Kep Solid Waste Improvement, Cambodia

Environmental Management Plan ______

May 2020

Cambodia: Second Greater Mekong Subregion Tourism Infrastructure for Inclusive Growth Project

Kep Solid Waste Management Improvements, Kep Province, Cambodia

Detailed Design

Prepared by the Ministry of Tourism for the Asian Development Bank.

This environmental management plan is a document of the borrower. The views expressed herein do not necessarily represent those of ADB's Board of Directors, Management, or staff, and may be preliminary in nature. Your attention is directed to the “terms of use” section on ADB’s website.

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

CURRENCY EQUIVALENTS (as of April 2020)

currency unit – Riel KR R1.00 = $0.00024 $1.00 = KR4,004

ABBREVIATIONS ADB - Asian Development Bank CEMP - contractor’s environmental management plan DAFF - Department of Agriculture, Forestry and Fisheries DOE - Department of Environment DPWT - Department of Public Works and Transport DOT - Department of Tourism DOWRAM - Department of Water Resources and Meteorology EA - executing agency EIA - environmental impact assessment EMC - environmental monitoring consultant EMP - environment management plan EO - environmental officer ERT - emergency response team FS - Feasibility Study EERT - external emergency response team ESS - Environmental safeguard specialist GMS - Greater Mekong Sub-Region IEE - initial environment examination IEIA - initial environmental impact assessment MAFF - Ministry of Agriculture, Forestry and Fisheries MOE - Ministry of Environment MPWT - Ministry of Public Works and Transport MOT - Ministry of Tourism MOWRAM - Ministry of Water Resources and Meteorology MRF - material recovery facility PAM - project administration manual PCU - project coordinating unit PIU - project implementation unit PMCES - project management and civil engineering support consultant PPTA - project preparatory technical assistance RP - resettlement plan STF - septage treatment facility SPS - safeguard policy statement (2009) SLF - Sanitation Landfill

WEIGHTS AND MEASURES km - kilometer kg - kilogram Hectare ha -

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

TABLE OF CONTENTS

I. INTRODUCTION ...... 1 II. INSTITUTIONAL ARRANGEMENTS & RESPONSIBILITIES ...... 8 A. Worker and Community Health and Safety ...... 11 B. Regulatory Framework for Kep Subproject ...... 11 III. SUMMARY OF POTENTIAL IMPACTS ...... 12 A. Comprehensive Corrective Environmental Action for Kep Subproject ...... 14 B. Summary of Public Consultation in Provincial and Kep Town ...... 15 IV. MITIGATION PLAN ...... 17 V. MONITORING PLAN ...... 34 VI. ESTIMATED COST OF EMP ...... 39 VII. INSTITUTIONAL CAPACITY REVIEW AND NEEDS ...... 40 VIII. EMERGENCY RESPONSE PLAN ...... 42 A. Alert Procedures ...... 43 B. Emergency Response Situations...... 44

APPENDIXES A. Indicative Responsibilities of Key Management Units of EMP ...... 48 B. Reference Environmental Standards ...... 50 C. Indicative Plan for Remaining Public Consultation ...... 53 D. MOE Unit Costs for Groundwater Quality Analyses ...... 54 F. Pictures Of Public Consultation Meeting ...... 70 G. Soil Drilling Testing ...... 71 H. Result of Air, Noise, Vibration and Water Quality Test for Base Line ...... 76 I. License of IESIA from MOE ...... 81

LIST OF FIGURES

Figure 1. Project Location Map ...... 2 Figure 2. Excavated Soil and Existing Waste at Kep Dumpsite ...... 4 Figure 3. Plan View of Access Road and New SLF (From Fig 1b) ...... 5 Figure 4. Plan View of SLF...... 6

LIST OF TABLES

Table 1: Regulations and Guidelines Applicable to the Subproject ...... 12 Table 2. Summary of Potential Impacts of Solid Waste Subproject in Kep ...... 13 Table 3. Summary of Key Requirements of Landfill Siting and Design** ...... 14 Table 4. Impact Mitigation Measures Plan ...... 18 Table 5. Environmental Monitoring Plan ...... 36 Table 6. Performance Monitoring Indicators for Kep Subproject ...... 38 Table 7: Estimated Costs for Environmental Monitoring Plan of EMP ...... 39 Table 8. Indicative Training On EMP Implementation ...... 40 Table 9: Roles and Responsibilities in Emergency Incident Response ...... 42 Table 10: Evacuation Procedure ...... 45 Table 11: Response Procedure During Medical Emergency ...... 45 Table 12: Response Procedure in Case of Fire ...... 46

I. INTRODUCTION

1. The detailed design (DED) of the subproject of the Second Greater Mekong Sub-Region (GMS) Tourism Infrastructure for Inclusive Growth Project (TIIG) that will improve solid waste management in Kep, Cambodia has been completed. The original Initial Environmental Examination (IEE) of the Feasibility Study (FS) of the subproject has been updated to meet the DED of the subproject and is reported separately. The environmental management plan (EMP) provided herein has been updated to support of the updated IEE.

2. The primary purpose of the EMP for the Kep subproject is twofold:

a. Prescribe required mitigation and monitoring requirements for potential environmental impacts of the subproject that are identified by the updated IEE, institutional responsibilities for implementation of the EMP, and the cost of the EMP implementation; and b. Provide the needed guidance for contractors to prepare the Contractor’s Environmental Management Plan (CEMP) which they must include with their bids for construction package(s).

3. The EMP will be appended to contractor tender documents. The CEMPs will prescribe the mitigation and monitoring requirements for which contractors are responsible for their specific construction packages. As indicated above, the CEMPs will be reviewed and approved by the Project Management and Civil Engineering Support Consultant (PMCES) and Project Implementation Unit (PIU).

Subproject components

4. The improvements to solid waste management in Kep consist of the following two main components:

a. upgrading of existing Kep dumpsite to a modern sanitary landfill (SLF); and b. improvements to solid waste collection and management in Kep and vicinity.

5. The SLF will consist of the following main components:

a. four lined waste cells to be constructed serially over time; b. a leachate collection and treatment system; c. a septage treatment system; d. a hazardous waste disposal cell; e. a materials recovery facility (MRF) to modernize waste recycling; f. office, utility/storage buildings, and onsite waste loaders/movers; and g. an upgraded 3.0km access road to SLF, to improve the existing dirt road by proper vertical alignment, concrete pavement, adequate side drains and cross drainage;

6. Improved solid waste collection will consist of:

a. segregated recyclable waste collection created by a major O&M program and awareness campaign

b. new compactor and vacuum trucks; c. urban garbage bins of various sizes; d. expanded catchment for solid waste collection; e. new staff to work with operator (Kep Municipality) of SLF; and f. training and capacity development of existing and new solid waste management staff.

Figure 1. Project Location Map

a) aerial view map of proposed location of 13.39 ha selected

Source: from IESIA

b) topographic map of proposed location of 13.39 ha selected

Source: from IESIA

7. The SLF site (existing dumpsite) is located 6 km north of the Municipality of Kep and it is 3.5 km from the national road 33 at Northeast. It will occupy a small, gently to moderately sloping valley underlain by weathered and fractured metamorphic rocks. The SLF will be constructed within a former borrow pit where waste has been dumped since 2014. The existing waste has been partially been burned out and will initially be excavated and replaced in a man-made pit at the easternmost section of the property. The pit is currently partially filled with waste. The project location of Kep Control landfill is covering on 13.39 hectares that it locates in the existing dumpsite in the Damnak Chang Ae village, Sangkat Prey Thom, Kep City that it is the property of Kep Province.

8. Small catchments areas drain the steep to very steep areas northeast, east and southeast of the site. Two courses of streams come down in the eastern end of the site, while some smaller courses come in the southern side. Storm water from these must be collectively channeled around and past the SLF site.

9. Fractured rocks are either exposed or very close to the surface, and there is limited clay in the area. The soil cover at the site ranges in depth from < 1m to 7m, as illustrated in the Figure 2, which also shows the current disposal and open burning practices.

Figure 2. Excavated soil and existing waste at Kep dumpsite

Source: From Norconsult, footnote #5

10. Also shown in Figure 4 (as map in appendix G) are the five test boreholes (BH1 – BH5) from which soil and groundwater samples were extracted. The drilling results indicate a soil/weathered rock cover which ranges from 3 to 7m in thickness. The underlying rocks are fractured, so the site will require an artificial liner, preferably of HDPE which will be determined by the PMCES before construction begins. Toward the end of the wet season, groundwater was present within a weathered zone at depths between 1- 3.3 m. so excavation in waste Cell 1 and Cell 2 will be limited compared to Cells 3 and 4. The groundwater quality and soil type data are presented in next chapter on the Description of Affected Environment.

Figure 3. Plan view of access road and new SLF (from Fig 1b)

Source: From Norconsult, footnote #5

Figure 4. Plan view of SLF

Source: From Norconsult, footnote #5

Facilities and other components of the SLF project

- Cell 4 set 70.595 m2 - Wetland 1 set 187 m2 - Sedimentation Treatment Pond 1 set 324 m2 - Aeration Treatment Pond 1 set 130.5 m2 - Septage Treatment Drainage 2 set 800 m2 - Hazardouse Waste Secure Landfill 1 set 450 m2 - Service Building and Workshop 1 set 250 m2 - Parking 1 set 71.5 m2 - Administration and Wardrobes 1 set 200 m2 - Future Weighing Bridge 1 set 30 m2 - Future Guard House 1 set 6.26 m2 - Washing Bay 1 set 44 m2 - Ramp 2 set 26.4 m2 - Materials Recovery Facility (MRF) 1 set 580 m2 - Truck Parking 1 set - Roof Covered Storage For Hazardous Waste 1 set 180 m2 - Landfill Gas (LFG) Facility 1 set 20 m2 - PVC 2 Ø 90mm - Storm Water Canal/Ditch 1 - - Weir of Reservoir 1 - - Fence 1 1,400 m (L) * 2m (H)

11. The principal design of the SLF including facilities and infrastructure has been developed with consideration of the existing site conditions with recent topographic maps. The SLF will have four (4) waste cells with a combined estimated footprint of 68,000 m3 and a capacity of about 600,000 to 700,000 m3 depending on the final height of the landfill. This will allow for minimum 20 years of operation. The existing waste will be bulldozed and reshaped into a separate cell and permanently capped.

12. A Landfill Gas (LFG) extraction system (see below) which consists of extraction wells/channels, pipeline system and processing facility, will be installed at the reshaped capped cell of old waste at the same time, and as a part of tendering and construction. This will be included as an optional item depending on test pumping indicating LFG of adequate volumes and quality.

13. Waste cell development will be from the east to west. The soil and weathered rock materials to be excavated from Cell 1 will partly be used for the capping of the old waste cell. The excess will be temporarily stored at Cell 2 area for subsequent use for temporary cover during the operation of Cell 1.

II. INSTITUTIONAL ARRANGEMENTS & RESPONSIBILITIES

National Level

1. Ministry of Environment (MoE) 2. Ministry of Public Work and Transport (PMU)

Under Stational Level

1. Kep provincial Hall 2. Kep Municiplity 3. MoE of Kep 4. Department of Public Work and Transports of Kep (PIU) 5. Department of Water Resource of Kep 6. Department of Agrilculture, Forestry and Fisheries 7. Department of Rural Development 8. Department of Skills Development and Vocational Training Vacancies 9. Department of Land management, Construction and Land title 10. Firefighting Unit 11. Commune leader of Prey Thom and relevant villages

14. For the detailed design (DED the main management framework for implementation of the environmental management plan (EMP) for the Kep solid waste management improvements subproject is summarized below as the direction line of management.

15. The Ministry of Public work and Transport (MPWT), which is the executing agency (EA) for the project, will take overall responsibility for successful implementation of the EMP. The EA will establish a Project Management Unit (PMU) based in Phnom Penh, which will be responsible for general project implementation. The Implementation Agency is the Provincial Department of Public Work and Transport (PDPWT) for this subproject in Kep province. The PDPWT will establish a Project Implementation Unit (PIU) in this subproject in Kep province, comprising relevant provincial departments/government representatives including provincial department of environment (PDoE) and provincial department of tourism (PDoT).The PIU with support from the IA will implement the EMP. The PIU will include an Environmental Safeguards Specialist (ESS) who will lead the implementation of the EMP in conjunction with the designated Environmental Officer(s) (EO) of the construction contractor(s). The tender documents for construction packages will specify the requirement for an experienced EO.

16. A Project Steering Committee (PSC) will be created to provide policy and technical guidance for subproject implementation. The PSC is chaired by the EA and comprising relevant agency representatives including Ministry of Environment, General Department of Resettlement (GDR), Ministry of Tourism and Ministry of Labor as a minimum.

17. The Safeguards Coordination Unit of the PCU as indicated in PAM will provide operational guidance to the PIU for EMP implementation and will liaise with the ADB on safeguard reporting and issues. The PIU’s Safeguards Specialist will oversee the work of the EO to implement the CEMP.1

18. External support to the IA/PIU for implementation of the EMP will be provided by the International and National Environment Specialists (I/N-ES) of the Project Management and Civil Engineering Support Consultant (PMCES) and an external Environmental Monitoring Institute (EMI) which will conduct the field sampling and laboratory analyses of environmental quality (e.g., water quality, air quality) that cannot be performed by the contractor or PMCES. The ToR for the EMI is appended to EMP.

19. ADB is responsible for monitoring in order to ensure that the component meet the environmental safeguards of the SPS (2009)

20. The responsibilities of different agencies in the management framework are listed in Appendix A. Provided below is a summary of responsibilities for EMP implementation.

21. The EA will hold overall accountability of the project implementation and operation on behalf of the Royal Government of Cambodia. The responsibility of EA in relation to the environment safeguards requirement are summary in below:

 Overall responsibility for subproject implementation and establish of Project Management Unit (PMU)  Approval procurement plans, bidding documents, bid evaluation and contract awards including EMP  Submit regular quarterly and annual subproject reports to ADB including the EMP implementation reports  Ensure compliance of subproject/component implementation with ADB’s social and environmental policies and guidelines;  Approve proposed actions in the event of adverse audits or monitoring and evaluation reports.  Ensure compliance of Loan Covenants

1 Contractor Environmental Management Plan prepared by contractor, based on updated EMP.

22. The responsibility of PMU in the relation to the safeguards requirement are summarized in below:

 Undertake day to day management of subproject activities  Implementation approval annual rolling work and financial plan  Prepare and submit regular quarterly and annual subproject/component report including environmental safeguard report  Liaise with ADB on the EMP implementation and supervise civil work of the contractor;  Ensure that EMP are incorporated in the detail designs and include in civil work contracts  Ensure EMP implementation and submit regular monitoring report to IA and EA  With assistance from PMU submit semi-annual environmental monitoring reports to ADB;  Dissemination and coordination of Grievance Redress Mechanism (GRM), and  Resolve with the PMU, and ADB if necessary, issues arising from the implementation of EMP.

23. The key responsibilities of the PMCES international and national environmental specialists for the EMP are listed below:

 Update the EMP to meet final detailed designs of subprojects;  Assist PIU add EMP requirements to construction tender documents;  Assist PIU review submitted CEMPs  Provide technical direction and support to the PMU/PIU for implementation of the EMP;  Oversee the design and delivery of capacity development and training for the PIU and EO of contractor(s);  Provide advice and support to the EMI to conduct their monitoring activities;  Review all reports prepared by the PIU, EMI, and PCU; and  Review the location of any possible contaminated sites near subprojects.

24. The responsibilities of the contractor’s Environmental Officer (EO) include:

 Prepare the CEMP to be approved by the Engineer  Implement the CEMP during construction; and  Prepare and submit monthly reports on mitigation and monitoring activities of the CEMP and any environmental issues at construction sites.

25. The responsibilities of Environmental Monitoring Institute (EMI) include:

 Implement the environmental sampling required in the EMP monitoring plan, which cannot be conducted by the contractor or PIU.  Perform required laboratory analyses for the EMP monitoring program; and  Prepare and submit quarterly reports to the PIU on monitoring activities.

26. The Department of Environment (DOE) is the provincial agency which oversees environmental management of Kep. The DOE with District staff provides direction and support for environmental protection-related matters including application of the Law on Environmental Protection and Natural Resources Management, Preah Reach Kram/NS-RKM-1296/36, enacted by Minister of Environment, 1996; EIA, and environmental standards.

27. ADB provides guidance to EA/PCU with any issues related to EMP and reviews quarterly and semi-annual safeguards monitoring reports on EMP activities compiled and submitted by PCU.

A. Worker and Community Health and Safety

28. In 2003 the International Labour Organization (ILO) created the New Global Strategy for Occupational Safety and Health (OSH). Based on the OSH2 the Ministry of Labour and Vocational Training (MLVT) through the Department of Occupational Safety & Health, developed the Occupational Safety and Health Master Plan (OSHM; 2009-2013) of Cambodia.

29. The OSHM, inter alia, addresses worker and public safety in the construction and operation of small-medium enterprises and notably rural roads. The EA/PCU as supported by the PIUs must obtain and implement the directives of the OSH Master Plan. The pertinent associated law and directives is the Labour Law of Cambodia (1997), with specific reference to chapter VIII governing health and welfare of workers and the public. However, The OSH directives for Cambodia will need to be supplemented with the international the IFC EHS/OSH Guidelines for Construction and Decommissioning, Waste Management Facilities, and Toll Roads. The contractor will have to identify how they will use the appropriate national and IFC OHS guidelines in their bid documents for joint review by the PMCES and PIU.

B. Regulatory Framework for Kep Subproject

30. Applicable national regulations and guidelines for the improvements to solid waste management drawn from the IEE are summarized in Table 1. The regulations and guidelines identify how solid waste should be managed to prevent or minimize negative impacts on the environment. The current environmental standards for Cambodia are provided in Appendix B. See the IEE for the complete legal and regulatory framework for environmental management in Kep province.

2 ILO. 2009. Asean-Oshnet, Occupational Safety and Health Practices.

Table 1: Regulations and Guidelines Applicable to the Subproject

Solid Waste Management

 Law on Environmental Protection and Natural Resources Management, Preah Reach Kram/NS-RKM-1296/36, enacted by Minister of Environment, 1996,  Sub-decree No. 72 ANRK.BK on EIA process (MoE, 1999),  Sub-decree No. 36 ANRK.BK on Solid Waste Management (MoE, 1999),  Sub-decree No. 27 ANRK.BK on Water Pollution Control (MoE, 1999),  Sub-decree No. 42 ANRK.BK on Air Pollution Control and Noise Disturbance (MoE,2000),  Technical Guidelines on Garbage and Urban Solid waste Management (MOE 2016),  Sub-decree No. 113 ANRK.BK on Management of Urban Garbage and Solid Waste (MoI and MoE, 2015),  Sub-decree on No. 235 on Drainage System Management and Wastewater Treatment Plant (MoI, MPWT and MoE, 2017),  Directive Managing Health Wastes in the Kingdom of Cambodia (MOH, 2008),  Directive on Industrial Sludge Management (MOE, 2000), and  Directive on Industrial Hazardous Waste Management (MOE, 2000).

31. The operation and management of the upgraded solid waste management system of Kep including garbage generation, collection, transport, treatment and disposal at the upgraded landfill must also follow the IFC EHS Guidelines for Waste Management Facilities and Tourism & Hospitality.

III. SUMMARY OF POTENTIAL IMPACTS

32. The potential environmental impacts of improvements to solid waste management in Kep from the updated IEE are summarized in Table 2. The required mitigation measures for the three phases of the implementation of the subproject (pre-construction, construction, and operation) are detailed in the Mitigation Plan below.

Public Consultation

33. The second series of public consultations were conducted for the DED of the subproject in Kep in October 2018. The issues and concerns of the consultations which are reported in the updated IEE in April 2020 are addressed by this EMP. Input from stakeholders on the subproject will continue through to the operational phase of the completed SLF which is tabled in Appendix C. As indicated in Appendix C, the DPWT and Kep Municipality must assume responsibility for receiving stakeholder input on the completed project, and for convening public stakeholder meetings on improved solid waste management in Kep when required. The DOE should also be directly involved to address any issue of environment, or to clarify any aspect of environmental management of the improved solid waste management.

Table 2. Summary of potential impacts of solid waste subproject in Kep

Pre-construction Phase

 None, no resettlement or land acquisition compensation is required

Construction Phase

Physical Resource:  Air, dust, and noise, water quality contamination (surface and ground water) from excavation and earthworks along the access road and from the removal and disposal of existing solid waste deposit  potential contamination of soil and the adjacent seasonal streams and heavy equipment maintenance that occurs too near the streams,  solid and liquid construction waste, wastewater from the camp sites,  contamination of groundwater from the excavations of waste cells, Biological Resource:  Hunting birds or reptile or other wildlife by workers of project, Health, Safety and Social matter  increased risk of traffic and risk of traffic accidents,  disruption of traffic and on-going extraction and hauling of construction materials from operating borrow areas)  reduced local access to the area, and transmission diseases  increased risk of public and worker injury,  periodic local drainage and flooding events,  minor disruption of waste picking and recycling, since most of separation of recyclable materials is done before the garbage truck collection,  depending on outside worker population, potential social problems with local community.  No external borrow pits will be required during construction because all required soil will be obtained on site of SLF.

Operation Phase

 contamination of groundwater by new waste cells and insufficient leachate treatment  increased traffic and risk of traffic accidents, noise, odor and dust along upgraded access road and from the sanitary landfill.

A. Comprehensive Corrective Environmental Action for Kep Subproject

34. The DED of the new SLF along with improved solid waste collection (including septage and hazardous waste) for Kep and vicinity provides the corrective action that meet the requirements of the current national SWM directives listed below.

 Technical Guidelines on Garbage and Urban Solid waste Management (MOE 2016)  Management of Urban Garbage and Solid Waste, RGC Decree No. 113, NKR-PR 2015;

35. The components of the DED of the new SLF and improved solid waste collection in Kep provide significant improvements to environmental protection and management of the affected environment that meet the key requirements specified by MOE (2016) which are summarized in Table 3 with the following comments. Item #2 is not possible because Kep province is too small and suitable well drained locations are within 10km of Kep town. The updated ADB EMP will be submitted to MOE as per due national IEIA/EIA process which will assist with item #11.

Table 3. Summary of key requirements of landfill siting and design**

1) Landfill site selection should be done based on district land use plan, if available, and have City Hall (provincial authorities) approval for the site. 2) Landfill sites should be preferably over 10km away from town centers in the most suitable available location to allow for urban expansion. 3) A thorough geotechnical study is required to confirm depth to groundwater for each site and should identify the complex nature of groundwater and the direction of flow which is essential for groundwater monitoring. Groundwater cleanup when contaminated is difficult so contamination prevention in the landfill design is essential. 4) Regarding landfill site selection and distance to airports, the key concern is increase in number of birds which may impact on aircraft safety, whereas for residential housing and places of worship it is odor and flies. 5) Appropriate mitigation measures include on-site measures on landfill, covering and compacting waste, and improving houses against flies and odor. 6) Acceptance that the sites need to be operated within available budgets so operation of a sanitary landfill is not possible and application of daily cover is cost prohibitive. Distance to receptors depends on the landfill design, daily management, O&M, mitigation measures and landfill closure procedures. 7) Flooded areas are generally defined in the guidelines as areas connected to permanent water bodies through inundation and flooding originating from the permanent waterbody. Areas occasionally inundated by rainfall caused runoff, lacking natural drainage, are not regarded as flooded areas in the guidelines. 8) Flooded or periodically flooded run-off areas can be used for landfill with appropriate design preventing flooding of the landfill site, specified in the EMP.

9) Priority for landfill site design and management is to avoid environmental damage, especially groundwater contamination. This is to be minimized using liners to prevent water entering and leaving the landfill cell and leachate collection and treatment before release to environment if suitable for the site. 10) Clay layer thickness depends on the exact conditions of each landfill site. 11) IEIA/EIA under Cambodian law and the associated EMP, is required to be submitted to MOE for each landfill site. MOE recommend submitting separate IEIA/EIAs for each sub-project so if one IEIA/EIA is not approved, the remaining projects are not delayed. 12) The preparation and management of Landfill should be followed the Technical Guideline on Garbage and Urban Solid Waste Management (MoE, 2016) 13) For future ADB projects, ADB should invite MOE to comment preliminarily on landfill site selection in feasibility study stage, but EIA can be submitted after detailed engineering design. 14) Waste pickers are allowed to work in controlled fashion in a separate waste separation site3, or Material Recovery Facility (MRF), for their own and others safety. Health and safety procedures have to be followed. Recycling of waste materials is to be encouraged for longevity of the landfill site. 15) Public consultations are highly important to improve public acceptance of the landfill, establish affected households’ priorities, and identify suitable mitigation measures. 16) Option to relocate away from the landfill should be provided for the affected households too close to the site that wish to relocate. 17) New Environment Code is too far from adoption to consider at the moment. It will be submitted to the Council of Ministers for debate at the end of 2017.

**Tabled at a joint meeting with MOE & ADB safeguards for landfill siting in Phnom Penh, 31/10/17

36. Compliance of the new SLF with the above directives plus other site and waste type information, updated views of local community of the DED, and groundwater and soil quality data at the dumpsite area of the DED that are provided in Chapters II and IV of the separate updated IEE were specified in the ToR of environmental compliance audit (ECA) and ground water quality study that were identified in the original IEE of the FS design of the Kep subproject. The DED of improvements to solid waste management in Kep, includes the groundwater and soil quality, and the updated IEE represents the comprehensive corrective environmental action of subproject, and major result of the ECA.

B. Summary of Public Consultation in Provincial and Kep Town

37. The list of participants and recorded minutes and photographs of the public consultation meetings held in Kep are in Appendix E and pictures of meeting are in Appendix F. Below is a summary of discussions.

3 New government directives may disallow waste pickers working on open waste piles.

Public Consultation with provincial departments

38. On November 27, 2019 at 08:30 am, the study team met with relevant departments and institutions, opening the meeting by H.E Prum Kunthi, Vice Governor of Kep province. There are 16 departments and institutes participated as the following:

- Administration office of Kep Provincial Hall - Kep Municipal Administration office - Department of the Environment - Department of Public Works and Transport - Department of Health - Department of Land Management, Urban Planning, Construction and Cadastral - Department of Planning - Department of Women's Affairs - Department of Agriculture, Forestry and Fisheries - Department of Tourism - Department of Water Resources and Meteorology - Department of Labor and Vocational Training - Department of Rural Development - Department of Culture and Fine Arts - Provincial Water and Electricity Authority of Kep - NGO.

39. After understanding the project information and conditions of the existing social and environmental conditions in and near the project site. All relevant institutions and departments know about the project name, the type of project and the location of the project that will be developed in their area. In this consultation meeting for Environmental Impact, they supported the project, but they just suggested the project owner:

- To pay attention with this work and properly manage this new waste disposal landfill with highly technical and its mitigation for long term of operation. - Request for preventing rainwater flowing from the mountains because the project site is in a part of mountain. - Solid Waste shall be well managed separated for purpose of reducing its volume. - UXO shall be cleared because the project site used to be a former battlefield. - Composing process and programme handicraft for plastic trash or old tires. - Wastewater treatment tank shall have in the site of this landfill because this area is a part of mountain; so its slop is high easing to pollute at downstream.

40. However, they also have some concerns related to projects that could have environmental and social impacts, such as transportation and air pollution whenever it burns and using access road in the operation stage.

Public Consultation with local people

41. October 21, 2019 at 02:30 pm, team of SBK met with Mr. Sem Phoeun, Chief of Damnak Chang Ae Village, Sangkat Prey Thom, Kep Town, Kep Province. Because the project site is located about 3 to 4 kilometers away from his village. He added that around the project site was mostly covered by mango orchards. They said that last two or three years ago there was a problem that people were complaining about the flies around the landfill, but the project owners had improved, then we did not get any matter until now.

Their Concerns:

- It may pollute groundwater.

Their suggestions:

42. Please highly pay attention with the well management of solid waste to avoid making issues from this landfill.

IV. MITIGATION PLAN

43. The impact Mitigation Plan for solid waste management improvements in Kep is presented in Table 4. The tabled Mitigation Plan identifies potential impacts, required mitigations, responsible parties, location, timing, and any indicative costs. The potential impacts identified in Table 4 elaborate the impacts summarized in Table 2 above which are taken directly form the updated IEE.

44. Note that Mitigation Plan in Table 4 indicates that the responsibilities of the contractor(s) for implementation of the Mitigation Plan are essentially restricted to the mitigation subplans of the Construction Phase, with the IA, and PMCES being responsible for the implementation of the mitigations measures of the Pre-construction and Operation Phases. This distinction will assist the contractors to identify the mitigation activities and subplans for which they are responsible to finalize and implement.

Table 4. Impact Mitigation Measures Plan

Responsibility Potential Estimated Subproject Activity Environmental Mitigation Measures Location Timing Cost4 Activity Reporting Supervision Implement Impacts (USD) ation

Preconstruction phase

1. Confirm initiation Information Disclosure and Grievance Redress Mechanism of IEE A few weeks Disclosure, & re- and distribute construction activity For all No community before No marginal engagement of schedule to affected community and construction Once IA/PIU PIU impacts construction cost5 community businesses including waste pickers at sites. starts dumpsite to allow continued waste picking/recycling.

2. Confirm with MoE/DOE for required project Before Government No negative Entire No marginal permits and license certificate of IESIA. construction Once PIU/DOE DOE approvals impact subproject, cost begins

Contact current No negative 3. Inform waste pickers of future training and Existing Before No marginal waste pickers at impact on waste As required PMCES/PIU PMCES/PIU placement at future new MRF. dumpsite construction cost dumpsite pickers

4. PMCES6 to ensure the following management measures are organized and in place:

Minimize a) identification of spill management Once with Before Final design of negative prevention plans, and emergency final No marginal Final siting construction PMCES/EA PMCES/PIU subproject, environmental response plans for all construction designs cost initiated impacts activities at new SLF site and along documents access road. b) locate possible concrete batch plant location for access and internal roads at least 2km from local villages, i.e., Damnak

4 Costs will need to be updated by contractors, but the cost for testing air, noise, vibration and water may be high (around USD5,000.00 for one semester). 5 No marginal cost indicates that costs to implement mitigation are to be built into cost estimates of contractor bid documents. 6 PMCES is Project management and supervision consultant.

Responsibility Potential Estimated Subproject Activity Environmental Mitigation Measures Location Timing Cost4 Activity Reporting Supervision Implement Impacts (USD) ation Chamour village, and surround batch plants with fencing and access barriers. d) ensure no disruption to water supply, utilities, and electricity to local villages with set contingency plans for any unavoidable disruptions planned; e) no disruption to normal pedestrian and vehicle traffic along all access road to SLF and NR-33 with planned contingency alternate routes;. f) erect/install signage at intersection of access road and along NR-33 to warn public and motorists of construction schedule along access road and at new SLF site, and of increased vehicle traffic along NR-33.

5. Review and ensure climate change Capped mitigation and resilience measures of DED existing waste are integrated with subproject cell. Peripheral implementation; drainage of 6. The borrow pits, storage yard and workers’ SLF and camp need to be identified before starting access road to carry out the construction works; drainage

7. Finalize IEE and this EMP where necessary to meet any late changes to Once with Positive Before subproject final design to protect affected detailed No marginal Finalize EMP environmental All sites construction PMCES EA/PIU environments. If changed submit final IEE designs cost impacts initiated and EMP to ADB to review and approval documents prior to bidding.

Confirm 8. Notify DOE, DPWT to confirm locations of Government No negative Entire Before No marginal PIU/DOE/ sites for disposal areas for construction As required PIU approved impact subproject construction cost /DOT waste for subproject, and obtain required construction waste

Responsibility Potential Estimated Subproject Activity Environmental Mitigation Measures Location Timing Cost4 Activity Reporting Supervision Implement Impacts (USD) ation disposal sites permits.

9. Ensure Government and military is See UXO survey, & Injured worker or consulted and clears areas where All construction Beginning of Government, Once Monitoring EA/PIU removal public necessary at SLF property and along sites. subproject military Plan below access road

10. Ensure this updated EMP is included in contractor tender documents, and that tender documents specify requirement for No negative site-specific, budgeted CEMP. Before Develop bid All subproject Once for all No marginal environmental construction PMCES/EA PIU documents 11. Specify in bid documents that contractor areas tenders cost impact must have experience with implementing begins EMPs and provide designated environment, health and safety staff with experience.

12. Contractors to comply with all statutory Obtain & activate requirements of Government for use of For all Prevent or Beginning of No marginal PIU & permits and construction equipment, and operation construction Once PMCES minimize impacts construction cost contractors licenses construction plants such as concrete sites batching.

13. Finalize and schedule training plan for (PIU/SS) to be able to fully implement Initially, No negative EMP, and to manage implementation of Before Capacity All subproject refresher No marginal environmental mitigation measures by contractors. construction PMCES PMCES/PIU development areas later if cost impact begins 14. Create awareness and training plan for needed contractors whom will implement mitigation measures.

15. Use local workers as much as possible Spread of All construction thereby reducing number of migrant Throughout Worker Contractor’s Recruitment of sexually areas and No marginal workers. This proviso should be included construction hiring EA/PIU bid workers transmitted communities cost in contractor tender documents phase stages documents disease nearby. 16. The local workers has to have women at

17. The training on sanitation, waste management in Camp and sexually transmitted and HIV/AIDs to workers need to be done prior commencement of work in regularly (at least 3 months once);

18. The site-inspector responding for Environment, Health and Safety shall be planned to recruit for each site.

19. Prepare site-specific CEMP(s) for different potential impacts of construction of new SLF, and access road upgrades.

Prevent or 20. The CEMP need to be attached with other All construction Ahead of No marginal Prepare CEMP Once PMCES/PIU Contractors minimize impacts management plan such as: solid waste sites construction cost and waste water management plant, dust and air monitoring plan, health and safety management plan and other relevant management plan

Construction Phase

Physical Resource

21. Regularly apply wetting agents (e.g., All construction - PMU Fulltime by water, CaCl2) to exposed soil, access sites. And Air, dust, Noise and Dust & observation No marginal - MoE road, and approach sections NR-33. Water Entrance road 6 monts contractor vibration 7sub-plan and Test cost Noise truck must be on site for immediate to the landfill - PIU watering as needed. some time (X:425607; - PIC

7 We have the results of Air, Noise, vibration and water for baseline attached in appendix H to let contractor compare;

Responsibility Potential Estimated Subproject Activity Environmental Mitigation Measures Location Timing Cost4 Activity Reporting Supervision Implement Impacts (USD) ation 22. Cover or keep moist all stockpiles of Y:1165319) - Local construction aggregates, and all truckloads authorities of aggregates. - PMCES 23. Minimize time that excavations and exposed soil are left open/exposed. Backfill immediately.

24. As much as possible restrict working time between 07:00 and 17:00. In particular are activities such as pile driving.

25. Maintain vehicles and equipment in proper working order with a monthly check/service schedule

26. Replace unnecessarily noisy vehicles and machinery.

27. Vehicles and machinery to be turned off when not in use.

28. Construct temporary noise barriers around excessively noisy activity areas.

29. Clean mud from access road off construction trucks at the end of each day to reduce dust and skid risk.

30. Provide watering on the access road in regularly to ensure that the dust is not come out.

31. Transportation of soil and construction material must be limited the speed;

32. Checking on the pollution from trucks

33. Dust shall be mitigated by spray water on the used road for project;

34. All of wastes are not allowed to burn in order to avoid the air pollution;

35. Limited the speed of all transportations in the worksites to mitigate vibration;

Parameter: CO, NO2, SO2 ,CH4, O3, TSP, PM10, PM2.5 នឹង Pb

Pond nearby the worksite 36. Proper management of all wastes to avoid - PMU (X:426781; water pollution; y:1167842) - MoE Water quality Every 6 Base on the - PIU Water Pollution 37. Used oil from trucks and other machinery And at well in Semester Contractor control month real cost will be kept in the safe place; and make village - PIC sure that it will not leak to pollute surface, (x:426303; ground water and soil; - Local y:1166299) authorities

38. Berms, and plastic sheet fencing should be placed around all excavations and - PMU earthwork areas to contain erosion. - MoE 39. Earthworks should be conducted during Throughout Erosion control sub- All construction No marginal - PIU Land erosion dry periods if possible and not during wet construction Monthly contractor plan sites cost season. phase - PIC 40. Protect exposed or cut slopes with planted - Local vegetation, and have a slope stabilization authorities protocol ready.

Biological Resource

42. Contact provincial forestry department for advice on how to minimize damage to trees and vegetation. 43. Restrict tree and vegetation removal to within SLF property and along RoW of - PMU access road. - MoE Birds, wildlife, Tree Hunting, Damage 44. Minimize tree removal, and install Beginning and vegetation or loss of trees, All construction No marginal - PIU protective physical barriers around trees and end of Monthly contractor removal, and site vegetation, and sites. cost that do not need to be removed. subproject restoration sub-plan landscape - PIC 45. SLF property and ROW of access road - Local needs to re-vegetated and landscaped authorities after construction completed. Consult provincial forestry department to determine the most successful restoration strategy and techniques.

Safety, health and Social

46. Locate worker camps at least 1km away from nearby villages, i.e., Damnak Throughout Pollution and Chamour village. All worker Worker camps construction Monthly No marginal cost PMCES/PIU contractor social problems camp sites 47. Must be informed in advance to the local phase authorities on the worker camp construction and work closely with

Responsibility Potential Estimated Subproject Activity Environmental Mitigation Measures Location Timing Cost4 Activity Reporting Supervision Implement Impacts (USD) ation competencies authorities. 48. Name list of workers shall monthly be updated to local authorities, especially commune and police office. 49. Ensure that there are no alcohol and drug used and traffic in the camp and to residential people. 50. Ensure adequate housing and waste disposal facilities including pit latrines and garbage cans. 51. A solid waste collection program must be established and implemented that maintains clean worker camps, and which separates recyclables from waste for landfill 52. Locate separate pit latrines for male and female workers away from worker living and eating areas. 53. A clean-out or infill schedule for pit latrines must be established and implemented to ensure clean operable latrines are available at all times. At the workers’ camp must install enough latrines, bathroom and clean water. Actually, worker from 1 to 8 people need 1 latrine (but it is good, if contractor has one for male and another for female). 54. Must have enough mosquito net, hammock, First Aid box with medicine, and other supporting stuffs for health. 55. Contractor shall have the agreement with local post health or referral hospital to ensure that they will cooperate whenever we have the emergency case.

Responsibility Potential Estimated Subproject Activity Environmental Mitigation Measures Location Timing Cost4 Activity Reporting Supervision Implement Impacts (USD) ation 56. Worker camp must have adequate drainage. 57. Local food and clean water should be provided to worker camps. Guns and weapons not allowed in camps. 58. Interaction of transient workers with local community should be discouraged. HIV Aids test and education should be given to workers. 59. Camp areas must be restored to original condition after construction completed.

60. Implement training and awareness plan for PIU/SS and contractors. 61. The training on sanitation, waste management in Camp and sexually transmitted and HIV/AIDs to workers need to be done prior commencement of work in regularly (at least 3 months once); Prevention of 62. Toolbox meeting to review and patrol on PIU office, After Training & capacity Beginning of PMCES/PIC/ PMCES//con impacts through the uniform and safety shall be done construction each No marginal cost building construction PIU tractor education regularly; sites event 63. Mapping to all of workers about location of latrine and clean water shall be done in the toolbox meeting; 64. All of workers need to be trained before starting their work about safety, uniform, sanitation or hygiene and their waste management in the worksite.

65. All topsoil and overburden removed for Construction Pollution, injury, For all Throughout waste cells should be stockpiled on site PMCES/PIU/ materials increased traffic, construction construction Monthly No marginal cost contractor for later restoration. PIC acquisition, disrupted access areas. phase transport, and 66. Storage yard for all construction materials

Responsibility Potential Estimated Subproject Activity Environmental Mitigation Measures Location Timing Cost4 Activity Reporting Supervision Implement Impacts (USD) ation storage sub-plan and parking place for all trucks, excavators, bulldozers… shall be ready before starting work of construction. 67. Remaining unstable slope conditions on SLF property should be rectified with tree planting, or initially with quicker growing local grasses if necessary. 68. Define & schedule how material from slopes on northern boundary of SLF are extracted, moved, and stored on site. 69. All piles of aggregates on SLF property and along access road must be covered. 70. All aggregate loads on trucks transported from outside SLF boundary must be covered. 71. Limited the speed for transportation of construction material and soil 72. Installation safety sign board and all kind of traffic sign boards at construction sites and access road 73. At storage site, there must be concrete in order to avoid leakage oil and hazardous material, especially, must equipped with the adequate firefighting equipment

74. Any uncontaminated excavated spoil that Contamination of needs to be disposed outside SLF soil and adjacent property or from access road must be Excavated spoil seasonal stream preferably reused on another construction Throughout PMCES & All excavation management sub- from excavated site, or disposed of in DOE-designated construction Monthly PIU & DOE & contractor areas See Monitoring plan spoil, and sites. phase Plan for PIC construction contaminated waste 75. All bad soil or excavated soil from clearance at worksite shall have the soil analyses possible places to dispose; that make sure

Responsibility Potential Estimated Subproject Activity Environmental Mitigation Measures Location Timing Cost4 Activity Reporting Supervision Implement Impacts (USD) ation that it is not affected to residential land or crop land or farmland of people; 76. 77. A record of type, estimated volume, and source of disposed spoil must be recorded. 78. Any excavated contaminated spoil must be handled following DOE regulations including transport, treatment (if necessary), and disposal.

79. Management of general construction solid and liquid waste from SLF site and access road construction sites must follow DOE regulations, and will cover, collection, handling, transport, recycling, and offsite disposal of waste created from construction activities and work force. 80. Offsite disposed of construction waste should be catalogued for type, estimated - PMU Contamination of weigh, and source. - MoE Solid and liquid land and surface All construction Throughout 81. Construction sites should have enough construction waste waters from sites and construction Monthly No marginal cost - PIU contractor large garbage bins that enable separation sub-plan construction worker camps phase of recyclable waste from waste that needs - PIC waste to be disposed at landfill. -Local 82. A schedule of solid and liquid construction authorities waste pickup and disposal from SLF and along access road must be established and implemented to ensure construction sites are clean as possible. Hazardous Waste 83. Collection, storage, transport, and disposal of hazardous waste such as used

Responsibility Potential Estimated Subproject Activity Environmental Mitigation Measures Location Timing Cost4 Activity Reporting Supervision Implement Impacts (USD) ation oils, empty drums, gasoline, paint, and other toxics must follow MOE regulations and work closely with local authorities in regularly. 84. Wastes should be separated (e.g., hydrocarbons, batteries, paints, organic solvents) 85. Wastes must be stored above ground in closed, well labeled, ventilated plastic bins in good condition at least 30m from construction activity areas, adjacent stream, and nearby villages. 86. All spills must be cleaned up completely with all contaminated soil removed and handled as contaminated spoil.

87. Develop plan of days and locations where outages in utilities and services will occur, or are expected. Loss or disruption of utilities and 88. Contact local utilities and services with Implement utility PMCES & services to local schedule, and identify possible All construction and power Fulltime Monthly No marginal cost PIU & Utility contractor villages such as contingency back-up plans for outages. sites. disruption sub-plan company water supply and 89. Contact affected villages to inform them of electricity planned outages. 90. Try to schedule all outages during low use time such between 24:00 and 06:00.

91. Proper fencing, protective barriers, and buffer zones should be provided around Public and Implement worker all construction sites to protect public. worker injury, and All construction PMCES & and public safety Fulltime Monthly No marginal cost contractor health 92. Sufficient signage and information sites. PIU & PIC sub-plan disclosure, and site supervisors and night

guards should be placed at all sites. 93. Worker and public safety guidelines of the

Responsibility Potential Estimated Subproject Activity Environmental Mitigation Measures Location Timing Cost4 Activity Reporting Supervision Implement Impacts (USD) ation Government should be followed. See draft Occupational Safety & Health Master Plan of Ministry of Labor & Vocational Training. Supplement as needed with IFC EHS guidelines for Waste Management Facilities, Toll Roads, and Construction and Decommission 94. Speed limits suitable for the size and type of construction vehicles, and current traffic patterns should be developed, posted, and enforced on all roads used by construction vehicles. 95. Standing water suitable for disease vector breeding should be filled in. 96. Worker education and awareness seminars for construction hazards should be given at beginning of construction phase, and at ideal frequency of monthly. A construction site safety program should be developed and distributed to workers. 97. Appropriate safety clothing and footwear should be mandatory for all construction workers.

98. Adequate medical services must be on site or nearby all construction sites.

99. Drinking water must be provided at all construction sites.

100. Sufficient lighting must be used during Degradation of necessary night work. SLF Throughout PMCES & Civil works water quality of construction construction Monthly No marginal cost contractor 101. All construction sites should be examined PIU & PIC adjacent streams daily to ensure unsafe conditions are sites phase removed. Unsafe situations should be

Responsibility Potential Estimated Subproject Activity Environmental Mitigation Measures Location Timing Cost4 Activity Reporting Supervision Implement Impacts (USD) ation recorded in site diaries for subsequent preventive maintenance 102. Protective berms, plastic sheet fencing, or silt curtains should be placed between all earthworks and the streams near boundary of SLF property 103. Erosion diversion channels and collector ponds must be built around and adjacent to aggregate stockpile areas to contain rain-induced erosion. 104. Earthworks should be conducted during dry periods. 105. All construction fluids such as oils, and fuels should be stored and handled well away from streams near boundary of SLF property 106. No waste of any kind is to be thrown in the adjacent streams. 107. No washing or repair of machinery near the adjacent streams. 108. Pit latrines to be located well away from the adjacent streams. 109. The earth work and excavation must be done in the dry season only

110. Ensure the established depth of water Degradation of table at SLF site is clearly understood by Area of waste groundwater excavators when the first waste cell is cell #1 quality excavated including rainy season depth

111. Contractor has to work closely with At the start, Damage to All construction - PMU contractor provincial department of Cultural, Fine and and Monthly No marginal cost Cultural chance cultural property sites Art in case of finding heritage sites throughout - MoE finds sub-plan or values, and

Responsibility Potential Estimated Subproject Activity Environmental Mitigation Measures Location Timing Cost4 Activity Reporting Supervision Implement Impacts (USD) ation chance finds 112. Chance finds of valued relics and cultural construction - PIU values should be anticipated by phase contractors. Site supervisors should be on - PIC the watch for finds. -Local 113. Upon a chance find all work stops authorities immediately, find left untouched, and PIU notified to determine if find is valuable. Culture section of DOT notified by telephone if valuable. 114. Work at find site will remain stopped until DOT and DoCFA allow work to continue.

115. Create adequate traffic detours, and sufficient signage & warning lights along access road and on NR-33 if necessary. 116. Post speed limits, and create dedicated construction vehicle roads or lanes along access road if possible. Construction and Traffic disruption, All construction PMCES & urban traffic sub- accidents, public 117. Install signages on NR-33 and access Fulltime Monthly No marginal cost contractor sites PIU plan injury road to inform community of location of construction traffic areas and provide them with directions on how to best co- exist with construction vehicles on their roads. 118. Create safe pedestrian walkway areas around construction sites.

119. Provide adequate short-term drainage away from construction sites to prevent ponding and flooding. Design & Construction Loss of drainage All areas with PMCES & construction Monthly No marginal cost contractor drainage sub-plan & flood storage 120. Install temporary storm drains or ditches surface waters PIU on construction sites where necessary phases 121. Ensure natural stormwater runoff around SLF site and along access road is

Operation of completed SLF and access road

123. Regularly monitor groundwater quality from test boreholes BH3, BH4, & BH5 that were Pollution of Operation of established as part of the DED to ensure groundwater and SLF Quarterly Annually O&M Kep Municipality completed SLF waste cells and leachate treatment system downstream area are operating properly. BH4 will be phase out as waste cells are developed

124. Enforce clearly post speed limits along road. 125. Mandate regular SLF vehicle inspections to Operation of Increased traffic ensure all vehicles kept in good working SLF access upgraded access accidents & air Biannually Annually O&M DPWT condition. road road pollution 126. Upgraded access road drainage culverts or ditches must be regularly cleaned and maintained

V. MONITORING PLAN

45. The environmental monitoring plan for the subproject is provided in Table 5. The monitoring plan consists of environmental indicators, the sampling locations & frequency, method of data collection, responsible parties, and estimated costs. The purpose of the monitoring plan is to determine the effectiveness of the impact mitigations, to document any unexpected positive or negative environmental impacts of the subproject, and to determine the proper functioning of select components of the SLF. The indicative costs of monitoring are shown in Table 7.

Monitoring strategy

46. The strategy for monitoring some environmental parameters such as dust levels is to conduct continuous or daily qualitative observations, not periodic (e.g., quarterly) quantitative measurements that provide limited information and which require expensive laboratory analyses. When the common occurrence of dust on construction sites and along roads is observed by contractor staff or the public from for example truck traffic, excavation operations, or from wind-blown aggregate piles, the problem should be remediated immediately by the contractor with wetting agents that are on standby for quick and immediate application. Similarly, when noise levels are considered too high either qualitatively or from a portable onsite sound meter the equipment/vehicle producing the noise should be immediately checked for working condition and repaired asap. Or the equipment operation rescheduled.

47. Environmental standards for ambient water quality for Cambodia are found in Appendix D. The environmental standards provided by the Environmental, Health and Safety Guidelines of the IFC/World Bank (2007) (e.g., ambient air quality and noise) should be followed to supplement standards that are not provided by the Government.

48. An independent environmental monitoring institute (EMI) will be required to perform the groundwater sampling and laboratory analyses that cannot be conducted by the IA, PMCES or contractors. The SS will coordinate with the EMI under the direction of the PMCES/PIU who will provide logistical support to the EMI where necessary. The PMCES will be given a budget for the EMI which will come from the loan. The budget for the work of the EMI will become the costs for monitoring which are estimated in Table 6.

1. Performance Monitoring

49. Performance monitoring is required to assess the overall performance of the EMP. A performance monitoring system is normally developed by the EA for the entire subproject. Select indicators of major components of the environment that will be affected primarily by the construction phase are drawn from the mitigation and monitoring plans and summarized in Table 6.

2. Reporting

50. Regular reporting on the implementation of mitigation measures, and on monitoring activities during construction phase of the subproject is required. Reporting is the responsibility of PIU and should include regular meetings with stakeholders as part of the continuation of stakeholder communications. The mitigation and monitoring plans (Tables 4 and 5) summarize proposed timing of reporting. A report on environmental monitoring and implementation of EMP will be prepared quarterly for the EA/PCU by the PIU. For the quarterly report the PIU report will compile monthly reports provided by the EO of contractor, the reports of the EMI on monitoring, and input from the IES/NES of the PMCES. The PIU reports will be compiled into the semi- annual environmental safeguards monitoring report that the EA/PIU submits to the ADB and DOE.

51. The reports will track all indicators measured in the EMP monitoring plan, including performance monitoring indicators (Table 6) and will include relevant Government environmental quality standards. Contractor/PIC shall regularly prepare the report of monitoring submit to MoE via PMU. This monitoring report shall be following this EMP and report of IESIA that MoE approved in April 2020. Base on the sub plan that concerned in table 4 for mitigation measure plan and table 5 for monitoring plan, report of monitoring and safety will be submitted to ADB and MOE regularly.

Table 5. Environmental Monitoring Plan

ENVIRONMENTAL EFFECTS MONITORING

Responsibility Estimated Cost8 (USD) Environmental Indicators Location Means of Monitoring Frequency Reporting Supervision Implementation

Just before Construction Commences - Update Baseline

Remaining public and stakeholder issues and concerns of construction Villages, in particular Damnak Chamour Repeated community consultations Once Once EA/PIU $1000. activities including construction village near existing dumpsite and on NR-33. PIU schedule.

Construction Phase of SLF and Access Road

A) Qualitative Air, dust and noise Along access road and on SLF boundary and 9 A – B): Using simple visual field A – C): Contractor, & levels, and ground and surface water nearest residential receptors. All construction observation methods approved PMCES/PIU contractor to sites. And Entrance road to the landfill B) Qualitative turbidity levels by DOE. mitigate issue (X:425607; Y:1165319 immediately C) Operational health and Safety C) Visual inspections including Continuously PIU and (OHS) complaints from local community daily contractor, with D): EA/PIU A) In streams adjacent to SLF property or workers. observations issue addressed D) Qualitative level of unmanaged and D) Information transferred by recorded in immediately uncontained worker (domestic) B) All construction sites, worker camp living site diary and construction solid waste. hotline telephone number, Monthly and pit latrine areas through GRM, and direct public E): EA/PIU PIU and Management E) Public comments and complaints complaint at construction site. contractor, with overhead cost C) From all project-affected community areas, F) Incidence of worker or public issue addressed from hotline telephone number placed along E) Regular reporting by contractors accident or injury immediately access road and at gate to SLF.

D) At all construction areas

8 Units costs of parameter analyses conducted for DED by MOE. 9 All parameters are based on the results of baseline as in appendix H.

ENVIRONMENTAL EFFECTS MONITORING

Responsibility Estimated Cost8 (USD) Environmental Indicators Location Means of Monitoring Frequency Reporting Supervision Implementation

Operation of Completed SLF and Upgraded Access Road

Proper function of waste cells, and 1) Borehole wells BH5, BH4, and BH3 at SLF, Quarterly for Using field and analytical methods 1): $26,676. leachate treatment system of SLF: 3 years then 2) effluent (below wetland) of leachate approved by DOE and MOE groundwater quality at SLF: 20 biannually for treatment system 2): $8,892. parameters analyzed as part of DED: next 12 years

Kep Municipality Proper function and operation of LFG Monitoring procedure of equipment Biannual LFG system extraction system manufacturer O&M to be Improved solid waste collection: determined Biannually decreased solid waste litter on Entire solid waste collection catchment Observation streets, and at households/businesses Vehicle traffic accidents Upgraded / improved subproject roads. For each DPWT Regular record keeping. Continuous event $0.0 Good health of SLF workers All workers at SLF Kep Municipality

Table 6. Performance monitoring indicators for Kep subproject

Major Environmental Key Indicator Performance Objective Data Source Component Pre-construction Phase Public Continued meetings with Affected public and Minutes of meeting, Consultation stakeholders contacted during stakeholders and participants list and Disclosure DED and through GRM Contractor, EMI, and No significant environmental EMP EMP finalized Kep municipality contamination or problems reports EMP appended to bidding Completed with Bid Documents documents with clear instructions Bid documents appended EMP 10 to bidders for CEMP CEMP(s) prepared by CEMP(s) reviewed and approved Bid documents and CEMP(s) contractor(s) by PMCES/PIU PMCES/PIU By end of preconstruction phase, Course(s) outline, Training of Training course(s) & required course(s) that will be participants, and PIU/SS schedule delivered are designed and schedule scheduled Background Parameters analyzed for Clearer understanding of impact of groundwater EMI DED existing dumpsite quality at SLF Construction Phase Air quality at contractor Qualitative dust, noise Levels managed to minimum SLF monitoring reports, Surface and ground water Quality of surface and contractor Level managed to minimum quality at SLF ground water monitoring report and vicinity Adherence to Government policy Public and Frequency of injuries and site-specific procedures to Contractor reports worker safety prevent accidents Traffic, Safety Frequency of disruptions, Disruptions, stoppages, or detours Public input, and Health as accidents, and blocked are managed to minimum. contractor reports, well as OSH access Operation of Improved Solid Waste Management Groundwater parameters Proper function analyzed for DED at of waste cells boreholes BH5, BH4, EMI/Kep and leachate SLF operating properly BH3, and effluent of municipality reports treatment leachate treatment system of SLF system (below wetland) Incidence of traffic No deviation from baseline Public safety DPWT accidents on access road frequency Reduced solid waste litter Cleaner Improved solid waste collection Kep Municipality or throughout Kep environment and management outsourced operator municipality

10 Contractor Environmental Management Plan developed from EMP in contractor bidding document.

VI. ESTIMATED COST OF EMP

52. The marginal costs for implementing the EMP are primarily for environmental monitoring because the costs for implementing impact mitigation measures are included with the construction costs in contractor bid documents. From Table 5 the estimated costs for the implementation of the EMP for solid waste management improvement in Kep are summarized in Table 7. The costs of the qualitative environmental monitoring during construction phase is easily assumed by management overhead. The groundwater sampling costs (USD) are based on the parameter unit costs of the analyses conducted by MOE for the DED (Appendix D).

53. An estimated budget of USD5,000.00 is required for capacity building for environmental management in conjunction with other capacity development activities of the subproject. The costs will need to be updated by the PMCES in conjunction with the PIU during the preconstruction, detailed design phase of the subproject.

Table 7: Estimated costs for environmental monitoring plan of EMP

Estimated Cost11 Activity Type (USD)

Pre-construction Phase $500. management Construction Phase12 overhead cost but it shall be USD 20,000.00 Post-construction Operation Phase USD 35,568

Capacity development and training USD 5,000.00 Total USD 61,068.00

11 To be updated with EMP at Detailed Design Phase. 12 It is costly for Air quality test as parameters in appendix H.

VII. INSTITUTIONAL CAPACITY REVIEW AND NEEDS

54. Currently understanding and experience with the operation of sanitary landfills is absent in Kep, and there is insufficient understanding, experience and capacity for environmental management among provincial and municipal authorities responsible. i.e., DOT/PIU, and Kep municipality for overseeing successful implementation of the EMP, and for environmental management of the completed SLF. The required capacity development and training of KEP municipality and DPWT staff on SLF operation and management will be developed from by the future PMCES that will be retained by the project (Norconsult pers. communication, 2018) and beyond the scope here. Training and awareness for the critical understanding of the need for segregated wet and dry solid waste at source is also included. This will form a major part of the extensive O&M and program that needs to be developed for the solid waste collection component of the subproject.

55. No dedicated environmental experts are currently appointed to Kep Municipality and PIU. The PMCES with assistance from the SS of the subproject will develop and deliver training courses to the DOT/PIU staff responsible for the implementation of the subproject. The purpose of the course(s) is to strengthen the ability of the PIU/PMU to oversee implementation of the EMP by construction contractors, and EMI

56. The SS who will be full-time environmental member of the PIU as well as the EO of the contractor should attend training courses as required. Costs for training should be included with costs for implementation of the EMP.

57. Training on the implementation of an EMP should address two thematic areas. The first area should introduce principles environmental management focused on the potential impacts of subproject activities on the natural and social environment. The second area should be environmental safeguard requirements of the ADB and the Government with specific focus on the preparation of an EMP, and contractor EMPs (CEMP). Table 8 lists the indicative course topics and target participants. The estimated budget of USD $5.000 is listed in Table 7.

Table 8. Indicative training on EMP Implementation

Course Topic Areas Target Participants Period Introduction to EIA, Cambodia EIA policy Pre-construction phase: framework & procedures, EA, KEP Municipality*, shortly after PMCES is and environmental PIU/SS, hired standards, and ADB Safeguard Policy Purpose and content of an EMP. Development and Construction phase implementation of the EMP EA, PIU/SS, contractor shortly after for Kep solid waste EOs construction packages management improvements, are let including review of contractor CEMPs Protection of aquatic and Construction phase terrestrial environment from shortly after PIU/SS, contractor EOs road and landfill construction packages construction are let

Course Topic Areas Target Participants Period Grievance Redress EA/PIU/SS, contractor Construction phase Mechanism, & public EOs, village leaders, shortly after consultation business construction packages representatives are let Occupational and Construction phase community health and shortly after PIU/SS, contractor EOs safety construction packages are let Traffic management and Operation phase shortly safety on roads PMU before subprojects are completed * Not included is special course for Kep Municipality for the operation and maintenance of the New SLF and waste collection service improvements

58. Separate to the training plan in Table 8 will be the development of the capacity and programming of the DPWT and Kep Municipality for monitoring water table and groundwater quality at the SLF. The scope and details of the capacity development will be finalized by PMCES.

VIII. EMERGENCY RESPONSE PLAN

59. The Contractor must develop emergency or incident response procedures during construction. In the operational phase the operator/civil authorities will have responsibility for any emergencies or serious incidents. The construction phase should ensure:

a. Emergency Response Team (ERT) of the Contractor as initial responder; b. District fire and police departments, emergency medical service, the Department of Public Health (DPH), collectively referred to as the External Emergency Response Team (EERT), as ultimate responders.

60. The Contractor will provide and sustain the required technical, human and financial resources for quick response during construction.

Table 9: Roles and responsibilities in emergency incident response

Entity Responsibilities Contractor Team (ERT) - Communicates / alerts the EERT. - Prepares the emergency site to facilitate the response action of the EERT, e.g., vacating, clearing, restricting site. - When necessary & requested by the EERT, lends support / helps during EERT’s response operations. External Emergency Response Team - Solves the emergency/incident (EERT) Contractor Resources - Provide and sustain the people, equipment, tools & funds necessary to ensure Subproject’s quick response to emergency situations. - Maintain good communication lines with the EERT to ensure prompt help response & adequate protection, by keeping them informed of Subproject progress.

61. The ERT will be led by the senior contractor engineer (designated ERTL) on site with a suitably trained foreman or junior engineer as deputy. Trained first-aiders and security crew will be the core members of the ERT.

62. The Contractor will ensure that ERT members are physically, technically and psychologically fit for their emergency response roles and responsibilities.

63. Prior to the mobilization of civil works, the Contractor, through its Construction Manager, ERTL, in coordination with the PCU/PIU, will meet with the ultimate response institutions to discuss the overall construction process, including, but not limited to:

i) subproject sites; ii) construction time frame and phasing;

iii) any special construction techniques and equipment that will be used; i iv) any hazardous materials that will be brought to and stored in the construction premise and details on their applications and handling/management system; v) the Contractor’s Emergency Management Plan vi) names and contact details of the ERT members

64. The objective of this meeting is to provide the ultimate response institutions the context for:

i) their comments on the adequacy of the respective Emergency Management Plans ii) their own assessment of what types, likely magnitude and likely incidence rate of potential hazards are anticipated iii) the arrangements for coordination and collaboration.

65. To ensure effective emergency response, prior to mobilization of civil works, the Contractor will:

i) set up the ERT; ii) set up all support equipment and facilities in working condition iii) make arrangements with the EERT; iv) conducted proper training of ERT members, and encouraged and trained volunteers from the work force; v) conducted orientation to all construction workers on the emergency response procedures and facilities, particularly evacuation procedures, evacuation routes, evacuation assembly points, and self-first response, among others; and vi) conducted drills for different possible situations.

66. To sustain effective emergency response throughout Subproject implementation an adequate budget shall be provided to sustain the capabilities and efficiency of the emergency response mechanism, the emergency response equipment, tools, facilities and supplies. Drills and reminders will take place regularly, the former at least every two months and the latter at least every month.

A. Alert Procedures

67. Means of communicating, reporting and alerting an emergency situation may be any combination of the following: i) audible alarm (siren, bell or gong); ii) visual alarm (blinking/rotating red light or orange safety flag); iii) telephone (landline); iv) mobile phone; v) two-way radio; and vi) public address system/loud speakers. Some rules relative to communicating/alerting will be:

(i) Whoever detects an emergency situation first shall immediately: - call the attention of other people in the emergency site, - sound the nearest alarm, and/or - report/communicate the emergency situation to the ERT. (ii) Only the ERTL and, if ERTL is not available, the Deputy ERTL are authorized to communicate with the EERT. Exceptional cases to this rule may be necessary and should be defined in the Emergency Management Plans. (iii) When communicating/alerting an emergency to the EERT, it is important to provide them with at least: i) the type of emergency; ii) correct location of the emergency; ii) estimated magnitude of the situation; iii) estimated persons harmed; iv) time it happened; v) in case of a spill, which hazardous substance spilled; and vi) in case of

fire and explosion, what caused it. Such details would allow the EERT to prepare for the appropriate response actions.

68. For an effective reporting/alerting of an emergency:

(i) The names and contact details of the relevant persons and institutions should be readily available in, or near to, all forms of communication equipment, and strategically posted (at legible size) in all Subproject sites and vehicles: - Most relevant construction/operations staffs namely, the ERTL, Deputy ERTL, first-aiders, supervising engineers, foremen - EERT institutions/organizations - Concerned village authority/ies - PIU Office, SS (ii) All Subproject sites should have good access to any combination of audible and visual alarms, landline phones, mobile phones and two-way radio communication at all times. (iii) Contractor’s construction vehicles should also be equipped with the appropriate communication facilities.

B. Emergency Response Situations

69. The following tables suggest general procedures that will be finalized just before construction commences, and will be described in more detail in the Emergency Management Plans of the Contractor

Table 10: Evacuation procedure

Procedure Remarks . Move out as quickly as possible as a . All workers/staff, sub-contractors, site group, but avoid panic. visitors to move out, guided by the ERT. . Evacuate through the directed . The safe evacuation shall have been evacuation route. determined fast by the ERTL/Deputy ERTL & immediately communicated to ERT members. . Keep moving until everyone is safely . A restricted area must be established away from the emergency site and its outside the emergency site, all to stay influence area. beyond the restricted area. . Once outside, conduct head counts. . Foremen to do head counts of their sub-groups; ERTL/Deputy ERTL of the ERT. . Report missing persons to EERT . ERTL/Deputy ERTL to communicate immediately. with the EERT. . Assist the injured in evacuation & . ERT to manage injured persons to hand them over to the ERT first- ensure proper handling. aiders or EERT medical group . If injury warrants special care, DO . ERTL/Deputy ERTL communicates NOT MOVE them, unless necessary with EERT to get & instructed/directed by the EERT. instructions/directions in handling the injured.

Table 11: Response procedure during medical emergency

Procedure Remarks . Administer First Aid regardless of . Fundamentals when giving First Aid: severity immediately. - Safety first of both the rescuer and the victim. - Do not move an injured person unless: - victim is exposed to more danger when left where they are, e.g., during fire, chemical spill - it would be impossible for EERT to aid victims in their locations, e.g., under a collapsed structure - instructed or directed by the EERT. . First AID to be conducted only by a person who has been properly trained in giving First Aid. . Call the EERT emergency medical . ERTL/Deputy ERTL or authorized on- services &/or nearest hospital. site emergency communicator . Facilitate leading the EERT to the . ERTL/Deputy ERTL to instruct: emergency site. - an ERT member onsite to meet EERT in access road/strategic location. He/she shall hold orange

Procedure Remarks safety flag to get their attention & lead them to site. - Other ERT members to clear access road for smooth passage of the EERT. . If applicable, vacate site & influence . Follow evacuation procedure. area at once, restrict site, suspend work until further notice.

Table 12: Response procedure in case of fire

Procedure Remarks . Alert a fire situation. . Whoever detects the fire shall immediately: - call the attention of other people in the site, - sound the nearest alarm, and/or - Foreman or any ERT member among the construction sub-group contacts the fire department (in this case it should be agreed on that it is alright for any ERT member in the sub-group to alert the fire department) - Report/communicate the emergency to the ERTL/Deputy ERTL. . Stop all activities/operations and . All (non-ERT) workers/staff sub- evacuate. contractors, site visitors and concerned public to move out to safe grounds following the evacuation procedure. . Activate ERT to contain fire/control . Guided by the training they undertook, fire from spreading. ERT members assigned to mitigate the fire shall assess their own safety situation first before attempting to control fire spread. . Call the nearest fire & police . When alerting the EERT, ERTL will stations &, if applicable, emergency give the location, cause of fire, medical services. estimated fire alarm rating, any injuries. . Facilitate leading the EERT to the . ERTL/Deputy ERTL to instruct: emergency site. - an ERT member to meet the EERT in the access road or strategic location and lead them to the site. He/she shall hold the orange safety flag to get their attention and lead them to the site.

Procedure Remarks - some ERT members to stop traffic in, & clear, the access road to facilitate passage of the EERT. . ERT to vacate the site as soon as . Follow appropriate evacuation their safety is assessed as in procedure. danger.

48 Appendix A

APPENDIXES

APPENDIX A: INDICATIVE RESPONSIBILITIES OF KEY MANAGEMENT UNITS OF EMP

EMP Implementation Roles and Responsibilities organizations

Executing agency (EA)  Overall responsibility for the execution of the project (MOT)  Reviews the project implementation progress  Reviews and endorses any proposed change in the project scope or implementation arrangements  Supervises compliance with loan covenants  Responsible for ensuring GRM is successful

Project Coordination Unit  Project preparation, including the setting up of financial and management (PCU), inside MOT systems and procedures, and the procuring of PCU office equipment  Consultant recruitment and supervision  Review and approval of goods and civil works contracts, including bid documents  Coordination between the concerned agencies at the national and provincial levels  Coordination of activities of the PIUs and the inputs of concerned stakeholders  Coordination of all reporting aspects of the project  Coordination of institutional strengthening measures  Ensuring compliance with ADB Loan covenants, assurances and safeguard requirements, as well as with national and provincial policies and regulations  Provision of administrative and technical support to the PIUs  Preparation of consolidated Project accounts to be forwarded to ADB  Advice to PIUs on revenue-enhancing activities related to the recovery of costs of constructing, operating, and maintaining Project facilities and equipment;  Coordination of project audits  All specified monitoring, evaluation and reporting activities  Communication of Project's outcomes, outputs, and activities to all stakeholders  Provide coordination for safeguards and monitoring for PIU

Provincial Project  Ensuring that concerns of all stakeholders are adequately reflected in the project Steering Committee  Coordination of project implementation between the concerned agencies (PPSC)  Confirming compliance with local regulations and provincial policies  Overseeing budgeting and disbursement of counterpart funds  Overseeing implementation of resettlement plans, compensation schemes and all other project safeguard procedures

Project Implementation  Coordination and supervision of consultants’ inputs on the appraisal of feasibility Units (PIUs) DOT, studies, and conceptual and detailed designs construction DPWT  Procurement of goods and civil works contracts, including the preparation of bid documents and bid evaluations  Approving payments to contractors and maintaining disbursement records  Ensuring that institutional-strengthening and capacity-building initiatives involving DMOs, private partners, SMEs and CBTOs are implemented in line with agreed Project designs, schedules and budgets  Ensuring compliance with loan covenants and assurances in respect of all sub projects, including updating of IEEs, EMPs, IPPs, GAPs, resettlement plans  Oversee implementation of EMP by contractor EO, and EMI  Prepare quarterly reports on EMP implementation for PCU  Coordinate with PMCES to design and deliver capacity development & training.  Meetings with all concerned stakeholders  Quarterly progress and monitoring-and-evaluation reporting to the PCU

Appendix A 49

EMP Implementation Roles and Responsibilities organizations

 Co-ordinate and report on the project specific safeguards GRM, ensure that necessary actions to resolve complaints are taken, documented and reported;  Ensure monitoring of environmental parameters specified in the EMPs;  Ensure compliance with loan covenants in accordance with agreed formats and frameworks;  Oversee monthly environmental monitoring of the project and submit

Project Management &  Completes detailed designs of subprojects with PIU Supervision Consultant  Update EMP to meet final detailed designs of subprojects (PMCES)  Supervises and assists PIU with contractor management  Provides technical advice and support when needed to PIU and EMI  Designs and oversees delivery of all training and capacity development of PIU for construction and operation of completed subprojects including EMP.  Provides advisory role for implementation of EMP by PIU and EMI  Examine the CEMP prepared by contractor for compliance with the EMP and advice PIU of revisions that need to be incorporated prior approval and commencement of civil work  Ensure that all associated project facilities have the required permits prior to commencement of civil works;  Brief to engineering and PIU supervision staff on EMP provisions and  Provide checklists to ensure that they will be able to adequately supervise on a day-to-day basis the contractors and subcontractors about proper and timely implementation of mitigation measures specified in the EMP;  Monitor implementation of environmental mitigation measures and environmental performance of contractors based on the EMP

Environmental  Implements environmental sampling for EMP Monitoring Institute (EMI)  Conducts laboratory analyses of environmental quality samples from field sampling  Prepares periodic monitoring reports for PIU

Environmental Officer  Implements the CEMP for the construction phase (EO) of Contractor  Maintains a daily log of environmental issues at the construction sites  Prepares brief monthly summaries of mitigation activities and environmental issues at constructions site to PIU.  Prepare site-specific CEMP containing the method statements for compliance Contractor with environmental management standards in the EMPs;  Allocate sufficient funding for proper and timely implementation of environmental mitigation and monitoring measures;  Conduct daily inspection of the site and ensure the implementation of the CEMP during the construction phase;  Prepare/submit monthly reports on mitigation and monitoring activities to the PMU through the PMCES/ESS

ADB  Assists PCU through timely guidance at each stage of project implementation following agreed implementation arrangements  Review all documents that require ADB approval  Review of monitoring reports on EMP implementation to ensure EMP meets SPS (2009)  Approval of procurement activities  Periodic project review missions, a mid-term review and a completion mission for the project  Ensuring compliance of all loan covenants  Timely processing of withdrawal applications and release of eligible funds  Ensuring compliance of financial audit recommendations  Regularly updates project information disclosure on the ADB website

50 Appendix B

APPENDIX B: REFERENCE ENVIRONMENTAL STANDARDS

From Government Sub-decree on Water Pollution Control (1999) http://www.wepa-db.net/policies/law/cambodia/02.htm Table 1. Effluent standard for pollution sources discharging wastewater to public water areas or sewer access Allowable limits for pollutant substance discharging to No Parameters Unit Protected public water area Public water area and sewer 1 Temperature 0C < 45 < 45 2 pH 6 – 9 5 - 9 3 BOD5 (5 days at 200 C) mg/l < 30 < 80 4 COD mg/l < 50 < 100 5 Total Suspended Solids mg/l < 50 < 80 6 Total Dissolved Solids mg/l < 1000 < 2000 7 Grease and Oil mg/l < 5.0 < 15 8 Detergents mg/l < 5.0 < 15 9 Phenols mg/l < 0.1 < 1.2 10 Nitrate (NO3) mg/l < 10 < 20 11 Chlorine (free) mg/l < 1.0 < 2.0 12 Chloride (ion) mg/l < 500 < 700 13 Sulphate (as SO4) mg/l < 300 < 500 14 Sulphide (as Sulphur ) mg/l < 0.2 < 1.0 15 Phosphate (PO4 ) mg/l < 3.0 < 6.0 16 Cyanide (CN) mg/l < 0.2 < 1.5 17 Barium (Ba) mg/l < 4.0 < 7.0 18 Arsenic (As) mg/l < 0.10 < 1.0 19 Tin (Sn) mg/l < 2.0 < 8.0 20 Iron (Fe) mg/l < 1.0 < 20 21 Boron (B) mg/l < 1.0 < 5.0 22 Manganese (Mn) mg/l < 1.0 < 5.0 23 Cadmium (Cd) mg/l < 0.1 < 0.5 24 Chromium (Cr)+3 mg/l < 0.2 < 1.0 25 Chromium (Cr)+6 mg/l < 0.05 < 0.5 26 Copper (Cu) mg/l < 0.2 < 1.0 27 Lead (Pb) mg/l < 0.1 < 1.0 28 Mercury (Hg) mg/l < 0.002 < 0.05 29 Nickel (Ni) mg/l < 0.2 < 1.0 30 Selenium (Se) mg/l < 0.05 < 0.5 31 Silver (Ag) mg/l < 0.1 < 0.5 32 Zinc (Zn) mg/l < 1.0 < 3.0 33 Molybdenum (Mo) mg/l < 0.1 < 1.0 34 Ammonia (NH3) mg/l < 5.0 < 7.0

Appendix B 51

35 DO mg/l > 2.0 > 1.0 36 Polychlorinated Biphenyl mg/l < 0.003 < 0.003 37 Calcium mg/l < 150 < 200 38 Magnesium mg/l < 150 < 200 39 Carbon tetrachloride mg/l < 3 < 3 40 Hexachloro benzene mg/l < 2 < 2 41 DTT mg/l < 1.3 < 1.3 42 Endrin mg/l < 0.01 < 0.01 43 Dieldrin mg/l < 0.01 < 0.01 44 Aldrin mg/l < 0.01 < 0.01 45 Isodrin mg/l < 0.01 < 0.01 46 Perchloro ethylene mg/l < 2.5 < 2.5 47 Hexachloro butadiene mg/l < 3 < 3 48 Chloroform mg/l < 1 < 1 49 1,2 Dichloro ethylene mg/l < 2.5 < 2.5 50 Trichloro ethylene mg/l < 1 < 1 51 Trichloro benzene mg/l < 2 < 2 52 Hexaxhloro cyclohexene mg/l < 2 < 2 Remark: The Ministry of Environment and the Ministry of Agriculture, Forestry and Fishery shall collaborate to set up the standard of pesticides which discharged from pollution sources.

Table 2: Water Quality Standard in public water areas for bio-diversity conservation I. For River No Parameter Unit Standard Value 1 pH mg/l 6.5 – 8.5 2 BOD5 mg/l 1 – 10 3 Suspended Solid mg/l 25 – 100 4 Dissolved Oxygen mg/l 2.0 - 7.5 5 Coliform MPN/100ml < 5000 II. Lakes and Reservoirs No Parameter Unit Standard Value 1 pH mg/l 6.5 – 8.5 2 COD mg/l 1 – 8 3 Suspended Solid mg/l 1 – 15 4 Dissolved Oxygen mg/l 2.0 - 7.5 5 Coliform MPN/100ml < 1000 6 Total Nitrogen mg/l – 0.6 7 Total Phosphorus mg/l 0.005 – 0.05 III. Coastal Water No Parameter Unit Standard Value 1 pH mg/l 7.0 – 8.3 2 COD mg/l 2 – 8 3 Dissolved Oxygen mg/l 2 - 7.5

52 Appendix B

4 Coliform MPN/100ml < 1000 5 Oil content mg/l 0 6 Total Nitrogen mg/l – 1.0 7 Total Phosphorus mg/l 0.02 – 0.09

Table 3. Water Quality Standard in public water areas for public health protection No Parameter Unit Standard Value 1 Carbon tetrachloride µg/l < 12 2 Hexachloro-benzene µg/l < 0.03 3 DDT µg/l < 10 4 Endrin µg/l < 0.01 5 Diedrin µg/l < 0.01 6 Aldrin µg/l < 0.005 7 Isodrin µg/l < 0.005 8 Perchloroethylene µg/l < 10 9 Hexachlorobutadiene µg/l < 0.1 10 Chloroform µg/l < 12 11 1,2 Trichloroethylene µg/l < 10 12 Trichloroethylene µg/l < 10 13 Trichlorobenzene µg/l < 0.4 14 Hexachloroethylene µg/l < 0.05 15 Benzene µg/l < 10 16 Tetrachloroethylene µg/l < 10 17 Cadmium µg/l < 1 18 Total mercury µg/l < 0.5 19 Organic mercury µg/l 0 20 Lead µg/l < 10 21 Chromium, valent 6 µg/l < 50 22 Arsenic µg/l < 10 23 Selenium µg/l < 10 24 Polychlorobiohenyl µg/l 0 25 Cyanide µg/l < 0.005

Appendix C 53

APPENDIX C: INDICATIVE PLAN FOR REMAINING PUBLIC CONSULTATION

Organizer / Format Frequency Topic Attendees support Just Before Commencement of Construction PIU / PMCES Same public Once just before Presentation of planned Same affected consultation construction commences construction activities and households, district format used (public meetings), and as schedule; anticipated impacts representatives, and during FS and needed (site visits, and mitigation measures; and participants from DED stages, informal interviews) and GRM consultations for DED. including site thereafter during visits and construction phase as informal needed interviews as needed Operational Stage DPWT / Kep Public Once in the first year Effectiveness of mitigation Same affected Municipality consultation and measures, impacts of households, district site visits operation, comments and representatives, suggestions participants from consultations of DED Kep Public Once just before Project Public satisfaction with EMP Same affected Municipality satisfaction Completion Report (PCR) implementation comments and households, district survey if desired issued suggestions representatives, or needed participants from consultations of DED

54 Appendix D

APPENDIX D: MOE UNIT COSTS FOR GROUNDWATER QUALITY ANALYSES

Ministry of Environment Unit Costs

Unit Price Total Price No Elements Quantity (USD) (USD) 1 pH 1 2.00 2.00 2 Dissolved Oxygen (DO) 1 4.00 4.00 3 Electrode Conductivity (EC) 1 2.00 2.00 4 Total Dissolved Solids (TDS) 1 5.00 5.00 5 Chemical Oxygen Demand(COD) 1 10.00 10.00 6 Arsenic(As) 1 20.00 20.00 7 Cadmium (Cd) 1 22.50 22.50 8 Iron (Fe) 1 17.50 17.50 9 Lead(Pb) 1 20.00 20.00 10 Zinc (Zn) 1 17.50 17.50 11 Cupper (Cu) 1 17.50 17.50 12 Oil & Grease 1 12.00 12.00 13 Total Coliform 1 9.00 9.00 14 Fecal Coliform 1 9.00 9.00 15 Total Nitrogen 1 9.00 9.00 16 Ammonia 1 9.00 9.00 17 Nitrate (NO3) 1 9.00 9.00 18 Nitrite(NO2) 1 2.00 2.00

19 Ammonium(NH4) 1 7.00 7.00 20 Total Phosphorus(TP) 1 15.00 15.00

21 Phosphate(PO4) 1 6.00 6.00

22 Hydrogen sulphide(H2S) 1 7.00 7.00 23 Detergents(MBAS) 1 15.00 15.00 Total 247$

Appendix E 55

APPENDIX E: ATTENDANT LIST OF PARTICIPANT FOR PUBLIC CONSULTATION MEETING AND PICTURES

List of public consultation with provincial levels

56 Appendix E

Appendix E 57

Short of MM of Public consultation and List of public consultation with local authorities

On November 27, 2019 at 08:30 am, the study team met with relevant departments and institutions, Chaired by H.E Prum Kunthi, Vice Governor of Kep province. There are 16 departments and institutes participated as the following: - Administration office of Kep Provincial Hall - Kep Municipal Administration office - Department of the Environment - Department of Public Works and Transport - Department of Health - Department of Land Management, Urban Planning, Construction and Cadastral - Department of Planning - Department of Women's Affairs - Department of Agriculture, Forestry and Fisheries - Department of Tourism - Department of Water Resources and Meteorology - Department of Labor and Vocational Training - Department of Rural Development - Department of Culture and Fine Arts - Provincial Water and Electricity Authority of Kep - NGO.

# Institution/Department Name Key Idea and commend - The expert shall learn more Administration office 1 Mr. Khoeun Vuthy about the volume of wastewater of Kep Provincial Hall that flows from the landfill - Suggested for embankment or canal to prevent rain from this area to downstream - Wastewater treatment to treat waste water and leachate from Provincial Department 2 Mr. Im Panharith Landfill before discharging to of Environment wetlands - - Projects should be planned for the CELL to be effective for more than 20 years by reducing / isolating plastic or bottle types. - Programme of waste separation Mr. Hang at source and at landfill shall be 3 Department of Culture Sophanvong starting to do that it will help Provincial Department of

58 Appendix E

Environment in collaboration with the municipal authorities to train people to separate the waste according to type. - - wastewater from landfill shall have reservoir to discharge; - Agreed with the comments of the Department of Environment and other participants in the meeting. - Project shall not discharge waste water and leachate from landfill without treated because Department of Rural 4 Mr. Lim Sophorn it will pollute water at Development downstream due to the slope is high at the project site that can affect the source of drinking water, crops and animals. - - The project shall ensure that the smell of garbage does not affect living around the landfill.

Appendix E 59

60 Appendix E

Appendix E 61

62 Appendix E

List of Participants, Kep Public Consultations

Appendix E 63

64 Appendix E

Appendix E 65

66 Appendix E

Appendix E 67

Participants of Consultations for DED of Kep Subproject

68 Appendix E

Appendix E 69

70 Appendix F

APPENDIX F: PICTURES OF PUBLIC CONSULTATION MEETING

With concern department in Provincial levels

Source: from IESIA report, 20120

Public meeting with local people in Damnak Chang Ae village

Source: from IESIA report, 20120

Appendix G 71

APPENDIX G: SOIL DRILLING TESTING

- Location of drilling hole

72 Appendix G

- One of those holes

Appendix G 73

74 Appendix G

Appendix G 75

76 Appendix H

APPENDIX H: RESULT OF AIR, NOISE, VIBRATION AND WATER QUALITY TEST FOR BASE LINE

1. Air:

Appendix H 77

2. Noise

78 Appendix H

3. Vibration

Appendix H 79

4. Surface Water

80 Appendix H

5. Ground water

Appendix I 81

APPENDIX I: LICENSE OF IESIA FROM MOE

82 Appendix I