J.16-Site_wide_EMMP.pdf

DIOXIN REMEDIATION AT BIEN HOA AIRBASE AREA PROJECT

FINAL MASTERPLAN – VOLUME 1

ANNEX 4 – SITE-WIDE ENVIRONMENTAL MITIGATION AND

MONITORING PLAN (SWEMMP) INCLUDING THE SITE-

WIDE STORMWATER POLLUTION PREVENTION PLAN

(SWPPP)

DIOXIN REMEDIATION AT BIEN HOA

AIRBASE AREA PROJECT

SITE-WIDE ENVIRONMENTAL

MITIGATION AND MONITORING PLAN

(SWEMMP)

JULY 17, 2020

This publication was produced for review by the United States Agency for International Development.

DISCLAIMER

THE VIEWS EXPRESSED IN THIS PUBLICATION DO NOT NECESSARILY REFLECT THE VIEWS OF THE UNITED STATES AGENCY

FOR INTERNATIONAL DEVELOPMENT OR THE UNITED STATES GOVERNMENT.

DIOXIN REMEDIATION AT BIEN HOA

AIRBASE AREA PROJECT

SITE-WIDE ENVIRONMENTAL

MITIGATION AND MONITORING

PLAN (SWEMMP)

US AGENCY FOR INTERNATIONAL DEVELOPMENT

CONTRACT NUMBER: AID-OAA-I-15-00053

ORDER NUMBER: 72044019F00001

JULY 17, 2020

PREPARED BY

TRIGON ASSOCIATES, LLC

1515 POYDRAS ST. SUITE 2200

NEW ORLEANS, LA 70112

USA

SITE-WIDE ENVIRONMENTAL MITIGATION AND MONITORING PLAN (SWEMMP)

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CONTENTS

USAID STANDARD METADATA ........................................................................................................................ IV

LIST OF ACRONYMS AND ABBREVIATIONS ................................................................................................. V

1 PURPOSE

1.1 BASIS OF EMMP

1.2 USAID TEMPLATE EMMP

1.3 SWEMMP ORGANIZATION

1.4 SWEMMP REVIEW AND AMENDMENT

2 PROJECT SUMMARY

2.1 PROJECT OWNER AND IMPLEMENTING AGENCIES

2.2 PROJECT ACTIVITIES AND POTENTIAL NEGATIVE ENVIRONMENTAL IMPACTS

2.3 ROLES AND RESPONSIBILITIES FOR SWEMMP IMPLEMENTATION

2.4 ACTIVITY-LEVEL EMMPS

3 SITE-SPECIFIC INFORMATION

4 ANNUAL REPORTING

5 SWEMMP TABLES WITH DETAIL

5.1 WATER QUALITY

5.2 AIR QUALITY

5.3 AMBIENT NOISE / VIBRATION

5.4 GREENHOUSE GASES (GHG) EMISSIONS / WEATHER

6 REFERENCES

TABLES

TABLE 1A. WATER QUALITY – MITIGATION AND MONITORING

TABLE 1B. AIR QUALITY – MITIGATION AND MONITORING

TABLE 1C. AMBIENT NOISE AND VIBRATION – MITIGATION AND MONITORING

TABLE 1D. GREENHOUSE GAS (GHG) EMISSIONS AND WEATHER – MITIGATION AND

MONITORING

TABLES

Table 1A Water Quality – Mitigation and Monitoring

Table 1A.1 ……. Surface Water Quality Monitoring Locations

Table 1A.2 ……. Surface Water Quality Monitoring Parameters, Methods, Project Action Limits, and Frequencies

Table 1A.3 ……. Groundwater Quality Monitoring Locations

Table 1A.4 ……. Groundwater Quality Monitoring Parameters, Methods, Project Action Limits, and Frequencies

Table 1A.5 ……. Process Water Monitoring Locations

Table 1A.6 ……. Process Water Monitoring Parameters, Methods, Project Action Limits, and Frequencies

Table 1B Air Quality – Mitigation and Monitoring

Table 1B.1 ……. Non-Treatment Air Quality Monitoring Locations

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Table 1B.2 ……. Non-Treatment Air Quality Monitoring Parameters, Methods, Project Action Limits, and Frequencies

Table 1B.3 ……. Treatment Air Emissions Monitoring Locations for TCH Treatment Plant

Table 1B.4 ……. Treatment Air Emissions Monitoring Parameters, Methods, Project Action Limits, and Frequencies for TCH Treatment Plant – Emission Point (Stack)

Table 1B.5 ……. Treatment Air Emissions Monitoring Parameters, Methods, Project Action Limits, and Frequencies for TCH Treatment Plant – Perimeter

Table 1C Ambient Noise/Vibration – Mitigation and Monitoring

Table 1C.1 ……. Ambient Noise/Vibration Monitoring Locations

Table 1C.2 ……. Ambient Noise/Vibration Monitoring Parameters, Methods, Project Action Limits, and Frequencies

Table 1D GHG Emissions and Weather – Mitigation and Monitoring

Table 1D.1 ……. Weather Monitoring Location

Table 1D.2 ……. Weather Monitoring Parameters and Frequencies

FIGURES

Figure 1A Water Quality Monitoring Locations

Figure 1B Air Quality and Weather Monitoring Locations

Figure 1C Ambient Noise/Vibration Monitoring Locations

ANNEX

SITE-WIDE STORMWATER POLLUTION PREVENTION PLAN (SWPPP)

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USAID STANDARD METADATA

PROJECT/ACTIVITY DATA*

Project/Activity Name: Dioxin Remediation at Bien Hoa Airbase Area Project Geographic Location(s) (Country/Region): Bien Hoa, Dong Nai Province, Vietnam Implementation Start/End Dates: 2 April 2020 (Start)/TBD (End) Contract/Award Number: AID-OAA-I-15-00053

Implementing Partner(s):

Ministry of National Defense / Air Defence - Air Force Command, Architect and Engineering Services Contractor, Construction Contractors

Tracking ID: TBD Tracking ID/link of Related IEE: TBD Tracking ID/link of Other, Related Analyses: TBD

ORGANIZATIONAL/ADMINISTRATIVE DATA*

Implementing Operating Unit(s): USAID Vietnam Mission, Environment and Social Development Office, Environmental Remediation Unit

Lead BEO Bureau: BEO Asia Bureau Prepared by: Trigon Associates, LLC (A&E Bien Hoa Contractor) Date Draft Prepared: April 13, 2020 Submitted by: TBD Date Submitted: TBD

ENVIRONMENTAL COMPLIANCE REVIEW DATA*

Analysis Type: EMMP Additional Analyses/Reporting Required: EMMR

* Standard metadata fields for the USAID Environmental Compliance Database (ECD) and planned Development Information System (DIS).

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LIST OF ACRONYMS AND ABBREVIATIONS

ADAFC Air Defence - Air Force Command

ADS Automated Directives System

AMS Automated Measuring System

ARARs Applicable or Relevant and Appropriate Requirements

AWP Annual Work Plan

A&E Architect & Engineer

BMP Best Management Practice

CEM Continuous Emissions Monitor

CFR Code of Federal Regulations

CIL Climate Integration Lead

CLIN Contract Line Item Number

CO Carbon Monoxide

COD Chemical Oxygen Demand

COR Contracting Officer’s Representative

CQA Construction Quality Assurance d Day dB decibel dBA Decibels A-weighted average

DONRE Department of Natural Resources and the Environment

DO Dissolved Oxygen

DQO Data Quality Objective

DU Decision Unit

EA Environmental Assessment

ECD Environmental Compliance Database

EIA Environmental Impact Assessment

EMMP Environmental Mitigation and Monitoring Plan

EMMR Environmental Mitigation and Monitoring Report

ESS Environmental Scoping Statement

G2L Gate 2 Lake

GDWQ Guidelines for Drinking Water Quality

GHG Greenhouse Gas

GVN Government of Vietnam

HASP Health and Safety Plan kg kilogram

L liter

LTSA Long-term Storage Area m3 Cubic Meters

MCL Maximum Contaminant Level

MEO Mission Environmental Officer mg milligrams

MND Ministry of National Defence

MONRE Ministry of Natural Resources and the Environment

NDAMN National Dioxin Air Monitoring Network

NOx Nitrogen Oxides

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Pb Lead pg pico-gram

PMU Project Management Unit

PPE Personal Protective Equipment ppt parts per trillion ppq parts per quadrillion

REA Regional Environmental Administrator

RSL Regional Screening Level

SCM Site Conceptual Model

SO2 Sulfur Dioxide

SOW Statement of Work

SVOC Semi-volatile Organic Compound

SWEMMP Site-wide Environmental Mitigation and Monitoring Plan

SWPPP Storm Water Pollution Prevention Plan

TCH Thermal Conductive Heating

TDS Total Dissolved Solids

TEQ Toxicity Equivalent

TSS Total Suspended Solids ug microgram

USG United States Government

USAID United States Agency for International Development

USEPA United States Environmental Protection Agency

UXO Unexploded Ordnance

VOC Volatile Organic Compound

VOHAP Volatile Organic Hazardous Air Pollutant

VRTC Vietnam Russia Tropical Center

WHO World Health Organization

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1 PURPOSE

This Site-wide Environmental Mitigation and Monitoring Plan (SWEMMP) for the Dioxin Remediation at Bien Hoa Airbase Area Project (Project) was developed by Trigon Associates, LLC (A&E Bien Hoa Contractor) for the US Agency for International Development (USAID) under Contract No. AID-OAA-I-15-00053, Task Order No. 72044019F00001, in accordance with Section C – Description/Specifications/ Statement of Work (SOW), Subsection C.5 Statement of Work, Component 2 (CLIN 2), Task 2.3, Site-wide Environmental Monitoring and Mitigation Plan.

The purpose of this SWEMMP is to document site-wide environmental mitigation measures and monitoring actions to be implemented during Dioxin Remediation at Bien Hoa Airbase Area Project (Project) activities to minimize the potential for negative environmental impacts. This SWEMMP also prescribes minimum environmental mitigation measures and monitoring actions to be incorporated into Activity-level Environmental Mitigation and Monitoring Plans (EMMPs) developed for specific Project activities.

1.1 BASIS OF EMMP

Environmental Mitigation and Monitoring Plans (EMMPs) are required for USAID-funded projects under USAID Automated Directives System (ADS) 204, Environmental Procedures, when documentation prepared in accordance with Title 22 of the Code of Federal Regulations (CFR) Part 216 (22 CFR 216), Environmental Procedures, governs the USAID-funded project.

40 CFR 216.8, Monitoring, requires “to the extent feasible and relevant, projects and programs for which Environmental Impact Statements (EISs) or Environmental Assessments (EAs) have been prepared should be designed to include measurement of any changes in environmental quality, positive or negative, during their implementation. This will require recording of baseline data at the start. … Monitoring implementation of projects, programs and activities shall take into account environmental impacts to the same extent as other aspects of such projects, programs and activities.”

1.1.1 2016 ENVIRONMENTAL ASSESSMENT

Together the Government of Vietnam (GVN) and USAID prepared an Environmental Assessment (EA) for the Dioxin Contamination at Bien Hoa Airbase in 2016 that documents the nature and extent of dioxin contamination at the Bien Hoa Airbase Area and evaluated five major remedial alternatives ranging from no action through complete containment to complete treatment.

“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 USG and GVN regulatory preferences for treatment with more practical, lower cost options for management of the lower risk material (GV/UASID 2016).”

For all alternatives, the EA identified potential environmental impacts, mitigation measures, made a determination of significance, and then presented a preliminary conceptual EMMP.

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1.1.2 GVN ENVIRONMENTAL IMPACT ASSESSMENT

The Ministry of National Defence (MND) / Air Defence – Air Force Command (ADAFC), with limited USAID engagement1, conducted an EIA, identified the preferred alternative as EA Alternative 4, and developed the 2019 Report of Environmental Impact Assessment (EIA) outlining two phases of the Project:

- Project Phase 1 - focusing on remediation of the Pacer Ivy Area at Bien Hoa Airbase; and

- Project Phase 2 - focusing on remediation of the Z1 Area at Bien Hoa Airbase.

The EIA provides data on water, air, and soil quality, addresses Project activities, and the environmental mitigation measures and monitoring actions to be implemented during Project activities. The EIA was approved by the Ministry of Natural Resources and Environment (MONRE) in Decision No. 702/QD-BTNMT, Approval of Environmental Impact Assessment Report, the Dioxin Remediation at Bien Hoa Airbase Area Project, dated March 25, 2019.

Subsequent to the EIA, MND Decision No. 3869/QD-BQP on Approval of the Investment project and the plan for selection of the “Dioxin Remediation in Bien Hoa Airbase – Phase 1” Project with non-refundable Official Development Assistance from the United States of America, was made on September 6, 2019. This Decision (Project Approval) required the implementation of environmental protection measures and environmental monitoring, as well as the utilization of appropriate construction and management methods to mitigate pollution during Project implementation. The Project Approval specifically addresses ensuring compliance with air quality and air emission standards, noise and vibration standards, and water quality and water discharge standards.

1.1.3 PROJECT IEE AND EMMP REQUIREMENTS

On June 19, 2019, the USAID/Vietnam Mission Director approved and the USAID Asia Bureau Environmental Officer concurred on an Initial Environmental Examination (IEE) for the Dioxin Remediation at Bien Hoa Airbase Area Project (reference number ASIA-19-052). The IEE requires Activity-specific EMMPs to address environmental mitigation measures and monitoring actions to be implemented during all Project interim measures, treatment, and civil works activities.

The IEE further specifies that the Activity-Specific EMMP’s must be reviewed by the relevant Contracting Officer’s Representative (COR), the USAID/Vietnam Mission Environmental Officer (MEO), Climate Integration Lead (CIL), and the Regional Environment Adviser (REA) before BEO concurrence is sought. Finally, the IEE specifies that no interim measures, treatment, or civil works efforts will proceed without BEO concurrence on the relevant EMMP. In addition to this required USAID internal review and approval process, USAID/Vietnam will share the Site-wide

1 Award of an Architect and Engineering Services contract did not occur until after the GVN EIA and report were complete.

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EMMP and all Activity-level EMMPs with MND/ADAFC to reconcile the environmental requirements of both governments before implementation.

1.2 USAID TEMPLATE EMMP

USAID developed an EMMP template as part of a broader USAID-wide initiative to harmonize application of 22 CFR 216 and USAID ADS 204 environmental mitigation and monitoring requirements and their implementation on all USAID projects. The USAID EMMP template serves as a tool for translating applicable 2016 EA conditions and environmental mitigation measures into specific implementable, and verifiably actions and that “an EMMP is an action plan that clearly defines:

1. Mitigation measures. Actions that reduce or eliminate potential negative environmental impacts resulting directly or indirectly from a particular project or activity, including environmental limiting factors that constrain development.

2. Monitoring indicators. Criteria that demonstrate whether mitigation measures are suitable and implemented effectively.

3. Monitoring/reporting frequency. Timeframes for appropriately monitoring the effectiveness of each specific action.

4. Responsible parties. Appropriate, knowledgeable positions assigned to each specific action.

5. Field Monitoring/Issues. Field monitoring needs to be adequately addressed i.e. monitoring dates, observations, issues identified and resolution.”

The USAID EMMP template contains a standard page for USAID metadata (to facilitate USAID tracking) and section headings for:

- Project/Activity Summary;

- Site-specific Information;

- Annual Reporting; and

- EMMP Table for Project Activity(ies).

The EMMP table has standard column headings for Project/Activity/Sub-Activity, Identified Environmental Aspects/Impacts, Mitigation Measures, Monitoring Indicators, Monitoring and Reporting Frequency, Responsible Parties, and Field Monitoring/Issues.

1.3 SWEMMP ORGANIZATION

This SWEMMP for Dioxin Remediation at Bien Hoa Airbase Area Project activities has been prepared in accordance with 22 CFR 216 and USAID ADS 204, to include the utilization of the USAID EMMP template. Accordingly, this SWEMMP is organized as follows:

- Section 1, Purpose

- Section 2, Project/Activity Summary

- Section 3, Site-specific Information

- Section 4, Annual Reporting

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- Section 5, Environmental Mitigation and Monitoring Plan for Project Activities

EMMP tables developed for this SWEMMP are referenced within Section 5 and collectively presented as an Attachment. Supporting figures to these tables are also collectively presented as an Attachment.

A standard page for USAID metadata is included as a foreword to this document.

1.4 SWEMMP REVIEW AND AMENDMENT

EMMPs are living documents and it is incumbent on USAID to ensure that EMMPs are updated and tailored as needed.

Accordingly, this SWEMMP will be reviewed by the A&E Bien Hoa Contractor annually, in conjunction with the development of the Activity Annual Work Plan (AWP) and in consideration of Project plans, designs, and monitoring and results. USAID will update and amend this SWEMMP as warranted, including updates to maintain conformance with the GVN/MND EIA. The A&E Bien Hoa Contractor must also discuss the SWEMMP implementation and any recommended updates during quarterly technical review meetings held with USAID to gain agreement on any resulting amendments.

A Record of Revisions page is included as a forward to this SWEMMP. The Record of Revisions page documents the conduct of SWEMMP reviews and any resulting amendments.

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2 PROJECT SUMMARY

As noted in Section 1, after the joint GVN/USAID EA, MND/ADAFC conducted an EIA for the implementation of EA Alternative 4 in two Project phases (i.e., Phase 1 - remediation of the Pacer Ivy Area; and Project Phase 2 - remediation of the Z1 Area). Project Phase 1 activities were approved by GVN MND in Decision No. 3869/QD-BQP (MND 2019). Combined Project Phase I and Phase II activities encompass the excavation and on-Airbase treatment of approximately 250,000 m3 of dioxin-contaminated soils and sediments, and the excavation and isolation in a constructed on-Airbase storage facility of approximately 300,000 m3 of dioxin-contaminated soils and sediments.

MND expectations for Project Phase 1 activities are described in Decision No. 3869/QD-BQP as:

- Excavation and on-Airbase thermal treatment of approximately 150,000 cubic meters (m3) of dioxin-contaminated soils and sediments from different decision units (DUs) with dioxin concentrations at or above 1,200 parts per trillion (ppt) Toxicity Equivalent (TEQ) to below a 100 ppt remedial treatment threshold;

- Excavation and isolation of approximately 150,000 m3 of dioxin-contaminated soils and sediments with a concentration below 1,200 ppt but above MND land-use thresholds (300 ppt for urban lands, 150 ppt for sediment, 100 ppt for forested land and other lands with perennial trees) in a constructed on-Airbase facility; and

- Treatment of dioxin-contaminated wastewater and surface waters generated from Project activities with concentrations exceeding permitted thresholds (MND 2019).

Phase II activities would address the remaining dioxin-contaminated soils and sediments.

2.1 PROJECT OWNER AND IMPLEMENTING AGENCIES

USAID is the implementing US government agency. The Project is managed by the USAD/Vietnam Mission’s Environmental Remediation Unit.

MND is the GVN Project Owner assigned by Prime Minister decision for the Project. Through Decision No. 3869/QD-BQP, MND assigned ADAFC as the GVN Project Management Unit and the lead GVN agency responsible for ensuring Project activities are conducted in accordance with applicable or relevant and appropriate requirements (ARARs) and with established Project plans and procedures.

2.2 PROJECT ACTIVITIES AND POTENTIAL NEGATIVE ENVIRONMENTAL

IMPACTS

Project activities and their associated environmental aspects and potential impacts are addressed by both the EA (MND/USAID 2016) and the EIA (MND/ADAFC 2019). While the EA did not identify a preferred alternative, USAID has since reached agreement with the GVN to implement EA Alternative 4. Since the GVN EIA evaluates this alternative in greater detail than the EA, the structure of the GVN EIA will be used as the basis for organizing this SWEMMP. Throughout the document differences will be noted between 22 CFR 216 requirements, the EA preliminary conceptual EMMP, GVN EIA, and this SWEMMP.

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EIA Chapter 3, Environmental Impact Assessment, outlines four primary Project activities and discusses the associated environmental aspects and potential impacts:

1. Preparation;

2. Construction;

3. Remediation Operations; and

4. Environmental Restoration.

EIA Chapter 4 addresses measures to mitigate potential negative impacts. Negative impacts identified in the EIA relate to a broad range of concerns, not just environmental, to include minimizing dioxin exposure and ensuring worker health and safety, unexploded ordinance clearance, gender, minimizing impacts to Airbase activities and operations, accident and fire prevention, flight safety, and others. The EA identified potential negative impacts from unexploded ordnance clearance, solid waste generation, recontamination of treated lakes, and resettlement as additional potential impacts as well as potential negative effects to groundwater. Potential negative environmental impacts in MND’s EIA identified with respect to Project activities generally relate to:

- Air Quality (dust, vehicle/equipment emissions, thermal treatment facility emissions);

- Water Quality (erosion, stormwater drainage to surface waters, process water discharges);

- Ambient Noise / Vibration (vehicle/equipment noise and vibration); and

- Greenhouse Gases (GHG) / Weather (vehicle/equipment emissions, GHG effect).

EIA Chapter 5 presents a planned management and supervision program addressing the range of potential negative environmental impacts. USAID will specify how the EIA-identified potential non-environmental impacts are addressed in the Site-Wide Health & Safety Plan (HASP) and Activity-level Waste Management Plans. Dong Nai Province will address others in their local resident resettlement plans for off-base work areas.

The environmental mitigation measures and monitoring actions presented in this SWEMMP are organized by the EIA project activities (Preparation, Construction, Remediation Operations, and Environmental Restoration) and the associated potential negative environmental impacts (see Section 5).

2.3 ROLES AND RESPONSIBILITIES FOR SWEMMP IMPLEMENTATION

As a funding and US Government implementing agency, USAID is partnered with MND for Project implementation. USAID has procured the services of an oversight contractor, i.e., A&E Bien Hoa Contractor, to develop the Project Masterplan and to provide overall Project engineering design, construction management, and related implementation support.

USAID has or will procure the services of Implementing Contractors to execute Project activities (e.g., excavation and temporary storage of soils/sediments from targeted Decision Units [DUs], construction of Long-term Storage Area [LTSA] for soils/sediments, and the construction and operation of thermal treatment facility). USAID will require all Implementing Contractors to implement Activity-level monitoring and/or mitigation measures in accordance with this SWEMMP for remedial construction activities. USAID will either require individual Implementing

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Contractors to prepare an Activity-level EMMP or direct the A&E Bien Hoa Contractor to assist in developing such as part of contract requirements.

Each of these implementing organizations, i.e., the MND/ADAFC, USAID/Vietnam Mission, USAID A&E Bien Hoa Contractor, and USAID Implementing Contractors, have assigned responsibilities for environmental mitigation measures and monitoring actions contained in this SWEMMP (Section 5).

2.4 ACTIVITY-LEVEL EMMPS

As noted, multiple Implementing Contractors will be executing Project activities on behalf of MND/USAID. USAID will require that each of these Contractors implement Activity-specific environmental mitigation measures and monitoring actions as part of their respective activities.

In accordance with the USAID Project IEE, USAID will document these measures and actions in an Activity-level EMMP for all interim measures, civil works, treatment activities as described in the USAID Project Appraisal Document. USAID, the A&E Bien Hoa Contractor, and the Implementing Contractors will review all Activity-level environmental mitigation measures and monitoring on a quarterly basis to assess the need for updates.

This SWEMMP prescribes minimum environmental mitigation measures and monitoring actions to be applied to each activity (Section 5).

USAID will direct the A&E Bien Hoa Contractor to review and comment on any Implementing Contractor developed Activity-level EMMPs to ensure consistency with this SWEMMP. USAID will also provide any environmental monitoring observations, data, and/or results from Implementing Contractors’ environmental monitoring actions to the A&E Bien Hoa Contractor to allow for monitoring of EMMP implementation progress and in support of SWEMMP annual reporting (Section 4).

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3 SITE-SPECIFIC INFORMATION

Site-specific information relevant to the environmental conditions at Bien Hoa Airbase Area and the execution of the Dioxin Remediation of the Bien Hoa Airbase Area Project is summarized and presented in other Project documents. Most notably these documents include the Technical Memorandum (TM) Site Conceptual Model (SCM) and Data Gaps Analysis (DGA) (USAID 2020), Tabulated Summary of Applicable or Relevant and Appropriate Requirements (ARARs) (USAID 2020), Site-wide Sampling & Analysis Plan – Quality Assurance Project Plan (SAP-QAPP) (USAID 2020), and the Project Masterplan (still in development).

The TM SCM and DGA (USAID 2020a) describes the Bien Hoa Airbase Area site definition and environmental setting, sources of contamination and distribution, migration pathways and exposure routes, and sensitive receptors. Salient conclusions of the SCM relevant to the implementation of environmental mitigation measures and monitoring actions contained in this SWEMMP include:

- Secondary sources of dioxin contamination remain at the Bien Hoa Airbase Area in the form of dioxin-contaminated soils/sediment, with a significant fraction in the Pacer Ivy and Z1 areas.

- Off-Airbase dioxin contamination is primarily within soils/sediments located in land areas adjacent to Pacer Ivy Area.

- Dioxin-contaminated soils/sediment have migrated from original source sites through physical transport mechanisms, including storm water runoff during rain events, surface water flow, wind erosion and deposition, and excavation and movement of contaminated materials.

- Groundwater flow is not a significant physical transport mechanism as dioxin is not very soluble and is prone to partitioning to organic solids.

The Tabulated Summary of ARARs (USAID 2020b) forms a basis for establishing programs and procedures to achieve and maintain regulatory compliance during Dioxin Remediation of the Bien Hoa Airbase Area Project implementation. USAID reached consensus with GVN stakeholders on these ARARs during the February 27 – 28, 2020 Masterplan Roadmap Meeting 3 and through subsequent communications clarifying applicability of certain ARARs. All Project activities must be conducted in accordance with the ARARs.

ARARs support the development of the environmental mitigation measures contained in this SWEMMP and are directly relevant to the establishment of the environmental monitoring frequencies, parameters, methods, and thresholds. Where appropriate, ARARs are referenced in the presentation of SWEMMP environmental monitoring actions (see Section 5).

The Site-wide SAP-QAPP (USAID 2020c) provides a comprehensive, site-specific planning and guidance document for environmental sampling, field analysis, and environmental laboratory analyses for all work to be conducted during Dioxin Remediation of the Bien Hoa Airbase Area Project implementation. The Site-wide SAP-QAPP is applicable to USAID A&E Bien Hoa Contractor and all Implementing Contractors who will be performing environmental monitoring in accordance with this SWEMMP. The Site-wide SAP-QAPP is to be utilized during field sampling and laboratory analyses to ensure that collected environmental monitoring data meets specified data quality objectives (DQOs).

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Several additional Project documents are relevant to the understanding of the scope of the environmental mitigation measures and monitoring actions contained in this SWEMMP and the execution of the Dioxin Remediation of the Bien Hoa Airbase Area Project. Most notably these documents include the Initial Site-wide Health and Safety Plan (HASP) (USAID 2019), Compendium of Standard Specifications (under development), and Construction Quality Assurance (CQA) Plan (under development).

The Initial Site-wide HASP (USAID 2019) provides a comprehensive health and safety plan and procedures that apply to all Project activities, including site preparation, construction, remediation operations, and environmental restoration. USAID requires compliance with this Site-Wide HASP by Project Contractors and personnel. The Initial Site-wide HASP clearly presents exposure mitigation measures and personal and other monitoring with respect to ensuring the health and safety of all Project workers. The Initial Site-wide HASP provides activity-specific hazard analyses, work practices and engineering controls, personal protective equipment, monitoring and inspection, and medical surveillance, to include blood serum dioxin monitoring.

The Compendium of Standard Specifications (Compendium) provides a set of standard technical specifications specific to Project activities. The Compendium will serve as a basis for design activities to ensure consistency in approach and quality of Project work activities as well as to reflect best practices, to include green and sustainable practices. Relevant to the environmental mitigation measures contained in this SWEMMP, the Compendium provides specifications for: soil management, including excavation and stockpiling; use of clean fill materials; reuse/replacement of treated soils; testing to confirm soil chemical, geotechnical, and horticultural suitability for use; waste recycling and disposal; and site stabilization, including the use of soil stabilization materials.

A CQA is to be prepared by the engineer of record for each Project design activity funded by USAID during Project implementation. Relevant to the environmental mitigation measures and monitoring actions contained in this SWEMMP, the CQA provides: descriptions of inspection activities, including tests and observations used to monitor construction practices; construction monitoring requirements, to include documentation and reporting requirements; and control procedures for ensuring that inspection, measuring, and testing equipment are properly calibrated by qualified technicians at specific frequencies to maintain accuracy within required tolerances.

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4 ANNUAL REPORTING

Annual reporting on SWEMMP implementation progress is important and specifically addresses the “Field Monitoring/Issues” aspect to USAID EMMPs (see Section 1.2) documenting mitigation measures and monitoring actions, observations, and results, identified issues, and their resolution.

As noted above, SWEMMP implementation is to be discussed during quarterly USAID technical review meetings with the USAID A&E Bien Hoa Contractor, and reviewed annually throughout the duration of the Project in conjunction with the submission of AWPs. The USAID A&E Bien Hoa Contractor is specifically assigned by USAID with “monitoring adherence to the SWEMMP and Activity-level EMMPs” as a component of the A&E Bien Hoa Contractor’s daily construction management and oversight activities.

Annually, the USAID A&E Bien Hoa Contractor will prepare an Environmental Mitigation and Monitoring Report (EMMR) to be submitted to the USAID Contracting Officer’s Representative

(COR).

EMMRs will be submitted to the USAID COR by September 1st of each calendar year (coinciding with the submission of the USAID A&E Bien Hoa Contractor AWPs). EMMRs are to address, but are not limited to, the following content:

- Summary of SWEMMP implementation progress;

- Documentation of site-wide mitigation measures and monitoring actions;

- Discussion of site-wide observations and results;

- Summary of the effectiveness of the site-wide mitigation measures;

- Identification of Activity-level EMMPs developed by Implementing Contractors;

- Discussion of Activity-level EMMP implementation progress, mitigation measures, monitoring actions, and associated observations and results;

- Summary of the effectiveness of the Activity-level mitigation measures;

- Discussion of problems, issues or concerns with respect to SWEMMP implementation, resolution, and lessons learned; and

- Recommendations for revisions to mitigation measures or monitoring actions.

- Summary of engagement with MND on the SWEMMP, including summary of MND monitoring activities, frequency of data sharing between MND and USAID, any issues MND has raised, and how they were/are being resolved.

As appropriate, attachments supporting EMMR content will be included with the submissions.

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5 SWEMMP TABLES WITH DETAIL

This section provides site-wide environmental mitigation measures and monitoring actions that are to be implemented during Project activities to minimize the potential for negative environmental impacts. Measures are presented in the USAID EMMP tabular format organized by category of potential negative impact (Water Quality, Air Quality, Ambient Noise/Vibration, GHG Emissions/Weather) and the EIA Project activities (Preparation, Construction, Remediation Operations, and Environmental Restoration).

As noted, multiple Implementing Contractors will be executing Project activities and implementing Activity-specific environmental mitigation measures and monitoring actions. Nearly all construction activities are anticipated to take place during the dry season. As a result, monitoring locations are chosen based upon the prevailing environmental conditions during the dry season. If this changes during the life of the Project, additional monitoring locations may be needed and this SWEMMP will be updated (e.g., if the treatment contractor is able to operate during the rainy season).

The SWEMMP tables also specify Project Action Limits for all monitored environmental parameters. USAID will require all contractors to halt their operations and implement additional mitigation measures if monitoring results suggest that any Project Action Limit is being exceeded as a result of Project activities. USAID will only allow operations to resume when implemented mitigation measures suggest that Project Action Limits will no longer be exceeded as a result of Project activities.

5.1 WATER QUALITY

Water quality encompasses the mitigation and monitoring of potential negative impacts to surface water quality (including stormwater) and groundwater quality resulting from Project activities and addresses the discharge of process waters.

Critical to the environmental mitigation measures and monitoring actions to prevent negative impacts to water quality is the Site-wide Stormwater Pollution Prevention Plan (SWPPP) for the Project (see Annex). The Site-wide SWPPP for the Project addresses discharges during and post remedial construction until such sites are considered stabilized. The Site-wide SWPPP identifies potential sources of stormwater pollution based on Project activities and requires the implementation of erosion and sediment control best management practices (BMPs), good housekeeping practices, training, and inspection, maintenance, and record keeping measures. Any Activity-level SWPPPs and Activity-level EMMPs must be consistent with the Project Site-wide SWPPP and include environmental mitigation measures and monitoring actions to prevent negative impacts to water quality specific to the activities of all Implementing Contractors.

Table 1A provides the site-wide environmental mitigation measures and monitoring actions for potential impacts to water quality relevant to Project activities.

Tables 1A.1 through 1A.6 are referenced from within Table 1A and provide monitoring locations and frequencies as well as monitoring parameters, methods, and Project Action Limit references.

Tables 1A.1 through 1A.6 provide the minimum monitoring frequencies and monitoring parameters for Activity-level EMMPs. Activity-level EMMPs may include the installation and monitoring of additional groundwater monitoring wells in support of Activity-specific groundwater monitoring. These tables note several deviations from the monitoring called for in the GVN EIA. In some cases, USAID is proposing more frequent monitoring than called for in

| 12 the EIA (e.g. daily monitoring of turbidity); however, USAID is also proposing not to monitor several water parameters mentioned in the EIA because such parameters cannot be plausibly linked to proposed Project activities (e.g., coliforms or mercury). Also, USAID will not monitor water quality in several ponds on the airbase as these will be dewatered before excavating the contaminated sediment and will not receive effluent from other remediation activities. Thus, water quality will not be impacted in these ponds by remediation activities.

The Bien Hoa Airbase encompasses an area of approximately 1,000 hectares (ha) immediately to the east and northeast of the Dong Nai River. Elevations on the Airbase range from 4 to 30 meters (m) with a general topographic slope to the west and south towards the tidally influenced Dong Nai River, and a major southwest-northeast-oriented drainage divide cross cutting the Airbase (USAID 2016). The elevation of the Dong Nai River varies between -2.00 and +2.08 meters above sea level (Data for Dong Nai River at Bien Hoa from 2007 through 2015, http://lvsdongnai.cem.gov.vn). There are three major catchments on the Airbase. Drainage from on-Airbase to off-Airbase areas generally flows west from the Pacer Ivy Area, west and partly south from the Southwest Area and Z1 Area, and southeast from the Southeast Area and Northeast Area, with the respective drainage waterways eventually leading to the tidally influenced Dong Nai River. Stormwater runoff is identified as a significant dioxin migration pathway (USAID 2020a), in particular along drainage paths from the Pacer Ivy Area to adjacent off-Airbase land areas. Stormwater discharging from the Pacer Ivy Area to the surrounding land areas is through a rock gabion structure into a drainage canal that equipped with a rock weir near its confluence with the Dong Nai River.

Figure 1A shows site-wide water quality monitoring locations which were chosen to capture the major discharges from the Airbase that are anticipated to have potentially significant Project activities upstream.

Currently, a Vietnamese surveying firm is conducting a comprehensive topographic survey at the Bien Hoa Airbase at the direction of USAID Bien Hoa Contractor. The topographic survey is being conducted to an accuracy of 25 cm across Airbase areas that are to be disturbed (excavated, graded, etc.) during the Project remedial construction activities Resulting topographic data will be used to more accurately determine Bien Hoa Airbase surface water drainage pathways and storm water drainage patterns and supplement this SWEMMP.

5.2 AIR QUALITY

Air quality encompasses the mitigation and monitoring of potential negative impacts to air quality resulting from Project activities and addresses the emission of air pollutants from stationary sources.

Ambient air quality monitoring will be conducted on a Site-wide basis using active air monitoring equipment that operate for 24-hours up to 7-day intervals on an established schedule.

Table 1B provides the site-wide environmental mitigation measures and monitoring actions for potential impacts to air quality relevant to Project activities.

Tables 1B.1 through 1B.5 are referenced from within Table 1B and provide monitoring locations and frequencies as well as monitoring parameters, methods, and Project Action Limit references.

Tables 1B.1 through 1B.5 provide the minimum monitoring frequencies and monitoring parameters for Activity-level EMMPs.

http://lvsdongnai.cem.gov.vn/

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Figure 1B shows site-wide air quality monitoring locations. AIR1 was chosen to be a background reference site that will be largely unaffected by Project activities and is at the administrative center of the Airbase. AIR2, AIR3, AIR4, AIR6, and AIR7 are downwind of potentially significant Project activities. AIR3 and AIR7 are upwind of nearby residents outside of the Airbase. AIR5 is located downwind of urban activities and upwind of Project activities.

Climate at the Bien Hoa Airbase area is described in the EIA (MND/ADAFC 2019). Bien Hoa Airbase is in an area of Asian monsoon tropical climate; influenced by the Northeast monsoon and Southwest monsoon and the Pacific Ocean tropic atmosphere from April to October with two distinct rainy and dry seasons. The rainy season lasts 6 to 7 months, from approximately 1 May through 1 December. The main wind directions during the dry season are to the South and Southeast; whereas, during the rainy season is to the Southwest. Maximum wind speeds range from 3 meters per second (m/s) to 7 meters per second (m/s). Wind direction and speed are graphically summarized on Figure 1B.

5.3 AMBIENT NOISE / VIBRATION

Ambient noise / vibration encompasses the mitigation and monitoring of potential negative impacts with respect to noise and vibrations resulting from Project activities.

Table 1C provides the site-wide environmental mitigation measures and monitoring actions for potential impacts to ambient noise/vibration relevant to Project activities.

Tables 1C.1 and 1C.2 are referenced from within Table 1C and provide monitoring locations and frequencies as well as monitoring parameters, methods, and Project Action Limit references.

Tables 1C.1 and 1C.2 provide the minimum monitoring frequencies and monitoring parameters for Activity-level EMMPs. Figure 1C shows site-wide ambient noise / vibration monitoring locations that were chosen based on potentially significant Project activities occurring nearby and that are in close proximity to residents outside the Airbase.

5.4 GREENHOUSE GASES (GHG) EMISSIONS / WEATHER

Greenhouse gas (GHG) / weather encompass the mitigation and monitoring of GHG emissions resulting from Project activities and the monitoring of weather at the Bien Hoa Airbase Area.

As previously noted, Bien Hoa is in an area of Asian monsoon tropical climate; influenced by the Northeast monsoon and Southwest monsoon and the Pacific Ocean tropic atmosphere from April to October with two distinct rainy and dry seasons. The rainy season lasts 6 to 7 months, from approximately 1 May through 1 December. Rainfall during the rainy season accounts for approximately 80 percent (%) of the annual total rainfall, with rainfall intensities increasing gradually from the beginning of the season in June to the middle of the season, and peaking in the concluding month of November. With respect to climate change, the EA (USAID 2016) documents that current long-term predictions are: for an increase in mean annual temperature and mean annual precipitation of 1 degree Celsius and 0.7%, respectively, by 2050 for the southern portion of the Dong Nai Province; that Bien Hoa City and the Dong Nai Province will be relatively unaffected by inundation from sea level rise occurring as a result of climate change; and that higher-intensity typhoons and extreme weather events may become more frequent.

USAID will establish a single weather station (temperature, relative humidity, wind speed and direction, precipitation, and barometric pressure) at the Dioxin Remediation of the Bien Hoa Airbase Area Project Office in support of site-wide monitoring. Weather station data collection

| 14 will be real-time with data recorded for duration of the Project. The A&E Bien Hoa Contractor will implement a system for notifying Implementing Contractors of current or pending weather events (e.g., increasing wind speed, changing wind direction).

Table 1D provides the site-wide environmental mitigation measures and monitoring actions for potential impacts to GHG emissions resulting from Project activities.

Tables 1D.1 and 1D.2 are referenced from within Table 1D and provide the weather monitoring location and frequency as well as weather monitoring parameters.

Figure 1D shows the weather monitoring station located at the Project field office.

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6 REFERENCES

GVN/USAID (CDM International, Inc. and Hatfield Consultants). 2015. Environmental Assessment of Dioxin at Bien Hoa Airbase, Environmental Scoping Statement. March 13, 2015.

GVN/USAID (CDM International, Inc. and Hatfield Consultants). 2016. Environmental Assessment of Dioxin Contamination at Bien Hoa Airbase. May 3, 2016.

MND. 2019. Decision No. 3869/QD-BQP on Approval of the Investment project and the plan for selection of the “Dioxin Remediation in Bien Hoa Airbase – Phase 1” Project with non-refundable Official Development Assistance from the United States of America, September 6, MND/ADAFC. 2018. Project Pre-Feasibility Report, Dioxin Remediation at Bien Hoa Airbase Area Phase I. October 2018.

MND/ADAFC. 2019. Report of Environmental Impact Assessment for the Dioxin Remediation at Bien Hoa Airbase Area Project. February 27, 2019.

Ministry of Natural Resources and Environment (MONRE). 2019. Approval of Environmental Impact Assessment Report, the Dioxin Remediation at Bien Hoa Airbase Area Project. March 25, 2019.

USAID (Trigon Associates, llc). 2019. Initial Site-Wide Health and Safety Plan. December 5, 2019.

USAID (Trigon Associates, llc). 2020a. Technical Memorandum Site Conceptual Model and Data Gaps Analysis. May 2020.

USAID (Trigon Associates, llc). 2020b. Tabulated Summary of Applicable or Relevant and Appropriate Requirements (ARARs). May 2020.

USAID (Trigon Associates, llc). 2020c Initial Site-Wide Sampling and Analysis Plan–Quality Assurance Project Plan. May 2020.

TABLES

TABLE 1A WATER QUALTY – MITIGATION AND MONITORING

TABLE 1B AIR QUALITY – MITIGATION AND MONITORING

TABLE 1C AMBIENT NOISE/VIBRATION – MITIGATION AND MONITORING

TABLE 1D GHG EMISSIONS AND WEATHER – MITIGATION AND MONITORING

TABLES 1

TABLE 1A. WATER QUALITY – MITIGATION AND MONITORING

SUB-ACTIVITY

POTENTIAL

NEGATIVE WATER

QUALITY

MITIGATION MEASURES MONITORING

INDICATOR

MONITORING LOCATION,

FREQUENCY, AND

REPORTING

RESPONSIBLE PARTIES

Preparation and Construction

Site-wide Monitoring

Detrimental Changes from Baseline Conditions

Establish pre-construction surface water quality conditions (baseline) and initiate site-wide surface water quality (stormwater) monitoring.

Tables 1A.1 and 1A.2;

Tables 1A.1 and 1A.2;

USAID A&E Bien Hoa Contractor

Establish pre-construction groundwater quality conditions (baseline), install additional groundwater monitoring wells (as needed), and initiate site-wide groundwater monitoring.

Tables 1A.3 and 1A.4 Tables 1A.3 and 1A.4 USAID A&E Bien Hoa Contractor

Activity-level Monitoring

Detrimental Changes from Baseline Conditions

Activity-level EMMPs and SWPPPs will include surface water quality (stormwater) monitoring when appropriate. Minimum monitoring parameters and frequencies are specified in the referenced tables.

Tables 1A.1 and 1A.2; Tables 1A.1 and 1A.2; Implementing Contractor, or A&E Bien Hoa Contractor as directed by

USAID

Activity-level EMMPs will include groundwater monitoring when appropriate. Minimum monitoring parameters and frequencies are specified in the referenced tables.

Tables 1A.3 and 1A.4 Tables 1A.3 and 1A.4 Implementing Contractor, or A&E Bien Hoa Contractor as directed by

USAID

Clearing Site and Excavating Contaminated Soils/Sediments

Erosion, Runoff, Sedimentation

Erosion/sediment control best management practices (BMPs), inspection, and maintenance as per Project Site-wide SWPPP, Activity-level SWPPP, and/or Activity-level EMMP.

Excavation is to be done according to an Excavation Plan; surface water controls and diversionary structures are to be constructed to divert water around active excavations; excavation activities are to occur during the dry season to the extent practical to minimize potential for erosion, runoff, and sedimentation.

Decontamination water can be applied to the area if any residual soil present is of the same concentration and erosion outside that area can be prevented.

Compliance with

SWPPP.

Monitoring, inspection, and reporting in accordance with SWPPP.

Implementing Contractor;

USAID A&E Bien Hoa Contractor Construction Manager (CM) oversight

Contact with Groundwater and Potential for Contamination

Contact with groundwater is to be minimized during excavation;

dewatering systems are to be used to minimize groundwater seepage into excavations.

Compliance with

SWPPP.

Monitoring, inspection, and reporting in accordance with SWPPP.

Implementing Contractor;

USAID A&E Bien Hoa Contractor CM oversight

Dewatering of Contaminated Soils/Sediments

Discharge to Surface Water (Drainage Waters from Contaminated Soils/Sediments)

Discharges to groundwater prohibited.

Intermittent discharge only after testing and confirmation of compliance.

Decontamination water can be applied to the area if any residual soil present is of the same concentration and erosion outside that area can be prevented.

Discharges to surface waters must meet QCVN 08:2015/BTNMT, National Technical Regulation on Surface Water Quality.

Tables 1A.1 and 1A.2 Tables 1A.1 and 1A.2 Implementing Contractor;

CM oversight

TABLES 2

POTENTIAL

NEGATIVE WATER

QUALITY

MITIGATION MEASURES MONITORING

INDICATOR

MONITORING LOCATION,

FREQUENCY, AND

REPORTING

RESPONSIBLE PARTIES

Transporting Contaminated Soils/Sediments

Runoff, Spill or Release Potential

Soil/sediment transport practices as per Project Site-wide SWPPP, Activity-level SWPPP, and/or Activity-level EMMP.

Exposed soils/sediments are to be covered during transportation to avoid reduce spillage; transport vehicles are to remain on designated haul routes;

transport vehicles are to abide by Airbase speed limits; rinsing/cleaning of transport vehicles is to occur at designated area(s) after each vehicle trip.

Compliance with

SWPPP.

Monitoring, inspection, and reporting in accordance with SWPPP.

Implementing Contractor;

USAID A&E Bien Hoa Contractor CM oversight

Stockpiling/Placing of Contaminated Soils/Sediments

Erosion, Runoff, Sedimentation

Erosion/sediment control BMPs, inspection, and maintenance as per Project Site-wide SWPPP, Activity-level SWPPP, and/or Activity-level EMMP.

Contaminated soils/sediments are to be stockpiled or placed only in designated storage areas or soil staging areas; stockpiled soils/sediments are to be managed to prevent erosion or stormwater runoff; stockpiled soils/sediments are to be covered daily.

Compliance with

SWPPP.

Monitoring, inspection, and reporting in accordance with SWPPP.

Implementing Contractor;

USAID A&E Bien Hoa Contractor CM oversight

Constructing Storage Areas

Erosion, Runoff, Sedimentation

Erosion/sediment control BMPs, inspection, and…