J.1- ENVIRONEMENTAL ASSESSMENT (EA) BH 2016-05-03_EN.pdf

Environmental Assessment

FINAL

May 3, 2016 This document was produced for review by the United States Agency for International Development. It was prepared by CDM International, Inc. and Hatfield Consultants.

ENVIRONMENTAL ASSESSMENT

OF DIOXIN CONTAMINATION AT

BIEN HOA AIRBASE

Environmental Assessment of Dioxin Contamination at Bien Hoa Airbase

Environmental Assessment in Compliance with 22 CFR 216 - FINAL

Submitted by: Peter Chenevey, Chief of Party CDM International, Inc.

75 State Street, Suite 701 Boston, Massachusetts 02109 Telephone: +1 617 452 6000 Email: cheneveypm@cdmsmith.com

Submitted to: Maura Patterson, Contracting Officer’s Representative United States Agency for International Development / Vietnam

USAID Contract No.: AID-EDH-1-00-08-00023

USAID Task Order No.: AID-486-TO-13-00009

Report Date: May 3, 2016

CONTENTS

EXECUTIVE SUMMARY

SECTION 1 SUMMARY

1.1 Purpose and Procedure

1.2 Project Area

1.3 Historical Use of Agent Orange and Other Herbicides at Bien Hoa Airbase

1.4 Potential Exposure Pathways and Site Conceptual Model

1.5 Dioxin Contamination on and around Bien Hoa Airbase

1.6 Risk Reduction Measures

1.7 Long-Term Remediation Alternatives

1.7.1 Alternative 1: No Action

1.7.2 Alternative 2: Containment Only

1.7.2.1 Alternative 2A: Landfill

1.7.2.2 Alternative 2B: Solidification/Stabilization

1.7.2.3 Comparison of Containment Alternatives

1.7.3 Alternative 5: Treatment Only

1.7.3.1 Alternative 5A: Incineration/Ex Situ Thermal Treatment

1.7.3.2 Alternative 5B: Ex Situ TCH

1.7.3.3 Alternative 5C: MCD

1.7.3.4 Comparison of Treatment Alternatives

1.7.4 Alternative 3: Landfill Material < 2,500 ppt, Ex Situ TCH Material > 2,500 ppt . 18

1.7.5 Alternative 4: Landfill Material < 1,200 ppt, Ex Situ TCH Material > 1,200 ppt . 18

1.8 EA Evaluation and Results

1.8.1 Effectiveness

1.8.2 Implementability

1.8.3 Cost

1.8.4 Environmental and Social Consequences

1.9 Stakeholder Engagement and Response

1.10 Additional Considerations

SECTION 2 BACKGROUND

2.1 Need for the Development of Remedial Alternatives

2.2 Threshold Determination and Study Purpose

2.3 Environmental Scoping Statement

2.4 Stakeholder Engagement and Host Government Consultations

2.5 Legal and Regulatory Considerations

2.5.1 Vietnam

2.5.2 United States

2.5.3 Consideration of Requirements of Both Countries

2.5.3.1 Laws and Regulations

2.5.3.2 Guidance

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Contents

2.6 Obligations under International Environmental Conventions and Agreements

SECTION 3 SUMMARY OF CURRENT SITUATION

3.1 Bien Hoa Airbase and Surrounding Communities

3.2 Dioxin Contamination on and around Bien Hoa Airbase

3.2.1 Summary of Previous Studies at Bien Hoa Airbase

3.2.2 USAID Sampling at Bien Hoa Airbase

3.2.3 Potential Exposure Pathways and Site Conceptual Model

3.2.4 Land Use Planning for Bien Hoa Airbase

3.2.5 Volume of Contaminated Material to be Remediated

3.3 Risk Reduction Measures

3.3.1 Current Measures

3.3.2 Recommendations for Additional Interim Measures

SECTION 4 EVALUATION OF ALTERNATIVES

4.1 Potentially Applicable Technologies/Strategies

4.2 Screening of Technologies and Description of Alternatives

4.2.1 Technologies and Strategies

4.2.2 Alternatives

4.3 Description of Evaluation Criteria

4.3.1 Effectiveness

4.3.2 Implementability

4.3.3 Cost

4.3.4 Environmental and Social Consequences

4.4 Alternatives Evaluation and Findings

4.4.1 Alternative 1: No Action

4.4.1.1 Conceptual Design

4.4.1.2 Effectiveness

4.4.1.3 Implementability

4.4.1.4 Cost

4.4.1.5 Environmental and Social Consequences

4.4.2 Alternative 2A: Landfill

4.4.2.1 Conceptual Design

4.4.2.2 Effectiveness

4.4.2.3 Implementability

4.4.2.4 Cost

4.4.2.5 Environmental and Social Consequences

4.4.2.6 Active Landfill

4.4.3 Alternative 2B: Solidification/Stabilization

4.4.3.1 Conceptual Design

4.4.3.2 Effectiveness

4.4.3.3 Implementability

4.4.3.4 Cost

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4.4.3.5 Environmental and Social Consequences

4.4.4 Comparison of Containment Alternatives

4.4.5 Alternative 5A: Incineration/Ex Situ Thermal Treatment

4.4.5.1 Conceptual Design

4.4.5.2 Effectiveness

4.4.5.3 Implementability

4.4.5.4 Cost

4.4.5.5 Environmental and Social Consequences

4.4.6 Alternative 5B: Ex Situ TCH

4.4.6.1 Conceptual Design

4.4.6.2 Effectiveness

4.4.6.3 Implementability

4.4.6.4 Cost

4.4.6.5 Environmental and Social Consequences

4.4.7 Alternative 5C: MCD

4.4.7.1 Conceptual Design

4.4.7.2 Effectiveness

4.4.7.3 Implementability

4.4.7.4 Cost

4.4.7.5 Environmental and Social Consequences

4.4.8 Comparison of Treatment Alternatives

4.4.9 Alternative 3: Containment of Materials Less than 2,500 ppt TEQ, Treatment of

Materials Greater than 2,500 ppt

4.4.9.1 Conceptual Design

4.4.9.2 Effectiveness

4.4.9.3 Implementability

4.4.9.4 Cost

4.4.9.5 Environmental and Social Consequences

4.4.10 Alternative 4: Containment of Materials Less than 1,200 ppt TEQ, Treatment of Materials Greater than 1,200 ppt

4.4.10.1 Conceptual Design

4.4.10.2 Effectiveness

4.4.10.3 Implementability

4.4.10.4 Cost

4.4.10.5 Environmental and Social Consequences

4.4.11 Summary of Evaluation

4.5 Lessons Learned

SECTION 5 AFFECTED ENVIRONMENT

5.1 Physical Environmental Resources

5.1.1 Climate

5.1.2 Site Topography and Surface Water Hydrology

5.1.3 Soils and Sediments

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5.1.4 Groundwater Resources

5.1.5 Groundwater Quality

5.1.6 Surface Water Quality

5.1.7 Air Quality

5.2 Natural and Biological Resources

5.2.1 Terrestrial Ecosystems and Biodiversity

5.2.2 Wetlands, Aquatic Ecosystems and Biodiversity

5.2.3 Endangered Species

SECTION 6 GENDER BASELINE

6.1 Gender-Specific Regulatory Requirements

6.2 Role and Status of Women in Vietnam

6.3 Gender Conditions at Bien Hoa Airbase and Bien Hoa City

6.3.1 Residents of Bien Hoa City

6.3.2 Military Personnel and Airbase Workers

6.3.3 Construction Workers

SECTION 7 ENVIRONMENTAL CONSEQUENCES

7.1 Effects Assessment

7.1.1 Environmental Impacts Not Considered

7.1.2 Potential Effects on Land Use and Land Disturbance

7.1.2.1 Description of Effects

7.1.2.2 Impact Analysis

7.1.2.3 Determination of Effects

7.1.3 Potential Environmental and Health Impacts Associated with UXO Cleanup .. 244

7.1.3.1 Description of Effects

7.1.3.2 Recommended Mitigation and Monitoring Measures and Impact

Analysis

7.1.3.3 Determination of Effects

7.1.4 Effects on Surface Water Hydrology and Surface Water Quality

7.1.4.1 Description of Effects

7.1.4.2 Impact Analysis

7.1.4.3 Recommended Mitigation and Monitoring Measures

7.1.4.4 Determination of Effects

7.1.5 Effects on Groundwater

7.1.5.1 Description of Effects

7.1.5.2 Impact Analysis

7.1.5.3 Recommended Mitigation and Monitoring Measures

7.1.5.4 Determination of Effects

7.1.6 Potential Effects of Dioxin-Contaminated Material, Other COPCs, and Dust on Air Quality

7.1.6.1 Description of Effects

7.1.6.2 Impact Analysis

iv

7.1.6.3 Recommended Mitigation and Monitoring Measures

7.1.6.4 Determination of Effects

7.1.7 Potential Effects on Greenhouse Gas Emissions

7.1.7.1 Description of Effects

7.1.7.2 Impact Analysis

7.1.7.3 Recommended Mitigation and Monitoring Measures

7.1.7.4 Determination of Effects

7.1.8 Potential Effects on Terrestrial Ecosystems and Biodiversity

7.1.8.1 Description of Effects

7.1.8.2 Impact Analysis

7.1.8.3 Recommended Mitigation and Monitoring Measures

7.1.8.4 Determination of Effects

7.1.9 Potential Effects on Wetlands, Aquatic Ecosystems, and Aquatic Biodiversity . 256

7.1.9.1 Description of Effects

7.1.9.2 Impact Analysis

7.1.9.3 Recommended Mitigation and Monitoring Measures

7.1.9.4 Determination of Effects

7.1.10 Potential Effects on Noise Levels

7.1.10.1 Description of Effects

7.1.10.2 Impact Analysis

7.1.10.3 Recommended Mitigation and Monitoring Measures

7.1.10.4 Determination of Effects

7.1.11 Potential Effects on Natural or Depletable Resource Requirements

7.1.11.1 Description of Effects

7.1.11.2 Impact Analysis

7.1.11.2 Recommended Mitigation and Monitoring Measures

7.1.11.4 Determination of Effects

7.1.12 Potential Long-Term Environmental Risks Associated with Operation of Selected Remedial Alternative

7.1.12.1 Description of Effects

7.1.12.2 Recommended Mitigation and Monitoring Measures and Impact

Analysis

7.1.12.3 Determination of Effects

7.1.13 Risk of Re-Contamination of Treated Lakes

7.1.13.1 Description of Effects

7.1.13.2 Recommended Mitigation and Monitoring Measures and Impact

Analysis

7.1.13.3 Determination of Effects

7.1.14 Potential Requirements for Resettlement

7.1.14.1 Description of Effects

7.1.14.2 Impact Analysis

7.1.14.3 Recommended Mitigation and Monitoring Measures

7.1.14.4 Determination of Effects

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7.1.15 Potential Impacts from Climate Change

7.2 Gender Issues in Relation to Remediation Alternatives

7.2.1 Assessment of Gender-Related Effects

7.2.1.1 Construction Workers

7.2.1.2 Military Personnel and Airbase Workers

7.2.1.3 Residents

7.2.2 Project Beneficiaries

7.3 Environmental Mitigation and Monitoring

7.3.1 Overview

7.3.2 Environmental Mitigation

7.3.3 Environmental Monitoring

7.3.4 Gender Considerations in EMMP Design and Implementation

7.3.5 Resettlement Considerations in EMMP Design and Implementation

7.4 Summary of Environmental Consequences

7.4.1 No Action Alternative

7.4.2 Remedial Alternatives

SECTION 8 OVERALL SUMMARY AND ADDITIONAL CONSIDERATIONS

8.1 Overall Summary

8.2 Additional Site Characterization Considerations

8.3 Pre-Implementation Considerations

8.4 Technology Evaluation Considerations

SECTION 9 REFERENCES

SECTION 10 LIST OF PREPARERS

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TABLES

Table 1-1 GVN Dioxin Standards/Allowable Limits of Dioxin Contamination Specified in GVN

National Technical Regulation on Allowed Limits of Dioxin in Soils (QCVN

45:2012/BTNMT)

Table 1-2 Summary of Alternatives Evaluation Table 1-3 Summary of Comments Received from GVN Stakeholders on EA Document Table 2-1 GVN Dioxin Standards/Allowable Limits of Dioxin Contamination Specified in GVN

National Technical Regulation on Allowed Limits of Dioxin in Soils (QCVN

45:2012/BTNMT)

Table 2-2 Representative International Guidelines and Standards for PCDD and PCDF TEQ Table 2-3 Representative International Guidelines and Standards for Dioxin Concentrations in Fish

Tissues Table 2-4 International Conventions and Agreements to which Vietnam is a Signatory that are of

Potential Relevance to this Study Table 3-1 Characterization Studies of Dioxin Contamination Conducted at Bien Hoa Airbase Table 3-2 Summary of Sampling Results of Dioxin Source Areas of Bien Hoa Airbase 1990-2013 Table 3-3 Summary of Samples Collected during 2014/2015 EA Sampling Program Table 3-4 Summary of Samples Analyzed Table 3-5 Areas Sampled as Part of the 2014/2015 EA Sampling Program and Significant Findings for

Each Area Table 3-6 Estimated Area of Contaminated Soil and Sediment at Bien Hoa Airbase Table 3-7 MND-Approved Allowable Dioxin Concentration Limits for Sampling Decision Units Table 3-8 Estimated Volume of Contaminated Soil and Sediment at Bien Hoa Airbase Table 3-9 Estimated Contamination Volume Distribution by Depth Table 4-1 Technologies Identified and Screening Results Table 4-2 Summary of Estimated Haul Distances from Contaminated Locations to

Containment/Treatment Areas Table 4-3 Summary of Estimated Excavation Volumes for Alternatives 1 through 5 Table 4-4 Alternative 2A Passive Landfill – Preliminary Estimated Overall Cost Table 4-5 Alternative 2B Solidification/Stabilization – Preliminary Estimated Overall Cost Table 4-6 Alternative 5A Incineration – Preliminary Estimated Overall Cost Table 4-7 Alternative 5B Ex Situ TCH – Preliminary Estimated Overall Cost Table 4-8 Alternative 5C MCD – Preliminary Estimated Overall Cost Table 4-9 Alternative 3 and 4 Containment/Treatment Hybrids – Volumes Summary Table 4-10 Alternative 3 Containment/Treatment Hybrid (2,500 ppt) – Preliminary Estimated Overall

Cost Table 4-11 Alternative 4 Containment/Treatment Hybrid (1,200 ppt) – Preliminary Estimated Overall

Cost Table 4-12 Comparison of Effectiveness Evaluation of Remediation Alternatives Table 4-13 Comparison of Implementability Evaluation of Remediation Alternatives Table 4-14 Comparison of Implementation Cost Evaluation of Remediation Alternatives Table 4-15 Comparison of Potential Environmental Consequences Evaluation of Remediation

Alternatives vii

Table 6-1 Vietnam’s Performance on GGIs, 2014 Table 6-2 Vietnam’s Performance on Human Development Index (HDI), 2013 Table 6-3 Indicators for Vietnam for Gender Related Development Indices Table 7-1 Comparison of Land Disturbance Area for the Remediation Alternatives Table 7-2 Estimated Volumes of Contaminated Wastewater for the Remedial Alternatives Table 7-3 Comparison of Estimated GHG Emissions for the Remedial Alternatives Table 7-4 Indicative Costs of Purchasing the Required Carbon Credits for each of the Remedial

Alternatives Evaluated in this EA Table 7-5 Comparison of Noise Impacts for the Remedial Alternatives Table 7-6 Comparison of Clean Fill Required for the Remedial Alternatives Table 7-7 Key Environmental Issues and Indicative Mitigation Measures Table 8-1 Summary of Remediation Alternatives viii

FIGURES

Figure 1-1 Overall Site Map, Bien Hoa Airbase, Vietnam Figure 1-2 Overall Site Map with Sampling Decision Units, Bien Hoa Airbase, Vietnam Figure 1-3 Range of Remediation Alternatives Considered for Bien Hoa EA Figure 2-1 Bien Hoa Airbase Location Map and Areas of Known and Potential Dioxin

Contamination Figure 3-1 Overall Site Map with Sampling Decision Units, Bien Hoa Airbase, Vietnam Figure 3-2 2014/2015 Soil and Sediment Sampling Results – Z1 Area Figure 3-3 2014/2015 Soil Sampling Results – ZT Area Figure 3-4 2014/2015 Soil Sampling Results – Southwest Area Figure 3-5 2014/2015 Soil and Sediment Sampling Results – Pacer Ivy Area Figure 3-6 2014/2015 Sediment Sampling Results – Northwest Area Figure 3-7 2014/2015 Soil Sampling Results – Northern Forest Area Figure 3-8 2014/2015 Soil and Sediment Sampling Results – Northeast Area Figure 3-9 2014/2015 Soil Sampling Results – Southeast Area Figure 3-10 2014/2015 Sediment Sampling Results – Outside of the Airbase Figure 3-11 Conceptual Transport and Exposure Pathway Model for Human and Ecological Receptors from Contaminant Sources Figure 4-1 Range of Remediation Alternatives Considered for Bien Hoa EA Figure 4-2 Primary Trucking Haul Routes Figure 4-3 Conceptual Layout of Alternative 2A in Pacer Ivy Area Figure 4-4 Conceptual Layout of Alternative 2A in Z1 Area Figure 4-5 Conceptual Landfill Cross-Section Figure 4-6 Alternative 2A Landfill Schedule Figure 4-7 Conceptual Layout of Alternative 2B in Pacer Ivy Area Figure 4-8 Conceptual Layout of Alternative 2B in Z1 Area Figure 4-9 Alternative 2B Stabilization/Solidification Schedule Figure 4-10 Conceptual Layout of Alternative 5A in Pacer Ivy Area Figure 4-11 Conceptual Layout of Alternative 5A in Z1 Area Figure 4-12 Incineration Conceptual Process Flow Diagram Figure 4-13 Alternative 5A Incineration Schedule Figure 4-14 Conceptual Layout of Alternative 5B in Pacer Ivy Area Figure 4-15 Conceptual Layout of Alternative 5B in Z1 Area Figure 4-16 Ex Situ TCH Conceptual Cross Section Figure 4-17 Ex Situ TCH Treatment System Process Flow Diagram Figure 4-18 Alternative 5B Ex Situ TCH Schedule Figure 4-19 Conceptual Layout of Alternative 5C in Pacer Ivy Area Figure 4-20 Conceptual Layout of Alternative 5C in Z1 Area Figure 4-21 MCD Conceptual Process Flow Diagram Figure 4-22 Alternative 5C MCD Schedule Figure 4-23 Conceptual Layout of Alternative 3 in Pacer Ivy Area Figure 4-24 Conceptual Layout of Alternative 3 in Z1 Area ix

Figure 4-25 Alternative 3 Containment/Treatment Hybrid (2,500 ppt) Schedule Figure 4-26 Conceptual Layout of Alternative 4 in Pacer Ivy Area Figure 4-27 Conceptual Layout of Alternative 4 in Z1 Area Figure 4-28 Alternative 4 Containment/Treatment Hybrid (1,200 ppt) Schedule Figure 5-1 Summary of Climatic Conditions for Bien Hoa City Figure 5-2 General Pattern of Surface Water and Groundwater Flows on and in the Vicinity of Bien

Hoa Airbase x

APPENDICES

A Summary of Dioxin Contamination at Bien Hoa Airbase B Volume Estimates C Description of Potentially-Applicable Technologies/Strategies D Preliminary Estimated Overall Costs for Alternatives E Environmental Baseline Information F Supporting Analyses for Environmental Assessment G Results of Additional Sampling Performed by AMST, December 2015 to January 2016 xi

ACRONYMS AND ABBREVIATIONS

°C degrees Celsius °F degrees Fahrenheit µg/L micrograms per liter 10-80 Division 10-80 Division of the Ministry of Health 2,4,5-T 2,4,5-trichlorophenoxyacetic acid 2,4-D 2,4- dichlorophenoxyacetic acid ACC American Chemistry Council ADAFC Air Defense Air Force Command ADB Asian Development Bank ADS Automated Directive System Airbase Bien Hoa Airbase AMST Academy of Military Science and Technology ASEAN Association of Southeast Asia Nation ASTM American Society for Testing and Materials ATSDR Agency for Toxic Substances and Disease Registry AXYS AXYS Analytical Services Ltd.

BEM BEM Systems, Inc.

BEO Bureau Environment Officer BMP best management practice CC Chemical Command CDCS Country Development and Cooperation Strategy CDM Smith CDM International, Inc.

CEDAW United Nations Convention on the Elimination of Discrimination against Women CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CFIA Canadian Food Inspection Agency CFR United States Code of Federal Regulations CIA United States Central Intelligence Agency cm centimeter CO2 carbon dioxide CO2e carbon dioxide equivalent COPC contaminant of potential concern CSF concentration safety factor DE destruction efficiency dioxin 2,3,7,8-tetrachlorodibenzo-p-dioxin DOD United States Department of Defense DONRE Department of Natural Resources and Environment DQO data quality objective DU decision unit xii

EA Environmental Assessment EDL Environmental Decontamination, Ltd.

EIA Environmental Impact Assessment EMMP Environmental Mitigation and Monitoring Plan ESS Environmental Scoping Statement EU European Union FAA Foreign Assistance Act FAR Federal Acquisition Regulation FDA Food and Drug Administration FS feasibility study GAC granular activated carbon GCL geosynthetic clay liner GDP gross domestic product GEF Global Environment Facility GFH granular ferric hydroxide GGI Gender Gap Index GHG greenhouse gas GII gender Inequality Index GIS geographic information system GNI gross national income GPS global positioning system GSO General Statistics Office GVN Government of Vietnam H&S Health and Safety ha hectare Hatfield Hatfield Consultants Partnership HDI Human Development Index HDPE high density polyethylene hp horsepower hr hour HR-GCMS high-resolution gas chromatography – mass spectrometry IBT Institute of Biotechnology ICEM International Centre for Environmental Management IEE Initial Environmental Examination ILO International Labor Organization IPTD® In-Pile Thermal Desorption IR Intermediate Result ITRC Interstate Technology and Regulatory Council JAC Joint Advisory Committee KAP knowledge, attitude, and practice xiii kg bw/d kilograms body weight per day km kilometer km2 square kilometer kWh kilowatt-hour L liter LLDPE linear low-density polyethylene LVTP liquid vapor treatment plant LWIC lightweight insulating concrete m meter M million m2 square meter m3 cubic meter masl meters above sea level MCD mechano-chemical destruction MCL maximum contaminant level MCS Matrix Constituent Separator mg/kg milligrams per kilograms MIS multi-increment® sampling mm millimeter MMBTU million British Thermal Unit MND Ministry of National Defense MOH Ministry of Health MOLISA Ministry of Labor, Invalids and Social Affairs MONRE Ministry of Natural Resources and Environment MPPE macroporous-polymer extraction MSD Military Science Department NAPL non-aqueous phase liquid NCFAW National Committee for the Advancement of Women in Vietnam NIP National Implementation Plan No. number NOx nitrous oxide O&M operation and maintenance Office 33 Office of National Steering Committee 33 OSHA Occupational Safety and Health Administration PAH polycyclic aromatic hydrocarbons PAP project affected people PAVN People’s Army of Vietnam PCB polychlorinated biphenyls PCDD polychlorinated dibenzo-p-dioxin PCDF polychlorinated dibenzofuran xiv pg picograms pg/g picograms per gram pg/L picograms per liter POP persistent organic pollutant PPE personal protective equipment ppm parts per million PPP purchasing power parity ppq parts per quadrillion ppt parts per trillion QA/QC quality assurance/quality control RAP Resettlement Action Plan RCE Request for Categorical Exclusion RCRA Resource Conservation and Recovery Act RPD relative percent difference SAP sampling and analysis plan SARA Superfund Amendments and Reauthorization Act of 1986 SCM site conceptual model SEP stakeholder engagement plan SITE Superfund Innovative Technology Evaluation SPLP Synthetic Precipitation Leaching Procedure SpO Special Objective SRB sex ratio at birth Study Environmental Assessment at Bien Hoa Airbase SVOC semivolatile organic compound t ton TCDD tetrachlorodibenzo-p-dioxin TCH Thermal Conductive Heating TCLP Toxicity Characteristic Leaching Procedure TDI tolerable daily intake TEQ toxicity equivalent TOC total organic carbon tph tons per hour U.S. United States UCL upper confidence limit UNDP United Nations Development Programme UNESCAP United Nations Economic and Social Commission for Asia and the Pacific UNESCO United Nations Educational, Scientific and Cultural Organization UNPF United Nations Population Fund UNVN United Nations Vietnam USAID United States Agency for International Development xv

USD U.S. Dollar USEPA United States Environmental Protection Agency USG United States Government UXO unexploded ordnance VAST Vietnamese Academy of Science and Technology VCP Vietnamese Communist Party VEA Vietnam Environment Administration VOC volatile organic compound VPHA Vietnam Public Health Administration VRTC Vietnam-Russia Tropical Center WHO World Health Organization ZT Z1 Taxiway xvi

Executive Summary

On September 29, 2013, the United States Agency for International Development (USAID) awarded a contract to CDM International, Inc. (CDM Smith) to carry out the project, "Environmental Assessment of Dioxin Contamination at Bien Hoa Airbase." The purpose of the project is to complete an Environmental Assessment (EA) at the Bien Hoa Airbase (referred herein as the Airbase) that meets the requirements of Title 22 of the United States (U.S.) Code of Federal Regulations (CFR), Part 216. The Airbase is a key dioxin contamination hotspot due to past usage, storage, and handling of Agent Orange and other herbicides during the U.S.-Vietnam War. The overall objective of the EA at Bien Hoa Airbase (Study) is to inform potential future actions on the Airbase to address dioxin-related contamination.

An Environmental Scoping Statement (ESS), prepared as the first step in the development of the EA and approved by the USAID Asia Bureau Environment Officer (BEO) in October 2014, defined the scope of the EA. The scope of work for the EA at the Airbase included addressing significant potential adverse health-related, environmental, and social issues associated with implementing activities for remediation of dioxin-contaminated soil and sediment to Government of Vietnam (GVN) standards and enhancing beneficial use of the Airbase. The ESS determined that the EA would need to document stakeholder engagement discussions and consultations, applicable GVN standards for remediation, supplemental investigation sampling and analyses, the site conceptual model, evaluations of remediation alternatives, affected environment and environmental consequences of implementing remediation, consequences to social resources if they are indirectly affected through changes in the physical and natural environment from implementing remediation, approaches for environmental mitigation and monitoring, and resettlement.

Dioxin Contamination on and Around Bien Hoa Airbase Prior to this Study, there had been at least eleven studies characterizing dioxin contamination in and around the Airbase since 1990. Seven of the eleven studies were obtained, but only five of the studies had data available. There are multiple areas of known or suspected contamination on the Airbase (Z1 Area, Southwest Area, Pacer Ivy Area, Northeast Area, and Northwest Area) and areas outside of the Airbase (west of the Pacer Ivy Area, and Gate 2 Lake and Bien Hung Lake to the south of the Airbase).

The locations of these areas are shown in Figure 2-1.

Considering the results from historical sampling efforts, it was evident that dioxin-contaminated soil and sediment exists as a result of past handling, storage, and disposal of Agent Orange and other herbicides.

When released, these extremely hydrophobic/water insoluble compounds became associated with the organic fractions of Airbase soils and sediment. Contaminated surface soils and sediments have spread from their original sites of storage, handling, and spills through several primary transport and release mechanisms: runoff during rainfall events; excavation and movement of contaminated material during the course of Airbase activities, such as construction and agriculture; and through wind erosion.

However, while the historical data provided good information on the nature of the contamination, there remained potential discrepancies in historical data and areas in need of further and better characterization to determine the full extent of contamination and to calculate a reliable estimate for the volume of dioxin-contaminated soil and sediment. To address these data gaps and needs, a sampling program was designed and implemented in close collaboration with the Vietnamese-assigned Study counterpart, the Vietnam Ministry of National Defense’s Academy of Military Science and Technology (AMST). Samples were collected at the Airbase as part of this Study from 76 different areas called decision units during two separate field mobilizations in 2014 and 2015. These samples were collected using a comprehensive sampling methodology known as multi-increment® sampling (MIS), which is designed to best account for heterogeneity in soils and generate results with significantly less variability and a higher statistically-defensible level of confidence than discrete sampling or other less robust composite sampling methods. In total, the sampling program generated more than 1,400 samples, which included more than 1,300 composite soil and sediment samples for potential dioxin analysis and 100 samples of soil, sediment, groundwater, and biota for various chemical and/or physical property testing.

The number of samples collected and analyzed as part of this Study is unprecedented in Vietnam and is the largest dioxin sampling program undertaken to date in the country.

Approximately 550 composite dioxin soil and sediment samples were analyzed and compared with the land use based dioxin limits approved by the Ministry of National Defense (MND) for the Airbase. The MND-approved dioxin limits are consistent with the Government of Vietnam’s land use based standards for allowable limits of dioxin in soils (QCVN 45:2012/BTNMT) and sediment (TCVN 8183: 2009) and were applied based on current and likely future land use. Based on laboratory results, dioxin contamination was confirmed in known source areas (i.e., the Z1, Southwest, and Pacer Ivy Areas), other known, less contaminated areas on and off the Airbase (i.e., the Northeast and Northwest Areas, areas to the west of Pacer Ivy Area, and Gate 2 lake), and was also identified in a few new areas on and off Airbase (i.e., the Z1 Taxiway Area, and other portions of the Southwest and Pacer Ivy Areas). The total estimated volume of dioxin-contaminated soils and sediments identified during this Study is approximately 408,500 to 495,300 cubic meters (m3). This consists of approximately 315,700 to 377,700 m3 of contaminated soil and 92,800 to 117,600 m3 of contaminated sediment found both on and off the Airbase.

Given the distribution of dioxin contamination in Airbase soils and sediments, as well as some off base sediments and fish, there remains exposure risk to receptors both inside and outside of the Airbase.

Previous studies (Hatfield and Office 33 2011; Durant et al. 2014) have identified that the main pathway for exposure to dioxin from the site is consumption of fish and other aquatic organisms. All but one of the fish samples analyzed during the 2014/2015 sampling effort was contaminated, and fishing bans have historically not been effective (Thanh 2015). Thus, the raising, harvesting, and transport of contaminated fish and other aquatic animals to consumers both inside and outside the Airbase results in a high potential for dioxin contamination in the general population of Bien Hoa. There are other exposure pathways that remain open, but this potential consumption of fish and other aquatic animals remains the largest contributor to human health risk.

A subset of the soil and sediment samples was also analyzed to understand the influence of physical properties and/or potential impacts from the presence of other compounds and contaminants of potential concern (COPC) on a future remediation project. These analyses indicate that remediation alternatives need to consider the potential human health impact of arsenic in soils and sediments, but no other COPC were found to be located in areas of identified dioxin contamination, nor were they present at concentrations above applicable GVN standards or appropriate U.S. Environmental Protection Agency (USEPA) risk-based screening levels.

Samples of drinking water and shallow groundwater were also collected to understand current exposure pathways and pathways that may arise during future remediation. Several historical samples and two recent samples from shallow groundwater (not a drinking water source) collected on the Airbase adjacent to identified source areas have contained dioxin concentrations above the GVN wastewater discharge standard of 10 parts per quadrillion (ppq) as well as the USEPA drinking water standards (30 ppq) in unfiltered water. In the two recent samples with exceedances, the filtered water exceeded only the GVN wastewater discharge standard, and not the higher USEPA standard. Samples from on-site drinking water sources as well as off-site groundwater production wells did not contain concentrations of dioxin above applicable USEPA or GVN standards.

Remediation Alternatives Data and information collected during the EA process were used to generate several remediation alternatives for evaluation ranging from no action through complete containment to complete treatment. The alternatives were developed using technologies identified from a literature review and that met screening criteria for maturity, cost competitiveness, and GVN acceptance. The alternatives evaluated in this EA include the following:

• Alternative 1: No Action (baseline; for comparison purposes).

• Alternative 2: Provide containment of all soil and sediment above the MND-approved dioxin limits established for the various areas of the Airbase:

− Alternative 2A: Contain in a Passive or Active Landfill.

− Alternative 2B: Contain using Solidification/Stabilization.

• Alternative 3: Treat all soil and sediment above 2,500 ppt; contain the soil and sediment between MND-approved dioxin limits and 2,500 ppt.

• Alternative 4: Treat all soil and sediment above 1,200 ppt; contain the soil and sediment between the MND-approved dioxin limits and 1,200 ppt.

• Alternative 5: Treat all soil and sediment above the MND-approved dioxin limits established for the various areas of the Airbase:

− Alternative 5A: Treat using Incineration/Ex Situ Thermal Treatment.

− Alternative 5B: Treat using Ex Situ Thermal Conductive Heating (TCH).

− Alternative 5C: Treat using Mechano-Chemical Destruction (MCD).

Conceptual designs of the above alternatives were developed and evaluated with regard to effectiveness, implementability, cost, and environmental and social impact. All alternatives (except for the No Action Alternative, Alternative 1) would comply satisfactorily with GVN regulations and the MND-approved dioxin limits for the Airbase and achieve acceptable environmental and social impacts, including the removal and destruction of all fish and aquatic animals in all lakes. As such, all actionable alternatives reduce risk of human exposure to dioxin contamination. Therefore, any of the actionable alternatives (Alternatives 2 through 5) presented herein are preferable to the No Action Alternative.

Given the current and foreseen land use of a large majority of the contaminated area as a military airbase, a hybrid alternative that treats the highest risk material and contains all other excavated material is a reasonable option that balances U.S. Government (USG) and GVN regulatory preferences for treatment with more practical, lower-cost options for management of the lower risk material. Between the two containment technologies, the solidification/stabilization option is preferable to landfilling as it requires less maintenance and is a potentially permanent solution that could allow some reuses of the land, whereas landfilling requires maintenance and monitoring for the anticipated life of the landfill (typically 50 years, after which the integrity of the landfill may become compromised) and no land reuse within the landfill footprint. Among the treatment technologies, incineration and ex situ TCH are preferable to MCD, as incineration and ex situ TCH are well demonstrated for dioxin remediation at full scale, and can be implemented with effective treatment of off-gases at the concentrations found at Bien Hoa. While the MCD technology has been demonstrated for concentrations found at the Airbase, the test was not full scale (6 kilograms batches), upgrades are needed to improve issues associated with fugitive dust and off-gas controls, and air emissions control still needs to be verified through strict stack testing. Incineration bears more upfront capital costs but has the advantage of not requiring a patent and is something that could be sustained by the Vietnamese and used after dioxin remediation for treatment of other persistent organic pollutants. Ex situ TCH, on the other hand, must be conducted by a patented vendor, and while the good performance of such technology at the Danang Airport remediation project provides more certainty in implementation, this technology is not something that could be “left behind” for the Vietnamese to use for other contaminants and/or at lesser dioxin hotspots.

A preliminary estimated overall cost was developed for each alternative (with the exception of Alternative 1 – No Action) based on the conceptual-level design presented in the EA. At the alternatives evaluation stage, the designs for the remediation alternatives are still conceptual, not detailed, and the cost estimates are considered to be "order-of-magnitude." The remediation alternative preliminary estimated overall costs were developed during the EA primarily for the purpose of comparing alternatives during the remediation alternative selection process, not for establishing Project budgets. Costs for remediation alternatives are expected to have accuracies between -40% to +75% of actual costs, based on the scope presented.

Alternative 2A is the least expensive while Alternative 5A is the most expensive. Based on the contaminated volume estimate of 495,300 m3, the preliminary estimated overall cost estimate for a passive landfill under Alternative 2A is $137 million (with an estimated cost range of $82 million to $239 million) over 5 to 6 years of implementation while for incineration under Alternative 5A the preliminary estimated overall cost estimate is $794 million (with an estimated cost range of $476 million to $1.4 billion) over 8 to10 years of implementation. For Alternative 1 – No Action, there are no costs associated with implementation or long-term operation and maintenance (O&M). However, there could be significant externalized costs, such as the costs associated with illness that might result from exposure to elevated concentrations of dioxin. While these costs cannot be quantified, they are important to note and could be substantial.

All remediation alternatives have a number of positive environmental consequences as a result of removing dioxin exposure pathways and reducing exposure risk to dioxin, as well as removing dioxin concentrations on the Airbase as a constraint to land use changes and development. In general, the overall environmental and associated social and gender impacts of all remediation alternatives are potentially substantial. However, there are mitigation and monitoring measures available to address all potential environmental and associated social and gender impacts and at a small fraction of the costs for any of the alternatives.

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Additional Future Considerations All remediation alternatives require planning and engineering designs, project approval by the GVN, and procurement. It is anticipated this process could take three to five years prior to implementation of any alternative. In general, once an alternative and technology(ies) have been selected and a design contractor has been procured (a process which could take one to two years), approximately two to three years should be allowed for the development of full implementation designs, the GVN’s required environmental impact assessment, and all associated approval processes.

Moving forward, project stakeholders have several considerations and actions that are necessary to develop a remediation project from the conceptual designs discussed within this EA. In approximate chronological order according to a typical project lifecycle (i.e., study through implementation), project stakeholders should consider some additional targeted site characterization and baseline data gathering to assist with future design and planning activities. This should include: a risk assessment; further evaluation of specific remediation technologies identified during the EA process; consultations with the GVN and other potential implementing partners to select an overall remediation strategy including roles and responsibilities, and develop full design packages for the chosen strategy; and incorporation of lessons learned from the implementation of remediation at Danang Airport. Stakeholders should also consider implementation of additional interim measures to reduce ongoing exposure risk to the local population both on and off of the Airbase, especially from consumption of contaminated fish and biota, regardless of how or when implementation occurs.

Section 1 Summary

1.1 Purpose and Procedure

This document is the Environmental Assessment (EA) prepared under Task Order AID-486-13-00009, Environmental Assessment at Bien Hoa Airbase (the Study), funded by the United States Agency for International Development (USAID). This document has been prepared by CDM International, Inc.

(CDM Smith) and Hatfield Consultants (Hatfield) in compliance with Title 22 of the United States (U.S.)

Code of Federal Regulations (CFR), Part 216.

The Bien Hoa Airbase (referred herein as the Airbase) is a prominent dioxin contamination hotspot due to past usage, storage, and handling of Agent Orange and other herbicides during the U.S.-Vietnam War.

The overall objective of this EA is to inform potential future actions on the Airbase to address Agent Orange-related contamination. Specifically, the purpose of this EA is to:

• Understand the full nature and extent of dioxin contamination on and around the Airbase.

• Determine exposure pathways from dioxin contamination.

• Evaluate feasible environmental short-term mitigation and monitoring/interim measures.

• Evaluate potential long-term remediation alternatives.

In addition, a gender assessment was conducted and is included in this EA to:

• Determine if there are gender biases regarding exposure to dioxin in the home or workplace resulting from current exposure pathways or which might result from recommended dioxin containment and remediation at the Airbase.

• Develop measures to mitigate gender bias that would be incorporated into containment and remediation designs, if necessary.

The EA at Bien Hoa Airbase is subject to the environmental procedures established under Title 22 U.S.

CFR Chapter 216 (22 CFR 216) and the Request for Categorical Exclusion (RCE) prepared as part of the Initial Environmental Evaluation (IEE), approved on September 6, 2012, and the IEE Amendment to the RCE, approved on March 2, 2015, which changed the EA categorization to a Negative Determination with Conditions. The purpose of this EA is to fulfill requirements for environmental remediation at the Airbase in accordance with 22 CFR 216.6(a) which states:

“The purpose of the Environmental Assessment is to provide Agency and host country decision makers with a full discussion of significant environmental effects of a proposed action. It includes alternatives which would avoid or minimize adverse effects or enhance the quality of the environment so that the expected benefits of development objectives can be weighed against any adverse impacts upon the human environment or any irreversible or irretrievable commitment of resources.”

The Bien Hoa EA began with a scoping phase, which included information gathering of historical environmental data and current site specific conditions; this scoping phase was documented in an Environmental Scoping Statement (ESS) as required under 22 CFR 216 and was approved by the USAID

Section 1 Summary

Asia Bureau Environment Officer (BEO) in October 2014. The ESS determined the scope and significance of issues to be analyzed in the EA and identified and eliminated from detailed study those issues that were not significant or had been covered by earlier environmental reviews, thereby defining the scope of the EA. The scope of work for the EA at the Airbase included addressing significant potential adverse health-related, environmental, and social issues associated with implementing activities for remediation of dioxin- containing soil and sediment to GVN standards and enhancing beneficial use of the Airbase. The ESS determined that the EA would need to document stakeholder engagement discussions and consultations, applicable GVN standards for remediation, supplemental investigation sampling and analyses, the site conceptual model, evaluations of remediation alternatives, affected environment and environmental consequences of implementing remediation, consequences to social resources if they are indirectly affected through changes in the physical and natural environment from implementing remediation, approaches for environmental mitigation and monitoring, and resettlement.

These key findings and recommendations of the ESS were reviewed and re-assessed as new information became available during the preparation of the EA regarding existing environmental and social resources and assets and details of the alternatives being considered.

Following the ESS, an extensive sampling program was developed and conducted in close collaboration with the GVN – in particular the Ministry of National Defense (MND) – between November 2014 and April 2015 to determine the current nature and extent of dioxin contamination at the Airbase. Based on the resultant data and the MND-approved dioxin limits for the Airbase, dioxin-contaminant volumes were calculated and remediation alternatives were conceptualized. At the same time, an environmental, social, and gender baseline of the Airbase and adjacent communities was developed using existing information. Each of the remediation alternatives was then assessed for potential environmental, social, and gender effects, cost, implementability, and effectiveness, and a conceptual Environmental Mitigation and Monitoring Plan (EMMP) was prepared.

As such, this EA provides the basis for selection of a preferred project alternative or alternatives for remediation of dioxin contamination at the Airbase. Vietnamese environmental law and its environmental compliance regulations require an Environmental Impact Assessment (EIA) for dioxin remediation activities once a preferred remediation alternative has been selected and a specific project defined. Therefore, this EA also represents a first step in the GVN EIA process, to be elaborated upon if and when a remediation alternative is selected and accompanying designs and cost estimates are prepared. If additional, potentially significant impacts on the environment are identified during the design process of a selected alternative, the EA will be amended to reflect these. Additional detail on the purpose, regulatory framework, and interaction with GVN is included in Section 2.

1.2 Project Area

The Airbase is located in Bien Hoa City (Figure 1-1), Dong Nai Province, approximately 30 kilometers

(km) northeast of Ho Chi Minh City. Bien Hoa City has an average population density of approximately 3,400 persons per square kilometer (km2) (Dong Nai Statistical Office 2013). The Airbase property is adjacent to Trung Dung, Quang Vinh, and Buu Long Wards and lies within Tan Phong Ward.

Surrounding areas are densely populated, with most of the land used for housing, industrial facilities, transportation, and associated infrastructure. There were approximately 885,000 persons living in Bien Hoa City in 2013 (Dong Nai Statistical Office 2013); in 2012, approximately 111,000 persons lived in the city wards surrounding the Airbase and 1,200 persons lived on the Airbase (Canh 2012b). Current estimates provided by the Air Defense Air Force Command (ADAFC) indicate that there are up to

2,200 workers on the Airbase at peak times. Given recent population growth estimates of Dong Nai Province (Dong Nai Statistical Office 2013) it is estimated that the current population living in the city wards surrounding the Airbase and on the Airbase itself is approximately 120,000 persons1.

The Airbase is an active military airbase and encompasses a total area of approximately 1,000 hectares (ha). Situated on low-lying land immediately to the east and northeast of the Dong Nai River, the Airbase has been used for agriculture, forestry, and aquaculture particularly in the northern part of the property. From 2007 to 2009, the Vietnam Public Health Association (VPHA) and, in 2013, the Office of National Steering Committee on Overcoming Consequences of Toxic Chemicals Used by U.S. during the War in Vietnam (Office 33) implemented awareness raising activities and interim measures to reduce exposure of airbase workers and the local communities to dioxin contamination (Vu-Anh et al 2010; Hatfield and Office 33 2011). The dangers associated with dioxin exposure were explained to residents, and signs were erected to warn people not to fish in the numerous aquaculture ponds.

Aquaculture was banned by the Airbase authorities in 2010 per Office 33’s recommendations and fences were constructed around the perimeter of key aquaculture ponds to restrict access. Despite these efforts, fishing activities continue to occur in Airbase waterbodies and have been observed as recently as December 2015 (Thien-Le Quan 2015).

With respect to land use on the Airbase property:

1. Approximately 1,200 people live on the Airbase (Canh 2012b), with up to 2,200 workers on the Airbase during peak times.

2. There are 20 units of army guards on the Airbase, which is enclosed by a perimeter wall/fence.

3. Air force training activities are extensive, and occur mainly in the east apron area.

4. There is a factory complex with an area of 50 ha southeast of the runways.

5. Part of the Airbase property is used for warehouses and storage.

6. The northern part of the Airbase property is used for agriculture (including family gardens and cattle grazing, which were noted as recently as April 2015) and contains rubber plantations.

7. There are a number of aquaculture ponds on the Airbase property (raising primarily Nile Tilapia, Oreochromis niloticus, but also ducks and other aquatic organisms); use of these ponds for aquaculture purposes was officially banned in 2010 by the Airbase (per Office 33’s recommendation). However, enforcement of the fishing ban has been challenging. Reports from local residents indicate that the majority of fishing taking place since the ban is by migrants from other provinces, who have not benefited from the education programs implemented by Office 33 (Thien-Le Quan 2015).

1 In 2012, approximately 111,000 persons lived in the city wards surrounding the Airbase, while approximately 1,200 persons lived on the Airbase itself (Canh 2012b). For the purposes of this EA a current population of 120,000 persons living in the vicinity of and on the Airbase is estimated, with 1,200 of these persons assumed to be living on the Airbase. This estimate is reflective of recent population growth estimates of Dong Nai Province reported in Dong Nai Statistical Office (2013) and Hatfield (2015).

1.3 Historical Use of Agent Orange and Other Herbicides at

Bien Hoa Airbase

During the U.S.-Vietnam War, over 80 million liters of herbicides were sprayed over South Vietnam in a code-named mission called Operation Ranch Hand (Cecil 1986). Bien Hoa Airbase was the largest and most active Ranch Hand site in Vietnam. These herbicide mixtures were predominantly used to defoliate forests and crops, and many of them contained 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD) as a contaminant by-product. The Airbase is recognized as a dioxin hotspot due to high TCDD concentrations remaining decades after the large volumes of Agent Orange and other herbicides were stored, handled, and spilled at the Airbase during the U.S.-Vietnam War (Dwernychuk et al. 2002;

Dwernychuk 2005).

Three large storage tanks were used for herbicide storage at the Airbase; one each for Agent Orange, Agent White, and Agent Blue. According to U.S. military data, the Airbase was used to store and handle 98,000 45-gallon (170-liter) barrels of Agent Orange, 45,000 barrels of Agent White and 16,000 barrels of Agent Blue (U.S. Department of Defense [DOD] 2007). Agent Blue did not contain dioxin but organic arsenic was in the formulation. Additional herbicide formulations were also used at the Airbase included Agents Purple, Pink, Green and others.