J.3 - ENVIRONMENTAL IMPACT ASSESSMENT (EIA).pdf

MINISTRY OF NATIONAL DEFENSE

AIR DEFENSE - AIR FORCE COMMAND

REPORT

OF ENVIRONMENTAL IMPACT

ASSESSMENT

for

THE DIOXIN REMEDIATION

AT BIEN HOA AIRBASE AREA PROJECT

(This version was revised in accordance with the comments of the Appraisal Council on February 27, 2019)

BIEN HOA, 2019

BIEN HOA, 2019

Northwest Area Northern Area

Northeast Area

Pacer Ivy Area

Southeast Area

Southwest Area

Bien Hung Lake

Z1 Area

Former Z1 Area

Taxiway

Boundary between Decision Units

MINISTRY OF NATIONAL DEFENSE

AIR DEFENSE - AIR FORCE COMMAND

REPORT

OF ENVIRONMENTAL IMPACT

ASSESSMENT

for

THE DIOXIN REMEDIATION AT AT BIEN HOA

AIRBASE AREA PROJECT

(This version is revised in accordance with the comments of the Appraisal Council on February 27, 2019)

PROJECT OWNER

AIR DEFENCE - AIR FORCE

COMMAND

CONSULTING AGENCY

NEW TECHNOLOGY INSTITUTE

FOR RESEARCH AND

DEVELOPMENT OF NEW

TECHNOLOGIES

The Ministry of Natural Resources and Environment hereby certifies that the report of environmental impact assessment for “the dioxin remediation at Bien Hoa Airbase area project” was approved through Decision No. …… dated …… by the Minister of Natural Resources and Environment.

Hanoi, P.P. MINISTER

GENERAL DIRECTOR

i

TABLE OF CONTENTS

INTRODUCTION

1. ORIGIN OF THE PROJECT

1.1. Project background

1.2. Project approving competent agencies

1.3. Relationship between the project and other development projects and plans approved by state agencies

2. LEGAL AND TECHNICAL BASIS FOR ENVIRONMENTAL IMPACT

ASSESSMENT

2.1. Legal basis

2.2. Technical documents

3. ORGANIZATION AND IMPLEMENTATION OF EIA

4. METHODOLOGY FOR THE EIA PROCESS

CHAPTER ONE

DESCRIPTION OF THE PROJECT

1.1. PROJECT NAME

1.2. PROJECT OWNER

1.3. PROJECT GEOGRAPHIC LOCATION

1.3.1. Geographic location

1.3.2. Project location in relation with transportation networks, factories, industrial zones, neighboring export-processing zones and public works

1.3.3 Land use status

1.3.4. Infrastructure status of the project area

1.3.5. Dioxin Contamination at Bien Hoa Airbase

1.3.6. Current status of ongoing projects at Bien Hoa Airbase

1.4. MAIN CONTENTS OF THE PROJECT

1.4.1. Objectives of the Project

1.4.2. Volume and scale of the construction categories of the Project

1.4.3. Technologies and methods for implementation of construction categories of the Project

1.4.4. Production and operation technologies

1.4.5. Equipment list of the Project

ii

1.4.6. Materials of the Project

1.4.7. Project implementation schedule

1.4.8. Investment capital

1.4.9. Project management and implementation

CHAPTER TWO

NATURAL ENVIRONMENTAL AND SOCIO-ECONOMIC CONDITIONS

OF PROJECT AREA

2.1. NATURAL ENVIRONMENTAL CONDITIONS

2.1.1. Geographical and geological conditions

2.1.2. Climate and meteorological conditions

2.1.3. Hydrological/oceanographic conditions

2.1.4. Current situation of environmental components quality in air, water and soil

2.1.5. Current situation of biological resources

2.2. SOCIO-ECONOMIC CONDITIONS

2.2.1. Tan Phong Ward’s socio-economic conditions

2.2.2. Buu Long Ward’s socio-economic conditions

2.2.3. Trung Dung Ward’s socio-economic conditions

2.2.4. Quang Vinh Ward’s socio-economic conditions

2.2.5. Binh Hoa Commune’s socio-economic conditions

2.2.6. Tan Binh Commune’s socio-economic conditions

2.2.7. Subjects affected and impacted in the area during project implementation…….146

2.2.8. Health and awareness of people around the project area in previous studies ... 146

CHAPTER THREE

ENVIRONMENTAL IMPACT ASSESSMENT

3.1. IMPACT ASSESSMENT

3.1.1. Impact assessment in the Project preparation phase

3.1.2. Impact assessment in construction phase

3.1.3. Impact assessment in remediation operation phase

3.1.4. Impact assessment during backfill, environmental remediation

3.1.5. Impact assessment of gender baseline

3.1.6. Assessment, prediction of impact by the project risks, problems iii

3.2. EVALUATION OF METHOD USED IN ENVIRONMENTAL IMPACT

ASSESSMENT RESEARCH

CHAPTER FOUR

MEASURES ON ENVIRONMNETAL MITIGATIONAND ENVIRONMENTAL

INCIDENTS PREVENTION AND RESPONSE

4.1. MEASURES TO PREVENT, MITIGATE NEGATIVE IMPACTS OF THE

PROJECT

4.1.1. Measures to mitigate impacts from non-waste related sources during preparation222

4.1.2. Measures to prevent and mitigate Project's negative impacts of during construction

4.1.3. Measures to prevent and mitigate Project's negative impacts of during construction

4.1.4. Measures to prevent and mitigate Project's negative impacts of during reclamation, environment remediation

4.1.5. Requirements on gender are combined in the impact mitigation measures

4.1.6. Other measures

4.2. MEASURES TO MANAGE, PREVENT AND RESPOND TO INCIDENTS OF

PROJECT

4.2.1 General measures

4.2.2. Measures to manage, prevent and respond to risks and incidents of the project during preparation and construction stage

4.2.3. Minimize incidents during the Project’s operation stage

4.2.4. Minimize incidents during reclamation, environment remediation of the Project

4.3. ORGANIZATION PLAN ON IMPLEMENTATION OF ENVIRONMENT

PROTECTION WORKS AND MEASURES

CHAPTER FIVE

ENVIRONMENT MANAGEMENT AND SUPERVISION PROGRAM

5.1. ENVIRONMENT MANAGEMENT PROGRAM

5.2. ENVIRONMENT SUPERVISION PROGRAM

5.2.1. In preparation stage

5.2.2 In construction stage

iv

5.2.3. Stage of operation

5.2.4. During environment remediation

CHAPTER SIX

COMMUNITY CONSULTATION

CONCLUSION, RECOMMENDATION AND COMMITMENT

1. Conclusion

2. Recommendation

3. Commitment

REFERENCES

v

LIST OF TABLES

Table 1.1. Assessment results of Dioxin Contamination at Bien Hoa Airbase

Table 1.2. Volume of contaminated soil and sediment to be treated in Pacer Ivy Treatment Area

Table 1.3. Summary table of Dioxin contaminated soil - sediment in Pacer Ivy Area . 34

Table 1.4. Summary table of Dioxin contaminated soil - sediment to be isolated in Pacer Ivy Area

Table 1.5. Summary table of Dioxin contaminated soil - sediment to be transported and treated on site

Table 1.6. Summary table of the volume of soil, sediment that needs to be treated and isolated in Pacer Ivy Area

Table 1.7. The volume of soil, sediment that needs to be treated and isolated in Z1 Area

Table 1.8. Summary table of the volume of soil, sediment thats need to be treated and isolated for the whole project

Table 1.9. Main characteristics of the thermal desorption pile

Table 1.10. Summary chart of mass balance calculation results in Phase II of the dioxin contamination remediation at Da Nang Airport project

Table 1.11. Equipment during preparation phase

Table 1.12. Equipment during construction phase and land restoration, environmental recovery phase

Table 1.13. Materials used in the project

Table 1.14. Summary table of project implementation schedule

Table 1.15. Total expense of project implementation by ODA capital

Table 1.16. Total expense of project implementation by in-country reciprocal capital 76

Table 1.17. Summary of the main information of the project

Table 2.1. Table of particle size, moisture content, and total organic carbon distribution in soil samples at Bien Hoa Airbase Table 2.2. Monthly average temperature in years (2013 – 2017) vi

Table 2.3. Average rainfall in years of 2013-2017 (Unit: mm)

Table 2.4. Max wind speed and wind direction in Bien Hoa in recent years Table 2.5. Average relative humidity in years of 2013-2017 (Unit: %) Table 2.6. Average sunshine hours in years of 2013 - 2017 (Unit: hour) Table 2.7. Dioxin sampling locations in air Table 2.8. Dioxin sampling locations in surface water Table 2.9. Dioxin sampling locations in groundwater Table 2.10. Dioxin sampling locations in soil Table 2.11. Dioxin sampling locations in sediments Table 2.12. Results of dioxin monitoring in air Table 2.13. Results of dioxin monitoring in air

Table 2.14. Results of dioxin monitoring in surface water

Table 2.15. Results of dioxin monitoring in surface water

Table 2.16. Results of dioxin monitoring in surface water

Table 2.17. Results of dioxin monitoring in groundwater

Table 2.18. Results of dioxin monitoring in sediments

Table 2.19. Results of dioxin monitoring in soil

Table 2.20. Results of dioxin monitoring in soil

Table 2.21. Results of dioxin monitoring in soil

Table 2.22. Results of dioxin monitoring in soil

Table 2.23. Results of dioxin monitoring in soil

Table 2.24. Air quality in the Project area

Table 2.25. Air quality in the Project area

Table 2.26. Air quality in the Project area

Table 2.27. Air quality in the Project area

Table 2.28. Surface water quality in the Project area

Table 2.29. Surface water quality in the Project area

Table 2.30. Surface water quality in the Project area

Table 2.31. Surface water quality in the Project area

Table 2.32. Results of groundwater quality analysis vii

Table 2.33. Results of analysis of soil sampled in the Project area

Table 2.34. Results of analysis of soil sampled in the Project area

Table 2.35. Results of analysis of soil sampled in the Project area

Table 2.36. Component of flora species in Bien Hoa Airbase and surrounding areas

Table 2.37. Component of bird species in Bien Hoa Airbase and surrounding areas

Table 3.38. Component of fauna species in Bien Hoa Airbase and surrounding areas

Table 2.39. Component of Reptilia and Amphibians species in Bien Hoa Airbase and surrounding areas

Table 2.40. Component of Phytoplankton species in Bien Hoa Airbase and surrounding areas

Table 2.41. Density of Phytoplankton species in Bien Hoa Airbase and surrounding areas

Table 2.42. Component of Zooplankton species in Bien Hoa Airbase and surrounding areas

Table 2.43. Density of Phytoplankton species in Bien Hoa Airbase and surrounding areas .

Table 2.44. Component of Zoobenthos species in Bien Hoa Airbase and surrounding areas

Table 2.45. Density and biomass of Zoobenthos species in Bien Hoa Airbase and surrounding areas

Table 2.46. Component of Fishes in Bien Hoa Airbase and surrounding areas

Table 3.1. Sources of impact and impacted subjects in the Project preparation phase

Table 3.2. Estimate of fuel amount consumed per day of construction and leveling equipment in Isolation ground

Table 3.3. Air pollution emissions generated from construction and leveling vehicles in the Landfill using Diesel fuel

Table 3.4. Concentration of contaminants by distance

Table 3.5. Noise level of construction equipment

Table 3.6. Maximum noise propagation by distance viii

Table 3.7. Exhaust gas load of transportation vehicles

Table 3.8. Load of contaminants of vehicles transporting building materials

Table 3.9. Dispersion of contaminants in exhaust gas due to transportation of building material

Table 3.10. Load of contaminants of vehicles transporting contaminated materials to Pacer Ivy Treatment Area

Table 3.11. Dispersion of contaminants in exhaust gas due to transportation of contaminated materials to the Pacer Ivy Treatment Area

Table 3.12. Load of contaminants of vehicles transporting materials below threshold values to Isolation areas

Table 3.13. Dispersion of contaminants in exhaust gas due to operation transportation of materials below threshold values to Isolation areas

Table 3.14. Estimated amount of materials consumed during construction phase

Table 3.15. Air pollution emissions generated from construction and excavation, leveling vehicles using Diesel fuel

Table 3.16. Concentration of contaminants bydistance

Table 3.17. Load of contaminants in domestic wastewater

Table 3.18. Types of domestic waste

Table 3.19. Estimated mass balance for industrial soil treatment with concentration of

1.320 ppt TEQ

Table 3.20. Estimated mass balance for industrial soil with average in-pile concentration of 5.270 ppt TEQ

Table 3.21. Calculation of greenhouse gas emissions

Table 3.22. Load of contaminants in domestic wastewater

Table 3.23. Estimated amount of contaminated wastewater in treatment plan

Table 3.24. Total contents of nitrogen and phosphorus in drainage water

Table 3.25. Calculation of wastewater sources of the project

Table 4.1. Organization plan on implementation of environment protection works and measures

Table 5.1. Environment management program of the Project ix

Table 5.2. Locations for groundwater and wastewater environment quality monitoring during preparation and construction stage of the Project

Table 5.3. Water quality monitoring parameters

Table 5.4. Air quality monitoring parameters

Table 5.5. Air monitoringlocations during preparation and construction stages of the Project

Table 5.6. Monitoring locations of surface water, groundwater, wastewater during operation stage of the Project

Table 5.7. Water quality monitoring parameters

Table 5.8. Air quality monitoring parameters

Table 5.9. Air monitoring locations during operation stage of the Project

Table 5.10. Monitoring locations of dioxin in surface water, groundwater during operation stage of the Project

Table 5.11. Monitoring locations of dioxin in air during operation stage of the Project x

LIST OF FIGURES

Figure 1.1. Bien Hoa Airbase via satellite images Figure 1.2. Map of the Project’s transportation route

Figure 1.3. Contaminated lakes and Warning signs

Figure 1.4. Zoning map of dioxin sampling at Bien Hoa Airbase

Figure 1.5. Map of the level of dioxin contamination in areas at Bien Hoa Airbase

Figure 1.6. Map of additional sampling at Bien Hoa Airbase

Figure 1.7. Map of Dioxin Contamination on the Ground Surface of Bien Hoa Airbase30

Figure 1.8. Dioxin Treatment Goal at Bien Hoa Airbase

Figure 1.9. Treatment layout in Pacer Ivy Area

Figure 1.10. Treatment layout in Z1 Area

Figure 1.10a. Landfill layout and transporting roads for contaminated soil, sediment by trucks

Figure 1.11. The cross section view of the landfill

Figure 1.12. Plan view of the landfill

Figure 1.13. Structural section of the bottom of the landfill

Figure 1.14. Structural section of the walls of the landfill

Figure 1.15. Structure of the bottom layers of the landfill

Figure 1.16. Structure of the surface cover

Figure 1.17. Diagram of surface drains

Figure 1.18. Chart of dioxin flows in Phase 2 of Dioxin contamination remediation project at Da Nang Airport

Figure 1.19. Dioxin volume balance in Phase 2 of in-pile thermal desorption of Dioxin contamination remediation project at Da Nang Airport

Figure 1.20. Diagram of ex-situ TCH treatment technology

Figure 1.21. Diagram of ex-situ TCH treatment technology

Figure 1.22. Steps in treatment operation

Figure 1.23. Process of ex-situ TCH treatment technology

Figure 1.24. Diagram stimulating ex-situ TCH equipment system

Figure 1.25. Structure of the thermal treatment pile

Figure 1.26. Design solution of in-pile wells xi

Figure 1.27. Arrangement diagram of steam collection system Figure 1.28. Structure of the surface coating Figure 1.29. Waste water treatment diagram Figure 1.30. Vapor and exhaust gas treatment diagram Figure 2.1. Wind roses in 2 seasons in Bien Hoa area Figure 2.2. Surface water and groundwater flow model in Bien Hoa Airbase area Figure 2.3. Air sampling locations in the project area’s environment Figure 2.4. Surface water sampling locations in the project area’s environment Figure 2.5. Groundwater sampling locations in the project area’s environment Figure 2.6. Soil sampling locations in the project area’s environment Figure 2.7. Sediment sampling locations in the project area’s environment Figure 3.1. Network diagram of main environmental impacts of the Project in 4 phases

Figure 3.2. Impact of noise to organs of human body Figure 3.3. The structural formula of a dioxin Figure 3.4. Chart of dioxin flows during thermal desorption Figure 3.5. Result of exhaust gas monitoring in treatment pile of phase 2, Da Nang project Figure 3.6. Routes of dioxin exposure

Figure 4.1. Composition of improved cesspool

Figure 4.2. Principle diagram of the TCH treatment system on Site

Figure 4.3. Vapor, off-gas treatment system diagram

Figure 4.4. Waste water treatment system diagram

Figure 5.1. Diagram of air environment quality monitoring locations during preparation and construction stage of the Project

Figure 5.2. Diagram of surface water environment quality monitoring locations during preparation and construction stage of the Project

Figure 5.3. Diagram of groundwater and wastewater environment quality monitoring locations during preparation and construction stage of the Project

Figure 5.4. Diagram of environment quality monitoring locations during operation stage of the Project

Figure 5.5. Diagram of monitoring locations of dioxin in soil, water and air during operation stage of the Project xii

LIST OF ACRONYMS & ABBREVIATIONS

AQC Air Quality Control

BOD Biological Oxygen Demand

BOND Ministry of National Defense

ADAFC Air Defense - Air Force Command

CAAV Civil Aviation Administration of Vietnam

CDM CDM International, Inc.

CFR Code of Federal Regulations, USA

CO2 Carbon doxide (chemical formula)

COD Chemical Oxygen Demand

COPC Contaminant of Potential Concern

U.S. G U.S. Government

DE Destruction Efficiency

DER Destruction and Removal Efficiency

Project The Dioxin Remediation at Bien Hoa Airbase Area Project

EIA Environmental Impact Assessment

EMP Environmental ManagementPlan

EVSA Excess Volume Stockpile Area

FDI Foreign Direct Investment fg Femtogram (international unit)

GC-MS Gas Chromatography – Mass Spectrometry

GDP Gross Domestic Product

GFH Granular Ferric Hydroxide

Hatfield Hatfield Consultants

HDPE High-density Polyethylene

IUCN International Union for Conservation of Nature

S-E Socio-economic

LVTP Liquid/Vapor Treatment Plant

LGAC Liquid-phase Granular Activated Carbon

LWIC Lightweight Insulating Concrete

MCL Maximum Contaminant Level xiii

MPPE Macro-porous Polymer Extraction

MW Megawatt(s)

NAPL Non-aqueous Phase Liquid

OWS Oil- Water Separator

PAHs Polycyclic Aromatic Hydrocarbon

PCB Polychlorinated biphenyl

FPAF Fire Prevention and Fighting

PCDD Polychlorinated dibenzo-p-dioxin (Dioxin)

PCDF Polychlorinated dibenzofuran (Furan) pg Picogram (international unit) ppt Part per trillion

VTR Vietnam Technical Regulation

DONRE Department of Natural Resources and Environment

TCDD 2,3,7,8-tetrachlorodibenzo-p-dioxin

VS Vietnam Standard

TEQ Toxicity Equivalency

TOC Total Organic Carbon

TTZ Thermal Treatment Zone

NRE Natural Resources and Environment

FP Floating Plant

UNDP United Nations Development Program

USAID United States Agency for International Development

USEPA United States Environmental Protection Agency

VAST Viet Nam Academy of Science and Technology

Office 33 Office of the National Steering Committee on Resolving Post-war Consequences of Toxic Chemicals

VND Vietnam Dong

VGAC Vapor-phase Granular Activated Carbon

VOC Volatile Organic Compound

WHO World Health Organization

INTRODUCTION

1. ORIGIN OF THE PROJECT

1.1. Project background:

Although the American War in Vietnam ended over 40 years ago, the legacy of Agent Orange/dioxin has still lingered on, severely affecting the health of people and the environment of Vietnam. According to research and surveys, Vietnam is considered to have the most elevated dioxin-contaminated sites. Agent Orange/Dioxin contamination in Vietnam began in wartime from 1961 to 1971 when over 80 million liters of herbicide and over 9,000 tons of CS gas were sprayed throughout the battlefields in Central and Southern Vietnam. Primarily used to defoliate plants in forests and fields, these types of herbicide contain 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD) - a highly toxic pollutant.

Previous studies have shown that dioxin concentrations in airbases, especially in “hot spots”, are higher than international and Vietnamese dioxin contamination standards (Hatfield and 10-80 Committee, Ministry of Health [10-80 Committee], 2016, Hatfield and Office 33, 2011). In particular, Bien Hoa, Da Nang and Phu Cat Airbases in Vietnam are considered “dioxin hot spots” where, during wartime, enormous quantities of Agent Orange and other defoliants were transported and sprayed, hence high dioxin concentrations left there for decades(Dwernychuk et al., 2002; Dwernychuk, 2005).

Due to the storage, usage, and spill of those toxic chemicals at Bien Hoa Airbase during the years of war, the concentration of TCDD, which is quite high, has still persisted until now (Dwernychuk et al., 2002; Dwernychuk, 2005). This place used to be home to 3 huge tanks of herbicide, each of which contained Orange Agent, Agent White, and Green Agent. According to the data of the United States Army, Bien Hoa Airbase was utilized as a place of storage, usage, and transportation of 98,000 45-gallon (170-liter) barrels of Orange Agent, 45,000 barrels of Agent White, and 16,000 barrels of Green Agent (U.S. Department of Defense [DOD] 2007). On September 15, 1971, Operation Pacer Ivy was launched with the aim of gathering, packaging, and transporting all Orange Agent and other herbicides of Operation Ranch Hand from the Southern Vietnam to Johnston Atoll in the Central Pacific region (Environmental impact assessment report - Dioxin contamination at Bien Hoa Airbase, USAID, 2016).

As can be seen from the survey and analysis results, the total volume of soil and sediment which needs remediation due to the dioxin level beyond the permissible limit is 500,000 m3 (including 400,000 m3 of soil and 100,000 m3 of sediment), so the range of contamination both on and off the Airbase is about 60 ha. In general, the site can be divided into 02 contaminated areas: Pacer Ivy Area (including the East, Northeast, North, Northwest, and West of the airbase) and Z1 Area (including the North, Northeast, and Southeast of the airbase).

Bien Hoa Airbase is situated in Bien Hoa City, Dong Nai Province with the West end about 700 m from Dong Nai River and the total area of about 1,000 ha. It is estimated that there are approximately 120,000 residents in the wards around and within the Airbase. The Airbase is located in Tan Phong Ward which borders Trung Dung, Quang Vinh and Buu Long Wards. The surrounding areas are densely populated, therein most of the area are being used for housing, industrial production facilities, transportation, and related infrastructure.

There are a number of fish ponds within the Airbase area, particularly in the Northeast area. These ponds have been in active use since before 2010, mainly by the locals farming fish, ducks and other aquatic animals (Hatfield and Office 33, 2011).

Currently, there are approximately 1,200 people living in the Airbase and sometimes, there can be up to 2,200 people, most of whom are soldiers from military units (about 20 units) stationed within and around the Airbase. Some factories and warehouses can also be found here. The northern part of the Airbase is used for agricultural production (including fields and gardens, livestock production areas as mentioned recently in April 2015) and some areas are used for growing rubber trees. Besides, there are a number of fish ponds in the Airbase (mainly raising tilapia, but the residents also raise ducks and other aquatic animals), mainly in the Northeast area; however, until 2010, the Airbase officially banned the use of these ponds for aquaculture to increase production as recommended by Office 33.

Some interim measures have been implemented since 2009, including an Awareness Raising program conducted by Office 33 in October 2013 to warn the residents against the dangers related to fish farming in the ponds of the Airbase, as well as installing fences and warning signs.

To prevent the risk of dioxin spread, from 2009 to 2015, the Ministry of National Defense landfilled and contained a part of the contaminated site (about over 100,000 m3 in Z1 Area). In addition, in the Dioxin Project of UNDP-GEF, there were several short-term interim actions taken to contain the dioxin spread. So far, there has been no overall treatment conducted in this place, although it is identified as one of the “dioxin hot spots”. Besides, because the situation of dioxin contamination in Bien Hoa Airbase is quite complicated with high dioxin concentrations distributed in various zones to different extents, the application of appropriate management measures and technology to treatment in accordance with applicable standards of Vietnam is an urgent and topical matter.

From 2012 to 2017, with non-refundable aid of the U.S. Government (with ODA capital via USAID), in Da Nang Airport, more than 90,000 m3 of soil/sediment with the dioxin level above 1,000 ppt was successfully treated by thermal desorption and about 60,000 m3 of soil/sediment with the dioxin level below the threshold was safely contained, thereby minimizing the risk of dioxin exposure to humans.

On January 23, 2018, the United States Agency for International Development (USAID) and the Military Science Department/Ministry of National Defense signed a Memorandum of Intent on dioxin remediation at Bien Hoa Airbase area.

On May 11, 2018, the United States Agency for International Development (USAID), on behalf of the United States, and the Air Defense - Air Force Command, on behalf of the Ministry of National Defense under the Government of the Socialist Republic of Vietnam, signed an Agreement on non-refundable aid, worth $183 million, for the project of dioxin treatment in Bien Hoa Airbase.

According to the Notice No. 329/TB-VPCP dated August 30, 2018 of the Government Office on the conclusions of Prime Minister Nguyen Xuan Phuc at the meeting of the National Steering Committee on Resolving Post-war Consequences of Toxic Chemicals and Unexploded Ordnance (Committee 701), Point 5.b (Section IV) states that “Regarding the Vietnam – U.S. corporation project on dioxin remediation at Bien Hoa Airbase with the reciprocal capital from the State budget and ODA non-refundable capital from the U.S.: To assign the Ministry of National Defense promptly to complete the Project documents to submit to the Prime Minister for approval; To assign the Ministry of Planning and Investment and the Ministry of Natural Resources and Environment to research ensuring the Project reciprocal capital”

For the aforementioned reasons, based on the Vietnam Laws, to ensure safety for people, the remediation of dioxin contamination at Bien Hoa Airbase area is very urgent.

1.2. Competent project-approving agencies and organizations: Ministry of National Defense

1.3. Relationship between the project and other development projects and plans approved by state agencies:

The Dioxin remediation at Bien Hoa Airbase area project, under the management of the Air Defense - Air Force Command, will be implemented at Bien Hoa Airbase area in accordance with the military land use planning at this site.

(Military land use Planning at Bien Hoa Airbase was approved by the Air Defense - Air Force Command on May 23, 2017).

To facilitate the implementation of the overall the dioxin remediation at Bien Hoa Airbase area project, the Dioxin pre-treatment and infrastructure construction at Bien Hoa airbase project, approved by the Ministry of National Defense, was implemented under the management of the Air Defense - Air Force Command (2017 - 2019). This project aimed at moving military units and constructions in the contaminated area or near the heavily contaminated area, building fences around the contaminated area to eliminate risks of exposure, clearing the ground, and upgrading the transportation road system to serve the overall the dioxin remediation at Bien Hoa Airbase area project.

2. LEGAL AND TECHNICAL BASIS FOR ENVIRONMENTAL IMPACT

ASSESSMENT

2.1. Legal basis

Herein is the legal and technical basis for the report of environmental impact assessment (EIA) for the "Dioxin remediation at Bien Hoa Airbase area project":

- Law on Environmental Protection No. 55/2014/QH13 approved by the Thirteenth National Assembly of the Socialist Republic of Vietnam dated June 23, 2014;

- Law on Biodiversity 20/2008/QH10 approved by the Tenth National Assembly of the Socialist Republic of Vietnam dated November 13, 2018;

- Law on Construction No. 50/2014/QH13 approved by the Thirteenth National Assembly of the Socialist Republic of Vietnam dated June 18, 2014;

- Law on Investment No. 49/2014/QH13 approved by the Thirteenth National Assembly of the Socialist Republic of Vietnam dated June 18, 2014;

- Decree No. 19/2015/ND-CP detailing the implementation of a number of articles of the Law on Environment Protection of the Government dated February 14, 2015;

- Decree No. 18/2015/ND-CP of the Government dated February 14, 2015 on environmental protection planning, strategic environmental assessment, environmental impact assessment and environmental protection plans.

- Decree No. 155/2016/ND-CP of the Government dated November 18, 2016 on penalties for administrative violations against regulations on environmental protection;

- Decree No. 136/2015/ND-CP of the Government dated December 31, 2015 on guidance on implementation of the Law on Public Investment

- Decree No. 120/2018/ND-CP of the Government dated September 13, 2018 on amendments to Decree No. 136/2015/ND-CP on guidance on implementation of the Law on Public Investment;

- Circular No. 27/2015/TT-BTNMT of the Ministry of Natural Resources and Environment dated May 29, 2015 on strategic environmental impact assessment, environmental impact assessment and environmental protection plans;

- Decree No. 81/2007/ND-CP on specialized organizations and sections of environmental protection in the state agencies and state enterprises;

- Decision No. 651/QD-TTg of the Minister of National Defense dated September 16, 2013 approving “the Action Plan to 2015, with orientation to 2020, to overcome fundamental consequences of toxic chemicals used by the United States in the Vietnam War”;

- Circular No. 101/2017/TT- BQP of the Ministry of National Defense dated April 24, 2017 regulating decentralization and authorization for investment decisions and preparing, appraising and approving investment projects of the Ministry of National Defense;

- Decision No. 79/QD-BXD of the Ministry of Construction dated February 15, 2017 on standard project management and construction consulting costs;

- Directive No. 05/CT-BQP of Minister of National Defense dated February 03, 2017 on executing projects and programs on disposal of toxic chemicals/dioxin for the military.

- Letter from US Ambassador to Vietnam Ted Osius to Senior Lt. General Nguyen Chi Vinh on May 31, 2017;

- Official Dispatch No. 4299/VPCP-QHQT of the Government Office dated May 10, 2018 on signing the agreement on non-refundable aid for the dioxin remediation at Bien Hoa Airbase area project;

- Official Dispatch No. 198/BTNMT-TCMT-M from the Ministry of Natural Resources and Environment to the Government Office dated July 17, 2017 reporting the project appraisal results.

- Memorandum of intent signed between the Department of Military Science/the Ministry of National Defense and the United States Agency for International Development (USAID) (January 23, 2018);

- LSGA signed on May 11, 2018 between the United States Agency for International Development (USAID), on behalf of the United States, and the Air Defense - Air Force Command, on behalf of the Ministry of National Defense under the Government of the Socialist Republic of Vietnam.

- Environmental assessment of dioxin contamination at Bien Hoa Airbase (EA report) of USAID Vietnam appraised by the Ministry of Natural Resources and Environment through Official Dispatch No. 198/BTNMT-TCMT-M dated July 17, 2017.

- Notice No. 329/TB-VPCP of the Government Office dated August 30, 2018 on the conclusions of Prime Minister Nguyen Xuan Phuc at the meeting of the National Steering Committee on Resolving post-war consequences of toxic chemicals and unexploded ordnance (Committee 701).

- Official Dispatch No. 11398/BQP-KHQS dated October 12, 2018 of Deputy Minister of National Defense, Head of Standing Borad 701, Senior Lt. General Nguyen Chi Vinh requesting the Air Defense - Air Force Command and the Academy of Military Science and Technology to promptly prepare the report of environmental impact assessment for the Dioxin remediation at Bien Hoa Airbase area project and submit it to the Ministry of Natural Resources and Environment for appraisal and approval.

Documents relevant to hazardous waste

- Decree No. 104/2009/ND-CP of the Government dated November 09, 2009 regulating the list of dangerous goods and transporation of dangerous goods by road motor vehicles;

- Decree No. 38/2015/ND-CP of the Government dated April 24, 2015 on management of waste and waste materials.

- Circular No. 36/2015/TT-BTNMT of the Minister of Natural Resources and Environment dated June 30, 2015 on management of hazardous wastes.

- Circular No. 52/2013/TT-BTNMT of the Minister of Natural Resources and Environment dated December 27, 2013 regulating g the transportation of dangerous goods being hazardous and infectious substances.

Documents relevant to water resources:

- Law on Water Resources No. 17/2012/QH13 passed by the National Assembly of Vietnam dated June 21, 2012.

- Decree No. 201/2013/ND-CP of the Government dated November 27, 2013 detailing the implementation a number of articles of the Law on Water Resources.

Documents relevant to chemical safety

- Law on Chemicals No. 06/2007/QH12 passed by the National Assembly of Vietnam dated November 21, 2007;

- Decree No. 113/2017/ND-CP of the Government dated October 09, 2017 specifying and providing guidelines for implementation of certain articles of the Law on Chemicals;

- Circular No. 32/2017/TT-BCT of the Ministry of Industry and Trade dated October 09, 2017 specifying and providing guidelines for implementation Decree No. 113/2017/ND-CP of the Government specifying and providing guidelines for implementation of certain articles of the Law on Chemicals;

Documents relevant to labor safety and hygiene

- Labor Code No. 10/2012/QH13 passed by the Thirteenth National Assembly of Vietnam dated June 18, 2012.

http://luatvietnam.vn/VL/662/Luat-Tai-nguyen-nuoc/259A2B8A-983F-4CAE-889F-6057738A3F6D/default.aspx http://luatvietnam.vn/VL/662/Nghi-dinh-1791999NDCP-cua-Chinh-phu-ve-viec-quy-dinh-chi-tiet-viec-thi-hanh-Luat-Tai-nguyen-nuoc/7BBF19DD-E9CB-4659-9915-58E9E623B460/default.aspx http://luatvietnam.vn/VL/662/Nghi-dinh-1791999NDCP-cua-Chinh-phu-ve-viec-quy-dinh-chi-tiet-viec-thi-hanh-Luat-Tai-nguyen-nuoc/7BBF19DD-E9CB-4659-9915-58E9E623B460/default.aspx http://luatvietnam.vn/VL/662/Nghi-dinh-1791999NDCP-cua-Chinh-phu-ve-viec-quy-dinh-chi-tiet-viec-thi-hanh-Luat-Tai-nguyen-nuoc/7BBF19DD-E9CB-4659-9915-58E9E623B460/default.aspx http://luatvietnam.vn/VL/662/Luat-hoa-chat-so-062007QH12-cua-Quoc-hoi/403FC34C-0D47-496C-9452-86EBFF59E5B3/default.aspx http://luatvietnam.vn/VL/662/Luat-hoa-chat-so-062007QH12-cua-Quoc-hoi/403FC34C-0D47-496C-9452-86EBFF59E5B3/default.aspx

- Law on Protection of People’s Health No. 21/LCT/HDNN8 passed by the Eighth National Assembly of Vietnam dated June 30, 1989.

- Decree No. 05/2015/ND-CP of the Government dated January 12, 2015 defining and providing guidance on the implementation of a number of contents the Labor Code.

2.2. Technical documents

A. Standards and regulations relevant to air quality

- QCVN 05:2013/BTNMT. National technical regulation on ambient air quality.

- QCVN 06:2009/BTNMT. National technical regulation on maximum allowable concentrations of harmful substances in ambient air.

- QCVN 19:2009/BTNMT. National technical regulation on industrial emission of inorganic substances and dusts.

- QCVN 20:2009/BTNMT. National technical regulation on industrial emission of organic substances.

- QCVN 30: 2012/BTNMT. National technical regulation on emission of industrial waste incinerators.

B. Standards and regulations relevant to soil and sludge quality

- QCVN 03- MT:2015/BTNMT. National technical regulation on the allowable limits of heavy metals in the soils.

- QCVN 50:2013/BTNMT. National technical regulation on sludge from the water treatment process.

C. Standards and regulations relevant to water resources and water quality

- QCVN 08-MT:2015/BTNMT. National technical regulation on surface water quality.

- QCVN 09-MT:2015/BTNMT. National technical regulation on ground water quality.

D. Standards and regulations relevant to wastewater quality

- QCVN 14: 2008/BTNMT. National technical regulation on domestic wastewater.

- QCVN 40:2011/BTNMT. National technical regulation on industrial wastewater.

E. Standards and regulations relevant to solid waste

- QCVN 25: 2009/BTNMT. National technical regulation on solid waste landfill sites.

- TCVN 6705:2000. Non-hazardous solid wastes - Classification.

F. Standards and regulations relevant to noise

- QCVN 26:2010/BTNMT. National technical regulation on noise

G. Standards and regulations relevant to vibration

- QCVN 27:2010/BTNMT. National technical regulation on vibration

- TCVN 7378:2004. Vibration and shock - Vibration of buildings - Limits of vibration levels and method for evaluation.

H. Standards and regulations relevant to fire prevention and fighting

- TCVN 3890:2009. Fire protection equipment - Installation, storage, inspection, maintenance.

- QCVN 06:2010-BXD. National technical regulation on fire safety of buildings.

I. Standards and regulations relevant to labor safety and hygiene

- TCXDVN 319:2004. Installation of the equipment-grounding system for industrial projects - General requirements.

- Decision No. 3733/2002/QD-BYT of Minister of Health dated October 10, 2002 promulgating 21 labor hygiene standards, 5 principles and 7 labor hygiene measurements.

K. Standards and regulations relevant to hazardous waste

- QCVN 07:2009/BTNMT. National technical regulation on hazardous waste thresholds.

- TCVN 5507:2002. Hazardous chemicals - Code of practice for safety in production, commerce, use, handling and transportation.

- TCVN 6707:2000. Hazardous wastes. Warning signs.

L. Standards, regulations and documents relevant to dioxin

- TCVN 8183:2009. Dioxin threshold in the soil and sediment. Decision No.

1762/QD-BKHCN of the Ministry of Science and Technology dated August 27, 2009.

- QCVN 43:2012/BTNMT. National technical regulation on sediment quality.

- QCVN 45:2012/BTNMT. National technical regulation on allowed limits of dioxin in soils.

- TCVN 9737:2013. Dioxin limits in wastewater and emission from persistent dioxin remediation.

- TCVN 10843:2015 on air quality - the maximum concentration of dioxin in ambient air.

M. Standards and regulations on construction:

- QCVN 07:2016/BXD: National technical regulation on technical infrastructure works

- TCVN 7957:2008: Drainage and sewerage - External networks and facilities

N. Documents provided by USAID, agencies and the project owner:

- USAID. Title 22, Code of Federal Regulations (CFR), Part 216, Environmental Compliance Procedures.

- Report of environmental impact assessment in the dioxin pre-treatment and infrastructure construction at Bien Hoa

Airbase project, 2017.

- Report of environmental impact assessment for dioxin contamination at Bien Hoa Airbase of the U.S. Agency for International Development in 2016.

- Report of dioxin analysis in water, sediment, soil, air of Vietnam-Russian Tropical Center, 2017 - 2018.

- Notes of the Dioxin remediation at Bien Hoa Airbase area projectof Vietnam People's Air Force, 2019.

- Completion Report No. 1 – Construction management and supervision – Environmental remediation of dioxin contamination at Da Nang Airport project, USAID, 2014.

- Completion Report No. 2 – Construction management and supervision – Environmental remediation of dioxin contamination at Da Nang Airport project, USAID, 2016.

- Completion Report No. 3 – Construction management and supervision – Environmental remediation of dioxin contamination at Da Nang Airport project, USAID, 2016.

- Completion Report No. 4 – Construction management and supervision – the environmental remediation of dioxin contamination at Da Nang Airport project, USAID, 2017.

- Evaluation of Dioxin volume balance in In-Pile Thermal Desorption (IPTD) Stage 2 - Management and supervision of construction - Environmental remediation of dioxin contamination at Da Nang Airport project, USAID, 2018.

- Evaluation of dioxin and arsenic contamination risk in treated materials in stage 2 combining with Lightweight insulating concrete - Management and supervision of construction - Environmental remediation of dioxin contamination at Da Nang Airport project, USAID, 2018.

3. ORGANIZATION AND IMPLEMENTATION OF EIA

To prepare the EIA report for the Dioxin remediation at Bien Hoa Airbase area project ", the Project Owner has cooperated with New Technology Institute /Academy of Military Science and Technology to establish the Research Team consisting of scientific experts on environment, chemistry, ecology and sociology and several chemical (dioxin) analysts to produce the report for the Project. The steps are as follows:

Sequence in the implementation of EIA

According to the Law on Environmental Protection in 2014 and Decree No.

18/2015/ND-CP of the Government, the EIA report shall be conducted in the following sequence:

- Step 1: Research documents of the Project, relevant records and documents provided by USAID Vietnam.

- Step 2: Research and gather data about the natural and socio-economic conditions of the Project area.

- Step 3: Conduct field surveys, measurements and analyses at the Project area.

- Step 4: Research documents provided by USAID.

- Step 5: Determine impacting sources and objects and scales of the impacts.

Analyze, identify and assess the impacts of the Project on the natural and social environments.

- Step 6: Develop measures to mitigate negative impacts and prevent and respond to environmental risks and incidents arising from the Project.

- Step 7: Research and build construction works for environmental treatment and set up an environmental management and monitoring supervision program for the Project.

- Step 8: Develop contents of the EIA report for the Project.

- Step 9: The Project Owner works with consulting agencies at People’s Committees of wards and communes which will be directly affected by the Project.

- Step 10: Complete the EIA report and hold a workshop to consult experts.

- Step 11: Submit the EIA report appraisal to the authority (the Ministry of Natural Resources & Environment).

Step 12: Revise the report as required by the EIA Appraisal Council.

The EIA report prepared by: Air Defense - Air Force Command/Ministry of National Defense Represented by: Major General Bui Anh Chung Position: Vice Chief of the Air Defense - Air Force Command Address: 167 Truong Chinh, Hanoi, Vietnam

Consulting agency: New Technology Institute/Academy of Military Science and Technology Represented by: Colonel To Van Thiep Position: Director of the Institute Address: 17 Hoang Sam, Nghia Do, Cau Giay, Hanoi Tel.: 069694759 Email: thiepcnm@gmail.com Herein is a list of individuals who participate in researching and preparing this

EIA report:

- Air Defense - Air Force Command

No. Full name Specialty Primary task Signature

1 Colonel Pham Quang Vu Head of the Military Science

Department

Supervising the consulting agency for the report

2 Lieutenant Colonel Nguyen Xuan Trong

Assistant of the

Military Science

Department

Working with the consulting agency for the report

- New Technology Institute/Academy of Military Science and Technology

No. Full name Specialty Primary task Signature

1 Ph.D. To Van Thiep Chemistry Providing general guidelines on the report preparation

2 Ph.D. Nguyen Van Hoang Chemistry Taking charge of environmental monitoring and analysis

3 Ph.D. Pham Hoai Nam Environment Assessing impacts during the phase of operation and recovery

4 Ph.D. Nguyen Le Tu Quynh Environment Assessing impacts during the phase of pre-preparation, excavation and transportation;

Holding community consultation

5 MS. Nguyen Van Huong Environment Assessing the socio-economic situation and mitigation measures

6 Ph.D. Do Binh Minh Chemistry Carrying out laboratory analysis

7 Ph.D. Nguyen Tam Thu Biology Conducting ecological assessment

8 Ph.D. Nguyen Thi Nhung Biology Conducting ecological assessment

9 Engr. Doan Cong Danh Environment Collecting samples from the environment and assessing the natural conditions for the Project

10 Dir. Duong Thanh Loan Environment Constructing an management and supervision program

4. METHODOLOGY FOR THE EIA PROCESS

a. EIA methods:

• Network diagram method (used in Chapter 3)

This method is used to create a network of impacts and their consequences based on the Project’s specifications and the natural conditions of the project area. The network diagram will lead to further studies into the impacts arising from the project.

In the report, this method helps visualize the link between activities in the Project and potential environmental impacts (causality). However, it only provides general comments without going into details of environmental impacts.

• Rapid assessment method (used in Chapter 3)

Proposed by the World Health Organization in 1993, this method is used to rapidly assess the pollution load of pollutants (exhaust gas, solid waste and wastewater) caused by the Project. In the report, this method is used in Chapter 3 to determine the pollution load of dust, exhaust gas, wastewater and solid waste resulting from the Project, so that the extent and scope of the Project area and surroundings which may be affected can be assessed.

• Expert method (used in Chapter 3)

The expert method is used to collect and process assessments and forecasts by gathering experts from a specific aspect of science - engineering or manufacturing - to ask them questions.

In the report, this method is utilized almost throughout the EIA process which includes steps such as writing the outline, determining the research scope and environmental issues, surveying natural and ecological conditions, analyzing environmental components, identifying, assessing and proposing mitigation measures, and constructing a supervision program.

• Modeling method (used in Chapter 3)

The environmental modeling method is a mathematical approach simulating the development of environmental quality under the impact of one or a set of factors which are likely to affect the environment.

In the report, models can be used to assess the possibility of spreading pollutants and the pollution level. This method is applied in Chapter 3 to forecast the level of impacts caused by activities in the Project:

- Using models to forecast the spreading extent and scope of SO2, NO2, CO and

VOC.

- Method of forecasting noise levels by source and reduction by distance (cited from “Air Environment” by Prof. Dr. Sc. Pham Ngoc Dang - Science and Technics Publishing House in 2003).

• Other methods:

- Method of surveys and investigations (used in Chapter 2):

By this method, surveys and investigations are directly conducted among residents in the wards adjacent to Bien Hoa Airbase (Trung Dung, Tan Phong, and Buu Long Wards) to study the situation of economy, society and waste and their requirements and desires related to the Project.

- Method of inheritance and reference (used in Chapter 2 and Chapter 3):

This method is used to make preliminary assessment of the environmental impacts arising from the Project based on domestic and foreign materials and expert experience. In the report, this method is utilized to process data and materials relevant to the natural, hydrometeological and ecological conditions of Bien Hoa Airbase and surrounding areas. Data for the Project at Bien Hoa Airbase is inherited from the Environmental remediation of dioxin contamination at Da Nang Airport project.b.

Method of measurements, surveys and analysis

Pursuant to Circular No. 24/2017/TT-BTNMT dated September 01, 2017 of the Ministry of Natural Resources and Environment on environmental monitoring techniques, at the project area, samples are taken and analyzed according to Vietnam standards and technical regulations, including: surveys, field measurements, sampling and analysis and determination of environmental specifications in the laboratory with specialized equipment. Samples of air, noise, vibration, surface water, ground water and soil are taken at the site intended for the Project and surrounding areas. Sampling locations represent the current environmental quality at the areas and the environmental carrying capacity and help assess the spreading extent of pollutants caused by activities in the Project. The chosen environmental specifications are those which show the quality of the background environment at the project area as well as characteristics of sources of waste arising from the Project.

Here are some methods of sampling, analyzing and assessing the soil, water and air quality.

- Method of air sampling and analysis

The method of air sampling and air pollution indicator analysis is conducted in accordance with TCVN 1995 and 1999 and instructions from “Methods of Air Sampling and Analysis” and “Standard Method”.

To take samples of the ambient air, the sampling height is 1.5 m above the ground. During the sampling process, measuring instruments and analytical methods are used in accordance with their respective Vietnam and ISO standards.

Microclimate indicators are measured with TESTO 451 and sound levels are determined with Rion NL-21, a handheld meter. Air samples are taken with KIMOTO Handy Sampler HS - 7.

Indicators for CO, SO2, NOx dust are identified according with the following standards:

- TCVN 5067:1995. Air quality. Weighing method for determination of dust content.

- TCVN 6138:1996 (ISO 7996:1985). Ambient air. Determination of the mass concentration of nitrogen oxides. Chemiluminescence method.

- TCVN 5972:1995 (ISO 8186:1989). Ambient air. Determination of the mass concentration of carbon monoxide (CO). Gas chromatographic method.

- TCVN 5978:1995 (ISO 4221:1980). Air quality. Determination of mass concentration of sulfur dioxide in ambient air. Thorin spectrophotometric method.

- Method of water sampling and analysis The sampling method complies with Vietnam standards including TCVN 5992- 1995 (ISO 5662-2:1991), Water quality - Sampling - Guidance on sampling techniques, and TCVN 5993-1995, Water quality - Guidance on curing and treatment of samples.

The analytical method adheres to Vietnam and ISO standards, in particularly:

- Indicators for pH, temperature, conductivity and turbidity are determined by the YSI water quality meter.

- TCVN 6625-2000 (ISO 11923-1997). Water quality - Determination suspended solids by filtration through glass-fiber filters.

- TCVN 6001-1995 (ISO 5815-1989). Water quality - Determination of the biochemical oxygen demand after 5 days (BOD5) - Dilution and seeding method.

- TCVN 6491-1999 (ISO 6060-1989).