2,300 m3/s. River flowrate during wet season is around 350 – 400 m3/s and during dry season is around 200 m3/s. The minimum recorded flowrate is 40 – 50 m3/s. The highest river speed could reach 1.5 m/s. Thi Vai River based on Dong nai Province planned landuse, is for aquaculture farming

4. Nearby discharge

Nearby discharges sources into Thi Vai River is as below: Industrial sources: Discharges from Hung Nghiep Formosa, Nhon Trach 2 and 3 IPs, with a flowrate of approximate 20,500 m3/day Agricultural sources: The total volume of wastewater from aquaculture activities discharged into Thi Vai river is estimated at 7,043,760 to 9,391,680 m3/farming season. Most of these wastewater is discharged only after harvested (after around 3-4 months) Residental sources: Domestic wasteater from Long Tho Commune, Nhon Trach District and Hiep Phuoc District is 1,467 – 1,956 m3/day.

5. Nearby water supply intake

Within 3 km downstream of Thi Vai (from Mareng discharge point), there’s no river water intake sites, even for industrial or aquaculture purposes.

3. ALTERNATIVE SOLUTION

1. Discharge point location

As the Module 2 used the same discharge point with the Module1, hence there’s no alternative solution for the discharge point location

2. Wasteawter treatment technology

As the Module 2 have to integrate into Module 1, hence there’s no alternative solution for the already chosen technology in Module 1

3. Sludge treatment

As the sludge treatment of Module 1 still can provide the extra capacity, hence the Moduel 2 still use the same method as Module 1

4. DISCHARGE IMPACT ASSESSMENT

1. On water quality

10 After the Module 2 start operating, a flow of 2,000 m3/ day will contribute into Mareng

Canal flow, bring with it an equivalence of 31.6 kg TSS, 14 kg BOD5, 104 kg COD, 0.76 kg ammonia and 0.36 kg Total iron

2. On the ecology

Currently, there is no expected impact by the discharge onto the ecology and mangrove areas downstream (Long Thanh – Nhon Trach areas)

3. On river flow

The discharge rate from the CETP (Module 2) is insignificant comparing to Mareng and Thi vai river, hence won’t affect the river and canal flow

4. On air quality

The discharge from The CETP does not produce odour as from the interviews toward the residential areas and hence does not impact onto regional air quality

5. Associated risks and accidents

Due to the low discharge rate 2,000 m3/day or 23.14 l/s, the discharge won’t affect the travel of canoes on the canal and rvier

6. Socio-economical impacts

There’s no negative feedbacks from the nearby residential areas (around Mareng and Thi Vai) on whether their socio-economical situations are affected by the project

7. Accumulated and integrated impacts

For Ma Reng Canal, after received the treated wastewater from the IP will still be able to sustain the loads of parameters BOD, SS, As, Pb, Cd and Hg. Only COD already over the river maximum pollution loads; due to the current pollution load of Mareng is already higher than the Canal max pollution load. In that way, even when the pollution loads from the CETP contribute unsinificant amount, the river still can’t receive more loads.

Similarly for Thi Vai River, after received the treated wastewater from the IP will still be able to sustain the loads of parameters BOD, COD, As, Pb, Cd and Hg. Only COD already over the river maximum pollution loads; due to the current pollution load of Mareng is already higher than the Canal max pollution load. So even when the pollution loads from the CETP contribute unsinificant amount, the river still can’t receive more loads

5. POLLUTION MITIGATION TOWARD NEARBY SURFACE WATER

11 1. Environmental Management Program

1. Construction stages Water pollution mitigation measures Air pollution mitigation measures Mitigation measures for smpacts from solid wastes

2. Operation stages Water pollution mitigation measures Air pollution mitigation measures Negative impacts mitigation for solid wastes Negative impacts mitigation for sludges

2. Risks managements

1. Constructs stages Measures to prevent and mitigate the impacts of these risks: Risk of fires and explosions Traffic Accidents Risks associated with labour and health safety

2. Operation stages Measures to prevent and mitigate the impacts of these risks: Risk of fires and explosions Risks associated with labour and health safety Chemical leakage Thunder/ lightning Impactsassociated when the plant stop operating

3. Public consulting and Information publication

During the construct of this EMP, the project owner have consult the local government (People Committee, Fatherland Front Committee) and the residents living in affected areas

4. Capacity building

The project owners will carry own measuress to strengthen the capacity to react against environmental and CETPworkers health risks.

12 5. Project owner organisation and responsibilties

The issues related to environmental management will be implemented by the CETP Environmental Department as regulated plan

6. Environmental quality Monitoring

The project owners will be responsible for the monitoring of nearby surce water sources, along with the periodic sampling of Nhon Trach 3. The results will be presented to authorised body of local government as required

7. Costs and schedules of EMP

6. PUBLIC CONSULTING

The project owners carried out consultations with the following subject groups:

People Committee, Fatherland Front Committee of Long Tho Commune where generally these two local governmental bodies have provided their opponents over the proposal and the measures mentioned in this EMP The residents living near the site and under effects of the project, where 17/24 agreed with the projects, while most of others does not give comments on it. The residents also mentions the issues of flooding during rains and the stagnation of effluent in the canal during the dry season

Commitment From Tin Nghia

The project owners commit to meet Vietnam regulations during the construction and operations The project commit to apply all of risks control measures as presented in the plan, while promote internal capacity building and environmental awareness, to ensure best environmental management plans for the project will be carried out. The project owners will under full responsibilities if violating Vietnam regulations or International Convention

13 1. PROJECT DESCRIPTION

PROJECT ORIGIN

In compliance with the existing regulations over the environmental qualities within and surrounding Nhon Trach 3 Industrial Park, Tin Nghia Corporation have invested in the implementation of a centralised wastewater treatment system (Module 1) in Nhon Trach 3 Industrial Park - Phase 2, capacity of 2,000 m3/day and night. This Module 1 central wastewater treatment system was officially put into operation since November 2007, meeting wastewater treatment requirements and demands from Nhon Trach 3 Industrial Park, and Vietnam environmental regulations.

However, due to the increasing number of facilities within the industrial park, the wastewater discharge demand has been increasing rapidly. That’s why the project entitled “Development of the CETP of Nhon Trach 3 IP - Phase 2 (Module 2) capacity of 2,000 m3/day (the total capacity of two phases is 4,000 m3/day) has been proposed to meet the wastewater treatment demand in the industrial park.

Some facilities are currently under construction at the IP, and already sent the notification on the expected operation time in 2012 and the estimated discharge volume. Or more specifically: Rohm & Haas Vietnam Co., Ltd: April, 2010. The estimated wastewater volume is 80 m3/day Promax Textile Vietnam Co., Ltd.: July 2012; the estimated wastewater volume is 1,400 m3/day YKK Vietnam Co., Ltd.: November 2012; the estimated wastewater volume is 250 m3/day. By November 2012, the total wastewater volume of Nhon Trach 3 IP, Phase 2 will increase to around 3,000 m3/day. To properly collect and treat this wastewater volume to the existing requirement (Decision No. 1696/QD-BTNMT dated November 15, 2006 of MONRE on approving EIA report of Nhon Trach 3 IP, Phase 2), Tin Nghia has been developing the second module to expand the total capacity of the wastewater treatment facility of Nhon Trach 3 IP, Phase 2 to 4,000m3/day.

1. CETP OWNER Nhon Trach 3 IP Investor Group: Tin Nghia Corporation Representative: Mr. Quach Van Duc - Position: General Director Address: No. 96, Ha Huy Giap Street, Quyet Thang Ward, Bien Hoa City, Dong Nai Province. Telephone No.:061.3822486 Fax No.: 061.3823747 The assigned unit to manage the services of infrastructures of Nhon Trach 3: Nhon Trach 3 IP One member Affiliated Co., Ltd Representative: Mr. Nguyen thanh Binh - Position: Director

14 Address: 25B Road, Hiep Phuoc Commune, Nhon Trach District, Dong Nai Province. Telephone No.:061.3822486 Fax No.: 061.3823747

CETP LOCATION

CETP Module 1 (existing) and Module 2 have the same location: Road No. 2, Nhon Trach Industrial Park No. 3 - Phase 2, Nhon Trach District, Dong Nai Province. A map that shows location of IZ and a map that shows the IZ, including service areas of CETP Module 1 and Module 2 is illustrated in appendix 1.

CURRENT SITUATION OF TECHNICAL INFRASTRUCTURE IN NHON TRACH INDUSTRIAL PARK NO 3 – PHASE II

The Industrial Zone is divided into two “phases”. Phase 1 is approximately the northern third of the IZ and Phase 2 is the southern two-thirds (see map in Appendix 1). In Phase 1 we find 9 existing industries (all serviced by the CETP-Module 1) and Formosa Industry which has its own pre-treatment and which does not send its effluent to the IZ CETP; it is discharged separately.

Nhon Trach 3 IP, Phase II covers a total area of 360.5 ha. There are an additional 20 industrial enterprises in the Phase II which are also connected to the CETP-Module 1. Future industries will be located in Phase II and will all connect to the CETP.

The IP’s EIA report was approved by the Ministry of Natural Resources and Environment(MONRE) in Decision No. 1696/QD-BTNMT dated November 15, 2006. The IP has been attracting various industries including garment and textile, footwear and leather, machine manufacturing, food processing, medicine and cosmetics, material technologies, interior decoration, wooden product processing and services such as banking, telecommunication, public cleaning service, warehouse, workshop rental among others. Area: 360.5 ha with the construction area of 262.5 ha (65.7% of total area) 29 investment facilities’ licenses were granted so far in Nhon Trach 3 IP. The occupied area: 126.95 ha; sharing 48%. The unoccupied area: 136 ha; sharing 52%. Tree growing area: 61.29 ha; sharing 17%.

1. List of Industries and Their Wastewater Treatment Capacity

The table below summarizes industries in Nhon Trach 3 IP, Phase 1 and Phase 2, with their size and type of production (as of April 2012). All of these industries are connected to CETP (Module 1 and Module 2).

15 Table 1: Industries in Nhon Trach 3 Industrial Park, Phase 2 and Phase 1

Industri Area (m2) Wastewater Main polluting Notes No Production es rate (m3/day) parameters I. NHON TRACH 3 IP – PHASE 2 OPERATING INDUSTRIES

Viet COD=90, BOD5=52, Have pre- Long TSS=69, TN=32, treatment plant 01 Paper packing manufacturing 50,000 70 Packing TP=2.4 Co. Ltd.

SPC COD=79, BOD5=40, No pre- Tianhua Manufacturing of chemicals TSS=66, TN=1.9, treatment 02 Co., Ltd for wastewater treatment 20,000 1 TP=0.2 (Vietnam industries )

Tin COD=8, BOD5=3, No pre- Nghia TSS=10, TN=4.3, treatment Construc TP=2.7, Color=7Pt- tion Co Material 03 Brick and tile manufacturing 62,429 12 One- member Affiliate d Co., Ltd.

04 Shun Yin Ceramics manufacturing 20,000 3 COD=22, BOD5=15, No pre-

16 Industri Area (m2) Wastewater Main polluting Notes No Production es rate (m3/day) parameters Ceramics TSS=58, TN=3, treatment Materials TP=0.12, Zn=0.24 Co., Ltd. Le Phan TSS, heavy metal, No pre- Construc turbidity treatment 05 Fresh concrete manufacturing 20,613 13 tion Co., Ltd. Ampharc COD=159, Have pre-

o BOD5=70, TSS=20, treatment plant Cosmetic Pharmaceutical product TN=24, TP=2.2 06 64,377 17 s Joint manufacturing Stock Co. Bueno COD=120, Have pre- Techniqu Manufacturing of valves and BOD =52, TSS=45, treatment plant 07 68,053 26 5 e Co., Steeless steel spare parts TN=18, TP=2.0 Ltd.

CSB COD=82, BOD5=38, Have pre- 08 Battery Dry battery manufacturing 100,000 188 TSS=66, TN=38, treatment plant Co., Ltd. TP=0.8 Machine and equipment Heavy metal, No pre- Velco 09 manufacturing for steel 30,000 2 inorganic grease, treatment Co., Ltd. industries TSS 10 Kirby Steel structure processing 65,862 25 COD=110, No pre-

17 Industri Area (m2) Wastewater Main polluting Notes No Production es rate (m3/day) parameters

Southeas BOD5=49, TSS=68, treatment t Asia TN=41, TP=1.8 Co., Ltd.

EU COD=29, BOD5=20, No pre- Construc TSS=36, TN=1.2, treatment PVC door and partition 11 tion 30,000 30 TP=0.1 manufacturing Material Co., Ltd. Tan Tien COD=480, No pre-

12 Plastic Plastic 50,000 5,5 BOD5=84, TSS=88, treatment JS Co. TN=1.2, TP=0.2 Towa COD=77, BOD =28, No pre- Plastic home appliances 5 13 Vietnam 17,000 5 TSS=58, TN=49, treatment manufacturing Co., Ltd. TP=0.4 COD=35, BOD =20, Have pre- Sammi Steeless steel wire and net 5 14 17,052 6 TSS=36, TN=14, treatment plant Co., Ltd. manufacturing TP=0.1 An Lac Heavy metal, No pre- Nhon turbidity, treatment 15 Toilet paper processing 24,000 4,5 Trach temperature, TSS Co., Ltd

16 Plust Stationery manufacturing 30,000 12 COD=38, BOD5=21, Have pre- Vietnam TSS=48, TN=10, treatment plant Industry TP=0.1, Oil=4

18 Industri Area (m2) Wastewater Main polluting Notes No Production es rate (m3/day) parameters Co., Ltd.

Y.S.P COD=55, BOD5=24, Have pre- Vietnam TSS=41, TN=11, treatment plant Co., Ltd. TP=0.3 Pharmaceutical product 17 (experim 68,000 6 manufacturing ental operation ) Manufacturing of industrial Heavy metal, No pre- Soltec equipment, environmental inorganic greases, treatment 18 Vietnam treatment equipment, industrial 20,000 2 TSS Co., Ltd. steel pipe and construction scaffolding Manufacturing of steel and COD=85, BOD =38, No pre- Kyowa 5 stainless steel components, TSS=45, TN=21, treatment 19 Vietnam 15,000 2 industrial pipe, industrial valve TP=1.3 Co., Ltd. and cranes Rohm Heavy metal, No pre- Polymer chemical 20 and Haas 40,764 - inorganic greases, treatment manufacturing Co., Ltd TSS II. NHON TRACH 3 IP – PHASE 1 OPERATING SERVICES AND THE SERVICE CENTER 16 HA 1 YoungTe Clothing industry 30,000 85 COD=192, No pre-

x Vina BOD5=60, TSS=160,

19 Industri Area (m2) Wastewater Main polluting Notes No Production es rate (m3/day) parameters Co., Ltd. TN=35, TP=7.4 treatment

2 Sinpoong Zipper materials COD=47, BOD5=22, Have pre- Vina 10,000 14 TSS=33, TN=2.0, treatment plant Co., Ltd. TP=0.5 3 Hung Ta Steel industries COD=263, No pre-

Co., Ltd. 30,000 42 BOD5=81, TSS=53, treatment TN=11, TP=0.6 4 TM Thai Pesticides pouring and COD=135, Have pre-

Nong distributing 5000 8 BOD5=47, TSS=48, treatment plant Co., Ltd. TN=42, TP=3.3

5 Kim Concrete manufacturing BOD5, COD, heavy No pre- Long 21,000 14 metal, specific treatment Co., Ltd. chemicals

6 Han Huu Concrete manufacturing COD=37, BOD5=8, No pre- Co., Ltd. 15,000 5 TSS=54, TN=3.8, treatment TP=0.4 7 Song Hui Under construction (office) COD, BOD , TSS, No pre- 1,500 1 5 Co., Ltd. TN, TP treatment

8 Tung Aquaculture product COD, BOD5, TSS, No pre- Kong processing 12,000 32 TN, TP, color treatment Co., Ltd.

9 Service Office rent for companies in 160,000 29 COD=57, BOD5=28, No pre- providin the IP TSS=65, TN=15, treatment

20 Industri Area (m2) Wastewater Main polluting Notes No Production es rate (m3/day) parameters g center/ TP=2.4 supermar ket

21 Furthermore, based on Decision 2376/QĐ-UBND dated 24/7/2008 of Dong Nai People’s Committee, the project treatment plant will also collect the wastewater from facilities from Formosa (of Nhon Trach 3 IP- Phase 1) and 51.73 ha of Tin Nghia service center. At this moment the CETP also collects and and treats waste water from the 16 ha of Tin Nghia service center .

Industrial wastewater of industries in Nhon Trach 3 IP, Phase 2 will be treated and meet the wastewater treatment contract prior to discharging (attached Table of Allowable Limits of Concentration of Parameters prior discharging to the wastewater treatment system of Nhon Trach III in the appendix).

Thus, the entire amount of waste water flowing to CETP of Nhon Trach 3 - Phase 2 (Module 1) includes the industries in Nhon Trach 3 IP - Phase 2 which are listed in Table 1 and the industries in Nhon Trach 3 IP - Phase 1 which are listed in the same table. The area where CETP of Nhon Trach 3 - Phase 2 (Module 1) received waste water is shown in appendix 1.

In Nhon Trach 3 IP - Phase 2: the wastewater discharge system of 20 operating industries has been connected to the CETP as signed under wastewater treatment contract with the Infrastructure Management Unit. Among them, 7 already have their own treatment systems for pre-treatment before being discharged into CETP of Nhon Trach 3 - Phase 2 (Module 1), they are shown in Table below.

Table 2: The industries in Nhon Trach 3 IP - Phase 2 have pre-treatment system

Waste water No Name Production system treatment rate (m3/day) Paper packing 1 Viet Long Packing Co. Ltd. 70 manufacturing Pharmaceutical Ampharco Cosmetics Joint 2 product 17 Stock Co. manufacturing Manufacturing of 3 Bueno Technique Co., Ltd. valves and Steeless 26 steel spare parts Dry battery 4 CSB Battery Co., Ltd. 188 manufacturing Steeless steel wire 5 Sammi Co., Ltd. and net 6 manufacturing Office stationary 6 Plus Vietnam Industrial Co.Ltd 12 manufacturing 7 Y.S.P Vietnam Co., Ltd. Pharmaceutical 6 (experimental operation) product

22 Waste water No Name Production system treatment rate (m3/day) manufacturing Total 325 Source: Nhon Trach 3 IP One member Affiliated Co., Ltd

In Nhon Trach 3 IP - Phase 1: two of nine industries have their own treatment systems for pre-treatment before being discharged into CETP of Nhon Trach 3 IP – Phase 2, they are shown in Table below:

Table 3: The industries in Nhon Trach 3 IP - Phase 1 have pre-treatment system

Waste water system No Name Production treatment rate (m3/day) 1 Thai Nong Co. Limited Pesticides Pouring 8 2 Sinpoong Vina Co. Limited Zipper Manufacturing 14 Source: Nhon Trach 3 IP One member Affiliated Co., Ltd

The CETP of Nhon Trach 3 - Phase 2 (Module 1) have original capacity of is 2,000 m3/day the system has been receiving and treating wastewater of operating industries in the industrial park. Currently the average wastewater volume is 780 m3/day; peaking at 1,346 m3/day. Wastewater is treated to meet Vietnam National Regulation QCVN 40:2011/BTNMT; column B, Kq=1.1; Kf=1,0 prior discharging through Lo Ren Discharge Point, and ultimately into Thi Vai River. The CETP of Nhon Trach 3 - Phase 2 (Module 1) addition of the treatment facility was examined and certified by Dong Nai Department of Natural Resources and Environment at Official Document No. 652/TNMT-CCBVMT dated March 18, 2010 and by Dong Nai People’s Committee under license No. 3571/GP-UBND in December 1, 2009 (see attached documents in the appendix). The company also has installed an automatic monitoring system to monitor the effluent quality (flowrate, pH, DO, TSS, COD, temperature).

Wastewater Collection System

The slope is inclined toward south west: with the elevation varies from 1 to 3.5 m. Wastewater is classified into two storing basins N1 and N2. In each basin, the wastewater is ran through reinforce concrete box culvert D300 – D400 – D600 and through the primary culvert system D800 – D1000 – D1200 to the centralised wastewater facility via D1500 culvert line. The wastewater discharge culverts are RC culvert, with manholes at the interval of 40-50 m along the culvert long. The sewage system covers total length of 15,704 m, comprising of D300 = 10,038 m,

23 D400 = 1,777 m, D600 = 1,489 m, D800 = 982 m, D1000 = 1,188 m, D1200 = 210 m, D1500 = 56 m. Currently, the construction of the entire system of waste water collection Tin Nghia Company has been completed. The treated wastewater is discharged to the environment via open ditch concrete culvert canal (B4000, 235 m in length) and closed box culvert (B3000, 524.3 m in length) before being discharged into Lo Ren Canal, and ultimately ends up in Thi Vai River.

Drainage System

Tin Nghia Corporation also developed the drainage system. The drainage system is the RC culvert, covering 30,211.4 m long, comprising of D600 culvert = 2,042 m, D800 = 6,905.6 m, D1000 = 7,020.2 m, D1200 = 485.6 m, D1500 = 11,254.2 m, open ditch B2000 = 997.5 m, B4000 = 982 m, and closed box culvert B3000 = 524.3 m.

People’s Committee of Nhon Trach District has only invested in the development of the drainage system along Road 25C. Companies along Road 25C (in Nhon Trach 3 IP, Phase I and Phase II) will have to continue the development and connect to the drainage system. When the local goverment develops the drainage system along Road 319B, the private sector will have to continue implementing a drainage system to connect from Youngtex Vina to the current one The stormwater in Nhon Trach 3 IP, Phase II is collected into the above concrete culverts, is run along the internal roads before being discharged to open ditch (the same one hosted the treated wastewater from the central wastewater treatment system) then being discharged into Mareng canal, and ultimately ends up in Thi Vai River.

Industrial waste management

Wastewater Treatment System

CETP of Nhon Trach 3 - Phase 2 (Module 1) has a capacity of 2,000 m3/day, and is already under operation since 11/2007.

Wastewater from Nhon Trach 3 IP - Phase 2 (module 1) is treated by two steps as follows:

1st Step (facilities own treatment): the wastewater from private companies will be treated preliminarily, to meet the influent standard of IP centralised treatment plant. 2nd Step (centralised treatment): Preliminarily treated wastewater is collected into the centralised treatment facility of the industrial park for further treatment (and to meet the QCVN 40:2011/BTNMT – National Technical Regulation on Industrial Wastewater, Column B, Kf=1.0, Kq=1.1) prior discharging into the environment

24 2. Solid Waste Management

Based on the collected information, 17 of total 20 companies there have already been granted “Hazardous solid waste registration books”. The last 3 companies are preparing paperwork to get the hazardous waste owner registration book.

Solid Waste Management of Nhon Trach 3 IP One member Affiliated Co., Ltd.

The IP got the hazardous waste registration book No. 587/SĐK-TNMT dated November 5, 2010, with hazardous solid waste management code No. 75001375.T. Domestic solid waste: The IP contracted Ha Long Bay Co., Ltd to collect the domestic solid waste properly (attached with the report is the solid waste collection contract). Hazardous Solid Waste: The IP contracted Tai Tien Co. Ltd to collect, transport and treat hazardous solid waste appropriately.

Solid Waste Management at Industries in Nhon Trach 3 IP, Phase 2

Nhon Trach 3 IP One-member Affiliated Co. Ltd. constructed the solid waste transit sites and signed the solid waste collection and transport with all companies within the IP. In addition, the company has also negotiated with hazardous solid waste disposal agencies (as mentioned above) to deal with them appropriately (following Circular No. 12/2011/TT-BTNMT dated April 14, 2011 of MONRE on hazardous solid waste management).

Nhon Trach 3 IP One-member Affiliated Co. Ltd. Also requested enterprises sorting out wastes at the discharge sources and store appropriately before delivering to the competent agency (the provisions of the land leasing contract).

The solid waste volume is specified as follows: The domestic solid waste is estimated at 17.423 tons per month, which is mainly collected by Nhon Trach 3 IP One-member Affiliated Co., Hiep Hoa Cooperative, Nhon Long Trade and Service Cooperative among others. Non-hazardous solid waste is estimated at 58.422 tons per month, which is mainly collected by Bay Ha Long Co., Ltd, Kim Xuan Private enterprise, Tuoi Sang Environment Co., Ltd and private recycling units. The hazardous solid waste volume is 98.252 ton per month which is collected by Green Viet Environmental Production and Trade Co., Ltd, Viet – Uc Environment Co., Tai Tien Co., Ltd., among others.

3. Transportation System

The internal road system of the industrial park run horizontal and diagonal along three main roads of the city. The ROW of the industrial park roads is as follows:

25 1. Main Industrial Park Road: Road 4D is the primary road in the industrial park (D is the code of north – south roads) ROW width: 47.00 m, double road. Carriage lane width: (3 lanes x 3.75 m/lane) x 2 + 1.5m = 24.00 m. Median: 3.00m. Sidewalk and technical corridor on each side: 10.00m. Step back on each side: 15.00m. Cross-section code No. 7 – 7. 2. Secondary Road: comprising of Roads 1N and 6D (N: east – west roads)

ROW width: 36.00 m. Carriage lane width: 20.00 m (4 lanes x 3.75 m/lane) = 15.00 m. Parking lane: 5.00 m. Sidewalk and technical corridor on each side: 8.00m. Setback on each side: 15.00 m. Road cross-section No. 4 – 4. 3. Tertiary Roads: Roads No. 3D, 5D, 7N and service road along Provincial Roads 25C and 319B.

Roads No. 3D and 5D: + ROW width: 31.00 m. + Carriage lane width: (4 lanes x 3.75 m/lane) = 15.00m. + Sidewalk and technical corridor on each side: 8.00m. + None stepback. + Road cross-section No. 5 – 5.

Road 7N:

+ ROW width: 19.50 m. + Carriage lane width: (2 lanes x 3.75 m/lane) = 7.50m. + Sidewalk on each side: 6.00m (Cross-section 6 – 6).

Service roads along PR25.C and PR319B: + ROW width: 18.50 m. + Carriage lane width: (2 lanes x 3.75 m/lane) = 7.50m. + Sidewalk on industrial land lots: 8.00m; sidewalk on PR25C and PR319B: 3.00m (Cross-section 1 – 1 and 2 – 2). The road system of the industrial park covers 12,416.94 m (rounding to 12.42 km). The primary roads, secondary and tertiary roads have been completely developed. Road area covers 36.64 ha and 1.12 ha depot, increasing the total transport land to

26 37.72ha, sharing 10.75% of the industrial park area. If one half of the primary road system of the city is included the total road area of the industrial park increases to 37.74 ha + 17.29 ha = 55.03 ha (rounding to 55ha, sharing 15.67 % (see Table of Road Inventory and Main Specifications).

4. Risk Management

The investor will take proper measures to prevent and response to environmental incidents and risks as follows

Fire and explosion

1. Fire and Explosion Prevention Workers who work directly at the construction site will be trained on fire and explosion methods. Inflammable solvents and fuel shall be stored at isolated warehouses, far from ignition sources. Provide fire and explosion prevention and fighting equipments at fuel warehouses; Provide proper fire and explosion prevention and fighting equipments in compliance with existing regulations;

Counter-measures

Follow PCCC approved methods by the PCCC

2. Chemical and Fuel Spill

1. Preparedness Departments/divisions who utilize chemical, fuel and lubricant shall be equipped with proper equipment to store clout. Annually, the team leader shall disseminate emergency preparedness and response knowledge to the team members. In every six months, the company shall formulate the emergency response rehearsal; record the rehearsal minutes of meeting properly.

2. Response The management board shall establish the emergency-aids team properly. The office staff is responsible to send the notice to all workers and staffs. Any individual who discovers the fuel/chemical spill shall report immediately to the in-charge staff of the emergency-aids team. If he could not contact with the person-in- charge he shall report to the team leader. The authorized person in each zone shall review the situation and take immediate measure. If the incident is not related to fuel/chemical spill the authorized person shall direct the site clearance properly. If it is fuel and chemical spill that affects to

27 environment or public health prompt measure shall be taken to cope with the situation and separate the site until the incident is addressed. Persons-in-charge shall minimize environmental pollution and impacts on people’s health. In case insufficient resources to address the incident, it should be reported to competent agency to get the support. When the incident is solved the authorized person shall report to EMR on solving situation. If the incident could not be solved completely and could cause pollution or people’s health, the team leader shall report to EMR and competent agencies for necessary intervention.

3. Power Shortage

1. Preparedness The company shall prepare list of electric generator leasing companies (name, address, contact number, email, etc.). Selection of a generator leasing company shall be conducted properly to select the most suitable agency. When receiving the power cut notice, the office shall confirm to the centralized wastewater treatment facility. The facility manager is responsible to hire the generator properly.

2. Response In case of sudden power cut the operator shall confirm to the facility management and contact to the generator leasing company immediately to hire the generator and operate within 6 hours. The generator shall be operated to supply power for the treatment system. The generator operation shall be in compliance with the guideline of the generator leasing company.

4. Failure of the Wastewater System

The wastewater system failures are comprised of pipe broken, flooding rainwater, etc.

1. Preparedness Proper equipment and tools shall be prepared to close the pipe broken and repair. In every six months, the company shall formulate the emergency response rehearsal; record the rehearsal minutes of meeting properly.

2. Response

In case of incident confirmation from the operation staff, cleaning team or other sources, the technical department/the centralized wastewater treatment facility shall

28 response to the incident immediately. In case of insufficient resources, it shall be reported to the manager immediately.

5. Failure of the Treatment System

1. Preparedness The treatment system manager shall assign staff to conduct the maintenance as scheduled. The operator shall prepare proper tools for repairing properly. The treatment system leader shall prepare the list of maintenance or repairing agencies adequately.

2. Response The operator or anyone who detects the failure (equipment damage, components of the treatment system, among others) shall report immediately to the repairing and maintenance manager. In the guarantee period, the manager shall contact to the guarantee agency properly. If the failure is out of the corporation control the manager shall conduct with the repairing and maintenance agencies. The repairing shall be conducted within 6 hours since the failure occurs.

Remark: In the rehearsal cases, the team leader shall evaluate the rehearsal results and requirements on activities to have experiences for the afterward turns. After every incident solving turn, the team shall address the issue properly, preventing impacts on environment.

Currently, the project owner have finished the construction of finishing ponds, with size 34m x 107.3m x 2.2m and holding a volume of 8,026 m3. This will also temporarily storing the waste water if the CETP stop working.

DESCRIPTION OF CETP OF NHON TRACH 3 IP – PHASE 2 (MODULE 2)

5. Treatment Technology, Influent and Effluent Characteristics

Based on a) the actual condition and requirement of Nhon Trach 3 IP, b) the influent characteristics, and c) the Module 1 technology for the wastewater treatment plant; Module 2 technology for Nhon Trach 3 IP CETP can be described as below:

1. The Step-By Step Processes of the Treatment Plant Preliminary and Primary Treatment: + Removal of wastewater constituents (rags, sticks, floatables, grits…). + Chemical treatment (mixing and flocculation). + Removed floating oils and greases. Secondary treatment (remove biodegradable organics):

29 + Aerobic treatment to removal biodegradable nutrients, BOD, COD. Tertiary treatment: + Advanced treatment by remove residual suspended solid and dissolved materials. + Disinfection. Sludge treatment: + Dewater and compact the dried sludge.

The more detail processes of the plant is presented in Section 1.5.2.2.

Actual Influent and the Required Effluent Characteristics The influent for CETP of Nhon Trach 3 IP – Phase 2 (Module 2) will have similar characteristics as CETP of Nhon Trach 3 IP – Phase 2 (Module 1) waste water. Based on the design, the influent characteristics of the CETP of Nhon Trach 3 IP – Phase 2 (both Module 1 and Module 2) requirements that industries have to meet through pre- treatment is:

+ Average BOD5 : ≤ 600 mg/l + Average COD : ≤ 1,000 mg/l + TSS : ≤ 300 mg/l + Colour : ≤ 100 Pt-Co + pH : not limited + Other parameters based on Regulation C of Vietnam. The effluent characteristics have to meet the national regulation QCVN 40: 2011/BTNMT, Column B, Kq=1,1; Kf=1,0

6. Characteristics of CETP and sluice-gates

Characteristics of wastewater

Wastewater profiles

Wastewaters toward the CETP of Nhon Trach 3 IP – Phase 2 is industrial and domestic wastewater which being generated by the operating facilities and workers onsite.

Influent profiles

The influent wastewater profiles of the industries within the IP are presented in table below. All of industries which connected to CEPT of Nhon Trach 3 IP – Phase 2 must send their environmental monitoring report to Nhon Trach 3 IP (1 time per three months) to prove that their waste water meet the influent standards of CEPT.

Effluent required characteristics The effluent characteristics have to meet the national regulation QCVN 40: 2011/BTNMT, Column B, Kq=1.1; Kf=1.0.

30 Assess the wastewater characteristics with available standard

As the technology from Module 2 of the CETP is similar is to Module 1, therefore the reports used the influent and the effluents waste water characteristics of Module 1 and place it against the “National regulation on industrial waste water discharge” QCVN 40:2011/BTNMT (column B) as below

Table 4: Influent and the effluents waste water characteristics of Module 1 versus the QCVN 40:2011/BTNMT

Efficiency QCVN No Parameters Units Influents Effluents (%) (***) 1 pH - 7.2 7.2 - 5.5 - 9 Colour 2 Pt-Co 31 24 22.6 165 (pH=7)

3 BOD5 mg/l 31 11 64.5 55 4 COD mg/l 80 32 60.0 110 5 TSS mg/l 58 20 65.5 165 6 As mg/l 0.038 0.034 10.5 0.011 Undetected Undetected 7 Hg (**) mg/l (LOD=0.000 - 0.55 (LOD=0.0003) 3) Undetected Undetected 8 Pb mg/l - 0.11 (LOD=0.01) (LOD=0.01) Undetected Undetected 9 Cd mg/l - 0.55 (LOD=0.005) (LOD=0.005) Undetected Undetected 10 Cr6+ mg/l - 0.11 (LOD=0.043) (LOD=0.043) Undetected Undetected 11 Cr3+ mg/l - 1.1 (LOD=0.025) (LOD=0.025) Undetected Undetected 12 Zn mg/l - 2.2 (LOD=0.1) (LOD=0.1) Undetected Undetected 13 Ni mg/l - 5.5 (LOD=0.06) (LOD=0.06) 14 Fe mg/l 0,52 0,27 48.1 3,3 Undetected Undetected 15 CN- mg/l - 0,11 (LOD=0.005) (LOD=0.005) Undetected Undetected 16 Phenol mg/l - 0,55 (LOD=0.01) (LOD=0.01) Undetected Undetected 17 Cl mg/l - 2.2 2 (LOD=0.1) (LOD=0.1) Undetected 18 S2- mg/l 0.063 96.8 0.55 (LOD=0,002)

19 N-NH3 mg/l 12.9 0.98 92.4 11 Undetected 20 TN (*) mg/l 15.7 99.9 44 (LOD=0,01) 21 TP mg/l 2.7 2.06 23.7 6,6 22 Inorganic mg/l Undetected Undetected - 11

31 Greases (*) Coliforms MPN/100 23 1400 110 92.1 5,5 (**) ml Organophos phate 24 mg/l - - - 1,1 pesticides (**) Source: Tin Nghia 05/2011.

Note: (*): parameters which has not yet acknowledged by Vilas (Bureau of Accreditation Vietnam) (**): was sampled by HCM ENTEC (***): QCVN 40:2011/BTNMT Column B Kq=1.1;Kf=1.0 LOD: Limit of Detection

As seen, many parameters of module 1 does not meet the regulation QCVN 40:2011/BTNMT column B with Kq=1.1; Kf=1.0.

Characteristics of CETP

Wastewater collection systems

All waste water from the IP is collected with a concrete drainage system, through D1.500 pipe toward the treatment plant.

From the CETP, the treated wastewater is discharged through a network of 235 m open ditches, and 524.3 m closed pipes (total length of 759.3 m).

The purpose using the 235 m open ditches is 1) To keep original landscape; 2) To monitor the storm water drainage (to avoid the industries discharge the waste water into environment .through the open ditches). .

Treatment Technology Description

The treatment technology is described in Figure below

Figure 1: CETP diagram

Technology description: Waste water from factories in industrial zones flows in the drainage system into manhole of the CEPT. Before entering the pump house, waste water is passed through the rough screen to remove the large solid residue out of the flow. From the pump house, the waste water be pumped the fine screen to remove the solid residue, which is larger than 1.5 mm, then flow into grease trap tank. In the grease trap tank, grease is removed ot of the waste water, then waste water continue flows into the equaliser tank.

32 The equaliser tank is arranged the blades system to mix the component, behaviour of the waste water to avoid the solid sedimentation, coinstantaneous, the equaliser tank is installed the add-in chemical system to neutralize the pH of waste water. From the equaliser tank, waste water continue to be led through the physical and chemical treatment systems. the wastewater will be treated with chemical through flocculation and flotation process in primary clarifier. The clarifier will separate the residue/sludge from influent, before it’s running through the aeration tank where being treated with activated sludge (aerotank). Organic substances treatment by aerotank is aerobic activated sludge suspended technology, in continuous agitation. The operating principle of the aerotank is an application of the growth of aerobic microorganisms - under the influence of supplied oxygen from the air through the aerator and plates smooth foam – it helps microorganism decompose organic matter, converting them into CO2, H2O, inorganic products and new biological cells. The wastewater after being treated with the aerobic process, will be run through the secondary clarifier. Some of the sludge from the secondary clarifier will be fed back to the aerobic tank to provide the foods and maintain the level of microorganism inside the aerobic tank. The rest of the sludge will be pumped out for dewatering and further treatment. The treated wastewater will then be pumped into disinfection tanks for disinfections and monitoring The stabilising pond acted as buffer to further treat the water before it’s released into the environment.

Characteristics of wastewater discharge

Discharge System

Technical aspects of discharge system

Industrial wastewater discharge

At the centralized wastewater treatment plant, after treated wastewater is discharged through Lo Ren canal (the regional discharge channel) through a network of open ditches B4000, and closed pipes B3000, with a total length of 759.3 m (B4000= 235 m, B3000 = 524.3 m)

Storm water drainage discharge Storm water is collected by the drainage system running along the internal roads (as mentioned previously), then is gathered and discharged through the drain pipe along D6 road. Finally the storm water is discharged through Lo Ren canal along with the treated wastewater from the treatment plant Currently all of the firms within the IP have connected their wastewater drainage system toward the IP’s centralized wastewater treatment plant; no industries have self treatment and discharged into the stormwater pipeline

33 Discharge method

As mentioned above, waste water after treatment will be flown through the open ditches B4000, then closed pipes B3000 before being directed along the upper stream of Lo Ren canal (along regional slopes toward southeast), and finally is discharged into Thi Vai River.

Discharge Schedule

The wastewater treatment plants used the combination of chemical and biological treatment methods (BNR), so wastewater treatment system is operated 24 hours a day.

Discharge flow rate

In the first 6 months of 2012, we have: Maximum discharge flow rate is 1,364 m3/day; Minimum discharge flow rate is 325 m3/day; Averaged discharge flow rate (the first 6 months of 2012) is 780 m3/day.

Sludge treatment technology On sludge treatment: sludge from primary and secondary clarifiers will be pumped out for solidified and dewatered (with mixing). Solidified and dewatered sludge are mixed with polymer before finally being compressed. This mud, and the greases from the container will be treated as hazardous wastes. Water from sludge in these processes will be pumped back and mixed with the influent.

7. Total investment and Progression pace of the Wastewater Treatment Plant

1. Project total investment

Table 5: Projected investment

Prices Costs No Items Units (VND) (VND) I. Investment before taxes 13,412,388,000 Investment before Tax 12,193,080,000 VAT 10% 1,219,308,000 1 Wastewater Pump 2 Disinfection Tank 3 Biological tank Already constructed during phase 1, 4 Sludge Tank have capacity for phase 1& 2 5 Laboratory 6 Administration Building 7 Chemical warehouse 8 Equalisation Tank 1 3,987,600,00 3,987,600,000

34 Prices Costs No Items Units (VND) (VND) 0 9 Flocculation Tank 1 23,250,000 23,250,000 10 Flotation tank 1 120,900,000 120,900,000 11 Primary Clarifier 1 447,330,000 447,330,000 12 Grease Trap 1 72,850,000 72,850,000 2,926,600,00 13 Aerobic Tank 2 5,853,200,000 0 1,687,950,00 14 Secondary Clarifier 1 1,687,950,000 0 II. Investments in machines and 7,544,863,333 equipments Equipment Investment before tax 6,858,966,667 VAT 10% 685,896,667 A. Equipments 1 Wastewater Pump 2 406,560,000 813,120,000 2 Transition wastewater pump 2 102,666,667 205,333,333 3 Blower for aerating of stabilizer 1 88,150,000 88,150,000 4 Aerating system for stabilizer 1 97,000,000 97,000,000 5 Acid, alkaline storage tanks 2 5,666,667 11,333,333 6 Acid, alkaline injectors 2 23,232,000 46,464,000 7 Mixer for flocculation tank 1 35,200,000 35,200,000 8 Mixer for flotation tank 1 68,400,000 68,400,000 Tank to mix chemicals for 9 1 5,666,667 5,666,667 flocculation Mixer to mix chemicals for 10 1 35,200,000 35,200,000 flocculation 11 Injector for flocculation 1 48,400,000 48,400,000 Tank to mix chemicals to aid 12 1 22,666,667 22,666,667 flocculation process Mixer to mix chemicals to aid 13 1 35,200,000 35,200,000 flocculation process Injector to aid flocculation 14 2 42,592,000 85,184,000 process Equipment to wipe sludge from 15 1 281,600,000 281,600,000 primary clarifier 16 Sludge pump of primary clarifier 1 64,533,333 64,533,333 Blower for aerating of aerobic 17 3 179,000,000 537,000,000 tank 18 Aerating system for aerobic tank 1 490,200,000 490,200,000 19 Nutrient mixing tank 1 5,666,667 5,666,667 20 Nutrient mixer 1 35,200,000 35,200,000 21 Nutrient pump 1 23,232,000 23,232,000 Equipment to wipe sludge from 22 1 354,666,667 354,666,667 secondary clarifier

35 Prices Costs No Items Units (VND) (VND) Cycling sludge pump of 23 3 82,133,333 246,400,000 secondary clarifier Sludge pump for treatment of 24 2 67,466,667 134,933,333 secondary clarifier B. Pipes, walking platform 1,066,666,66 33 Pipelines 1 1,066,666,667 7 34 Ladders, walking platform 1 70,000,000 70,000,000 C. Monitoring equipments 35 Automatic pH monitoring 1 55,100,000 55,100,000 36 DO measurer 1 62,700,000 62,700,000 Flow rate measurer using 37 1 104,500,000 104,500,000 ultrasonic waves 38 Water level switch 3 5,700,000 17,100,000 1,336,000,00 D. Electrical system 1 1,336,000,000 0 E. Automatic control system 39 PLC 1 332,500,000 332,500,000 Total 20,957,251,333 Other 2,095,725,133 TOTAL INVESTMENT 23,052,976,467

The above cost does not include costs from administration, technology transferring, and interest rates

Operating costs of the CETP

Due to the CETP of Nhon Trach 3 IP – Phase 2 (Module 2) similar to Module 1, The operating cost of the CETP Module 2 also the same with Module 1. The operating cost of the CETP Module 1 to treat 1 m3 can be calculated based on daily costs divide to the plant treatment capacity. These costs based on CETP running with the real data in the first 6 months of 2012.

Table 6: Daily operating cost

No Items Cost (VND/day) 1 Operating labour costs 1,160,493 2 CETP amortisation 3,486,257 3 Chemicals 683,030 4 PTN Chmicals 40,920 5 Power 1,764,112 6 Sludge treatment 5,880,000 7 Domestic water 140,936

36 No Items Cost (VND/day) 8 Maintenance costs 150,000 Total 13,305,749

Considering the CETP treatment rate is 2,000 m3/day, the treatment cost for each m3 of treated waste water will be 6,653 VND.

Operation schedule of CETP

June to August 2012: finish legal documents August to December 2012: start the construction January 2013: implement machineries, equipments February 2013: pilot run March- April 2013: technology transfer, take over and transfer

Pictures of the CETP Module 1:

Figure 2: Wastewater pump

37 Figure 3: treatment tanks

Figure 4: Finishing pond

Figure 5: Automatic effluent quality monitor

38 Figure 6: Sludge treatment

Figure 7: Labs in CETP environmental department

39 2. CHARACTERISTICS OF THE PROJECT AREA

2. GENERAL CHARACTERISTICS OF PROJECT AREA

Geography and Climate

Geography

Based on planning land use for Long tho Commune :  63.51% of the commune is located on top of the alluvial deposit, with an area of 1,541.81 ha  29.10% of the commune is located on top of marine sediment rocks, with an area of 706.53 ha

The basic geography is divided in these 3 categories : High terrains: toward the West of the Districts, along the 319 road toward Provincial War Memorial. 3 – 80 slope with solid foundation, suitable for planting long-growth plants such as rubber, fruit frees, cashew nut, or constructing industrial zones Medium terrains: toward the East of Road 19, the transition zone between the hills and mangrove areas, <30 slopes. Suitable for residential areas, garden and rice farming Is affected by tides, and have weak foundations for construction. Suitable for mangroves or agricultural farming. In general the terrain slop toward South West, with the highest terrain in North East 50-55m, while the low land in South West, 5-10 m

Climate

The high temperatures around the years are suitable for plant growing and farming The average annual temperature is 270C, highest at April with 27.30 – 30.7˚C, and lowest at December at 24.80C. Max recorded temperature is 380C while min is 180C. The variety of temperatures during wet season is 5.5 - 80C, and dry season is 5 - 120C. The humidity around the year is around 78 – 81.4%, with 85 – 93% during rainy season, and 68 - 83% during dry season. Peak humidity at 95% and lowest at 50% Rainfall is from 1,800 to 2,300 mm annually. Rainfall is not distributed evenly with really high rainfall during August, September, October, some month even reach 500 mm per month. The dry season from November to April only have 10% of the whole year rainfall, with months like February may not even have rain. Due to the geography, the regional agriculture depends almost on rain, with vegetables farming on the hill and 1-2 rice farming seasons a year Wind direction: have two main wind directions separate by seasons. During rain season, the wind flow toward South West, during dry season, wind flow North East- ward. There are some transition periods where winds blow East or South East. Wind speed is around 2.1-2.5 m/s, and peak at 25 m/s. The region is affected little by storms

40 The statistics in 5 years below includes: temperatures and humidity (from Bien Hoa station), rainfall (from Long thanh Station) Average temperature through the year in Dong Nai is in table below.

Table 7: Monthly temperature from 2007 to 2011 – Dong nai province Unit: 0C 2007 2008 2009 2010 2011 Annual average 26.9 26.7 26.8 27.9 27.5 January 25.2 25.8 25.0 26.5 26.1 February 26.6 25.0 26.4 27.8 27.0 March 28.1 27.2 28.8 28.9 27.6 April 29.0 28.5 27.5 29.9 28.5 May 28.6 27.3 29.0 30.7 28.7 June 27.3 29.1 28.4 28.5 28.0 July 26.9 27.6 26.0 27.5 27.5 August 26.7 26.7 27.2 27.6 27.9 September 26.7 25.7 26.4 27.9 27.5 October 26.3 27.0 27.3 26.9 27.3 November 25.9 25.9 26.2 26.7 27.6 December 25.0 25.3 24.8 26.6 26.5 Source: Hydrometeorology Division of South East Vietnam

Humidity:

Table 8: Monthly humidity from 2007 to 2011 – Dong nai province Unit: % 2007 2008 2009 2010 2011 Annual average 81 79.8 81.4 78 78 January 71 74.5 75 74 75 February 68 71.7 80 70 70 March 74 71.0 76 69 71 April 72 73.1 83 70 73 May 84 78.6 79 72 79 June 86 83.7 81 81 80 July 88 84.7 84 85 83 August 87 85.3 86 83 82 September 88 85.9 87 83 86

41 October 88 86.2 88 85 85 November 83 83.5 80 83 81 December 78 79.0 78 79 76 Source: Hydrometeorology Division of South East Vietnam Rainfall

Table 9: Average annual rainfall Dong Nai Unit: mm 2007 2008 2009 2010 2011 Annual rainfall 2,335 2,080 1,993 1,957 2,0179 January 13.0 8.1 14.0 26.3 10.2 February 4.7 8.4 5.5 0.0 0 March 70.6 12.5 13.9 13.5 54.2 April 59.6 72.9 60.9 8.8 35.5 May 280.3 382.3 211.3 128.5 289.5 June 270.3 162.1 282.6 165.7 271.5 July 366.1 336.9 323.0 338.2 414.5 August 349.0 266.7 297.3 261.2 219.0 September 450.0 433.8 352.3 157.3 407.0 October 260.5 211.0 280.0 504.3 250.7 November 205.3 160.0 109.0 293.7 201.7 December 5.6 25.4 42.9 59.2 25.6 Source: Hydrometeorology Division of South East Vietnam

Surface water

Wastewater from Nhon Trach IP – Module 2 will be discharged through Lo Ren Discharge point, into Mareng Canal, before finally being discharged into Thi Vai River. At Rach Mieu Section, the Ma reng flowrate is <2 m3/s during dry season, and <10 m3/s during wet/rain season.

River and Open Water Network

Thi Vai River is the wastewater receiving body for all of Nhon Trach 3’s wastewater. The river has a length of 76 km, start from Long Thanh Commune toward Chau thanh, before meet the South China Sea at Rach Gai Bay. Downstream, the river joins with Saigon- Dong Nai at some sections. The average river width is 400 – 650 m, depth at 22 m, with the lowest depth at 60 m.

42 River flowrate mixed with flood is peaked at 3,400 m3/s, with river with tide reverse flow peaked with tide at 2,300 m3/s. River flowrate during wet season is around 350 – 400 m3/s and during dry season is around 200 m3/s. The minimum recorded flowrate is 40 – 50 m3/s. The highest river speed could reach 1.5 m/s. Thi Vai River based on Dong nai Province planned landuse, is for aquaculture farming.

Tides: rise at 4-9 am, and 4-11 pm. The tide falls from 9am-4 pm and 11pm-4am. Thi Vai River is heavily affected by tide, and shows sign of being heavily polluted. The project location is 24 m above Thi vai River level, hence won’t be affected by tide

1. Socio-economic Conditions

1. Existing Socio-economic Conditions

According to the report on socio-economic development and public security and defense, year 2011 of Long tho commune, the socio-economic conditions are summarized as follows:

1. Agriculture Total cultivation land area was 270 ha, including: + Rice land: 95/90 ha, equally to 1065 of the planned target. The yield is 3.5 tons to 4.5 tons per ha. Various anti-pesticide rice species were introduced, including OM4900, OM6162, MTL 110, and Bac Thom… + Vegetable land: 155/150 ha, equally to 103% of the planned target due to expansion of vegetable land along Cau Mit canal. The productivity is 30 tons to 40 tons, generating stable income of 25 to 35 million VND per ha, minus the investment cost. + Cassava: reduces to 20 ha comparing to 30 ha planned, equally to 67%, mainly on the planned land of committed projects. Agricultural promotion: VNd 80 million was invested to develop 2,000 m2 vegetable land but the efficiency is not high due to lack of in-glass door vegetable nurturing experience. The Economy Department is introducing a new model. 7 excellent farmers are trained on vegetable cultivation at the provincial agricultural promotion center. Training course was hold at cooperative teams, attracting 30 trainees. Husbandry: The livestock herd is reducing due to narrowing glass land. There were 480 cow heads, reducing 50 heads comparing to that of 2010. The buffalo drove had 50 heads while the pig flock has 1,570 heads. The chicken and duck herd has 1,500 heads at household-scale. Aquaculture: 45 ha intensive shrimp rearing land was closed due to epidemic disease of 45-year young shrimp.

2. Trade and Service

So far, the commune has 296 business households in food processing, trading, food supply, accommodation services, internet service, increasing 24 households comparing to that of previous year. 161 households registered to tax department, increasing 71

43 households comparing to that of previous year. The accommodation leasing household number increases 22 households, increasing to 104 households with 1,346 rooms.

Businesses households at Long tho market were registered but the business is not stable. 161 households registered at the tax office, increasing 71 households comparing to that of previous year. 89 households were classified as low-income ones.

3. Education and Training School Year 2011 – 2012: 63 kindergarteners; and 412 preschoolers. Total student number is 556 students comparing to the target of 520 students, increasing 7%. Teaching methodology and vocational training are strengthened. The educational environment is improved to raise the teaching quality.

2. Economic Development Plan of the Wastewater Receiving Zone

Nhon Trach District Socio-economic Development Plan in 2006-2020 sets the socio- economic and environment development targets as follows: 2006-2010 Period: the average economic growth rate target is 16.4% per year, of which, the growth rate of industry, agriculture and service sectors are 17-17.5%, 4% and 24-25%, respectively. Those of 2011-2015 period are 15.5%, 15-15.5%, 3%, and 20-21%. 2016-2020 period targets are 14.5%, 13-13.5%, 1.5% and 18-19%, respectively. Natural population growth rate shall be controlled at less than 1.1% by 2010 and shall be maintained in the period up to 2020. Poverty household rate shall be reduced to fewer than 2% by 2010 and basically cleared in 2011-2015 period. High secondary school universalize shall be completed in 2010. Increase vocational training labor ratio to 30%, 60% and 80% by 2010, 2015 and 2020, respectively. Urban unemployment ratio shall be controlled at fewer than 3% in the period to 2020. Under-5-year old malnutrition ratio shall be reduced to 13%, 8% and 3% by 2010, 2015 and 2020, respectively. Power supply coverage shall be increased to 95% by 2010 and 100% in 2011-2015 period. . Clean water accessing ratio shall grow up to 95% in 2010 and 100% in 2011-2015 period. Forest and greenery tree coverage shall be expanded to 25%, 29% and 32% in 2010, 2015 and 2020 respectively. Collected non-hazardous industrial solid waste, and urban waste shall be 75% by 2010 and 100% in 2011-2015 period. Over 85% hazardous waste shall be collected and treated properly by 2010 and expanded to 100% in 2011-2015 period. Water environment pollution prevention: the centralized wastewater treatment system shall be developed at 100%W industrial parks by 2010; 70% urban wastewater is

44 collected to the centralized treatment system in 2010-2015 period and this number will increase to 100% in 2016-2020.

Decision No. 284/2006/QD-TTg dated December 21, 2006 of the Prime Minister approved the adjustment of Nhon Trach new town construction plan to 2020 sets Nhon Trach district development orientations as follows: To be one of industrial, trade-service, tourism, education and training and science and technology centers of Dong Nai province as well as Southern Focal Economic Zone, meeting urban category II standard; To be a key transport hub of the southern focal economic zone; Play a significant role in public security and defense of the southern focal economic zone . Population: Forecast by 2010: 265,000 people, of which, urban population is 150,000 people; Forecast by 2020: 600,000 people, of which, urban population is 450,000 people.

Construction Land Availability By 2010: the urban construction land will cover 10,000 ha, of which, the civil land will be 4,200 ha or 160 m2/capita; By 2020: the urban construction land will be expanded to 22,700 ha, of which, the civil land will be 9,200 ha or 155 m2/capita.

* Urban Spatial and Architecture Development Directions:

Urban Development Direction: the urban development is promoted in the zone surrounded by Road 25° and District 19, Dong Nai and Long Tau riverside zones connecting to District 2 and District 9 of Ho Chi Minh City, specifically as follows: Existing District Urban Center: develop compact urban centers, urban center, trade and service centers; Northwest side along Dong Nai River: develop urban and tourism center, university center; Southwest side: develop urban centers, rural residential centers, port and port- integrated industries along Long Tau River; Eastern side: develop industrial parks and rural residential centers; Southern and southeast side along Dong Tranh River, Thi Vai River adjoining to Can Gio district (Ho Chi Minh City) and Phu My new town (Ba Ria – Vung Tau): the submerged forest preserve zone.

Technical Infrastructure Development Orientations: a) Transport Primary Indicators:

45 + Transport land: 2,430 ha, including 1,030 ha urban transport land. + Urban transport land ratio: 11.2%, of which, traffic facilities land shares 1.7%. + Primary urban road density: 2.5 - 3 km/km2; + Urban transport land per capita: 22.8 m2/capita. b) Sewage and Environmental Sanitation: Indicators: the domestic wastewater volume is equally to 80% of supplied water; the industrial wastewater is 40 m3/ha; Domestic wastewater: + Total domestic wastewater volume will grow up to 80,000 m3/day by 2020; + Total industrial wastewater volume will be 144,000 m3/day; + Central center: to collect wastewater to a treatment facility at Phuoc An commune with capacity of 65,000 m3/day; the treated wastewater is discharged to Bau Bong stream, flowing to Ba Hao River. + Long Tho commune, Dong Mua Rua zone: the wastewater is transferred to a pumping station with capacity of 5,000 m3/day near the ring road to pump the water to the treatment facility Number 1; + Long Tan and Phu Hoi communes: the wastewater is collected to the second wastewater treatment facility at Dong Nai River spanning bridge foundation with capacity of 5,000 m3/day; + Hiep Phuoc commune: the wastewater is collected to the third treatment facility at northern urban residential center with capacity of 5,000 m3/day; the treated wastewater is discharged to Ba Ky canal; + Dai Phuoc commune and a part of Vinh thanh commune adjoining to Ong Keo canal: the wastewater is collected to the fourth treatment facility near Cau Trai River with capacity of 4,000 m3/day; + Other basins besides Ong Keo canal in Phu Huu commune and Phuoc Khanh commune, and the zone outside Dong Mon River in Phuoc Thien commune: local treatment. Industrial wastewater: + Industrial wastewater of plants and industries inner the urban area shall be processed meeting the limit B prior discharge to the urban sewage system. The centralized treatment system shall be developed at industrial parks. The wastewater shall be treated at the discharge source prior transferring to the centralized treatment system. The wastewater shall be treated at the centralized system meeting limit A to discharge into the environment; + Hospital waste shall be treated and pasteurized to discharge into the urban sewage system. Urban Sanitation: + Domestic Solid Waste: A domestic solid waste disposal site, covering 10 ha shall be developed in short-term at Dong Mu Rua zone, Phuoc An commune, outside inner ring

46 road. A provincial landfill is planned at Bau can commune, Long Thanh district, covering 100 ha. Hazardous solid waste shall be collected to Giang Dien landfill. + Cemetery: In the short term, a cemetery in Long Tho commune, covering 20 ha could meet the current cemetery requirement. In the future, the cemetery shall be developed far from the urban center 20 - 30 km;

Environment and Water Landscape Preservation: To control the domestic and industrial wastewater strictly To grow tree and protect greenery buffer zones along the river and canals, forming open space for new towns To control ecotourism development along rivers and on islands.

Initial Construction Development Plan and Prioritized Projects: To develop technical infrastructure of Nhon Trach industrial park which is 2,700 ha area To develop urban housing and public utilities To develop specific centers: education, sport, healthcare and trading centers To develop tourism centers, parks, especially along Dong Nai, Dong Mon, Nha Be and Cai Rivers.

3. CHARACTERISTICS OF RECEIVING WATERS

1. Discharge location

Wastewater after being treated is directed through Lo Ren canal, and then continues flowing into Ma Reng canal and its sub-canals, before being discharged into the upstream section of Thi Vai River (the section along Long Tho commune, Nhon Trach, Dong Nai)

The discharge point of Lo Ren Canal (near Lo Ren Bridge) is coordinated At (VN2000 coordinate system): + X: 1.184.745 m. + Y: 413.438 m. The location of receiving waters with nearby area is shown in appendix.

LOCATION OF RECEIVING WATERS

47 Open ditch for treated wastewater from treatment Open ditch, to collect stormwater plant andstorm water

The connection point between the above Lò Rèn discharge point before being discharged open ditch and closed culvets into the environment

Mareng Canal – taken from the middle Lo Ren Canal – section under Lo Ren Bridge of canal

48 THI VAI RIVER

Thi Vai River – the intersection with other Thi Vai River – section running streams within the border of Long Tho through Long Tho Commune Commune

Figure 8: Pictures of the site

Local Environment Status

2. Description Of All Discharge Sources With Same Final Discharge Receiving Body

The discharge sources are listed below in order of their location along the discharge network: upper Lo Ren Canal, lower Lo Ren Canal (downstream of project discharge point), and then the section along Thi Vai River (near Long Tho Commune).

Table 10: List of all wastewater discharge sources in vicinity of Nhon Trach 3 IP

Discharge rate No Wastewater Source Discharge point Receive body (m3/day) I Industrial sources 20,500 Mareng and Formosa Limited 1 5,000 Lo Ren Lo Ren Liability Company Canals Upstream of Rach Rach Mieu 2 Nhon Trach 2 IP 12,000 Mieu Upper stream of Thi vai River Thi Vai before (upper stream joined by Ma along Long 3 Nhon Trach 1 IP 3,500 Reng Canal, and Tho 100m downstream Commune) of discharge point

II Agricultural sources 7,043,760 – 9,391,680

49 Discharge rate No Wastewater Source Discharge point Receive body (m3/day) m3/farming season Wastewater from shrimp farming in Long 9,000 – 12,000 1 Thi vai River Thi vai River Thanh and Nhon Trach m3/ha District III Domestic 1,467 – 1,956 Domestic wastewater Mareng and from Long tho Lo Ren 1 536 – 715 Lo Ren Commune, Nhon Trach Canals District

Domestic wastewater Upper stream of Thi vai River from Hiep Phuoc Thi Vai before (upper stream District, after mixing joined by Ma along Long 2 930 – 1,240 with surface water of Reng Canal, and Tho Rach Mieu, Ba Ky and 100m downstream Commune) Ma Reng Canals of discharge point.

Industrial Sources

Wastewater after treatment of Nhon Trach 3 IP is directed into Lo Ren Canal, then mixed with wastewater from Formosa section of Industrial Park and the Long Tho Commune (Hiep Phuoc). This continues to flow southeast down the slope across terrain, receiving wastewater from residential areas along the canal, before running through Ma Reng Canals and finally being discharged into upper Thi Vai.

Agricultural Sources

In addition to industrial wastewater, the regional agricultural activities also contribute significant amounts of discharges into the Thi Vai River. Currently the main agriculture activities here are quite diverse: fishing, animal livestock, horticulture…. But the majority of wastewater is still generated by aquaculture activities (farming black tiger shrimp, white shrimp, and other types of fishes). The farming areas are distributed across Long Phuoc, Phuoc Thai Communes (Long Thanh - Dong Nai), Long Tho and Phuoc An Communes (Nhon Trach - Dong Nai) and My Xuan commune, Phu My town (Tan Thanh, Ba Ria - Vung Tau). This type of wastewater from shrimp farming arises mainly after the shrimps were harvested. As the farmers live on both sides of river banks often works in small scale/ household business (about 1-2 ha in farming area), they simply can’t afford an appropriate treatment system for these wastewater. The wastewater from shrimp farming, include ponds water with food scraps, wastes, and used biotic; is currently being discharged directly into the Thi Vai River without treatment.

50 According to survey data of Le Van Thu - Project "Investigation and proposing solutions for the development and protection of mangrove ecosystems in Long Thanh -Nhon Trach" in 2005; the mangroves areas in two districts of Long Thanh and Nhon Trach, have a total area of shrimp farming is 782.64 ha. This generate an amount of wastewater approximate 9000-12000 m3/ha. In another words, the total volume of wastewater from aquaculture activities discharged into Thi Vai river is estimated at 7,043,760 to 9,391,680 m3/farming season (or 58,698 to 93,917 m3/day due to a 100- 120 days/farming season). However, most of these wastewater is discharged only after being harvested (after around 3-4 months) so there is always a concentrated amount of discharge by the end of this period rather than distributed evenly into daily.

Domestic Uses Sources

In addition to the industrial and agricultural wastewater, the wastewater from nearby residential areas also should be mentioned. The demographic of those residential areas: Long Phuoc and Phuoc Thai Communes (Long Thanh - Dong Nai Districts ), Hiep Phuoc, Long Tho and Phuoc An Communes (Nhon Trach -Dong Nai Districts), in addition to Xuan My Commune and Phu My town (Tan Thanh district, Ba Ria-Vung Tau District) are as follows.

Table 11: The demographic of nearby residential areas to Thi Vai river

No Residential Area Population

Long Phuoc 1 10,402 Long Thanh District – Dong Nai Commune Province Phuoc Thai 2 13,105 Commune

Hiep Phuoc 3 10,338 Commune

Nhon Trach District – Dong Nai Long Tho 4 5,959 Province Commune

Phuoc An 5 6,547 Commune

6 Tan Thanh District, Ba Ria- My Xuan Commune 12,383 7 Vung Tau province Phu My Town 8,797

Total 67,531

Standard wastewater discharge per capital of households with sewer system, but without bathroom is ranged from 90-120 liters/capital/day (Nguyen Trung Viet, 2005). If apply that to the residents along Thi Vai River with a population of 67,531 residents, the daily discharged wastewater can be estimated at 6078-8104 m3.

51 However, at present, these residential areas still either does not connect to public sewer systems, or connect to an incomplete system. This means the majority of these domestic wastewaters are still left to run-off and eventually infiltrate into the grounds. That’s why the amount of discharged wastewater directly into Thi Vai River from this source can be considered negligible.

3. Nearby Water Supply Intake (within 3 km downstream)

The water quality of nearby open water source is much lower than the requirement for water supply source (mostly due to salinity) . Therefore the main use of them is for river transportation and aquaculture.

Along the Mareng and Lo ren, there is no water supply intake structure. Only the residents lives near the meet between Mareng and Thi vai working in fishing, and no river water was used for farming .

3km downstream of Thi Vai (from Mareng discharge point), there’s also no river water intake sites, even for industrial or aquaculture purposes.

4. CURRENT ENVIRONMENT STATUS

The environmental statistics of Nhon Trach 3 IP for Phase 2 was monitored by Tin Nghia Company every 6 months. The results of 12/2011 can be summarized as below.

1. Atmosphere Status

1. Location of samples

Table 12: Location of atmosphere quality testing is as below

No Samples Location 1 K1 In front of DerFul Co Limited 2 K2 In front of Sinpoong Vina Company 3 K3 Near Velco Company 4 K4 Near Viet Long Company 5 K5 Near Bueno Co Limited 6 K6 Near Kirby SEA company 7 K7 Near CSB battery Vietnam Company

2. Sampling and analyzing methods

Table 13: Sampling and analyzing methods

No Parameters Sampling methods 1 Noise TCVN 5964 : 1999

2 NO2 TCVN 6137 : 2009

3 SO2 TCVN 5971 : 1995

52 4 CO 52 TCN 352 - 89 5 Suspended dusts (*) TCVN 5067 : 1995 6 THC TCVN 7558-1:2005 7 Formaldehyde General method Note:(*): parameter accepted by Vilas

3. Results

Table 14: Results of Nhon Trach 3 – Phase 2 air quality

Noise Dusts NOx SO2 CO HC HCHO Samples s dBA mg/m3 K1 58.5 152.6 17.4 13.2 2461 UD UD K2 59.1 110.0 18.4 12.6 2280 UD UD K3 58.3 120.4 20.8 16.0 2931 UD 0.96 K4 59.5 120.5 18.4 16.8 1628 UD UD K5 63.1 146.4 12.8 12.2 1791 UD UD K6 59.1 112.0 20.2 16.5 2605 UD UD K7 54.7 155.2 21.1 18.7 2280 UD 1,3 QCVN 70 5,000 20 05:2009/BTNM 300 200 350 30,000 (*) (**) (**) T Source: Environment Technology and management Centre, 11/2011.

Notes UD: undetected QCVN 05:2009/BTNMT: Air quality, surrounding air quality (*) QCVN 26:2010/BTNMT: National regulation on noises (**) QCVN 06:2009/BTNMT: National regulation on hazardous air emission in surrounding air

Comments The analysed results showed all parameters met QCVN 05:2009/BTNMT, QCVN 26:2010/BTNMT, and QCVN 06:2009/BTNMT

2. Water Quality Status

Results of the sampling of water supply sources can be presented in table below:

Table 15: Tap Water quality

53 QCVN N Parameters Units Sampling Methods Results 01:2009/BY o T 1 pH - TCVN 6492:1999 7.24 6.5 – 8.5 2 Colour Pt Photometry 0.00 ≤15.0 No No offensive 3 Odour - Smelling offensive smell smell 4 Turbidity NTU Photometry 0.07 ≤2.0 5 Hardness mg/l SMEWW – 2340 C 58.0 ≤300 6 Chloride (Cl-) mg/l SMWW4500 – Cl- B 2.50 ≤250 Can’t be 7 Permanganate mg/l TCVN 1686 : 1996 ≤2.0 Detected US – EPA 1997 – 12.47 8 Sulfate mg/l ≤250 375,4 9 Iron mg/l SMEWW 3500Fe B 0.02 ≤0.3 1 0.02 Manganese mg/l AAS ≤0.3 0

1 - 0.009 Nitrite (NO2 ) mg/l TCVN 1678:1996 ≤3.0 1

1 - 2.03 Nitrate (NO3 ) mg/l TCVN 1680:1996 ≤50 2 1 0.33 Chloride residue mg/l RC Mater 0.3 -0.5 3 1 Total Coliforms / ISO 9308 – 2: 2000 0/100ml CFU 0 4 100ml (E) 1 ISO 9308 – 2: 2000 0/100ml E. coli/100ml CFU 0 5 (E) Can’t be 1 As (*) mg/l TCVN 4571 - 1988 Detected 0.01 6 (<35x10-4) Can’t be 1 Cd (*) mg/l TCVN 6197 - 1996 Detected 0.003 7 (<35x10-4) Can’t be 1 Pb (*) mg/l TCVN 4573 - 1988 Detected 0.01 8 (<35x10-4) Can’t be 1 Hg (*) mg/l TCVN 5991 - 1988 Detected 0.001 9 (<35x10-4)

54 QCVN N Parameters Units Sampling Methods Results 01:2009/BY o T 2 SMEWW 4500–Norg KPH Ammonia (*) mg/l 3 0 B (<35x10-4) (Source: Dong Nai Department of Health, 08/2011)

Note (*) From Center of environmental and labour health in 11/2011. QCVN 01:2009/BYT – National regulation on portable water

Comments

The results showed that water supply sources in Nhon Trach 3 IP met all of the required regulation in QCVN 01:2009/BYT.

1. Surface Water Quality

1. Sampling locations

Table 16: Locations of Surface water Sample

55 No Sample Location 1 NM1 Mareng Canal On Thi Vai River, 500m upstream from the join with Mareng NM2 2 canal during high tide On Thi Vai River, 500m upstream from the join with Mareng NM3 3 canal during low tide On Thi Vai River, 500m downstream from the join with Mareng 4 NM4 canal during high tide On Thi Vai River, 500m downstream from the join with Mareng 5 NM5 canal during low tide

- The sample is taken 20 cm below the surface specialized scoops

2. Sampling and analyzing method

The sampling method for surface water in Ma Reng Canal, Thi Vai River is presented in thetable below:

Table 17: The sampling method for surface water

No Parameters Methods 1 pH TCVN 6492: 1999 2 DO Hanna 9142 Equipment

3 BOD5 SMEWW 5210 B 4 COD SMEWW 5220 C 5 TSS SMEWW 2540 D 6 As ASTM D 2972-08 7 Hg ASTM D 3223-02 8 Pb Hach - 8033 9 Cd Hach - 8017 10 TN TCVN 6638:2000 11 TP Hach – 8190 12 Oil and Greases SMEWW 5520 B

56 Table 18: Surface water quality

Parameter QCVN 08:2008, No Units NM1 NM2 NM3 NM4 NM5 s Column B1 1 pH - 6.8 6.7 6.8 6.8 6.8 5.5 - 9 2 DO (*) mg /l 4.1 6.1 6 5.8 5.6 >4

3 BOD5 mg /l 6 3 4 3 4 15 4 COD mg /l 35 25 28 28 32 30 5 TSS mg /l 30 22 25 26 27 50 6 As (**) mg /l 0.044 0.115 0.052 0.028 0.032 0.05 Undete Undetected Undetected Undetected cted 7 Hg (**) mg /l Undetected (LOD=0.0003) (LOD=0.000 (LOD=0.000 (LOD=0.0003 0.001 (LOD= 3) 3) ) 0.0003) Undete Undetected Undetected cted Undetected 8 Pb mg /l Undetected (LOD=0.01) 0.05 (LOD=0.01) (LOD=0.01) (LOD= (LOD=0.01) 0.01) Undete Undetected Undetected cted Undetected 9 Cd mg /l Undetected (LOD=0.005) (LOD=0.005 (LOD=0.005 0.01 (LOD= (LOD=0.005) ) ) 0.005) Undete 10 TN (*) mg /l Undetected Undetected Undetected Undetected 0.5 cted

11 TP mg /l 0.2 0.16 0.2 0.1 0.13 0.3

Oil and Undete 12 mg /l Undetected Undetected Undetected Undetected 0.1 Greases (*) cted

57 (*) : Parameters not yet certified by Vilas. (**): by ENTEC; LOD: limit of Detection

58 Note

 Samples from Sonadezi Company collect and analyse in 5/2012

 QCVN 08:2008/BTNMT – National regulation on surface water, column B1: Use for irrigation and industrial uses.

Comments

Compare the sampling results against QCVN 08:2008/BTNMT, Column B1 showed: COD of 2 samples NM1, NM5 over the regulation from 1.17 times;

TSS, BOD5 and other parameters of all 5 samples meet the regulation

2. Groundwater quality

Currently there’s no groundwater intake structure within Nhon Trach 3 IP, so the up to date statistics will be updated in the next EIA report. Below is the underground water quality as measured in April 2006.

Table 19: Groundwater quality of Nhon Trach 3 IP (Sampling date: 17/04/2006). QCVN Parameters Units N1 N2 N3 N4 09:2008 pH - 4.93 5.70 5.1 4.86 5.5–8.5 TDS mg/l 36 29 37 29 1,500 Hardness mg/l 20.8 18.2 21.2 19.3 500 Chloride mg/l 28.2 26.8 27.4 25.8 250 Fluoride mg/l UD UD UD UD 1.0 - N-NO3 mg/l 4.2 3.8 3.9 4.1 15 Total Fe mg/l 0.04 0,04 0.05 0.04 5 Mn mg/l UD UD UD UD 0.5 Sulfate mg/l 2.84 2.65 2.55 2.78 400 Lead mg/l UD UD UD UD 0.01 Hg mg/l UD UD UD UD 0.001 Zinc mg/l UD UD UD UD 3,0 Oils and greases mg/l UD UD UD UD - Pesticide chemicals mg/l UD UD UD UD - E.Coli MPN/100ml 3 2 3 2 UD Coliform MPN/100ml 12 10 12 10 3 Source: Nhon Trach 3 – Module 2 ‘s EIA report 2006

Notes : QCVN 09:2008/BTNMT: National regulations about underground water quality; UD : Undetected " – ": Not regulated

59 Sampling locations: N1: Samples from Mr. Tong’s farm. N2: Samples from Nhon Trach water supply plant. N3: Samples from wells of Lo Ren residential area. N4: Samples from well in 319B road.

Comments:. Comparing the results with QCVN 09:2008/BTNMT showed that the groundwater quality onsite have high E. Coli and Coliform (2-4 times higher than regulation) while all of the well samples have lower pH than the regulation (due to alum or salinity). Since local residents are extracting groundwater, the IZ will be periodically measuring groundwater at nearby sites.

3. Soil Status

The soil status within the project site can be presented in table below

Table 20: Soil quality in Nhon Trach 3 IP – Phase 2

Results QCVN No Parameters Unit D1 D2 D3 D4 03:2008/BTNMT 1 As mg/K 2.27 3.98 3.19 5.37 12 g 2 Cd mg/K UD UD 1.23 0.87 10 g (<0.2) (<0.2) 3 Cu mg/K 8.15 8.59 7.74 5.12 100 g 4 Pb mg/K 21.72 20.22 24.71 23.71 300 g 5 Zn mg/K 25.71 30.95 23.96 34.7 300 g Source: Tin Nghia

Note: D1: 100 m from head of project site; D2: Next to the surrounding walls of Y.S.P Company; D3: End of the project site, 100 m away from road 8; D4: Project site toward N2 Road. UD: undetected

Based on the results comparing to the national regulations on heavy metals in soils, we can see that the soils here are not polluted

60 4. Surrounding Deposit Status

Sludge quality from treatment plant

Sludge sample from B10 tank of the CETP was analysed by Hai Dang Company in 1/2011. He results are presented as below:

Table 21: Results of the sludge sampling

QCVN Parameter No Units Sampling method Results 07:2009/BTNM s T 1 pH - TCVN 5979 – 2007 6.50 - 2 As mg/kg TK TCVN 6496 – 2009 4.12 2.0 3 Cd mg/kg TCVN 6496 – 2009 0.40 0.5 4 Ni mg/kg TCVN 6496 – 2009 0.25 70 5 Pb mg/kg TCVN 6496 – 2009 2139.9 15 6 Hg mg/kg TK TCVN 6496 – 2009 0.61 0.2 7 Cr mg/kg TCVN 6496 – 2009 101.59 5.0 8 Zn mg/kg TCVN 6496 – 2009 522.04 250 9 CN- mg/kg TK TCVN 6181 – 1996 <0.05 - 10 Phenol µg/kg KTSK 21 – GC/MS 1.71 1,000 Sources: Sludge sample from Hai Dang Company, under no 11010211/KQ in 7th Jan 2011

Notes : QCVN 07:2009/BTNMT: national regulation on hazardous wastes

Comments:

The analysed results against Regulation QCVN 07:2009/BTNMT showed heavy metal parameters such as As, Pb, Cr and Zn are all over the regulation. This mean, the sludge from Nhon Trach IP treatment plant will be classified as hazardous waste.

1. Thi Vai River bed sediments

The sampling results of the sediments/ sludge from Thi Vai riverbed can be presented in below table:

Table 22: The sampling results of the sediments underneath Thi Vai river

61 QCVN No Parameters Units Methods Results 03:2008/BTNM T 1 Asen (As) ppm MOSA 23- 3 As 18.7 12 2 Cadmium (Cd) ppm TCVN 6496 - 2009 1.64 2 3 Mercury (Hg) ppm MOSA 23- 3 Hg 0.02 - 4 Lead (Pb) ppm TCVN 6496 - 2009 12.73 70 5 Total oil and ppm TCVN 7369 - 2004 105 - greases

Note Samples from Environmental Technology Advising & Labour Health and Safety Center 11/2011. QCVN 03:2008/BTNMT – National regulation on heavy metal in soils “-”: Not regulated

Comments

Due to the lack of national regulation on river sediments, the project used QCVN 03:2008/BTNMT – national regulation on heavy metal in soils instead. The results showed mostly meet the standard, except the level of As is 1.6 times higher than the required standard.

5. Ecological Environment

1. Flora

1. Long Thanh – Nhon Trach Mangrove Forest

Long Thanh – Nhon Trach mangrove forest is distributed along two banks of Thi Vai River where there are lots of habitat of typical floral species of the mangrove forest, playing significant role in maintaining eco-balance in the area. There are total 261 floral species of 61 families and 184 branches. They belong to Magnolyophyta, Magnolyopsida and Liliopsida.

Long Thanh – Nhon Trach mangrove forest is in the submerged land of the province, contributing to stabilize deposited alluvium, forming a protective wall, preventing river mouth erosion which is caused by tidal and other activities. The mangrove forest plays significant roles in maintaining the eco-balance, including alluvium transporting and movement of plankton, balancing fish and shrimp larva resources. The mangrove forest is managed by Long Thanh Farm, covering the area of 4 communes: Phuoc An, Long Tho (Nhon Trach district) and Phuoc Thai, Long Phuoc (Long Thanh district). The inland waterway transport system is densely in the forest area, favorable to transport and ecotourism development. It is estimated that the total natural area of Long Thanh – Nhon Trach mangrove forest is 7,952.67ha, comprising:

62 7,060 ha in Nhon Trach district (4,036 ha with forest trees and 3,024 ha without forest trees). 1,467 ha in Long Thanh district.

(a). Plant Plankton

The salinity-polluted zone is affected by industrial wastes. Number of species in this zone is less diversified, comprising 29 species where Bacillariophyta is dominated with 17 species or 58.6% of 10 families; following by Chlorophyta with 6 species or 20.7%, belonging to 6 families; Cyanophyta with 4 species (13.8%) of 4 families; Chrysophyta with one species (3.4%); and Euglenophycota with 1 species (3.4%). The average density is 19,000 to 45,000 individuals per 1 litter.

(b). Zoo Plankton and Zoo Benthos

In the salinity polluted zones which are affected by industrial wastes, Copepoda species are dominated with 11 species, 20 initials per liter; following by Rotifer – 2 species, 8 individuals per liter, Protozoa – 5 species, 7 individuals per liter, Cladocera – 11 species – 3 individuals per liter and larva – 38 individuals per liter.

(c). Crustacean

19 valuable shrimp species are identified, especially Penaeus indicus, Metapenaeus ensis; Metapenaeus lyssianassa Metapenaeus spinulatus is an important species in intensive rearing ponds in Long thanh and Nhon Trach. Scylla serrata crab is also exploited in mangrove forest. Regarding Penaeud monodon, the rearing has been developed rapidly.

(d). Mollusk

There are some mollusk species in Thi Vai River which are exploited to nurture duck and fish. They shall be further studied to maintain these valuable natural resources.

2. Terrestrial Ecosystem

The local terrestrial ecosystem is characterized as follows:

(a). Species

Characteristics of species in Thi Vai River are shown in Table 20.

(b). Species Coverage 139 species have small coverage, sharing 53%, distributed in incident-occurred zones or used to be densely community.

63 86 species have average coverage, sharing 33% which are mixed groups in the community, having characteristics of dominated species. 37 species have high coverage, sharing 14%, which are dominated species in riverside forest, of which, Rhizophora apiculata is dominated.

(c). Value 13 salt-water species distributed along canals, river banks in tidal inundation zones. Salt water species trees are planted or wild trees in fertilizer land along the river; 123 valuable tree species: green coverage, erosion-prevention, organic fertilizer, etc. 86 species used as medical herbs; 6 vegetable species 34 species as bonsai tree 62 wooden tree species 44 fruit tree species.

2. Aquatic Ecosystem (Zoo and Plant Plankton, Zoo Benthos)

1. Zoo Plankton

The survey results of past years show that there are replacement of various species such as substitution of Cartia clausi, Paracalanus parvus and shrimp larva by Oithona plumifera and nauplius.

2. Plant Plankton

The survey results show there are structure variations of individuals by dominant species. When the plants were not developed in Nhon Trach III IP, algae species are dominated, including Chaetoceros, Pseudocurvicetus, C. Spinosus, Skeletonema costatum, Ditylum sol and Coscinodiscus jonessiacus. When the plants are operating, silica algae species are dominated, including Chaetoceros abnormis, Nitzchia longissima, and especially Lepto-cylindiscus danicus.

3. Zoo Benthos

The river bed covers with gravel and stiff clay. Main zoo benthos species are Anthozoa, Spongia, Holothurian. There are Sedentaria or Terebellidesstroemi Sars, Sabllearia cenentarium Moore, Sternaspis sactata (Rosami) along the river bank.

64 CHAPTER 2 EVALUATION OF ALTERNATIVES

1. CRITERIA FOR SELECTING ALTERNATIVES

Any of the alternative solutions still have to meet the national regulation QCVN 40:2011/BTNMT. The discharge point have to ensure the discharge need, while avoid the negative impacts toward the environments and the local public. Sludge from the treatment system has to be treated as hazardous wastes, and avoid impacts toward the environment.

2. LOCATIONS OF OUTLETS

The purpose of the choosing the exist location of outlet is 1) To utilize the exist infrastructure of Nhon Trach 3 IP; 2) To save the construction cost; 3) The exits location of outlet is suitable with the real condition. Wastewater from Nhon Trach 3 IP – Module 2 will use the existing (Module 1) discharge network. Therefore, the location of Module 2 discharge 2 will be unchanged.

3. WASTEWATER TREATMENT TECHNOLOGY

Treatment efficiency of the treatment plant (Module 1) is very effective. The results from earlier treatment can be seen in Table 26 and 27 as below, while the up-to-date results 05/ 2012) were already presented in table below:

Table 23: The characteristics of the IP centralized wastewater treatment (Phase 2 - Module 1), September 2011

WASTE WATER QCVN characteristics 9/2011 40:2011/BTNMT No Parameters Unit Pre-treatment After Column B with (Equaliser) Treatment Kq=1.1;Kf=1.0 1 pH - 6.2 7.2 5.5 - 9.0 Undetected 2 COD mg O /L 760 165 2 (LOD=10)

3 BOD5 mg O2/L 330 9 55 4 TSS mg/L 148 48 110 5 Colour Pt-Co 42 13 165 Undetected 6 N-NH + mg/L 25.8 11 4 (LOD=0.056) 7 TN mg/L 27.3 4.8 44 8 TP mg/L 9.4 1.72 6.6

65 WASTE WATER QCVN characteristics 9/2011 40:2011/BTNMT No Parameters Unit Pre-treatment After Column B with (Equaliser) Treatment Kq=1.1;Kf=1.0 Undetected 9 CN- mg/L 0.013 0.11 (LOD=0.005) 1 Undetected Undetected Cr6+ mg/L 0.11 0 (LOD=0.01) (LOD=0.01) 1 Undetected Undetected Cr3+ mg/L 1.1 1 (LOD=0.025) (LOD=0.025) 1 Undetected Fe mg/L 1.37 5.5 2 (LOD=0.06) 1 Zn mg/L 0.19 0.21 3.3 3 1 Undetected Cu mg/L 0.18 2.2 4 (LOD=0.1) 1 Undetected Undetected As mg/L 2.2 5 (LOD=0.001) (LOD=0.1) 1 Undetected Hg mg/L 0.003 0.011 6 (LOD=0.001) 1 Undetected Pb mg/L 0.036 0.55 7 (LOD=0.001) 1 Undetected Undetected Cd mg/L 0.11 8 (LOD=0.005) (LOD=0.01) 1 Undetected Undetected Ni mg/L 0.55 9 (LOD=0.06) (LOD=0.005) 2 Inorganic Undetected mg/L 12.6 11 0 oils (LOD=3) 2 Organic mg/L 7.26 Undetected - 1 Oils 2 S2- mg/L 2.83 Undetected 0.55 2 2 Undetected Cl mg/L 1.85 2.2 3 2 (LOD=0.1) Phosphorus 2 Undetected based µg/L 0.0073 1.1 4 (LOD=0.001) Pesticides Chloride 2 Undetected Undetected based µg/L 0.11 5 (LDO=0.0005) (LOD=0.0005) Pesticides 2 Undetected Phenol µg/L 0.08 0.55 6 (LOD=0.01) 2 Coliforms MPN/ 3.5x106 < 1.8 5500 100mL

66 WASTE WATER QCVN characteristics 9/2011 40:2011/BTNMT No Parameters Unit Pre-treatment After Column B with (Equaliser) Treatment Kq=1.1;Kf=1.0

Source: Environmental monitoring report of Nhon Trach 3 IP, Phase 2, 2011

Table 24: The characteristics of the IP centralized wastewater treatment (Phase 2 -Module 1), fourth quarter, November 2011

WASTE WATER QCVN characteristics 9/2011 40:2011/BTNMT No Parameters Unit Pre-treatment After Column B with Treatment Kq=1.1;Kf=1.0 1 pH - 6.69 8,47 5.5 - 9.0 2 COD Pt-Co 278 13 165

3 BOD5 mg/L 192 18 55 4 TSS Mg/L 104 39 110 5 Colour mg/L 55 25 165 6 Undetected N-NH + mg/L 34.2 11 4 (<0.5) 7 TN mg/L 46.2 18.1 44 8 TP mg/L 8.18 1.58 6.6 9 Undetected Undetected CN- mg/L 0.11 (<0.005) (<0.005) Undetected Undetected 10 Cr6+ mg/L 0.11 (<0.01) (<0.01) 11 Cr3+ mg/L 0.024 0.009 1.1 12 Fe mg/L 2.199 0.017 5.5 13 Zn mg/L 0.081 0.619 3.3 14 Cu mg/L 0.098 0.011 2.2 15 As mg/L 0.017 0.076 2.2 Undetected Undetected 16 Hg mg/L 0.011 (<0.004) (<0.004) Undetected 17 Pb mg/L 0.167 0.55 (<0.004) Undetected 18 Cd mg/L 0.026 0.11 (<0.0002) Undetected Undetected 19 Ni mg/L 0.55 (<0.001) (<0.0002) Inorganic Undetected 20 mg/L 1.7 11 oils (<0.01) Undetected 21 Organic Oils mg/L 3.3 - (<0.01) 22 S2- mg/L 2.0 Undetected 0.55

67 (<0.1) Undetected 23 Cl mg/L - 2.2 2 (<0.1) Phosphorus Undetected Undetected 24 based mg/L 1.1 (<0.1) (<0.1) Pesticides Chloride Undetected Undetected 25 based mg/L 0.11 (<0.1) (0.1) Pesticides Undetected 26 Phenol mg/L 0.052 0.55 (<0.005) MPN/ Undetected 27 Coliforms 43x103 5500 100mL (<3) Source: Environmental monitoring report of Nhon Trach 3 IP, Phase 2, 2011

Notes: 9/2011 samples were collected and analysed by SONADEZI 11/2011 samples were collected and analysed by Environmental Technology and management Centre QCVN 40:2011/BTNMT – National regulation on industrial ww, Column B, with Kq=1.1 (Thi Vai flowrate > 200 m3/s) and Kf=1.0 (discharge rate ≤2,000m3/day). Wastewater monitoring results showed all parameters of the effluents meeting the Vietnam national standard

After considering the positive results from Module 1 of Nhon Trach 3 IP, Phase 2’s centralized waste water treatment plant. The project owners have decided to continue with the same technology for Module 2. The diagram for Module 2 CETP is presented in Figure 5 as below (as see, is connected straight into Module 1). More detail of Module 2 was also presented in Section 1.5.2.2.

Figure 9: Diagram of Module 2 of the treatment plant and how it’s connected to the system of Module 1

4. SLUDGE TREATMENT TECHNOLOGY

All of the sludge from Nhon Trach 3, Phase 2, centralized CETP will be compacted into blocks and landfilled by Tai Tien Co.Limited.

The technology used by Tai Tien is already been approved by the MONRE under license No 132/TCMT dated 01/12/2010 through the project earlier EIA report, and the DONRE under Document 1197/SKHCN-QLC dated 9/0/2011 (attached with the Appendix)

68 Just like the waste water treatment technology, after considering the positive results from the treatment of hazardous wastes generated from Module, the project owners have chose the same Tai Tien contractor to deal with the hazardous wastes of Module 2.

69 3. IMPACTS ASSESSMENT OF WASTEWATER DISCHARGE INTO RECEIVING WATER BASIN

5. EFFECTS ON WATER QUALITY

1. Pollution Load

At the maximum load of 2,000 m3/day, the pollutant load can be estimated as follows:

Table 25: Pollutant Load in Wastewater of Nhon Trach 3 IP Treatment Plant

Concentration Pollutant load No. Parameter (mg/l) (kg/day) 1 TSS 20 40

2 BOD5 12 24 3 COD 35.5 71

4 N-NH3 0.89 1,78 5 Total Fe 0.28 0,56

Note: The average pollutant concentration is measured 15/05/2012 (1st sample at 10:35am; 2nd sample at 13:15, 3rd sample at 16:20)

2. Assessment on the Impacts on Receiving Sources

Based on the calculation of Table 28, after the Module 2 start operating, a flow of 2,000 m3/ day will contribute into Mareng Canal flow. This equivalent to 31.6 kg

TSS, 14 kg BOD5, 104 kg COD, 0.76 kg ammonia and 0.36 kg Total iron

Thi Vai river water is not utilized for domestic water supply but only for waterway transport, irrigation and aquaculture among other. QCVN 08:2008/BTNMT column B2 (the National Technical Regulation on Surface Water Quality) is applied to evaluate the water quality.

Polluted wastewater can cause the following impacts when it is discharged to the environment: Increase turbidity of the river flow due to SS; alter photosynthetic efficiency and reduce DO in the surface water. Suspended solid could be deposited at the outlet, altering the river flow, river depth and hydraulic conditions. Organic sludge

depositing also causes oxygen deficient, forming toxic gases like H2S, CH4, etc. If the receiving source is not cleaned properly, the water will be changed to black and smelly.

Increase organic pollution load (BOD5, COD), increasing organic and inorganic compound oxidization, reducing DO concentration in the water.

70 Increase nutrients in the water (total N, total P), causing eutrophication Reduce load bearing and purifying capacity of the river. Affect to drinking and production water quality. Affect to load bearing and purifying capacity of receiving sources.

As Mareng Canal is quite short (1.5 km) with small slope, and is under affected by tide, the disperse of pollutants toward downstream from Mareng is slow. Furthermore this river section also receives a 5,000 m3/day from hung Nghiep Formosa Co.Lmited, that’s why the self-mechanism is overall limited. Especially when Mareng is the only discharge road from project site toward the main river (Thi Vai)

As the project treated wastewater will join other discharged sources toward Thi Vai river. That’s why the negative impacts of the project toward Thi Vai will be presented more detail in Section 4.7 “Accumulated and integrated Impacts”

6. EFFECTS ON ENVIRONMENT AND AQUATIC ECOSYSTEM

Increase turbidity, reduce DO, affecting to photosynthesis efficiency, altering number of aquatic species in the water. Impact on food chain of the ecosystem. If the river could not purified water will be polluted by organic substance and nutrients, affecting seriously to aquatic life, reducing biodiversity (species number and density), etc. narrowing habitat of small animal species in mangrove forest. Pollution of nutrients: Proper nutrient content will promote algae growing adequately in the food cycle. However, if it increases significantly eutrophication will occur, causing organic pollution. Nitrogen Impacts: + Toxic to fish at high concentration - + Small NH3 concentration and NO3 are nutrients to algae growth. + - + Conversion of NH4 to NO3 needs large volume of DO. Impacts of Phosphorus: Phosphorus is an essential nutrient for algae growth. High concentration will promote algae growth. When algae died it will be organic food for bacteria, altering oxygen content, causing fish dead. Organic Substance Pollution: reduce DO, threatening to fish and other aquatic species.

Impacts of wastewater discharge to mangrove forests (Long Thanh – Nhon Trach and Can Gio district) are not considered yet.

7. EFFECTS ON HYDROLOGY

71 Ma reng Canal flow volume is around 2 m3/s during dry season and increase to <10m3/s during flooding season. The wastewater volume of Nhon Trach 3 IP Treatment Plant is about 2,000 m3/day and night, equally to 0.023 m3/s which will not increase the water flow or the change hydraulic regime of Thi Vai River even during dry season.

8. EFFECTS ON AIR

The maximum capacity of Module 2 of the wastewater treatment facility of Nhon 3 Trach 3 IP, Phase 2 is 2.000 m /day. They could emit odor, H2S, Hydrocarbons, Mercaptan among others affecting to areas near the outlet. However currently there is no detected odour from the Nhon Trach 3 IP Treatment Plant’s discharges, and was reflected through the surveying of residents living along Mareng Canal. Hence it can be concluded that the discharge wastewater does not affect local air quality.

Obviously, the discharge from the Treatment Plant will be really small compare to Thi Vai River flowrate even during dry season (0.023 m3/s vs. 10 m3/s). So the affect toward Thi vai also minimum

9. IMPACTS OF RISK AND ACCIDENTS

The effluent is quite large at 2,000 m3/day of the treatment facility could cause river bank erosion. The large effluent may also disturb the river flow, affect small canoe navigation in the outlet area. However as the addition discharge is only 0.23 m3/s while the canoe trip record here is small, just 2-3 canoes travelling on the Canal a day, therefore the affect should be minimal

10. SOCIAL-ECONOMIC AND DOWNSTREAM WATER USE IMPACTS

Wastewater from the treatment facility contains organic substances (BOD5, and COD), causing turbidity increase in Thi Vai River water, offensive odor at the outlet. The effluent discharge can affect to socio-economic as follows:

The discharge of treated waste water into Mareng and Thi vai river more or less will impact on the economical activities of residents living along the river. However at this moment, the local government still has not received any complaints from the residents within the affected areas. The impact is analysed generally to be low considering the discharge rate of only 2,000 m3/day and waste water quality meeting the QCVN 40:2011/BTNMT column B (kq=1.1; kf =1.0)

72 11. CUMULATIVE IMPACTS

Thi Vai River is the final wastewater receiving source of Nhon Trach 3 IP. As mentioned before, the river water is not used for drinking purpose. The effluent, thus, have met TCVN 5945:2005 column B, Kq=1.1 and Kf depending on the discharge volume of the industries (pursuant to Appendix 1 of Decision No. 65/2007/QD-UBND dated December 11, 2007 of Dong Nai PC on environmental zoning for surface water basin to receive industrial wastewater..

At this moment, Thi vai river is the receiving body for the waste water from Nhon Trach IPs (1, 2 & 3, Clothing IP), Go Dau IP (Long Thanh District), and Phu My 1 (Ba Ria –Vung Tau Province). The intake for water supply form Thi vai river is small, with slow river speed, and narrow basin. As the river is heavily affected by tides, the mixing rate of river is slow, and the flow toward the sea is small. That’s why the wastewater from Nhon Trach 3 will cause some problematic negative impacts towards the basin if is not treated properly.

However, the effluent is small compared to the river flow and the wastewater is treated in compliance with Vietnam environmental standard so the impact is insignificant.

To analyse the accumulated impacts of the project toward Mareng canal and Thi Vai River, we will have to analyse the discharge receiving capacity of Mareng and Thi Vai. The assessment will be based on Circular 02/2009/TT-BTNMT dated 19/3/2009 of the MONRE

The wastewater of the project has to meet the national regulation on industrial discharge: QCVN 40:2011/BTNMT (column B), Kq=1.1, Kf=1.0, before being allowed to discharge into Mareng and Thi Vai

Mareng Pollution Loads Analysis

Mareng pollution loads can be analysed by the limits of polluting parameters in Mareng canal water. It can be presented in table below.

Table 26: Pollutant concentrations of Mareng

Parameters BOD COD TSS As Pb Cd Hg

Ctc (mg/l) 15 30 50 0,05 0,05 0,01 0,001

Note: Limitation value Ctc is based on QCVN 08:2008/BTNMT, column B1.

Max Pollution loads

73 Max pollution load that nearby surface water sources can receive, will be calculated using below equation:

Ltd = (Qs + Qt) x Ctc x 86.4 When:

- Ltd: max pollution load of that water sources with a certain pollutants; 3 - Qs: Flow rate during dry season, Qs= 2.0 m /s; 3 3 - Qt: waste water flowrate, Qt = 2,000 m /day = 0.024 m /s; - 86.4 is the coefficiency from (m3/s)x(mg/l) to (kg/day).

The max pollution load that nearby surface water sources can receive will be presented in below table:

Table 27: The max pollution load that nearby surface water sources can receive

Parameters BOD COD SS As Pb Cd Hg Q + Q s t 2.024 2.024 2.024 2.024 2.024 2.024 2.024 (m3/s)

Ctc (mg/l) 15 30 50 0.05 0.05 0.01 0.001 Ltd (kg/day) 2623.1 5246.2 8743.7 8.7 8.7 1.7 0.2

Current Pollution Loads

Current pollution loads will be calculated using below equation: Ln = Qs x Cs x 86.4 When:

- Ln: Present Pollution Loads in receiving water body; 3 - Qs: Flow rate during dry season, Qs= 2.0 m /s; - Cs: Max concentration of certain pollutants in the river before receives the waste water discharge; - 86.4 is the coefficiency from (m3/s)x(mg/l) to (kg/day).

The Current pollution loads will be presented in below table:

Table 28: The current pollution loads.

Parameter As Pb Cd Hg BOD COD SS s 3 Qs (m /s) 2 2 2 2 2 2 2

Cs (mg/l) 6 35 30 0.044 UD UD UD

Ln (kg/day) 1036.8 6048.0 5184.0 7.6 - - -

Notes: Cs is the average analysed results of Mareng Canal 11/2009. UD= undetected

Pollution loads from discharge source

Pollution loads from discharge sources will be calculated using below equation: Lt = Qt x Ct x 86.4

74 When:

- Lt: Pollution loads in effluent (kg/day); 3 - Qt: Discharge flow rate, Qt= 0,024 m /s; - Ct: Max concentration of certain pollutants in discharge; - 86.4 is the coefficiency from (m3/s)x(mg/l) to (kg/day).

Pollution loads from discharge sources will be presented in below table:

Table 29: Pollution loads from discharge sources

Parameters BOD COD SS As Pb Cd Hg 3 Qt (m /s) 0.024 0.024 0.024 0.024 0.024 0.024 0.024

Ct (mg/l) 12 35 20 0,0267 UD UD UD

Lt (kg/day) 24,88 73,27 41,47 0,06 - - - Notes: Pollutants concentration in effluents is taken from Monitoring Report 11/2011 UD= undetected

Mareng Pollution loads receiving capacity

Mareng receiving capacity of these pollution loads will be calculated using below equation: Ltn = (Ltd – Ln - Lt) x Fs When:

- Ltn: Mareng pollution loads receiving capacity (kg/day); - Ltd: Max pollution load of that water sources with a certain pollutants (kg/day);

- Ln: Present Pollution Loads in receiving water body (kg/day); - Lt: Pollution loads in effluent (kg/day); - Fs: safety coefficiency, Fs = 0.3 – 0.7, the project chose Fs = 0.5.

Mareng pollution loads receiving capacity after received the discharge from the CETP can be summarised as below:.

Table 30: Mareng pollution loads receiving capacity after received the discharge

Parameters BOD COD SS As Pb Cd Hg

Ltd (kg/day) 2623.1 5246.2 8743.7 8.7 8.7 1.7 0.2

Ln (kg/day) 1036.80 6048.00 5184.00 7.60 - - -

Lt (kg/day) 24.88 73.27 41.47 0.06 - - -

Ltn (kg/day) 780.71 -437.53 1759.10 0.54 4.37 0.87 0.09

Conclusion: Ma Reng Canal, after received the treated waste water from the IP will still be able to sustain the loads of parameters BOD, SS, As, Pb, Cd and Hg and remain within national standards. COD levels are already over the river maximum

75 pollution loads; thus the additional COD load will not in themselves cause a change in water quality of the canal with respect to existing standards.

Thi Vai Pollution Loads Analysis

Thi Vai pollution loads can be analysed by the limits of polluting parameters in Mareng canal water. It can be presented in table 29 as below

Table 31: Pollution load of Thi Vai

Parameters BOD COD TSS As Pb Cd Hg

Ctc (mg/l) 15 30 50 0.05 0.05 0.01 0.001

Note: Limitation value Ctc is based on QCVN 08:2008/BTNMT, column B1.

1. Max Pollution loads

Max pollution load that nearby surface water sources can receive, will be calculated using below equation:

Ltd = (Qs + Qt) x Ctc x 86.4 When:

- Ltd: max pollution load of that water sources with a certain pollutants; 3 - Qs: Flow rate Qs of Thi Vai=243.0 m /s (Under Decision No 65/2007/UBND of 11/12/2007 by Dong Nai people Committee); 3 3 - Qt: waste water flowrate, Qt = 2,000 m /day = 0.024 m /s; - 86.4 is the coefficiency from (m3/s) x (mg/l) to (kg/day).

The max pollution load that nearby surface water sources can receive will be presented in below table:

Table 32: The max pollution load that nearby surface water sources can receive

Parameters BOD COD SS As Pb Cd Hg Q + Q s t 2.024 2.024 2.024 2.024 2.024 2.024 2.024 (m3/s)

Ctc (mg/l) 15 30 50 0.05 0.05 0.01 0.001 Ltd (kg/day) 317,551.1 635,102.2 1,058,503.7 1,058.5 1,058.5 211.7 21.2

2. Current Pollution Loads

Current pollution loads will be calculated using below equation:

Ln = Qs x Cs x 86.4 When:

- Ln: Present Pollution Loads in receiving water body; 3 - Qs: Qs of Thi vai= 243.0 m /s (Under Decision No 65/2007/UBND of 11/12/2007 by Dong Nai people Committee);

76 - Cs: Max concentration of certain pollutants in the river before receives the waste water discharge; - 86.4 is the coefficiency from (m3/s)x(mg/l) to (kg/day).

The Current pollution loads will be presented in below table:

Table 33: The current pollution loads.

Parameters BOD COD SS As Pb Cd Hg 3 Qs (m /s) 243 243 243 243 243 243 243 Cs (mg/l) 4 27 24 0,08 UD UD UD

Ln (kg/day) 73,483.2 556,372.8 493,387.2 1,753.10 - - -

Notes: Cs is the average analysed results of Mareng Canal 11/2009.

3. Pollution loads from discharge source

Pollution loads from discharge sources will be calculated using below equation: Lt = Qt x Ct x 86.4 When:

- Lt: Pollution loads in effluent (kg/day); 3 - Qt: Discharge flow rate, Qt= 0,024 m /s; - Ct: Maximum concentration of certain pollutants in discharge; - 86.4 is the coefficiency from (m3/s)x(mg/l) to (kg/day).

Pollution loads from discharge sources will be presented in below table:

Table 34: Pollution loads from Mareng into Thi Vai

Parameters BOD COD SS As Pb Cd Hg 3 Qt (m /s) 0.024 0.024 0.024 0.024 0.024 0.024 0.024

Ct (mg/l) 20 46 128 0.002 0.005 UD UD

Lt (kg/day) 3497.47 8044.19 22383.82 0.35 0.87 0 0 Notes: Pollutants concentration in effluents is taken from Monitoring Report 11/2011

4. Pollution loads receiving capacity of Thi Vai

Thi Vai receiving capacity of these pollution loads will be calculated using below equation:

Ltn = (Ltd – Ln - Lt) x Fs When:

- Ltn: Mareng pollution loads receiving capacity (kg/day); - Ltd: Max pollution load of that water sources with a certain pollutants (kg/day);

- Ln: Present Pollution Loads in receiving water body (kg/day); - Lt: Pollution loads in effluent (kg/day); - Fs: safety coefficiency, Fs = 0.3 – 0.7, the project chose Fs = 0.5.

77 Mareng pollution loads receiving capacity after received the discharge from the CETP can be summarised as below:.

Table 35: Mareng pollution loads receiving capacity after received the discharge

Parameters BOD COD SS As Pb Cd Hg Ltd (kg/day) 317,551.1 635,102.2 1,058,503.7 1,058.5 1,058.5 211.7 21.2

Ln (kg/day) 73,483.2 556,372.8 493,387.2 1,753.1 - - -

Lt (kg/day) 1,061.7 6,121.3 5,225.5 7.7 - - -

Ltn (kg/day) 121,503.1 36,304.1 279,945.5 -351.1 529.3 105.9 10.6

Conclusion: Thi Vai River, after received the treated waste water from the IP will still be able to sustain the loads of parameters BOD, COD, SS, Pb, Cd and Hg without exceeding maximum pollution loads. Only arsenic (As) is already over the river maximum pollution loads.

78 CHAPTER 3 MITIGATION MEASURES

1. ENVIRONMENTAL MANAGEMENT PLAN AND RISK MANAGEMENT PLAN

Typical mitigation measures for the site clearance phase

The CETP of Nhon Trach 3 IP – Phase 2 is located in a clearance area in Road No. 2, Nhon Trach Industrial Park No. 3 - Phase 2, therefore, it is not necessary to carry out any additional to obtain the land for constructing CETP. This process has been done during construction phase of industrial zones.

Typical mitigation measures for CETP construction

1. Water Pollution Mitigation Measures Lubricant scrap shall be collected properly in the course of repairing and maintenance process, preventing pollution in the local area.

2. Air Environment Pollution Mitigation To spray water as needed to minimize dust pollution. To manage traffic flow properly; inspect construction equipment and machine and maintain them properly; To clean vehicles properly prior leaving the constructions

3. Solid Waste Pollution Mitigation Measures Solid wastes from construction activities, e.g. cement, brick, sand, stone, material shall be collected and categorized to reuse for land reclamation; Domestic solid waste and nonhazardous industrial waste shall be collected to specific tank and outsource Bay Ha Long Co., Ltd. to transfer the wastes to dispose properly (Bay Ha Long Co., Ltd. is collecting domestic waste at the centralized wastewater treatment system at Nhon Trach 3 IP, Phase II, Module 1. Metal, nylon and paper scraps are sold to recycling establishments. Hazardous solid wastes such as oil-tainted clout, lubricant, among others shall be collected to specific tanks and outsourced to Tai Tien Co., Ltd. to collect and dispose properly. To stipulate regulations on sanitation preservation with proper penalty for the one who committed to the regulation violation. To request workers enforcing occupational safety regulations, raising public awareness on environment protection.

79 4. Sludge Management to Minimize Adverse Impacts

Sludge is not generated in the construction stage

5. Soil Pollution Mitigation

The impact on soil environment is insignificant so it does not require soil pollution prevention measures.

Typical mitigation measures for CETP operation

6. Water Pollution Mitigation Measures

1. Industrial Wastewater

Industrial wastewater from enterprises in Nhon Trach 3 IP, Phase 2 shall be treated meeting the limit stipulated by Nhon Trach 3 IP One-member Affiliated Co. (see the limits of allowable parameters of the centralized wastewater treatment connection in appendix). The centralized wastewater treatment system, Module 1 of Nhon Trach 3 IP, Phase 2 was developed and is operating stably with design capacity of 2,000m3/day to meet the wastewater treatment demand of existing enterprises in the industrial zone. The total wastewater volume is about 780 m3/day. The centralized wastewater treatment system, module 2 of Nhon Trach 3 IP will be connected to Module 1 to expand the treatment capacity of the system. The treated wastewater is monitored properly in compliance with Vietnam Technical Regulation QCVN 40:2011/BTNMT (Column B) to discharge into Lo Ren culvert, flowing to Thi Vai River. The automatic wastewater monitoring system (with automatic recording system) will be installed to monitor flowrate, pH, DO, TSS and COD in the treated wastewater.

2. Domestic Solid Waste

Domestic solid waste will be collected to be treated in the septic tank.

3. Storm Water

Tin Nghia Corporation developed a separated drainage system in Nhon Trach 3 IP, Phase 2. The storm water is collected to the open canal and discharge into Lo Ren culvert, flowing to Thi Vai River. The reinforce concrete drainage system cover 30,111.4 m long, comprising of D600 = 2,042 m; D800 = 6,905.6 m; D1000 = 7,020.2 m; D1200 = 485.6 m; D1500 = 11,254.2 m open canal B2000 = 997.5 m; B4000 = 982 m; closed box culvert B3000 = 524.3 m meeting drainage requirements in the IP.

80 7. Air Environment Impact Mitigation Measures

1. General Measures to Minimize Air Pollution

The investor will take the following measures to minimize air pollution and impacts on worker’s health in the operation process: To develop the centralized wastewater treatment system in compliance with regulations on safety and industrial sanitation, meeting the ventilation standard by natural wind and forced fan. To clean the wastewater treatment zone properly

2. Air Pollution Mitigation at the Centralized CETP

1. Use of Bio-Products

If offensive arises, odor bio-products such as GEM-P, GEM-K, GEM, CTA-T will be used to minimize offensive odor from waste storage yard, sludge yard, etc.

2. Odor Oxidization

Odors will be deoxidized by strong oxidizers such as H2O2 or Ozone. H2O2 will be periodically electrolyzed to treat odor. Ozone generator may be installed to process odor. Ozone generator has been applied widely to deoxidize odor in Vietnam.

3. Air Pollution Control from Traffic Air Emission

The investor will take appropriate measures to control air pollution from traffic, including: Concretise inner plant roads and clean roads properly; install auto-water spraying system to water the roads effectively To turn off transport vehicle while waiting in the plant To regularly maintain and inspect vehicles

4. Noise Control Measures

The investor will take following measures to reduce noise the operation process: To install rubber buffer and anti-vibration spring for heavy loading equipments; To separate intensive noise sources (200 mm thick wall, 100 mm buffer zone, heavy wooden door, etc.); To regularly maintain equipment properly: the maintenance cycle is in every 4—6 months for branch new equipment and in every 3 months for the old equipment; Plant trees to mitigate noise dispersion.

81 (5). Mitigation of Heat Residue

Temperature will exceed the allowable standard from 1 – 30C in the CETP in sunny days. Ventilation will be designed properly. Drinks will be provided to workers.

8. Solid Waste Impact Mitigation

The company got the hazardous waste owner registration book No. 587/SĐK-TNMT dated November 5, 2010, hazardous solid waste management code No. 75001375 When the second module is developed completely the solid waste treatment contract will be signed with the following agencies: Domestic solid waste: The company signed the contract with Bay Ha Long Co., Ltd to collect the domestic solid waste properly (attached with the solid waste collection contract). Hazardous Solid Waste: The company continues singing the contract with Tai Tien Co. Ltd. To collect and transport hazardous solid waste properly.

9. Sludge Impact Mitigation Measures Sludge generated at the centralized wastewater treatment facility will be collected and treated by signing the contract with Tai Tien Co., Ltd.

Collection and transport processes

Hazardous sludge from the CETP of Nhon Trach 3 IP – Module 2 will be contracted with Tai Tien Co Limited to collect, transport and treat appropriately as below: Hazardous sludge after was pumped and compressed is marked hazardous and stored separately in hazardous wastes warehouse Periodically, Tai Tien Co Limited will bring their own vehicles to collect, and travel back with this path: Nhon Trach 3 IP  25B Provincial road  51 national road  Thai Lan 3-way crossroads  Trang Bom  1A national road  Tay Hoa District  Tai Tien hazardous treatment plant (Nhan Hoa commune, Tay Hoa District).

Sludge Treatment Technology at Tai Tien Ltd. Co.

Sludge from the wastewater treatment system currently contracted with Tai Tien Ltd. Co. and will be treated as below: The dried and dewatered sludge contains hazardous substances will be mixed with cement, then compressed into blocks to reduce pollution disperse into the environment. As cement has high alkalinity, the heavy metals will kept under hydroxide or carbonate salts. The compressing often also often include Ca(OH)2 solution (to increase its acidity), or coal slag. Coal slag and Ca(OH)2 can stabilize As, Cd, Cr, Cu, Fe, Pb, Mg, Se, Ag,

82 Zn…The blocks will then be landfilled under required standard inside the treatment plant border, rather than hand it to third party. The % of mixing based on mass is as below:

Table 36: Mixing Rates

Hazardous Wastes Incineration Slag Cement Lime Sand Water 100 20 35 10 100 65 30% 6% 10% 3% 30% 19%

With the mixing as above, the hazardous after compressed into blocks will increase weights by 2.75 times, due to 63.6% of the mass from addition.

The diagram for solidifying process can be seen as below:

Figure 10: Sludge solidifying process

Tai Tien landfill site

Tai Tien landfill site is constructed based on design TCXDVN 261:2001 with double layers and 2 trends to collect landfill leachate. The detail layers are as below + Compacted original soil; + 0.3 m compacted clay layer (filtration coefficiency k 10-7 cm/s); + 2 mm HDPE layer; + 0.3 m sand filtration layer, (filtration coefficiency k = 0,9); + Geotexttile layer; Area: 156.73 m x 33.24 m x 11 m Total potential landfill volume: 61,378 m3 Filled duration: 8 years (if the landfilling rate of hazardous solid wastes is 10 tons/ day). Actual landfilling rate at this point: 380 kg/day or around 10 tons per months

10. Soil Environment Impact Mitigation

Soil is not affected in the operation process.

83 Table 37: Typical mitigation measures for CETP construction

Issues/impacts Mitigation measures applied for CETP Vietnam code/regulation Construction vehicles must undergo a regular emissions check and get  TCVN 6438-2005: Road certified named: “Certificate of conformity from inspection of quality, vehicles. Maximum permitted technical safety and environmental protection” following Decision No. emission limits of exhaust gas; 35/2005/QD-BGTVT  Decision No. 35/2005/QD- Maintain vehicles and equipments daily and every 6 months (or 8.000 km on BGTVT on inspection of Air pollution the road) quality, technical safety and Do not burn waste on site environmental protection;  QCVN 05:2009/BTNMT: Monitoring air quality for dust emission, noise and ambient air quality National technical regulation on ambient air quality Removing waste out of construction site as soon as possible  QCVN 05: 2009/BTNMT: Cover the transport means to avoid dust, soil and building materials National technical regulation scattering during transportation on ambient air quality The Contractor is responsible for compliance with relevant Vietnamese legislation with respect to ambient air quality. The Contractor shall ensure that the generation of dust is minimized and is not perceived as a nuisance by local residents and shall implement a dust Dust generation control program to maintain a safe working environment and minimize disturbances for surrounding residential areas/dwellings The Contractor shall implement dust suppression measures (e.g. use water spraying vehicles to water roads, covering of material stockpiles, etc.) as required. Exposed soil and material stockpiles shall be protected against wind erosion and the location of stockpiles shall take into consideration the prevailing wind directions and locations of sensitive receptors. The Contractor shall prepare vegetation protection measures to be included  Law on Environment in the Construction Environment Management Plan for prior approval by the protection No. 52/2005/QH11 Disruption of vegetative cover and Construction Engineer, following relevant regulations. The Clearance Plan ecological resources shall be approved by Construction Supervision Consultant and followed strictly by contractor. Areas to be cleared should be minimized as much as possible.

84 Issues/impacts Mitigation measures applied for CETP Vietnam code/regulation Avoid construction at night (10 pm – 6 am)  QCVN 26:2010/BTNMT: The contractor is responsible for compliance with the relevant Vietnamese National technical regulation legislation with respect to noise and vibration. on noise Noise and Vibration  QCVN 27:2010/BTNMT: All vehicles must have appropriate “Certificate of conformity from National technical regulation inspection of quality, technical safety and environmental protection” on vibration following Decision No. 35/2005/QD-BGTVT; to avoid exceeding noise emission from poorly maintained machines. Ensure the technical requirements on treatment of wastewater and run-offs Increased turbidity in surface water Good management of soil erosion and sedimentation Build portable or use temporary toilet in IZs (if needed)  QCVN 14:2008/BTNMT: Construct septic tank (if needed) and withdraw the wastewater and sewage National technical regulation when the construction finishes on domestic wastewater The Contractor must be responsible for compliance with the relevant Domestic wastewater of workers Vietnamese legislation relevant to wastewater discharges into watercourses. Wastewater over permissible values set by relevant Vietnam technical standards/regulations must be collected in a conservancy tank and removed from site by licensed waste collectors. Periodic dredging sewers  TCVN 4447:1987: Earth To avoid sediment-laded runoff that could adversely impact watercourses, works-Codes for construction install sediment control structures where needed to slow or redirect runoff  Decree No. 22/2010/TT-BXD and trap sediment until vegetation is established. on regulation of construction Ensure drainage system is always maintained cleared of mud and other Drainage and sedimentation control safety obstructions and periodically check the status of the drainage system Areas of the site not disturbed by construction activities shall be maintained  QCVN 08:2008/BTNMT – in their existing conditions. National technical regulation Earthworks, cuts, and fill slopes shall be properly maintained, in accordance on quality of surface water with the construction specifications of CETP outlets or AMS. The Contractor shall follow the detailed drainage design included in the construction plans, intended to prevent storm water from causing local flooding or scouring slopes and areas of unprotected soil resulting in heavy sediment loads affecting local watercourses (Arrange drainage ditches around the construction area to collect rainwater runoff and sedimentation pits before leading into water resources)

85 Issues/impacts Mitigation measures applied for CETP Vietnam code/regulation  QCVN 09:2008/BTNMT: Ground water pollution due to sewage leak Leaks on drainage system must be detected and corrected promptly National Technical Standard on underground water Quality

Before construction, a solid waste control procedure (storage, provision of  Decree No. 59/2007/ND-CP on bins, site clean-up schedule, bin clean-out schedule, contract with waste solid waste management management company or waste treatment company to collect waste daily, etc.) must be prepared by Contractors and included in Construction Environment Management Plan and it must be carefully followed during construction activities.

Before construction, all necessary waste disposal permits or licenses must be obtained.

Solid waste may be temporarily stored on site in a designated area approved Solid Waste Management by the Construction Supervision Consultant and IZA prior to collection and disposal through a licensed waste collector. In case, if not removed off site, solid waste or construction debris shall be disposed of only at sites identified and approved by the Construction Supervision Consultant and included in the solid waste plan. Under no circumstances shall the contractor dispose of any material in environmentally sensitive areas, such as in areas of natural habitat or in watercourses.

Waste storage containers shall be covered, tip-proof, weatherproof and scavenger proof.

No burning, on-site burying or dumping of solid waste shall occur.

86 Issues/impacts Mitigation measures applied for CETP Vietnam code/regulation  Decision No. 23/2006/QD- Chemical waste of any kind shall be disposed of at an approved appropriate BTNMT with list of hazardous landfill site and in accordance with local legislative requirements. The substance Contractor shall obtain needed disposal certificates.  Circular No. 12/2011/TT- BTNMT on management of Used oil, lubricants, cleaning materials, etc. from the maintenance of hazardous substance vehicles and machinery shall be collected in holding tanks and removed from site by a specialized oil recycling company for disposal at an approved hazardous waste site.

Unused or rejected tar or bituminous products shall be returned to the Chemical or hazardous wastes supplier’s production plant.

Relevant agencies shall be promptly informed of any accidental spill or incident. Prepare and initiate a remedial action following any spill or incident. In this case, the contractor shall provide a report explaining the reasons for the spill or incident, remedial action taken, consequences/damage from the spill, and proposed corrective actions.

Store chemicals appropriately and with appropriate labeling

Appropriate communication and training programs should be put in place to prepare workers to recognize and respond to workplace chemical hazards

Traffic management Streamline traffic and navigation with consultations with local government  Law on traffic and and community, and traffic police transportation No. 23/2008/QH12  Law on construction No. 16/2003/QH11  Decree No. 22/2010/TT- BXD on regulation of

87 Issues/impacts Mitigation measures applied for CETP Vietnam code/regulation construction safety

Limit speed at the construction site  Decree No. 22/2010/TT- Avoid transportation in rush hours BXD on regulation of Installation of lighting at night construction safety Equipped workers with labor protection instruments (ie ear pieces are provided to and used by workers who must use noisy machines such as  Instruction No. 02 / piling, explosion, mixing, etc., for noise control and workers protection.) 2008/CT-BXD on safety and sanitation issues in construction agencies Training workers on occupational safety regulations  TCVN 5308-91: Technical regulation on safety Keep the construction area safe and orderly; If blasting is to be used, in construction Health and safety additional mitigation measures and safety precautions must be outlined in the CEMP.  Decision No. 96/2008/QD-TTg on clearance Clean the site prior to completion and closure; if previous assessments of UXO. indicate there could be unexploded ordnance (UXO), clearance must be done by qualified personnel and as per detailed plans approved by the Construction Engineer Workers should carry protective clothing and goggles to protect and not to work too long in the closed environment; Prepare and implement action plan to cope with risk and emergency (ie in case of problems, stop the construction and implement of necessary measures) as well as well prepare emergency aid service at construction site Contractor shall comply with all Vietnamese regulations regarding worker safety.

88 Issues/impacts Mitigation measures applied for CETP Vietnam code/regulation Copies in Vietnamese of these ECOPs and of other relevant environmental Communication with local communities  Decree No. 73/2010/ND- safeguard documents shall be made available to local communities and to CP on administrative workers at the site. penalization security and society issues Provide a community relations contact from whom interested parties can receive information on site activities, project status and project implementation results.

Provide all information, especially technical findings, in a language that is understandable to the general public and in a form of useful to interested citizens and elected officials through the preparation of fact sheets and news release, when major findings become available during project phase.

Monitor community concerns and information requirements as the project progresses; Respond to telephone inquiries and written correspondence in a timely and accurate manner; Chance find procedures Stop the construction activities in the area of the chance find and delineate  Law on Cultural Heritage (in case if the Contractor discovers the discovered site or area; Secure the site to prevent any damage or loss of (2002) archeological sites, historical sites, removable objects. remains and objects, including graveyards  Law on Cultural Heritage and/or individual graves during In cases of removable antiquities or sensitive remains, a night guard shall (2009) for supplementary and excavation or construction) be arranged until the responsible local authorities or the Department of reformation Culture and Information takes over;  Decree No. 98/2010/ND- Notify the Construction Supervision Consultant who in turn will notify CP for supplementary and responsible local or national authorities in charge of the Cultural Property reformation of Viet Nam (within 24 hours or less); Relevant local or national authorities would be in charge of protecting and preserving the site before deciding on subsequent appropriate procedures. This would require a preliminary evaluation of the findings to be performed. The significance and importance of the findings should be assessed according to the various criteria relevant to cultural heritage; those include the aesthetic, historic,

89 Issues/impacts Mitigation measures applied for CETP Vietnam code/regulation scientific or research, social and economic values; Decisions on how to handle the finding shall be taken by the responsible authorities. This could include changes in the layout (such as when finding an irremovable remain of cultural or archeological importance) conservation, preservation, restoration and salvage; Decisions concerning the management of the finding shall be communicated in writing by relevant authorities; Construction works could resume only after permission is granted from the responsible local authorities concerning safeguard of the heritage.

Table 38: Typical mitigation measures for CETP operation

Budget Difficulties/barriers No. Issues Impacts Mitigation measures Implementer Supervisors sources needed to be considered 1 Pollution at the Long-term  Regular monitoring Water Drainage IZA, DONRE, Budget Awareness of workers outlets Company IZD operatio and factories and CETP  Installing warning signs at n of suitable positions UDC  Regular dredging the manhole, sewerage system  Reducing the spilling of wastewater  Control the preliminary wastewater treatment at enterprises 2 Groundwater Long-term  Monitoring and controlling the Operation Unit IZA, DONRE, Budget contamination groundwater quality in the area IZD operatio n of  Preventing infiltration of CETPs anaerobic ponds  Preventing leakage at connections or transitions in the

90 Budget Difficulties/barriers No. Issues Impacts Mitigation measures Implementer Supervisors sources needed to be considered wastewater pipes 3 Operational Long-term  O&M training for workers Operation Unit IZA, DONRE, Lack of training for problems IZD operational workers  Monitoring of water quality to evaluate the efficiency of the operation  Installing the signs to warn people of the risks of contacting the water bodies  Noticing by the communication means  Repairing as soon as accident happens  Construct the bio- restoration pond (if applicable) 4 Odors Long-term  Ensuring the radius of buffer Operation Unit IZA, DONRE, Lack of financial budget zone at least 300 m IZD for O&M  Planting trees in the buffer zone to create landscape and prevent odor dispersion  Regular maintenance of treatment units  Solving operational accidents  Clearance of surroundings of the ponds 5 Noise Long-term  Planting trees Operation Unit IZA, DONRE, IZD  Appropriate O&M regime 6 Waste from the Long-term  A good plan of collection and Operation Unit IZA, DONRE, operation treatment IZD  Training for workers

91 Budget Difficulties/barriers No. Issues Impacts Mitigation measures Implementer Supervisors sources needed to be considered  Regular collection of sludge 7 Sludge Long-term  Checking sludge quality in order Operation Unit IZA, DONRE, Lack of covering the management to have a suitable plan: drying and IZD haulage vehicles using for making fertilizer or disposing at the landfill, which based on the sludge quality  Reducing the leakage along the haulage distance because dust could bear heavy metals and pathogens which result in food contamination and diseases related to skin and respiratory system  Workers must be equipped with appropriate safety clothes and prevent sludge contact to open wounds  Dried sludge will be treated as hazardous waste if sludge quality does not meet standards. 8 Health and Long-term,  Training and providing enough Operation Unit IZA, DONRE, working safety regularly equipments for checking labor health IZD  At least two workers working in a operating shift.  Keeping a good personal hygiene  Prepare detailed guidance of CETP operation manual

Table 39: Mitigation measures for environmental risks

No. Case Action plan responsibility 1 Complaints from the nearby industries and Immediately implement remedial measures if possible Contractors

92 No. Case Action plan responsibility Record in the logbook community on environmental issues of Discuss with investors, local government to address thoroughly the Contractors, NT3IP, DIZA, construction and operation activities contradictions DONRE, PC49 First aid and immediately transfer the victim to the nearest hospital Workers and local residents if necessary 2 Construction or operational accidents Place the danger signs Contractors, CETP, NT3IP, Make record of the accident DIZA Storage the untreated wastewater, built the biological pond if CETP, NT3IP, DIZA possible Have the back up equipments/facilities Place the danger signs and report to authorities 3 Failure operation of CETP Avoid over waste loading from enterprises' wastewater Training the staff on operation, regularly monitoring Check the design and prepare the new unit of CETP Prepare for accidental response action plan Contract with relative permitted agencies to disposal sludge CETP properly if they are found to be hazardous to environment and 4 Improper sludge disposal human health Report and check frequently all emitted amount of sludge Issue the strict penalties for violation cases DIZA, DONRE Inform authorities (in particular, is that fire police). Contractors, Rescue the objects in the danger zone. industries/enterprises CETP, Actively isolate the fire with the existing facilities on site IZA, DIZA (shepherds, water or fire extinguisher (if any)). Support under the guidance of the functional units until they are Contractors, CETP, NT3IP, present at the scene (especially in situations detect mines, DIZA, industries 5 Fires explosion caused by chemical substances etc.). Support functional units, local government to set up security Contractors, CETP, NT3IP, perimeter around hazardous areas. DIZA, industries/enterprises Check the conditions of fire and explosion safety on site, ensuring Contractors, CETP, NT3IP, the problem does not continue. DIZA, industries/enterprises Suspension of work if they violate conditions of fire safety. 6 Electric accidents Disconnect power sources in the incident area and surrounding Contractors, CETP, NT3IP,

93 No. Case Action plan responsibility areas DIZA, industries/enterprises Immediate rescue the objects in the danger zone Explore the causes of accidents, checking power sources, wires and contacts... Make records of accidents Contractors, CETP, NT3IP, DIZA, industries/enterprises

94 Typical mitigation measures for environmental risks

The typical mitigation measures for environmental risks is shown in the table below.

S1-6 Environmental Consultant Team 95 Table 40: Mitigation measures for environmental risks

No. Case Action plan responsibility Immediately implement remedial measures if possible Contractors Complaints from the nearby industries and Record in the logbook 1 community on environmental issues of Discuss with investors, local government to address thoroughly the Contractors, NT3IP, DIZA, construction and operation activities contradictions DONRE, PC49 First aid and immediately transfer the victim to the nearest hospital Workers and local residents if necessary 2 Construction or operational accidents Place the danger signs Contractors, CETP, NT3IP, Make record of the accident DIZA Storage the untreated wastewater, built the biological pond if CETP, NT3IP, DIZA possible Have the back up equipments/facilities Place the danger signs and report to authorities 3 Failure operation of CETP Avoid over waste loading from enterprises' wastewater Training the staff on operation, regularly monitoring Check the design and prepare the new unit of CETP Prepare for accidental response action plan Contract with relative permitted agencies to disposal sludge CETP properly if they are found to be hazardous to environment and 4 Improper sludge disposal human health Report and check frequently all emitted amount of sludge Issue the strict penalties for violation cases DIZA, DONRE 5 Fires Inform authorities (in particular, is that fire police). Contractors, Rescue the objects in the danger zone. industries/enterprises CETP, Actively isolate the fire with the existing facilities on site IZA, DIZA (shepherds, water or fire extinguisher (if any)). Support under the guidance of the functional units until they are Contractors, CETP, NT3IP, present at the scene (especially in situations detect mines, DIZA, industries explosion caused by chemical substances etc.). Support functional units, local government to set up security Contractors, CETP, NT3IP,

S1-6 Environmental Consultant Team 96 No. Case Action plan responsibility perimeter around hazardous areas. DIZA, industries/enterprises Check the conditions of fire and explosion safety on site, ensuring Contractors, CETP, NT3IP, the problem does not continue. DIZA, industries/enterprises Suspension of work if they violate conditions of fire safety. Disconnect power sources in the incident area and surrounding Contractors, CETP, NT3IP, areas DIZA, industries/enterprises Immediate rescue the objects in the danger zone 6 Electric accidents Explore the causes of accidents, checking power sources, wires and contacts... Make records of accidents Contractors, CETP, NT3IP, DIZA, industries/enterprises

S1-6 Environmental Consultant Team 97 2. RISK MANAGEMENT

The investor will take proper measures to prevent and response to environmental incidents and risks as follows:

1. Environmental Incidents in Preparation and Construction Stages

The construction volume is small and carried out in short period. Incidents can be prevented properly. Specifically:

1. Fire and Explosion Prevention Workers who work directly at the construction site will be trained on fire and explosion methods. Inflammable solvents and fuel shall be stored at isolated warehouses, far from ignition sources. Provide fire and explosion prevention and fighting equipments at fuel warehouses; Provide proper fire and explosion prevention and fighting equipments in compliance with existing regulations; In case of fire and explosion: the investor shall cooperate with Nhon Trach District Fire Police to response to the incident properly.

2. Mitigation of Traffic Accident Control and manage traffic properly; proper loading; Raise public awareness on traffic safety and road law enforcement.

3. Working Safety, Health Protection and Incident Prevention Measures

Compliance with the regulations on labor safety when elaborate construction plans; proper machine operation, preventive measures; provide adequate labor protection uniforms such as helmet, mask, gloves, clothing, welding glasses, shoes, boots, etc. To closely monitor the construction process; minimize occupational accidents; Develop fire and explosion prevention and fighting program, provide proper equipment for responding to the incident if any.

2. Operation Stage

1. Sanitation and Occupational Safety Measures

Equipment of the wastewater treatment facility comprises of various types. The Corporation will carry out working safety regulation in compliance with existing regulations. For all other machinery systems, the operation regulation will be elaborated based on their specs.

98 1. Safety for Workers: To train workers for working safety regulation. The Corporation shall cooperate with Working Safety Division of Dong Nai Department of Labor, War Invalid and Social Affairs to train on safety regulation and operation of specific equipments to secure safety; Provide proper protection uniform for workers. Train on and provide safety and sanitation information.

2. Fire and Explosion Prevention and Response Measures

1. Fire and Explosion Safety: Provide proper fire extinguisher Train workers on fire and explosion prevention and response Store inflammable fuels in isolated warehouses, far from ignition; install safety valve, temperature monitoring equipment, fire alarm for solvent tanks Provide adequate fire alarming system, information system; check and maintain the fire extinguisher properly. Smoking ban in inflammable zones Provide fire and explosion prevention equipment adequately.

2. Equipment

The fire extinguishing system shall be installed, comprising of: Fire –hydrant Foam and gas fire extinguisher Fire extinguisher for all workshops Water for firefighting: tower, pond

For the Operation Room: Provide ventilation system properly Design and install electricity system properly; regularly maintenance to prevent electricity leakage Install automatic fire alarm system and proper fire extinguisher in the inflammable zones. 3. Fire and Explosion Prevention and Response

In production spaces, fuel storage and product storage, there will be fire alarm, communication and alarming system. Fire prevention and extinguishing devices and means shall be regularly checked to ensure readiness;

99 Machines, equipment operated at high heat, high pressure will be managed via a profile of technical inspection and registration status at state functional bodies.; Inflammable solvents, fuels will be stored in isolated storage areas, far from potential source of fire, electrical spark. Fire extinguishing system is combined with distance of 10-12m among workshops for movement of vehicle and man, and sufficient space to prevent spread of fire. In fire risk spaces, workers must not smoke, carry lighter, matches and sparking or igniting tools;

The company will cooperate with Dong Nai Fire Fighting Police to elaborate fire prevention and response plan, training workers properly.

3. Fuel Leakage Prevention and Response

The investor will cooperate with competent agencies to inspect the specifications of the fuel storage system to prevent fuel leakage, specifically as follows: Regularly examine safety of fuel tank to maintain, replace broken device, prevent fuel leakage; Install fence around the fuel tanks, 5-10 m far from the tank; install warning board, fire ban properly Fuel and chemical tank truck shall be registered, inspected and maintained adequately. Raising public awareness on fire and explosion prevention and fighting

In addition, the investor will cooperate closely with competent agencies to elaborate fuel leakage prevention and response plan, inspect the technical system adequately.

4. Anti-Lightning

Install lightning prevention system at high positions of the factory; Install lightning conducting system, aggregated electricity conducting and system improvement which applies new technology to get safe height; Impulsive resistance < 10 while land’s resistance < 50,000 /cm2. Land-contacting impulsive resistance >10  while land’s resistance > 50,000 /cm2; Install the lighting prevention system for the whole project area and each workshop/warehouse properly; Using positive lightning prevention device; lightning conducting rods are installed across the project to protect the estimated height of 10-14m; Invest in the system in compliance with the infrastructure development construction schedule. 5. Failure of Centralized Wastewater Treatment System

Failure of centralized wastewater treatment system may occur since machines and equipment in the system, including pump, stirring machine, chemical gasification machine, are out of order (due to technical failure or power outage). Other possible

100 causes include worker’s failures to operate in accordance with technical requirements leading to death of microorganisms and temporary stoppage of centralized wastewater treatment system to replant microorganisms. Temporary stoppage of centralized wastewater treatment system will create a big accumulated and untreated volume of wastewater, leading to contamination of soil, water and air.

This incident can be avoided by conducting regular technical checks on operating machines and equipment, replace and repair timely broken ones; provide backup equipment, generator; provide proper technical training to workers.

One the incident occurs the investor will temporarily close all workshops that generate wastewater to discharge to the centralized wastewater treatment system.

PUBLIC INFORMATION PROGRAM AND COMMUNITY RELATION

2. Public Consultation in EMP Report Preparation

During the construction and operation of the CETP of Nhon Trach 3 IP, Phase 2, the project owners will publish all of the EMP information toward the People’s Committee and nearby residents so the public can monitor/ supervise the project.

The EMP includes these key points:  The organization and activities of project environmental department;  Training, awareness promoting of environmental issues and measures relating to the project;  Responsibilities of project owners in implement measures, impact mitigation activities in the situation of environmental catastrophic during both the construction and operation phases of the project;  Plans to operate environmental protection facility;  Plans to monitor wastes/emissions/ discharges sources and surrounding environment during both the construction and operation phases of the project.

3. Information Dissemination

The environmental management plan was approved and publicized at the people’s committee of Long Tho commune.

The environmental management plan covers: Organization and operation of the specific environmental division of the project; Environmental protection education and awareness strengthening; Responsibility of the project owner in implementation of adverse impact mitigation measures and environmental incident prevention and response in construction and operation stages; Environmental facilities operation plans;

101 Monitoring plan for waste sources: ambient air environment monitoring and other monitoring activities in construction and operation stages.

TRAINING

The Industrial Zone is in the process of determining the precise training needs of its staff and contracters to ensure efficient implementation of the EMP. The VIPMP will provide support for this training.

ORGANIZATION OF ENVIRONMENTAL MANAGEMENT AND RESPONSIBILITY FOR CETP AND IZ

The organization of environmental management and responsibility for CETP and Nhon Trach 3 IP includes Environment Department of Nhon Trach 3 IP – Phase 2 and CETP operation Team. Together other environmental management agencies at all levels in Dong Nai province form an organization structure as is shown in Figure below:

Figure 11: The Organization Structure of environmental management in Nhon Trach 3 IP – Phase 2

4. Environment Department of Nhon Trach 3 IP

1. Functions and Tasks

1. Function

To advise the corporation manager on environmental management, and wastewater treatment facility as well as to provide environmental consulting services for the customers.

To elaborate and propose environmental management plans, schemes and measures; the centralized wastewater treatment facility operation plan and to provide environmental consultation services for enterprises in and outside Nhon Trach 3 IP.

To cooperate with other competent agencies and customers in management the industrial park environment in compliance with “the Regulation on industrial parks, export processing zone and high-tech parks” which was promulgated together with Decree No. 36/CP in April 24, 2007 of the Government as well as other related regulations. To operate the centralized wastewater treatment system and other activities related to environment in the industrial park. To inspect, supervise, operate the centralized wastewater treatment facility and wastewater quality of enterprises in Nhon Trach 3 and conduct repairing in case of failure. To treat wastewater of Nhon Trach 3 IP meeting Vietnam standard prior discharging to the environment.

102 To manage, operate and utilize the centralized wastewater facility effectively and efficiently.

2. Tasks

Organise plans and required activities of the treatment plants, monitor business-related environmental contracts, and propose the Director for approval and implementation; Supervise land-renting investors on their contract to meet Environmental Protection laws. Follow the International Organisation for Standardsation (ISO 14001:2004) at the company; Ultilise the available resources, apply technology creativities on the managements of the treatment plants effectively; Supervise the effluent quality standard to ensure the treated waste water from Nhon Trach 3 meet all regulations before being released into the environments; Cooperate with Technical – Infrastructure Departments to maintain the plant and immediately repair any faults of the systems onsite; Hold responsibilities over the contract with environmental consultants; wastes treatments agencies, plant designers, drainage system supervisors and other economical-technical- environmental customers; Implements tasks from the Directors; Follow Organisational Regulations and Activities to promote company business; Implement operation plans and business developing activities as assigned by the company directors; Ultilise available resources, promote upgrades, apply scientific and technical innovations during the plant operation phase; Implement applied designs for the investors of company within Nhon Trach 3 IP; Maintenance the infrastructures of the centralised waste water treatment plant; Ultilise the assets, budgets of the company to continuously increase the efficiency of the business; Commit to provide and update information as requests by the company

2. Environmental Department Hierarchy

Figure 12: Environmental Department Hierarchy

5. CETP operation Team

1. Function and Task

1. Function

103 To manage and monitor compliance with the environment regulations stipulated at Decree No. 36/CP dated April 24, 1997 of the Government on “Regulation on industrial parks, export processing zones and high-tech parks”. To advise the corporation director on issues related to environment of Nhon Trach IP; to perform activities of the treatment facilities and other related activities related to environment in the industrial park. To inspect, monitor, operate the system and take remedial measures of the station and enterprises in Nhon Trach 3 IP prior transferring to the centralized treatment system. To treat wastewater of Nhon Trach 3 IP, Phase 2 in compliance with Vietnam standards prior discharge into environment. To manage, operate functions of the treatment facility effectively and efficiently. .

2. Tasks To perform the regulation on the Corporation organization and operation to promote business; To develop proper operation and business promotion plan, and submit to the corporation director for approval and organize the implementation; To exploit available resources effectively, R&D activities to improve the operation efficiency; To provide consulting services in designing, connecting, construction and supervision for investors in Nhon Trach 3 IP, Phase 2; To operate, maintain and repair the wastewater discharge infrastructure and centralized treatment system properly; To manage and develop the assigned fund effectively; To be compliance with information and reporting policy of the company as well as existing regulation; To perform other assigned tasks.

2. Organization Structure of CETP operation Team

Figure 13: Organization Structure of CETP operation Team

MONITORING PROGRAM AND CONTROL OF WATER QUALITY OF RECEIVING WATERS

The full monitoring program is under development and wil be subject to review and approval by VEPF.

6. Monitoring of the Centralized Wastewater Treatment Facility

104 The investor shall collect and analyze some pollution indicators at the treatment tanks and record the data properly to evaluate the operation daily. The monitoring shall be maintained properly.

Specifically as follows: To monitor the wastewater volume at every storage tank prior pumping to the centralized pipe to collect to the treatment system. To monitor the wastewater volume prior treatment (at the balancing tank) To monitor the sludge from the wastewater treatment system.

The mentioned tasks are performed daily.

7. Monitoring of Pre- and Post-Treated Wastewater Quality

Internal Check: + Are the wastewater treatment facility equipped with rapid metering and sampling equipment to analyze pH, SS, COD and temperature? The monitoring data shall be recorded as achieves to examine the treatment process. + Frequency: One in every day. + Install monitoring equipment to monitor basic indicators of the treated wastewater quality. Cooperate with competent agencies: The investor shall sign the contract with competent environmental analysis agencies to collect sample and analysis. Monitoring locations and indicators: 02 places

+ Pre-treated wastewater: pH, temperature, color, odor, COD, BOD5, TSS, total N, total P, ammonia (by Nitrogen), phenol, cyanua, Cr (VI), Cr (III), Cd, Pb, Cu, Zn, Ni, total Fe, Hg, As, Chloride pesticide, P-pesticide, mineral oil, vegetable oil, sulfur, and Coliform (28 indicators) + Treated wastewater: pH, temperature, color, odor, COD, BOD5, TSS, total N, total P, ammonia (by Nitrogen), phenol, cyanua, Cr (VI), Cr (III), Cd, Pb, Cu, Zn, Ni, total Fe, Hg, As, Chloride pesticide, P-pesticide, mineral oil, vegetable oil, sulfur, Chloride residue and Coliform (28 indicators) Comparing standard: QCVN 40:2011/BTNMT, column B, Kq=1.1, Kf = 1.0. Frequency: 4 times a year.

The analyzed results shall be compared to each other to evaluate the treatment efficiency and take necessary adjustment properly.

(The analysis and periodical environmental monitoring of Nhon Trach 3 IP provide data for local state management over environment adequately).

8. Monitoring of Water of Receiving Source at the Outlet

105 Monitoring locations: 2 places in Thi Vai River where receive wastewater of Nhon Trach 3 IP.

Analyzing indicators: pH, DO, SS, COD, BOD5, N-NO2, N-NO3, coliform. Comparing standard: QCVN 08:2008/BTNMT, column B2. Frequency: Twice a year.

3. CAPACITY BUILDING

To build the capacity of the project, the owner will carry out these measures: Workers working on-site will be frequently trained to deal with fire and explosions- related situations Train and assign tasks/ measures to mitigate the effect when the treatment plant encounters failure. This situation would also can be avoided by frequent maintenance and repairing of all equipments, machines onsite (the maintenance workers have to be trained and skillful at the job) Provide the workers all safety information about the plant. In the same time, the company will cooperate with Work Safety Office and Dong Nai Department of Labour- Invalids and Social Affairs to set up a safety guide for every step of the plant operation and allow the workers to understand their own responsibilities of the site’s safety.

A comprehensive training and capacity building program is outlined in the project’s ESMF and will be implemented in the Nhon Trach 3 IZ. It has been reviewed by the IZA and considered to be appropriate in scope for the needs of the IZ. During project implementation the EMP will be further updated with specific training needs if these are identified, above and beyond what will be covered in the standard program.

ESTIMATED COST AND TIME FOR IMPLEMENTATION OF EMP

EMP Budgets

Total budgets for the Environmental management Plan is presented I table below:

Table 41: EMP Budgets

No Items Costs Note 1. Construct the EMP report 71,000,000 Hire consultant 2. Monitoring process 2.1 During Construction 20,000,000 1 year . 2.2 During Operation 36,000,000 1 year .

EMP Schedule

106 The EMP schedule is listed in this table below

Table 42: EMP schedule

No Items Schedule 1. Construct the EMP May 2012 2. Carrying out the EMP Along with the construct of the treatment plant

107 CHAPTER 4 PUBLIC CONSULTATION

1. THE OBJECTIVE OF PUBLIC CONSULTATION

1. Toward Evaluation Authority

Based on the consulting from local authority and the public from the affected areas, it will assist Evaluation Authority to have a more complete view over the project, and make the process (of project evaluating) more efficient

2. Toward project owner

Receive feedback from local government and the public from the affected areas. From there, provide realistic and effective mitigation proposals and assessments. In the same time, hold up responsibilities to carry out mitigation to reduce long and short-term negative impacts from the projects

Furthermore, create understandings between the project investor the affected public.

3. Toward consulting agencies

Receive feedback from local government and the public from affected areas. From there, provide realistic and effective mitigation proposals and assessments.

4. Toward the People’s Committee and Fatherland Front Committee

Assist the authorised body to understand more on the projects through these points: benefits from carrying out the Project, the environment impacts, and negative effects mitigation methods.

This will create more understanding from local government toward the project

5. Towards the public from affected areas

Help the public to understand more on the projects through these points: benefits from carrying out the Project, the environment impacts, and negative effects mitigation methods.

This will create more understanding from the public; include acknowledging their raise of concerns toward the project

108 PUBLIC CONSULTATION IMPLEMENTATION

The public consultant was conducted with the people committee and the fatherland front committee of Long Tho commune. The contents are as follows: The project scale and characteristics; The project impacts on natural, socio-economic environments; The adverse impact mitigation measures of the project and Other issues if any.

Project owners have consulted these groups: People Committee and fatherland Front Committee in Long Tho (project location) The public, including residents lives nearby and will be affected by the projects

The planned activities are: Toward People Committee and fatherland Front Committee in Long Tho, the project owner has sent official dispatch toward these local governmental bodies. The official dispatch is attached along with this report; Towards the residents who live nearby and under effects of the project, the project owners have sent a survey to take their opinions and feedbacks about the projects. The surveys are also attached with this report

2. RESULTS OF PUBLIC CONSULTATION

1. Results from consulting the People’s Committee

1. On environmental and socio-economical negative impacts Project “Construct a CETP with capacity 2,000 m3/day at Nhon Trach 3 IP – Phase 2” at Long Tho Commune, Nhon Trach District, Dong Nai Province” will assist the government on the quests of environmental protection, residential health enhancements, therefore will be very essential in Dong Nai environmental protection plan. The People’s Committee of Long Tho Commune fully agree with points raised in this EMP report over environmental and socio-economical issues

2. Project Environmental Impact Assessment People’s Committee of Long Tho Commune has agreed with the environmental impact mitigation plan proposed by the project.

3. Feedbacks toward project owner Project owners need to pay special attention toward the environment protection efforts during the construction and operation of the project

109 Need to frequently assess, maintain the wastewater treatment plants, and avoid expected accidents that can affect the local environments and publics. Need to provide safety equipments for working staffs onsite to ensure their health and reduce risks when accidents occurred. This needed to be done in both construction and operation phases.

2. Results from consulting the Fatherland Front Committee

1. On environmental and socio-economical negative impacts Project “ Construct a CETP with capacity 2,000 m3/day at Nhon Trach 3 IP – Phase 2” at Long Tho Commune, Nhon Trach District, Dong Nai Province” will assist the government on the quests of environmental protection, residential health enhancements, therefore will be very essential in Dong Nai environmental protection plan. The People’s Committee of Fatherland Front Commune fully agree with points raised in this EMP report over environmental and socio-economical issues

2. Project Environmental Impact Assessment People’s Committee of Long Tho Commune have agree with the environmental impact mitigation plan proposed by the project Need to provide safety equipments for working staffs onsite to ensure their health and reduce risks when accidents occurred. This needed to be done in both construction and operation phases.

3. Feedbacks toward project owner Project owners have to follow legal regulations during both construction and operation phase of this treatment plant. Project owners have to carry out all environmental impact mitigation plan proposed by the project Project owners have to ensure order and security, and avoid conflicts between workers from different provinces and local residents

3. Results of consultations with the public

The results of consultations with the public are summarized below:

110 Table 43 Public consultations

Is affected by the Agree N Gen Birth Water Name Address project on the Other opinions o der year sources Air Quality projectHealth Others Response The project Adequately owner should reflected in ensure treated EIA Hamlet 2, Long Tho Nguye wastewater Mal Commune, Nhon Trach 1 n Van 1969 Well No No No meet national e District, Dong Nai Bang regulation Province

Hamlet 3, Long Tho Treat the Reflected in Nguye Mal Commune, Nhon Trach wastewater project design 2 n Tan 1956 Well No No No e District, Dong Nai and reduce Phuc Province pollution 384/19 Hamlet 2, Long Le Anh Mal Tho Commune, Nhon 3 1990 Well No No No Tuan e Trach District, Dong Nai Province

111 Is affected by the Agree N Gen Birth Water Name Address project on the Other opinions o der year sources Air Quality projectHealth Others Response Project owner Reflected in should project design cooperate with local government to monitor and Hamlet 2, Long Tho prevent solid Tran Mal Commune, Nhon Trach wastes and 4 Quoc 1964 No No No e District, Dong Nai wastewater to Hung Province enter the open water

The project Design of owner should discharge and be careful with drainage the discharge system has Nguye 877/1 Hamlet 2, Long during rain, to taken into n Thi Fem Tho Commune, Nhon 5 1969 Well No No No prevent flood account Kim ale Trach District, Dong Nai onto potential Lien Province residential flooding (see houses near Lo also text below Ren table)

Hamlet 2, Long Tho Nguye Fem Commune, Nhon Trach 6 n Thi 1955 Well No No No ale District, Dong Nai Lot Province, Dong Nai

112 Is affected by the Agree N Gen Birth Water Name Address project on the Other opinions o der year sources Air Quality projectHealth Others Response Ensure the Reflected in treated project design 859/6/7 Hamlet 2, Long wastewater Huynh Odours from Fem Tho Commune, Nhon meet the 7 Thi 1967 Well No No wastewater affects ale Trach District, Dong Nai standard and Nam the family Province won’t cause offensive odours 815/34/2 Hamlet 2, Long Nguye Fem Tho Commune, Nhon 8 n Thi 1950 Well ale Trach District, Dong Nai Dien Province Hamlet 2, Long Tho No Opinion Nguye Fem Commune, Nhon Trach 9 n Thi 1958 Well No No No ale District, Dong Nai Luom Province The project See above. owner should be careful with the discharge Hamlet 2, Long Tho Phan during rain, to Fem Commune, Nhon Trach 10 Thi 1971 Well No No No prevent flood ale District, Dong Nai Hong onto Province residential houses near Lo Ren

113 Is affected by the Agree N Gen Birth Water Name Address project on the Other opinions o der year sources Air Quality projectHealth Others Response The project See above. owner should be careful with Hamlet 2, Long Tho Phan the discharge Fem Commune, Nhon Trach 11 Thi 1964 Well No No No to prevent ale District, Dong Nai Loc flood onto Province residential houses near Lo Ren Hamlet 2, Long Tho No Opinion Nguye Fem Commune, Nhon Trach 12 n Thi 1968 Well No No No ale District, Dong Nai Luoc Province Please See above. excavate Lo Ren frequently, Tran Hamlet 2, Long Tho prevent Thi Fem Commune, Nhon Trach 13 1959 Well No No No wastewater Thu ale District, Dong Nai stagnant, Mai Province causing flood during rain

Ensure the Reflected in Hamlet 2, Long Tho treated project design Tran Mal Commune, Nhon Trach wastewater 14 Ngoc 1975 Well No No No e District, Dong Nai meet the Thanh Province standard

15 Phan Fem 1989 Hamlet 3, Long Tho Well No No No No Opinion

114 Is affected by the Agree N Gen Birth Water Name Address project on the Other opinions o der year sources Air Quality projectHealth Others Response Commune, Nhon Trach Thi ale District, Dong Nai Nhung Province 861, Hamlet 2, Long Tho No Opinion Nguye Fem Commune, Nhon Trach 16 n Thi 1958 Well No No No ale District, Dong Nai Tuyet Province Hamlet 3, Long Tho No Opinion Nguye Fem Commune, Nhon Trach 17 n Thi 1989 Well No No No ale District, Dong Nai Nuu Province Le 808, Hamlet 2, Long Tho Flood during See above. Binh Fem Commune, Nhon Trach rain, The water 18 1977 Well Yes Yes No Phuon ale District, Dong Nai colour is dark g Kim Province The project See above. owner should be careful with the discharge during rain, to prevent flood Doan Hamlet 2, Long Tho onto Bich Fem Commune, Nhon Trach residential 19 1961 Well No No No Nguye ale District, Dong Nai houses near Lo n Province Ren

115 Is affected by the Agree N Gen Birth Water Name Address project on the Other opinions o der year sources Air Quality projectHealth Others Response Before Lo Ren discharge is 874, Hamlet 2, Long Tho Tran showed to be Fem Commune, Nhon Trach 20 Kim 1969 Well No No No darken, ale District, Dong Nai Kieu however it Province have stopped recently Hamlet 2, Long Tho No Opinion Huynh Fem Commune, Nhon Trach 21 Thi 1971 Well No No No ale District, Dong Nai Nhieu Province Hamlet 3, Long Tho No Opinion Truong Mal Commune, Nhon Trach 22 Dinh 1964 Well No No No e District, Dong Nai Huu Province 877, Hamlet 2, Long Tho No Opinion Huynh Mal Commune, Nhon Trach 23 Van 1959 Well No No No e District, Dong Nai Hoa Province Hamlet 2, Long Tho Ensure flow Reflected in Le Van Mal Commune, Nhon Trach from Lo ren project design 24 1948 Well Yes Yes No Dao e District, Dong Nai and reach the Province main river

116 Based on the survey as above, few key points can be summed up as below: Most people agree with the construction of the CETP for Nhon Trach 3- Phase 2 (Module 2). Most of the others have no comments on the issues Many residents faced the issues of flooding from the canal during rainfall, and expected the project owners to have counter-measures for this problem

Project investors comments:

Currently the flooding issues at Long Tho Commune is caused by the discharge of Nhon Trach 6 IP, Nhon Trach Clothing IP,and current Nhon Trach 3 especially during high rainfall.

However, based on industrial parks planning, Nhon Trach 6 IP and Nhon Trach Clothing IP discharges will soon going through the discharge road at Suoi Can Bridge and Cai Sinh Canal, once the pipe network there constructed, hence relieve the flowrate through Mareng Canal (and reduce the flood issues here). Currently, the Cai Sinh Canal project have already been proposed by Nhon Trach People Committee and Dong Nai Department of Infrastructure and Planning to Dong Nai People Committee for fundings in fourth quarter of 2012, and start construction in early 2013.

INFORMATION DISCLOSURE

The Vietnamese version of the EIA was disclosed locally on July 16 2012 at Dong Nai DONRE office, Dong Nai Industrial Zone Management Board Office, Division of Natural Resources and Environment of Nhon Trach District; and Long Tho Commune People's Committee. It was also disclosed at the Vietnam Development Information Centre (VDIC) on July 17, 2012.

The English version was disclosed at VDIC on July 6 2012 and in the InfoShop on May 2, 2012. The final versions will be disclosed at the completion of Project appraisal.

3. COMMITTMENTS OF THE PROJECT OWNER

Project owners promised to follow all Vietnam regulation during the construction and operation of the project, include:

+ Nearby air quality: Air emissions have to meet Vietnam regulations (QCVN 05:2009/BTNMT, QCVN 06:2009/BTNMT). + Noise: have to be below the regulated level allowed for residential areas (QCVN 26:2010/BTMNT). + Treated wastewater: reach Vietnam regulation QCVN 40:2011/BTNMT – National regulation about industrial discharge, Column B, Kf=1.0, Kq=1.1. + Solid wastes: All domestic solid wastes will be contracted to be sorted and treated appropriately. + Sludge: is dewatered, compressed and transported to appropriate site. + Hazardous wastes: Stores under covers, then hand to authorized agents to handle.

117 + Hazardous and non hazardous wastes are collected, transported, and treated as Decree 59/2007/ND-CP on solid wastes and Circular 12/2011/TT-BTNMT of MONRE on hazardous wastes Project owners promise will apply safety features to reduce risks and environmental negative impacts as presented in the report, while strengthen the training of ground staffs to ensure effective operation of the system The project owner will take full responsible in front of Vietnam Law if violate International Convention or Vietnam Regulation.

118