world bank documentdocuments.worldbank.org/curated/pt/698391468328603200/pdf/e27620v80rev... ·...

- THE SOCIALIST REPUBLIC OF VIET NAM

MINISTRY OF AGRICULTURE AND RURAL DEVELOPMENT

Mekong Delta Water Management for Rural Development Project - (MDWM-RDP)

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Revised Final 1 5 April 2011

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E-2762 Vol8 Rev

Table of Contents

Page EXECUTIVE SUMMARy 4

I INTRODUCTION 6 bullbullII SUBPROJECT DESCRIPTION 6 21 Scope of the Subproject 6 22 Description of Works 6

III ENVIRONMENTAL BACKGROUND 9 31 32

General Characteristics Soil and Water Quality

9 bull 1 0

IV POTENTIAL IMPACTS AND MITIGATION MEASURES 12 41 Summary of the Subproject Impacts 12 42 Safeguard Screening and Identification of Issues 12 43 Potential Negative Impacts and Proposed Mitigation Measures 13 V EMP- ACTIONS TO BE CARRIED OUT UNDER THE SUBPROJECT 15 51 Mitigation Measures during Construction 15 52 Mitigation Measures during Operation 15 53 Consultation and Information Disclosure 15 VI IMPLEMENTATION ARRANGEMENT 17 61 Organization and Responsibilities 17 62 Monitoring and Reporting 17 63 Work Plan Schedule and Budget 17

List of Tables Table 21 General information on the subproject 7 bullTable 31 Ground water quality in the subproejct area 11 II Table 41 Results ofsafeguard screening 13

IIIJI Table 51 Water quality monitoring for Nhon Ai Water Supply 16 Table 52 Estimated unit cost for water quality analysis 16

Table 42 Potential negative impacts and proposed mitigation measures 14

Table 61 Institutional responsibilities forNhon Ai Water Supply 18 Table 62 Tentative work plan forNhon Ai Water Supply 19

List ofFi~ures

Figure 21 Nhon Ai water supply system 8 Figure 22 Technical design of water treatment process

Figure 32 Land use in Can Tho municipality 1 0

8 Figure 31 Location of the subproject 9

Annex 1 Environmental Code ofPractice (ECOP) for Nhon Ai Water Supply 20 II

2 II

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- ABBREVIATIONS

BOD Demand

CPMU -CSEP--middotmiddotmiddot-middot_- [Contract Specific Environmental Plan

[~~~~~~~I Department ofNatural Resources and Environment I

~CP~____ __ I Central Project Office

DARD i (Provincial) Department ofAgriculture and Rural Development [DpmiddotC----middot--1 District Peoples Committee

rECOp_-- Environmental Code ofPractices

EIA Environmental Assessment

EMP

EMDP

EMPF

ESMF Framework

GOY MONRE

f middotmiddotmiddotmiddot~middotmiddot-middotmiddotmiddot

CERWASS i (Provincial) Centered) for Rural Water Supply and Sanitation -PPC--middot------- Provincial Peoples Committee

[QCVN- middotmiddotmiddotmiddotmiddot1 National T echnic~ Regulations-__bull_ i---------=---------------- shy- I RAP i Resettlement Action Plan bull__--_ --------- shy- TCVN National Environmental Standard

rWB -1 World Bank ----

--- - 3

-

Plan

IVl Itqn ofNatural Resources and Environment

bull bull ItEXECUTIVE SUMMARY

Background The subproject comprises construction of one new water supply system with 40 cubic meters per hour (m3hr) capacity The system is designed to serve 1257 households (6885 people) The subproject area is located in Nhon Ai commune Phong Dien district Can Tho municipality The new system uses two deep wells as the water sources The Can Tho Center II for Rural Water Supply and Sanitation (CERWASS) will be the subproject owner

bull Impacts and mitigations III The subproject will create positive impacts to rural population Potential negative impacts will be minor due to small size of the water supply system and location in community area III and land acquisition will not be required Locations of the two deep wells have been II identified Impacts during construction will be limited to increasing dust noise and traffic at the construction site due to transportation of construction materials which will be small amount Increase in the wastewater from the proposed subproject would be minor and could be managed through the household sanitation to be supported by the project TheEMP To mitigate these impacts the following measures will be carried out in close consultation with local authority and communities

(I) Can Tho CERWASS will include the Environmental Code of Practice (ECOP) for construction (Part A and B) in the bidding and contract documents and ensure that contractor is aware of safeguard obligation and commit to comply (2) During construction the Can Tho CERWASS will assign field engineer to closely supervise and monitor safeguard performance of contractor and safeguard training will be provided to the staff and

(3) After completion of construction the Can Tho CERWASS will monitor water quantity and quality of groundwater on a monthly basis at least for the first year of the system operation Training will be provided to the operation staff as part of normal operation

Responsibility The Can Tho CERWASS will be responsible for ensuring effective implementation of the mitigation measures including reporting the implementation progress The CER W ASS will bullset up an Environment and Social Unit (ESU) comprising at least one full time staff to be lit responsible for forging effective implementation of safeguard measures A group of national consultant1 will be hired to assist the ESU in performing the safeguard activities under the responsibility of the Can Tho CERWASS

The Central Project Management Unit (CPMU) will be responsible for overall supervision and monitoring the implementation progress of the subproject including safeguards and provide safeguard training to the subproject staff I This consultant will also be responsible for management and monitoring of safeguard measures for all the subprojects to be implemented by Can Tho CERWASS

4 bull

- ---

-

Budget Cost for implementation of RAP will be financed by the Government Cost for implementation ofmitigation measures during construction and compensation to damage (if any) will be part ofthe subproject construction cost

Cost for supervision of contractor performance will be part of the subproject supervision cost Cost for water quality monitoring program will be part of the environmental monitoring cost and

Cost for safeguard training of staff will be part of the subproject andor project management as appropriate

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shy---- -

5

iIII

I INTRODUCTION

The Government of Vietnam (GOV) will be implementing the Mekong Delta Water bull Resources Management Project (MDWMP-RDP) during 2011-2016 with financing support from the World Bank (WB or the Bank) As part of the project component 3 Rural Water Supply and Sanitation the WB plan to finance about 59 newupgrade rural water supply systems and this subproject is part ofthe subproject cycle I The WB safeguard policy In line with the policy guidelines provided in the Environmental and Social Management Framework (ESMFi an Environmental Management Plan (EMP) for the subproject has been prepared It provides a brief summary of the subproject description and the environmental background and describes the potential negative impacts and the proposed mitigation measures to be carried out during preconstruction construction and operation stages including the implementation arrangement The EMP (this report) also describes the Environmental Code of Practice (ECOP) to be included in the bidding and contract documents GOVs EM regulation Given the small size of the proposed water system an EIA report is not required by the Governments EIA regulation However the subproject owner will be required to prepare an Environmental Commitment (EC) for each specific site and secure approval from the Provincial Peoples Committee (PPC) and the process is on go-ing During construction the contractor will be required to comply with a number of Government (GOV)s regulations standards code of practices etc related to environmental and safety II SUBPROJECT DISCRIPTION

21 Scope of the Subproject

The subproject is designed to provide clean water supply to 1257 households (6885 people) of rural popUlation living in remote areas in Nhon Ai commune Phong Dien District Can Tho municipality This effort will support the Governemnt policy to increase rural water bull supply and sanitation coverage of Can Thcr city for year 2020 (Decision No1 042000QpoundgtshyITG dated 25th August 2000) I 22 Description of Works

Construction os a new water supply system with a designed capacity of 40 m3 per hour is proposed Table 21 and below provide general information ofthe subproject bull

2 Environmental and Social Management Framework (ESMF) MDWRM-RDP Final Draft 31

March 2011

6

-

---------

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--Table 21 General information on the proposed subproject

Work Items Depth of extraction (m)

Designed Capacity (m3h)

Land Area (m2)

Length of water distribution pipeline system (m)

Nhon Ai new water supply

2 wells at depth of30Sm and 140m

40 36S7 20116

Ground water will be used as the water source and as follows (see Figure 21)

Drilling well 2 wells (one shallow and one deep)

o Shallow layer well The exploitable depth 140 meters (m) Diameter of

exploitation pipe 300 millimeters (mm) made of PVC IS mm in thickness 70m

in length standing pipes made of PVC with diameter 168 mm 9 mm in thickness

43 m in length

o Deep layer well The exploitable depth 30S m Diameter of exploitation pipe 300

mm made of PVC IS mm in thickness 70m in length standing pipes made of

PVC with diameter 168 mm 9 mm in thickness 43 m in length

Well pumping station Two underground pumps for two wells with capacity of 40 cubic

meters (m3) per hour H = 45m N=75KW three-phase electricity 01 standby

pump

- Ejector for de-irons

- Pressure filtration tank Two tanks with filtering material made of quartz sand Diameter

2m Height 3m Height of tank foot 1m

Clean water tank Made of reinforces concrete with volume 100m3 diameter 6mx6mx3m

Water support Overlapped-layer structure above the clean water tank with volume 28m3

- Chemical plant area 28 x 42m Barrels containing chemicals for water treatment are installed inside with a stirring motor of O2SKH and a metering pump with capacity 10

liters per hour -- Materials and pipelines are selected calculated and designed for the optimal option

regarding economic and technical conditions

Pipeline network To be installed with total length of20116m with diameter from 60 to - 168 mm - The water treatment process is shown in Figure 22 (see locations in Figure 31)

--7

bull

bullII

I II

Figure 21 Nhon Ai water supply system

I Chlprine

I Well Pump StatiUll Level 1

Air ejector De-oxidation

Pressure I I Clean

Filter tank I

(quartz - water tank

sand)

r---1f-+ Pump Station Level 2

Households 10 Distribution network

I Water support

Figure 22 Technical design of water supply treatment

8 Ii

- - III ENVIRONMENTAL BACKGROUND

- More details on the social and environmental background of Can Tho Municipality are summarized in the Regional Environemtnal Assessment (REA) reporeand the Social Assessment report4

bull Below highlights key information on the environmental background

31 General Characteristics

Nhon Ai commune is located in the central part of Mekong Delta The area is affected by the tropical and monsoon climate comprising 2 seasons rainy season (from May to November) and dry season (from December to April of the next year) An annual mean temperature is about 267 decgree celcious Agriculture production is the major land use in the subproject area (Figure 31) Rainy season starts in May and ends in November precipitation of this period occupy 95 of the whole year

- Figure 31 Location ofthe subproject

t

---- - - -

81

I

NhonAi Water Supply __fI ___bull~

System

- 3 Regional Environmental Assessment (REA) Appendix 3 Final Draft 10 March 2011 MDWRM-RDP

4 Social Assessment (SA) Draft Final February 2011 MDWRM-RDP 9

-

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Figure 32 Land use in Can Tho Municipality

AN GIANG ~J~ mmiddot~

-~mWMi)IlIirM-

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~W_- - - ~w_ -

90NG THAP

kl~N GIANG

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II III

II

Rice Farming

Other crops (eg sugar cane)

Residential Area

32 Soil and Water Quality

Groundwater Results from the groundwater quality monitoring (34 locations at depth of 80-200 m) during the past 10 year (from 1999 to 2009) undertaken by DONRE of Can Tho Municipality suggested that the levels of hardness chloride coliform bacteria and Biochemical Oxygen Demand (BOD) is higher than the national standards for groundwater quality (QCVN 092008) However the ground water quality for Nhon Ai water supply system (see Table 31) is quite good Surface water Results from the surface water quality monitoring undertaken by DONRE ofCan Tho Municipality during the past 10 year (from 1999 to 2009) showed sign ofpoUution Many water pollutants such as total suspended solid (TSS) total iron (Fe) nitrite (N02-) ammonia (NH4+) Coliform bacteria exceed the national standards for domestic uses (QCVN 0820081B1NampMT Column AI) III

lit 10 II

bull

--- Air quality In general air quality of the subproject area is quite good concentration

of air pollutants is lower than the national standards for ambient air quality (QCVN 052009IBlNMT)-Soil quality Analysis of soil quality was conducted during the preparation of REA in December 2010 The results suggested that soil pH is low total nitrogen is fair to rich level total phosphorus is low Concentrations of heavy metals including zinc (Zn) lead (Pb) arsenic (As) cadmium (Cd) copper (Cu) are low and are within the national standards for soil quality (QCVN 0320081B1NMT)

Table 31 Ground water quality in well ofNhon Sinh Hamlet Nhon Ai Commune

(a) At depth 212 meters

-------- - (b) At depth 94 maters-

No Parameter Unit QCVN 0120091BYT Testing Method Result (with

depth ofwell 212 meter)

1 pH 6-85 TCVN 6194 - 1996 68

2 Color TCU 15 TCVN 6185 -1996 0

3 Odor Non founded SMEWW2150B amp 2160B

Non founded

4 Turbidity NTU 5 ISO 7027 bull 1990 143

5 Hardness mgI 350 TCVN 6224 bull 1996 160

6 Chlorine mgI 300 TCVN 6194 middot1996 54

7 NH4 mgI 3 TCVN 5998 bull 1995 0

8 As mgI 001 TCVN 6626 - 2000 0

9 Florua mgll 15 TCVN 6195middot1996 0

10 COD mgll 4 KMn04 18

II Fe mgll 05 TCVN 6177-1996 005

12 Residual Chlorine mgI 03middot05 0

13 Total Coliform bacteria

MPNI00ml 50 TCVN 6187middot1996 ISO 9308 bull 1 bull 1990

0

14 EColi bacteria MPN100ml 0 TCVN 6187 - 1996 ISO 9308 - 1 - 1990

0

---

No Parameter Unit QCVN

0120091BYT Testing Method

Result (with depth ofwell

94 meter)

1 pH 6-85 TCVN 6194middot1996 67

2 Color TCU 15 TCVN 6185middot1996 0

3 Odor Non founded SMEWW 2150B amp 2160B

Non founded

-11

4 Turbidity NTU 5 ISO 7027 - 1990 90

5 Hardness mgI 350 TCVN 6224 - 1996 260

6 Chlorine mgI 300 TCVN 6194 - 1996 90

I 7 NH4 mgI 3 TCVN 5998 - 1995 0

I 8 As mgI 001 TCVN 6626 - 2000 0

9 Florua mgI 15 TCVN 6195 - 1996 0

10 COD mgI 4 KMn04 I

11 Iron (Fe) mgI 05 TCVN 6177 bull 1996 07

12 Residual Chlorine mgI 03 - 05 0

13 Total Coliform bacteria MPNIOOmI 50 TCVN 6187 -1996

ISO 9308middot I - 1990 0

14 EColi bacteria MPNIOOml 0 TCVN 6187 - 1996 ISO 9308 - 1 - 1990 0

bull

bull

IV POTENTIAL IMPACTS AND MITIGATION MEASURES

41 Summary of the Subproject Impact

Positive Implementation ofthe subproject will serve 1257 households including 6885 people At present this area does not have any water supply service Therefore inhabitants do not have access to clean water

Implementation- of the subproject will increase the number of rural population served l1li

bullby clean water and improve the living condition of local residents as well as reduce the risk for exposing to water born diseases (such as eye diseases diarrhea petechial fever)

bullNegative The potential negative impacts will be minor since the proposed treatment plant is located in the existing residential area and land acquisition will not be required The water treatment plant will be small and locations of the wells are identified Impacts during construction will be limited to increasing dust noise and traffic at the subproject site due to transportation of construction materials which will be small amount The increase in wastewater is not considered to be substantial and would be bullmitigated adequately through household level sanitation Below summarizes the impacts and proposed mitigations shy

12

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42 Safeguard Screening and Identification of Issues

(a) Initial and Technical Screening-Construction of new small rural water supply at capacity of 40 m3lhr will not create any irreversible andor significant negative impacts that could not be mitigated Result of the initial screening is shown in Table 41 while that from the technical screening is shown in Table 42

Table 41 Result of safeguard screening5

-Safeguard issues likely to be involved

Safeguard document prepared Remarks

(9) Impacts due to construction ofnew water supply

EMP The subproject located existing community area

in

43 Potential Negative Impacts and Proposed Mitigation Measures

- Public land will be used for the construction of the water treatment plant and pumping station and land acquisition will not be required and ethnic minority will not be involved Construction of water distribution system will be made along the existing roads Table 42 - summarizes the potential impacts and proposed mitigation measures for the subproject and the key one are discussed as follows -

- Extent and nature of the impacts during site clearance and construction will be limited to generation of wastes dust noise and vibration at the construction sites and adverse - impact on water pollution social issues and possible disruption of water supply are not anticipated All these impacts could be mitigated through the application of an -Environmental Code of Practice (ECOP) Parts A and B that has been adjusted for the subproject (Annex 1) with close supervision of field engineer and in close consultation with local authority and community -

- The potential impacts during operation of the subproject will be limited to waste generation (treatment sludge) and safety of operators during the water treatment process however the extent of the impacts will be small and can be managed through good housekeeping and training of operators Potential increase in wastewater generation in the service area would be minor however priority will be given to -improve the sanitary condition at household level andor in the service area through the planning of the sanitation program to be implemented under the project As part of -the system operation water quality monitoring will be carried out to ensure effectiveness of the water treatment process and safety to the water users including water quality monitoring at the water source intake

S per Table 51 ofthe ESMF

13

bull Table 42 Potential negative impacts and proposed mitigation measures

Key Activities

Potential Negative Impact Impact Level Proposed Mitigation Measures

1 Pre-construction Phase Land acquisition and relocation of local residents

Not required Not applicable No actions

2 Construction Phase

Site clearance and construction of the water treatment plant intake station and distribution system

Increase safety risk and obstruction of local traffic Increase dust noise vibration and other nuisance to local residents Water and land pollution due to leakage of waste oil and toxic materials disposal of solid wastes and wastewater etc

Small short term unavoidable controllable

Apply ECOP Parts A andB

(Annex 1)

Activities of construction workers including work camp

Generation of solid and liquid wastes Conflicts between workers and workers and workers and local people Health and safety issues


Apply ECOP Parts A andB (Annex 1)

3 Operation phase

Operation of water treatment plant

Generation of wastes and safety of workers during the treatment process Safety to water users and potential increase in wastewater generation in the service area


Proper disposal of treatment sludge and other wastes Training of staff monitoring ofwater quality and provide high priority for improve sanitation conditions

bull bullbull bull

bull

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14

III

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V EMP--ACTIONS TO BE CARRIED OUT UNDER THE SUBPROJECT

Sl Mitigation Measures during Construction

To mitigate the negative impacts during construction during detailed design ECOP Parts A and B (Annex 1) will be included in the bidding and contract documents and the contractor will be informed to the need to comply with the safeguard requirements Can Tho CERWASS will assign field engineer to closely supervise and monitor safeguard performance of contractor and safeguard training will be provided to the staff In addition a group of national consultant will be hired to monitor performance ofthe contractor

During construction Can Tho CERW ASS assisted by consultant will ensure that the contractor complies with the ECOP given due attention to the following areas

Management and control of sanitary condition of campsite safety of workers and worker behaviors

Management of construction site including covering material transport truck and watering to suppress dust generation and reduction and noise and vibration and

Cooperation with local residents and local authorities and be responsive to their requests related to mitigation ofpotential negative impacts

52 Mitigation Measures during Operation

During operation training of operational staff and water quality will be monitored periodically as part of the system operation Table 51 provides some guidance on water quality monitoring parameters and locations while Table 52 provides an estimate unit cost for

the analysis respectively These costs wil1 be part ofthe system operation cost

During the planning of sanitation improvement program Can Tho CERWASS will provide technical assistance to improve sanitation at household and service area level

53 Consultation and Information Disclosure

The EMP will be disclosed in the country at CPO as well as in Can Tho Municipality It will be translated into Vietnamese language and disclose in the country

Pre-meeting During detailed design and before bidding Can Tho CERW ASS will carry out a consultation with the local authority and community and inform them about the status of the subproject and how to access to safeguard information which has been disclosed both in English and Vietnamese

In the meeting the detailed design the potential negative impacts and mitigation measures proposed for the subproject will be discussed to facilitate effective implementation of the subproject and cooperation of local authorities and communities If needed the mitigation measures should be adjusted in line with the final agreement and the revised mitigation plan should be disclosed to the public locally The results will be included in the subproject progress report

15

I bull Table 51 Water quality monitoring for Nhon Ai Water Supply

Frequency WQ Parameters Location of Compared An estimated samples Standards costsample

Or Regulations

Surface water quality pH Dissolved Oxygen Upstream (when it is used for (DO) Biological Oxygen about 10-15

raw water) Demand (BOD) m before the Both wet and dry Chemical Oxygen pumping

season Demand (COD) total point Monthly for the first suspended solid (TSS)

year This frequency coliform bacteria Ecoli can be reduced if bacteria trace metals

justified (Arsenic irons etc)

Government standard for surface

water domestic uses (QCVN

0820081BTNMT column AI)

Monitoring

cost will be

part ofthe

normal

operating cost

of the system Water quality from pH DO BOD COD At storage Government

the treatment after TSS coliform bacteria tanks (after standard for chlorination (before As Fe residual chlorine treatment drinking water sending for (CI-) and (QCVN 01 and

distribution) chlorination) O21BYT) (l year after the works finish and

begin operation

Water quality from pH DO BOD COD At Government the households TSS coliform bacteria households standard for

(1 year after the As Fe ct- of the system drinking water

works finish and (QCVN 01 and

begin operation) 021BYT)

Table 52 Estimated unit cost for water quality analysis

Monitoring Parameters Unit Unit cost (VND) for each sample

(according to Circular No

23212009nt1BTC dated 911212009 of

MOF

pH - 40000 Metals (6) mgl 480000 TSS mwl 50000 DO mgl 80000 COD mgl 100000 BOD mWl 95000 EColi bacteria mgI 80000 Coliform bacteria MPNIlOOml 80000 Residual Chlorine (CI-) MgI 80000

Total 975000

16

bull

bullbull

bull

bull bull bull bullbull

-

- VI IMPLEMENTATION ARRANGEMENT

61 Organization and Responsibilities -The subproject owner The Can Tho CER W ASS is the subproject owner and will be responsible for ensuring effective implementation of safeguard measures and timely reporting the implementation progress The Can Tho CERWASS will set up an environment and social unit (ESU) comprising at least one full time staff to be responsible for forging effective implementation of safeguard measures

The safeguard consultant To ensure effective implementation of safeguard measures a team of qualified national consultant (Environmental Management Consultant or EMC) will be hired to assist Can Tho CER W ASS during the implementation of safeguard activities for all the subprojects to be implemented by Can Tho CESW ASS under the project including providing guidance on supervision and monitoring of contractors as well as safeguard training to ESU staff and field engineers

The Central Project Management Unit (CPMU) CPMU and its safeguard consultant will be responsible for periodic monitoring of safeguard measures for the subproject including providing clarification on issues related to safeguard policies and requirements and safeguard training to the subproject staffconsultant

Other entities The Can Thos People Committees and the Department of Natural Resources and Environment and (DONRE) are responsible for ensuring full compliance of GOVs regulations It is also a normal practice in Vietnam that local community andlor social entities - will also monitor the contractor performance as well as actual environmental and social impacts

Key responsibilities ofthese stakeholders are listed in Table 61 below

62 Monitoring and Reporting- Field engineer will report the safeguard performance of the contractor as part of the contracts - progress report to Can Tho CERWASS The CERWASS will submit a progress report to CPMU periodically including the progress on the implementation of the EMP and safeguard performance of the contractor CPMU will submit the following reports to WB (a) Semishyannual progress report including (b) Mid-term Review Report and Annual Environmental -and Social Safeguard Monitoring Report and the reports will also include the progress on safeguard implementation and performance ofcontractors -

- 63 Work Plan Schedule and Budget

Table 62 summarizes work plan and schedule of the EMP Cost for implementation of

-- mitigation measures during construction including consultation with local communities and

environmental monitoring as agreed with the local authorities and communities andlor compensation to damage (if any) will be part of the subproject construction cost Cost for supervision of contractor performance will be part of the subproject supervision cost Budget for safeguard training of staff will be part ofthe subproject management

-- 17

III Table 61 Institutional responsibilities for Nhon Ai Water Supply

bull IICommunityagencies Responsibilities

- Periodically monitor performance of the subproject and include CPMU shythe safeguard performance in the project progress report and be the overall contact point with the World Bank I

- As the subproject owner it is responsible for implementation of theI all the EMP activities including the mitigation measures during construction and operation including fostering effective

Can Tho CERW ASS coordination and cooperation between contractor local authorities and local communities during construction phase PCER W AS will be assisted by a team ofqualified consultant the environmental staff andor field engineer

- Assist Can Tho CERWASS in the routine supervision of contractor performance in line with the ECOP including reporting and

Supervision engineer maintain close coordination with local community - Take actions to mitigate all potential negative impacts in line with the objective described in the ECOP - Actively communicate with local residents and take actions to

prevent disturbance during construction - Ensure all the construction activities having sufficient documents

from the related organization Contractor - Ensure that all staffand workers understand the procedure and

their tasks in the environmental management program - Report to the Can Tho CERWASS on any difficulties and their

solutions - Report to local authority and Can Tho CERW ASS if environmental accidents occur and coordinate with agencies and

keys stakeholders to resolve these issues - These organizations could playa role as a bridge between the bull

Social organizations women union and Associations and Related organisations

Provincial andIDistrict Peoples Committee communities contractors and Can Tho CERWASS by assisting in community monitoring

- Mobilizing communities participation in the subproject providing training to communities and

- Participating in solving environmental problems if any - Oversee the implementation of the subproject under the

recommendations of the DONRE and the Can Tho CERW ASS to Can Tho ensure compliance of GOV policy and regulations Peoples Committee bull

- DONRE represents the MONRE for environmental management Itbull Can Tho DONRE

is responsible for monitoring the compliance with the GOVs

bullIf

environmental requirements I

Ibull 18

- Table 62 Tentative work plan for Nhon Ai Water Supply

- I Activities Responsible agency

Work schedule (tentative)

Remarks

I 1Setupsaf~uardcapacity

11 Set up ESU and assign staff Can Tho CERWASS

I 12 Provide safeguard training to CPMUCan Tho subproject staff CERWASS

By end July 2011

By end September 2011

Assume board approval in May 2011

-2 Consultation and detailed desil(D 21 Inform local authorities and Can Tho communities on the EMP and CERWASS adjust the plan as appropriate (Pre-meeting)


Assume project effectiveness in July 2011

-

22 Include the ECOP for the Can Tho subproject in bidding document CERWASS and contract document and inform all the bidders of the safeguard requirement

23 Coordinate with the Can Tho Sanitation Improvement Program CERWASS (SIP) to improve sanitary condition of the service area



Before finalize bidding and contract documents and the bidding process During the preparation of the SIP

--

3 Site clearance and construction manaaement 31 Implement the mitigation Contractor measures as required in the ECOP 32 Monitor and report on contractor performance and actual impact including consultation activities with local resident

Can Tho CERWASSfield engineer consultant

During construction

During construction

Expect in January 2012

bull Expect in bull January 2012

- 4 WQM pr02ram 41 Monitor water quality as part Can Tho Periodically as

- ofnormal operation CERWASS

Iconsultant planned

shy

-19

bull bull

III

Annex 1 Environmental Code ofPractice (ECOP) for Nhon Ai Water Supply

Table of Contents

Chapter 1 Introduction

Chapter 2 Relevant World Banks Safeguard Policies and Governments Regulations

Chapter 3 Responsibilities

Chapter 4 ECOP Part A General Provisions A 1 Contract Specific Environmental Plan (CSEP) A2 Non-compliance and Incident Reporting Procedure A3 Coordination with Government Authorities and the Public A4 Community Relations AS Mitigation Objective A6 Implementation of Chance Find Procedures A7 Prohibitions

Chapter 5 ECOP Part B Management of Construction Bl Management of Construction Sites and Activities B2 Management ofEnvironmental Quality B3 Management of Work Camp B4 Monitoring ofPotential Impacts

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---- Chapter 1 Introduction

This ECOP will be included in the bidding and contract documents of the subproject as an annex to the contract specification and the contractor will be informed of this obligation The ECOP comprises two parts Part A (General Provisions) describing basic requirements for implementation and supervision of works while Part B (Construction Management) describing basic requirements for all Contractors carrying out construction For the sake of clarification construction in this document includes all site preparation demolition of structures spoil disposal materials and waste removal and all related engineering and construction activities

- Below describes responsibilities and safeguard requirements during the construction stage

including closure of all construction sites and work camps


The subproject owner (Can Tho CERWASS) and the Contractor are the key entities responsible for implementation of this ECOP Key responsibilities of the subproject owners

-

and the contractors are as follows

(a) Subproject owner

General The subproject owner on behalf of the Central Project Management Unit (CPMU) is responsible for ensuring that the ECOP is effectively implemented The subproject owner will create a safeguard unit and assign a group of qualified staff to be responsible for preparation and management of environmental and social safeguard of the subproject throughout its life including supervision of contractors The subproject owner is responsible for preparing the safeguard reports and submitting to theCPMU

During construction the subproject owner will recruit an Environmental Management Consultant (EMC) to monitor the compliance of the contractor to fulfill the agreed Contract Specific Environmental Plan (CSEP) (see Al below) Responsibilities of the EMC would include the following (a) monitoring the contractors compliance with the environmental plan (b) taking remedial actions in the event of nonshycompliance andor adverse impacts occur (c) investigating complaints evaluating and identifying corrective measures (d) advising to the Contractor on environment improvement awareness proactive pollution prevention measures (f) supervising the Contractors activities in responding to the complaints (g) providing guidance and onshythe-job training to field engineers on various aspects to avoidmitigate potential negative impacts to local environment and communities during construction

-21

(b) Contractor

- Contractor has the responsibility of carrying out contracted works through fulfilling the agreed CESP In doing so the contactor will establish and maintain contact with the subproject owner and local residents and keep them informed of construction matters likely to affect them This may include regular and frequent distribution of newsletters and attendance at meetings at the request of the subproject owner with representatives of local residents groups Contractor will provide information and reporting telephone Hot Line staffed at all times during working hours Contact details should be prominently displayed at the sites Information on the construction progress including the projected activities that might require closure of traffic or may cause safety risk should be timely provided

Contractor has the duty to secure appropriate permits and licenses before undertaking bulliiithe works or moving heavy equipment It is the responsibility of the Contractor to monitor the development and implementation of new environmental legislation and regulation and to use the appropriate standards prevailing at the time of awarding bull contracts Contractor must comply with all prevailing legislation at the time of construction including any requirements under health and safety Key GOVs environmental regulations are listed as follows

o Vietnamese Environment Standards Environmental Protection Law No 522005QHll The Decree No 802006ND-CP and Decree No 2112008NDshyCP of Vietnam Government Circular No OS2008TT-BTNMT issued by the III MONRE QCVN 052009IBTNMT National Technical Regulation on Ambient Air Quality TCVN 5948-1998 Acoustics Noise emitted by accelerating road vehicles - Permitted maximum noise level QCVN 08 20081BTNMT National Technical Regulation on Surface Water Quality QCVN 09 20081BTNMT National Technical Regulation on Underground bull Water Quality QCVN 01 2009IBYT National Technical Regulation on Drinking Water Quality QCVN 022009IBYT National Technical Regulation bullon Domestic Water Quality

o Water supply TCXD 761979-(Procedures for technical management in operation of water supply system) Besides it is necessary to comply with TCXD661991-0peration of water supply and drainage systems - Safety 2 requirements Besides it is necessary to comply with TCXD66 1991shyOperation of water supply and drainage systems - Safety requirements In general the maintenance of the pipes should follow TCXD76 1979 and 20TCN33-85 TCXDVN 332006 regarding water supply - Pipeline networks and works Design standard

22 bull

-

Chapter 3 ECOP Part A General Provisions

AI Contract Specific Environmental Plan (CSEP) -1 Contractor will be required to prepare a CSEP describing how the Contractor intends to operate construction at works sites as well as other specific measures necessary to avoid andor reduce the potential negative impacts as required in the ECOP especially those related to management of the construction site transportation of construction materials especially dredge materials control of dust noise and vibration solid and liquid waste management and public health Given different scope and nature of civil works scope and nature of the CSEP could be differ and all the CSEP will be reviewed and approved by the EMC to be assigned by the subproject owner

A2 Non-compliance Reporting Procedures

2 Contractor must comply with the CSEP and must ensure that their Sub-Contractors (if- any) also comply with it To ensure that necessary action has been undertaken and that steps to avoid recurrence have been implemented the EMCs andor Contractor must advise the subproject owner within 24 hours of any serious incidents of non-compliance with the CSEP that may have serious consequence In the event of working practices being deemed dangerous either by the subproject owners the local authorities or the other concerned agencies immediate remedial action must be taken by the Contractors The Contractor must keep records of any incidents and any ameliorative action taken The records on nonshy-compliance that could be practically addressed (not cause serious impacts) should be reported to the subproject owner on a monthly basis -3 The Contractor will be responsible for dealing with any reports forwarded by the subproject owner Police or other agencies by (following instruction from the subproject - owner representative as appropriate) as soon as practicable preferably within one hour but always within 24 hours of receipt by either the Contractor The EMCs will monitor and ensure that the Contractor has taken appropriate action Where appropriate approval remedial actions may require an agreement from the local authorities andor other GoV agencies Procedures should be put in place to ensure as far as is reasonably practical that necessary actions can be undertaken to avoid recurrence andor serious damage

-A3 Liaising with Authorities and the Public --

-4 Prior to the commencement of subproject activities and throughout the construction duration the Contractors will work closely with the local authorities and other agencies to ensure full compliance with GOV regulations and will also provide adequate information on the Project to the General Public especially those that may cause public safety nuisance and sensitive areas and the locations of storage and special handling areas -5 The Contractor will provide information and reporting telephone Hot Line staffed at all times during working hours Information on this facility shall be prominently displayed on site hoardings

-- 23

bull A4 Community Relations

6 Contractor will assign a community-relation personnel who will be focused on engaging with the community to provide appropriate information and to be the flrst line of response to resolve issues of concern Contractor will take reasonable steps to engage with residents of ethnic minority backgrounds and residents with disabilities (or other priority bull groups as appropriate) who may be differentially affected by construction impacts 7 Contractor will ensure that local residents nearby the construction sites will be informed in advance of works taking place including the estimated duration In the case of It work required in response to an emergency local residents shall be advised as soon as reasonably practicable that emergency work is taking place Potentially affected residents will also be notifled of the Hotline number which will operate during working hours The Hotline will be maintained to handle enquiries regarding construction activities from the general public as well as to act as a flrst point of contact and information in the case of any emergency All calls will be logged together with the responses given and the callers bull

IIIconcerns action and a response provided promptly The helpline will be widely advertised and displayed on site signboards 8 The Contractor respond quickly to emergencies complaints or other contacts made via the Hotline or any other recognized means and liaise closely with the emergency services local authority officers and other agencies (based on established contacts) who may be involved in incidents or emergency situations 9 The Contractor will manage the work sites work camps and workers in a way that is acceptable to local residents and will not create any social impacts due to workers Any bullconstruction workers office staff Contractors employees or any other person related to the Project found violating the prohibitions activities listed in Section A2 below may be subject to disciplinary actions that can range from a simple reprimand to termination of hisher employment depending on the seriousness of the violation

AS Mitigation Objectives

10 Main objective of this ECOP is to minimize the potential negative impacts during construction on local environment local community and human and environmental safety and disturbance The Contractor is expected to implement the activities in line with the following approach as much as possible in close consultation with the supervision andor fleld engineers who will be assigned by the Can Tho CERWASS to supervise the contract Key approaches include but not limited to

Minimize impacts and restore damages

Replanting trees in project areas

Control erosion and sedimentation during construction

Proper control of runoff and erosion from acid sulphate soil (ASS) and contaminated sediments through special protection and management Use main roads when possible

bull24 II

--- Heavy traffic restrictions

Control (collection disposal) of wastes (solid and liquid) - Minimize disturbance to local population Frequent meetings with local people and provision of timely and adequate information to the project affected peoples (PAPs) so - that their living and production conditions could be managed

Engage and provide labor opportunity for local population - Application of proper safety and warning measures in the construction sites especially in dredging canals

- Provision of temporary crossings and bridges during construction of bridges Application of proper safety and warning measures - Conduct public information campaign and outreach program including training and capacity building

A6 Implementation of Chance Find Procedures -shy

II If Contractor discovers archeological sites historical sites remains and objects including graveyards andor individual graves during excavation or construction the Contractor will carry out the following steps

- Stop the construction activities in the area of the chance find

Delineate the discovered site or area

Secure the site to prevent any damage or loss of removable objects In cases of --

removable antiquities or sensitive remains a night guard shall be arranged until the responsible local authorities or the National Culture Administration take over

Notify the supervisory Project Environmental Officer and Project Engineer who - in turn will notify the responsible local authorities and the Culture Department of

- Province immediately (within 24 hours or less)

Responsible local authorities and the Culture Department of Province would be in charge of protecting and preserving the site before deciding on subsequent appropriate procedures This would require a preliminary evaluation of the- findings to be performed by the archeologists of National Culture Administration The significance and importance of the findings should be assessed according to the various criteria relevant to cultural heritage those

include the aesthetic historic scientific or research social and economic values

Decisions on how to handle the finding shall be taken by the responsible authorities and Culture Department of Province This could include changes in

25

bull bull

the layout (such as when finding an irremovable remain of cultural or archeological importance) conservation preservation restoration and salvage bull- Implementation for the authority decision concerning the management of the rmding shall be communicated in writing by relevant local authorities and bull Construction work could resume only after permission is given from the responsible local authorities or Culture Department of Province concerning safeguard of the heritage

A7 Prohibitions II

12 The following activities are prohibited on or near the Project sites Cutting of trees for any reason outside the approved construction area Building of fires Use of unapproved toxic materials including lead-based paints asbestos etc Use of firearms (except authorized security guards) Use of alcohol by workers in office hours Driving in an unsafe manner in local roads II Washing cars or machinery in streams or creeks Maintenance (change of oils and filters) of cars and equipment outside authorized areas Creating nuisances and disturbances in or near communities Disposing garbage in unauthorized places bull Indiscriminate disposal of rubbish or construction wastes Littering the site Spillage of potential pollutants such as petroleum products Collection of firewood Urinating or defecating outside the designated facilities and Burning of wastes andlor cleared vegetation

Chapter 4 ECOP Part B Management of Construction

B1 Management of Construction Sites

1 This section outlines the requirements relating to site management practices that Ishould be implemented during site operation These relate to working hours site layout and appearance and good housekeeping as well as operations of equipment and vehicles Monthly inspectionmeeting should be conducted to ensure that these procedures are adhered to The Contractor must follow a good housekeeping policy at all times The site should be cleared by the Contractor on completion of the construction

2 The Contractor is required to minimize as far as reasonably practicable any adverse environmental impact of their construction activities All appropriate licenses and consents in respect of site operations will be timely secured Key measures are as follows

I Working hours Core working hours will be from 0800 to 1800 on weekdays and 0800 to 1300 on Saturday Individual site requirements which differ from the above will be considered on a site by site basis Noisy operations shall not take place outside these hours without prior approval from the subproject owner All construction related

IIII26

--

-

-

--------

traffic will abide by the agreed hours of working for each site Any exemption will require an agreement with the Subproject owner subproject andor local authorities

Good housekeeping The Contractor will follow a good housekeeping policy at all times This will include but not necessarily be limited to the following Ensure considerate site behavior of the Contractors staff Prohibit open fires Ensure that appropriate provisions for dust control and road cleanliness are implemented Remove rubbish at frequent intervals leaving the site clean and tidy Remove food waste Prevent vermin and other infestations Frequently inspect repair and re-paint as necessary all site hoardings to comply with the local conditions and local regulations all flying postlboard is to be removed as soon as reasonably practicable and within 24 hours of notice from the Subproject owner Maintain toilet facilities and other welfare facilities for its staff Frequently cleanse wheel washing facilities and Undertake all loading and unloading ofvehicles offthe highway wherever this is practicable

Public information and site access As a minimum the Contractor will provide public information on the site program (start and finish dates) plus the telephone for public contacts andor requests Effort will be made as much as possible to ensure safety for workers as well as for the Public (especially children) Any un-authorized entry to or exit from the sites should be control as much as possible

Site layout and facilities Location of site huts office accommodation toilets and welfare facilities should be accommodated within the boundaries of the site

Emergency Procedures The Contractor will ensure that emergency procedures are developed to facilitate effective actions in case of medicaVfire emergency as well as environmental pollution (major spillage of gasoline used oil andor toxic chemicals etc) Further guidance will be provided by responsible agencies The emergency procedure will contain emergency phone numbers and the method of notifying the statutory authorities Contact numbers for the key staff of the contractor will also be included

Fire Prevention and Control AU construction sites and associated accommodation or welfare facilities will have in place appropriate plans and management controls to prevent fires The site fire plans will be prepared and will have due regard to the GOV regulations During operation and maintenance of equipment and vehicles the Contractor will ensure that its workers are well aware of the procedures and have enough knowledge to comply with them The specification of non-combustible materials products and packaging will be pursued wherever reasonably practicable The project will also have to comply with GOVs requirements as may be appropriate at specific sites

Pest control The Contractor shall ensure that the risk of infestation by pests or vermin is minimized Adequate arrangements for disposing of food waste or other material attractive to pests must be implemented If infestation occurs the Contractor must take such action to deal with it as required

-27

bull bull

bull bull

II1II

Operation of equipment The Contractor must take all reasonable precautions to ensure that equipment is operated in a manner so as not to cause safety risk andor nuisance to surrounding residents and occupiers Operations of crane and other large equipment will have to be closely supervised Permission may be required per GOV regulations

Clearance and rehabilitation ofconstruction site after completion On completion of the works the Contractor will clear away and remove all materials and rubbish and bulltemporary works of every kind The site will be left clean and in a condition to the satisfaction of the PPMU Any potentially hazardous defects to the highway will be made good prior to permanent reinstatement

B2 Management of Environmental Quality (a) Discharge of Wastes into the Canals II

3 The Contractor must take all the efforts to prevent wastes (solid and liquid) discharge into all rivers and canals and to protect surface and groundwater from pollution and other adverse impacts including changes to water levels flows and general water quality Discharge of engine oil and oily waste from dredgers and construction machines to the canals will be strictly prohibited Engine oil used oil and other toxic substances and hazardous wastes must be properly collected stored treated andor disposed off Key measures are as bull follows

Used oilengine oil The oil container at the construction site (especially when the site is located less than 10 meters from the waterways) must be of sufficient strength to ensure to prevent leakage The container must be situated within a secondary containment system (bunded) which will prevent the release of any leaked oil The Contractor must make provisions to ensure that all hazardous substances including oil drums or containers on site are properly labeled and properly stored and that no oil or other contaminants are allowed to reach water courses or groundwater

Wastewater from sites Whenever possible the Contractor must minimize the amounts of wastewater that need to be discharged and find alternative means of disposal The Contractor will ensure that any seepage and wastewater arising from the works and camp sites must be collected and discharged via a settlement tank The standards for wastewater treatment prior to discharge must be agreed in advance with the ESA II Contaminated water or water of an uncertain quality must be discharged into sewers by tankers or other approved means of disposal bullDrainage Water drainage must be designed to avoid stagnant conditions that could create bad smell and unsanitary condition The Contractor must agree with the ESA in advance details of the methodology to be employed prior to commencement of the construction Particular attention must be given to regular pest control treatment (particularly rats and flies) removal of sludge and other debris after drainage bull reducing smell nuisance from sludge and algae by measures including deodorizing bull hosing down etc Safety measures must also be taken to protect both the general public bull

28 bullbull

--

---

---and employees and to prevent fly-tipping and illegal access during the development works

Water quality monitoring The Contractor must ensure continuous compliance with all the above conditions under the monitoring of the Subproject Owner andor field

- engineer including undertaking water quality monitoring at specific sites and are in compliance with government regulation related to wastewater management and water quality monitoring

-

(b) Dust noise vibration

4 The Contractor must take all the efforts to control dust noise and vibration levels from the site as far as is reasonably practicable Excessive noisevibration generation activities must be in accordance with GOV standards For critical areas the Contractor many be required to conduct noise measurement in close consultation with the local residents and establish appropriate measures to control and manage noise level Measures for reducing dust and other air pollution noise and vibration are provided as follows

Inform the residents Prior to commencement of work at any site the Contractor will -- be required to inform the local authority and residents regarding the construction plan and potential noise and vibration that may occur from the construction activities -

-

including measures to reduce noise and vibration

Dust control The Contractor will ensue that no burning of waste materials on site adequate water supply is available on site dry sweeping of large areas is not allowed Cover all trucks carrying loose or potentially dusty materials (soil mud etc) to and from construction site Water or sprinkle the construction areas periodically especially at site located near residential area avoid overloaded of trucks routinely - clean public roads and access routes Ensure vehicles working on site have exhausts - positioned such that the risk of re-suspension of ground dust is minimized (exhausts should preferably point upwards) where reasonably practicable Control driving speed -on un-surfaced haul routes and work areas Ensure bulk cement and other fine powder materials are delivered in enclosed tankers and stored in silos with suitable emission control systems to prevent escape of material and overfilling during delivery Mix large quantities of cement betonies grouts and other similar materials in designated areas Store materials with the potential to produce dust away from site boundaries where reasonably practicable Minimize the amount of excavated material held on site Sheet seal or damp down unavoidable stockpiles of excavated material held on site - where required Seal or re-vegetate completed earthworks practicable after completion

as soon as reasonably

-Care must be undertaken during the transportation of dredge spoil to and from the construction site the spoil must be covered at all time Fly-tipping will not be permitted Loads must only be deposited at designated sites The Contractor will be responsible for all the trucks delivering to or exiting from a worksite and will clean up all damage that may occur to public road and other public facilities Care should be taken when loading or unloading vehicles or dismantling scaffolding or moving

29

materials to reduce impact noise Loading or unloading bays may have to be housed in bull suitable acoustic enclosures

The installation of sheet piling with a diesel or air driven impact or drop hammer may not be acceptable on some of the sites Use of hydraulically operated or vibratory hammers may be necessary in these circumstances to drive and extract sheet piling

IIbull

provided the soil strata are suitable for such equipment Where practicable rotary drills and bursters actuated by hydraulic or electrical power should be used for

bullIIexcavating hard material Noisy plant or equipment will be sited as far away as is practicable from noise sensitive buildings The use of barriers (eg soil mounds) site huts acoustic sheds or partitions to deflect noise away from noise sensitive areas must be employed wherever practicable bullIi The Contractor will be obliged to comply with the vibration levels established by agreement with the ESA on a site by site basis given due attention to minimize human exposure (1 Hz to 80 Hz) and protection ofdamage to nearby structures

bullbull (c) Traffic and Transportation

5 The Contractor will be required to use designated construction traffic routes as directed by the local authorities and the Police The number of truck movements hours of bull operation and any truck holding areas will be agreed in advance with the local authority and the Police Plans will be required for each site showing the site entrancesexits and the agreed access roads for use to the nearest main road and the routes to be used by truck to and from the strategic road network C

The Contractor will maintain an up to date log of all drivers that will include a written undertaking from them to adhere to the local authorityS approved routes for I construction traffic In the case of non-compliance the Contractor andor their subshycontractor(s) would be in breach of contract necessitating disciplinary action against individual drivers

The Contractor may be required to provide truck stickers uniquely identifYing the group of construction sites included in each contract details of which shall be bullsubmitted to the local authority for approval For identification purposes the Ii Contractor will fix these in a prominent position on all trucks frequently serving the

tilconstruction site The identification will need to be sufficiently large to be easily read from a distance of 20 meters Trucks waiting to enter or leave the site must switch off their engines to avoid unnecessary engine noise and emissions Restrictions on the size and weight of vehicles accessing each site may be imposed depending on agreed access routes II

For construction that interference with a carriageway or footway the Contractor will inform the local authorities responsible agencies and local residents before commencing the works and proposed measures to minimize the safety risk and bull inconvenience to the public All necessary consents and licenses must be obtained in advance The safety of the public must be ensured In the case of temporary footways bullIIIreasonable access shall be provided for people in accordance with the following requirements (a) Any temporary footways and carriageways will be constructed to the bull

30 iii bull

-bull -

--

reasonable requirements of the local authorities and should have uniform surfaces as much as possible (b) Clear signing must be provided at all times for pedestrian routes with the minimum number of changes to all temporary layouts in order to reduce confusion Advance warning should if possible indicate alternative existing wheelchair-accessible routes (c) After completion of the works all materials arising from the works will be cleared from the highway leaving the same in a clean and tidy condition to the reasonable requirements of the local authorities and (d) The Contractor will be responsible for any damage caused by their activities to the roads and public facilities in the vicinity of the worksite Any defects caused by the - Contractors must be rectified immediately if dangerous or otherwise within 24 hours -

Any street furniture (electrical or non electrical) cannot be removed or relocated by the Contractor or any of its sub-contractors without written agreement from the responsible agencies

(d) Waste disposal re-use and recycling

6 The Contractor must make an effort to minimize wastes and properly stored and disposed of toxic wastes (such as used oil battery etc) and this should be clearly defined in - CSEP Opportunities for re-using or recycling construction and demolition waste should be explored and implemented Where contaminated wastes are found to be present handling and disposal procedures must be proposed by the Contractor and agreed by the Subproject Owner

- The Contractor will be required to comply with these procedures during site development - The contractor will not be permitted to transport contaminated materials on canals unless

appropriate handling facilities and infrastructure are agreed with the responsible agency

- (e) Excavation Materials

7 Earth excavation must be carefully handled to reduce dust and possible obstruction and causing nuisance and health impacts to local residents Excavation that affect public - roads (such as pipeline and bridges) must be properly planned in consultation with local authority and inform the residents in advance All dredged spoil as well as excavation -materials will be reused for dikeroad construction andor land filling at or nearby the work site Care must be undertaken to excavate transport andor disposal of acid sulfate soil andor contaminated soil

- (f) Demolition Materials

8 Demolition materials must be properly disposed off The Contractor must consult the

--supervision engineer on the final selection of disposal sites and methods If the works involve the removal of asbestos or the demolition of premises containing asbestos the Contractor shall comply with related government regulations

- (g) Protection ofnatural habitats

9 The Contractor must observe the national and local regulations and policies related to - protected areasspecies wildlife sanctuaries and conservation of natural sceneries for tourism a development and strictly control disturbance to these areas Where species are protected by

specific legislation the Contractor must follow the guidance to comply with those I -

31

bullbull

requirements and allow sufficient time for obtaining licenses or consents No trees in these areas shall be cut without obtaining prior agreement with the authorities

B3 Management ofWork Camp

10 The Contractor will consult with local authority regarding the location of the worker camps and will provide appropriate water supply garbage collection toilets mosquito net and other health protection measures to all workers Fishing wildlife hunting and other social disturbance to local societies are prohibited Training of workers on safety good hygiene and prohibitions activities is required

B4 Monitoring of Potential Impacts

11 The Contractor will be required to carry out monitoring program as follows

IMPACT PARAMETERS EXAMPLE LOCATIONS

FREQUENCY

Air emissions Dust level Vicinity of In windy clearing works conditions

Noise and Noise levels to meet In the vicinity of In response to vibration TCVNQCVN sensitive receivers complaints generation requirements

I

I IIbull

32 II

Table of Contents

Page EXECUTIVE SUMMARy 4

I INTRODUCTION 6 bullbullII SUBPROJECT DESCRIPTION 6 21 Scope of the Subproject 6 22 Description of Works 6

III ENVIRONMENTAL BACKGROUND 9 31 32

General Characteristics Soil and Water Quality

9 bull 1 0

IV POTENTIAL IMPACTS AND MITIGATION MEASURES 12 41 Summary of the Subproject Impacts 12 42 Safeguard Screening and Identification of Issues 12 43 Potential Negative Impacts and Proposed Mitigation Measures 13 V EMP- ACTIONS TO BE CARRIED OUT UNDER THE SUBPROJECT 15 51 Mitigation Measures during Construction 15 52 Mitigation Measures during Operation 15 53 Consultation and Information Disclosure 15 VI IMPLEMENTATION ARRANGEMENT 17 61 Organization and Responsibilities 17 62 Monitoring and Reporting 17 63 Work Plan Schedule and Budget 17

List of Tables Table 21 General information on the subproject 7 bullTable 31 Ground water quality in the subproejct area 11 II Table 41 Results ofsafeguard screening 13

IIIJI Table 51 Water quality monitoring for Nhon Ai Water Supply 16 Table 52 Estimated unit cost for water quality analysis 16

Table 42 Potential negative impacts and proposed mitigation measures 14

Table 61 Institutional responsibilities forNhon Ai Water Supply 18 Table 62 Tentative work plan forNhon Ai Water Supply 19

List ofFi~ures

Figure 21 Nhon Ai water supply system 8 Figure 22 Technical design of water treatment process

Figure 32 Land use in Can Tho municipality 1 0

8 Figure 31 Location of the subproject 9

Annex 1 Environmental Code ofPractice (ECOP) for Nhon Ai Water Supply 20 II

2 II

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- ABBREVIATIONS

BOD Demand







EMP

EMDP

EMPF

ESMF Framework

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(Annex 1)





3 Operation phase





bull bullbull bull

bull

bullIi

14

III

--

---

--- -
















15



Or Regulations









Monitoring

cost will be

part ofthe

normal

operating cost




begin operation








23212009nt1BTC dated 911212009 of

MOF


Total 975000

16

bull

bullbull

bull


-












-- 17




















bullIf


Ibull 18




Remarks




By end July 2011






-






--



During construction

During construction





Iconsultant planned

shy

-19

bull bull

III


Table of Contents






bull bull ~

r III

bullbull

I bull

I

titshy20

bullW

~

-----

------







-





-21

(b) Contractor





22 bull

-







-- 23










bull24 II
















25

bull bull


A7 Prohibitions II







IIII26

--

-

-

--------








-27

bull bull

bull bull

II1II







28 bullbull

--

---




-




-





29



IIbull









30 iii bull

-bull -

--















31

bullbull







FREQUENCY



I

I IIbull

32 II

- ---

-




-- - - - -bull -shy

shy---- -

5

iIII

I INTRODUCTION






March 2011

6

-

---------

--




Land Area (m2)




40 36S7 20116






43 m in length






pump










--7

bull

bullII

I II


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II III

II

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lit 10 II

bull








1 pH 6-85 TCVN 6194 - 1996 68

2 Color TCU 15 TCVN 6185 -1996 0


Non founded




7 NH4 mgI 3 TCVN 5998 bull 1995 0

8 As mgI 001 TCVN 6626 - 2000 0



II Fe mgll 05 TCVN 6177-1996 005




0


0

---




94 meter)

1 pH 6-85 TCVN 6194middot1996 67



Non founded

-11




I 7 NH4 mgI 3 TCVN 5998 - 1995 0

I 8 As mgI 001 TCVN 6626 - 2000 0

9 Florua mgI 15 TCVN 6195 - 1996 0







bull

bull







12

--








in






13


Key Activities









(Annex 1)





3 Operation phase





bull bullbull bull

bull

bullIi

14

III

--

---

--- -
















15



Or Regulations









Monitoring

cost will be

part ofthe

normal

operating cost




begin operation








23212009nt1BTC dated 911212009 of

MOF


Total 975000

16

bull

bullbull

bull


-












-- 17




















bullIf


Ibull 18




Remarks




By end July 2011






-






--



During construction

During construction





Iconsultant planned

shy

-19

bull bull

III


Table of Contents






bull bull ~

r III

bullbull

I bull

I

titshy20

bullW

~

-----

------







-





-21

(b) Contractor





22 bull

-







-- 23










bull24 II
















25

bull bull


A7 Prohibitions II







IIII26

--

-

-

--------








-27

bull bull

bull bull

II1II







28 bullbull

--

---




-




-





29



IIbull









30 iii bull

-bull -

--















31

bullbull







FREQUENCY



I

I IIbull

32 II

I INTRODUCTION






March 2011

6

-

---------

--




Land Area (m2)




40 36S7 20116






43 m in length






pump










--7

bull

bullII

I II


I Chlprine



Pressure I I Clean

Filter tank I


sand)



I Water support


8 Ii







t

---- - - -

81

I


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-

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bull bull



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kl~N GIANG

bull

II III

II

Rice Farming


Residential Area



lit 10 II

bull








1 pH 6-85 TCVN 6194 - 1996 68

2 Color TCU 15 TCVN 6185 -1996 0


Non founded




7 NH4 mgI 3 TCVN 5998 bull 1995 0

8 As mgI 001 TCVN 6626 - 2000 0



II Fe mgll 05 TCVN 6177-1996 005




0


0

---




94 meter)

1 pH 6-85 TCVN 6194middot1996 67



Non founded

-11




I 7 NH4 mgI 3 TCVN 5998 - 1995 0

I 8 As mgI 001 TCVN 6626 - 2000 0

9 Florua mgI 15 TCVN 6195 - 1996 0







bull

bull







12

--








in






13


Key Activities









(Annex 1)





3 Operation phase





bull bullbull bull

bull

bullIi

14

III

--

---

--- -
















15



Or Regulations









Monitoring

cost will be

part ofthe

normal

operating cost




begin operation








23212009nt1BTC dated 911212009 of

MOF


Total 975000

16

bull

bullbull

bull


-












-- 17




















bullIf


Ibull 18




Remarks




By end July 2011






-






--



During construction

During construction





Iconsultant planned

shy

-19

bull bull

III


Table of Contents






bull bull ~

r III

bullbull

I bull

I

titshy20

bullW

~

-----

------







-





-21

(b) Contractor





22 bull

-







-- 23










bull24 II
















25

bull bull


A7 Prohibitions II







IIII26

--

-

-

--------








-27

bull bull

bull bull

II1II







28 bullbull

--

---




-




-





29



IIbull









30 iii bull

-bull -

--















31

bullbull







FREQUENCY



I

I IIbull

32 II

-

---------

--




Land Area (m2)




40 36S7 20116






43 m in length






pump










--7

bull

bullII

I II


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Pressure I I Clean

Filter tank I


sand)



I Water support


8 Ii







t

---- - - -

81

I


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-

bull bull

bull bull



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~W_- - - ~w_ -

90NG THAP

kl~N GIANG

bull

II III

II

Rice Farming


Residential Area



lit 10 II

bull








1 pH 6-85 TCVN 6194 - 1996 68

2 Color TCU 15 TCVN 6185 -1996 0


Non founded




7 NH4 mgI 3 TCVN 5998 bull 1995 0

8 As mgI 001 TCVN 6626 - 2000 0



II Fe mgll 05 TCVN 6177-1996 005




0


0

---




94 meter)

1 pH 6-85 TCVN 6194middot1996 67



Non founded

-11




I 7 NH4 mgI 3 TCVN 5998 - 1995 0

I 8 As mgI 001 TCVN 6626 - 2000 0

9 Florua mgI 15 TCVN 6195 - 1996 0







bull

bull







12

--








in






13


Key Activities









(Annex 1)





3 Operation phase





bull bullbull bull

bull

bullIi

14

III

--

---

--- -
















15



Or Regulations









Monitoring

cost will be

part ofthe

normal

operating cost




begin operation








23212009nt1BTC dated 911212009 of

MOF


Total 975000

16

bull

bullbull

bull


-












-- 17




















bullIf


Ibull 18




Remarks




By end July 2011






-






--



During construction

During construction





Iconsultant planned

shy

-19

bull bull

III


Table of Contents






bull bull ~

r III

bullbull

I bull

I

titshy20

bullW

~

-----

------







-





-21

(b) Contractor





22 bull

-







-- 23










bull24 II
















25

bull bull


A7 Prohibitions II







IIII26

--

-

-

--------








-27

bull bull

bull bull

II1II







28 bullbull

--

---




-




-





29



IIbull









30 iii bull

-bull -

--















31

bullbull







FREQUENCY



I

I IIbull

32 II

bull

bullII

I II


I Chlprine



Pressure I I Clean

Filter tank I


sand)



I Water support


8 Ii







t

---- - - -

81

I


System



-

bull bull

bull bull



-~mWMi)IlIirM-



MoIaIoi~ ~

---_ IW-ctlgt-

~W_- - - ~w_ -

90NG THAP

kl~N GIANG

bull

II III

II

Rice Farming


Residential Area



lit 10 II

bull








1 pH 6-85 TCVN 6194 - 1996 68

2 Color TCU 15 TCVN 6185 -1996 0


Non founded




7 NH4 mgI 3 TCVN 5998 bull 1995 0

8 As mgI 001 TCVN 6626 - 2000 0



II Fe mgll 05 TCVN 6177-1996 005




0


0

---




94 meter)

1 pH 6-85 TCVN 6194middot1996 67



Non founded

-11




I 7 NH4 mgI 3 TCVN 5998 - 1995 0

I 8 As mgI 001 TCVN 6626 - 2000 0

9 Florua mgI 15 TCVN 6195 - 1996 0







bull

bull







12

--








in






13


Key Activities









(Annex 1)





3 Operation phase





bull bullbull bull

bull

bullIi

14

III

--

---

--- -
















15



Or Regulations









Monitoring

cost will be

part ofthe

normal

operating cost




begin operation








23212009nt1BTC dated 911212009 of

MOF


Total 975000

16

bull

bullbull

bull


-












-- 17




















bullIf


Ibull 18




Remarks




By end July 2011






-






--



During construction

During construction





Iconsultant planned

shy

-19

bull bull

III


Table of Contents






bull bull ~

r III

bullbull

I bull

I

titshy20

bullW

~

-----

------







-





-21

(b) Contractor





22 bull

-







-- 23










bull24 II
















25

bull bull


A7 Prohibitions II







IIII26

--

-

-

--------








-27

bull bull

bull bull

II1II







28 bullbull

--

---




-




-





29



IIbull









30 iii bull

-bull -

--















31

bullbull







FREQUENCY



I

I IIbull

32 II







t

---- - - -

81

I


System



-

bull bull

bull bull



-~mWMi)IlIirM-



MoIaIoi~ ~

---_ IW-ctlgt-

~W_- - - ~w_ -

90NG THAP

kl~N GIANG

bull

II III

II

Rice Farming


Residential Area



lit 10 II

bull








1 pH 6-85 TCVN 6194 - 1996 68

2 Color TCU 15 TCVN 6185 -1996 0


Non founded




7 NH4 mgI 3 TCVN 5998 bull 1995 0

8 As mgI 001 TCVN 6626 - 2000 0



II Fe mgll 05 TCVN 6177-1996 005




0


0

---




94 meter)

1 pH 6-85 TCVN 6194middot1996 67



Non founded

-11




I 7 NH4 mgI 3 TCVN 5998 - 1995 0

I 8 As mgI 001 TCVN 6626 - 2000 0

9 Florua mgI 15 TCVN 6195 - 1996 0







bull

bull







12

--








in






13


Key Activities









(Annex 1)





3 Operation phase





bull bullbull bull

bull

bullIi

14

III

--

---

--- -
















15



Or Regulations









Monitoring

cost will be

part ofthe

normal

operating cost




begin operation








23212009nt1BTC dated 911212009 of

MOF


Total 975000

16

bull

bullbull

bull


-












-- 17




















bullIf


Ibull 18




Remarks




By end July 2011






-






--



During construction

During construction





Iconsultant planned

shy

-19

bull bull

III


Table of Contents






bull bull ~

r III

bullbull

I bull

I

titshy20

bullW

~

-----

------







-





-21

(b) Contractor





22 bull

-







-- 23










bull24 II
















25

bull bull


A7 Prohibitions II







IIII26

--

-

-

--------








-27

bull bull

bull bull

II1II







28 bullbull

--

---




-




-





29



IIbull









30 iii bull

-bull -

--















31

bullbull







FREQUENCY



I

I IIbull

32 II

bull bull

bull bull



-~mWMi)IlIirM-



MoIaIoi~ ~

---_ IW-ctlgt-

~W_- - - ~w_ -

90NG THAP

kl~N GIANG

bull

II III

II

Rice Farming


Residential Area



lit 10 II

bull








1 pH 6-85 TCVN 6194 - 1996 68

2 Color TCU 15 TCVN 6185 -1996 0


Non founded




7 NH4 mgI 3 TCVN 5998 bull 1995 0

8 As mgI 001 TCVN 6626 - 2000 0



II Fe mgll 05 TCVN 6177-1996 005




0


0

---




94 meter)

1 pH 6-85 TCVN 6194middot1996 67



Non founded

-11




I 7 NH4 mgI 3 TCVN 5998 - 1995 0

I 8 As mgI 001 TCVN 6626 - 2000 0

9 Florua mgI 15 TCVN 6195 - 1996 0







bull

bull







12

--








in






13


Key Activities









(Annex 1)





3 Operation phase





bull bullbull bull

bull

bullIi

14

III

--

---

--- -
















15



Or Regulations









Monitoring

cost will be

part ofthe

normal

operating cost




begin operation








23212009nt1BTC dated 911212009 of

MOF


Total 975000

16

bull

bullbull

bull


-












-- 17




















bullIf


Ibull 18




Remarks




By end July 2011






-






--



During construction

During construction





Iconsultant planned

shy

-19

bull bull

III


Table of Contents






bull bull ~

r III

bullbull

I bull

I

titshy20

bullW

~

-----

------







-





-21

(b) Contractor





22 bull

-







-- 23










bull24 II
















25

bull bull


A7 Prohibitions II







IIII26

--

-

-

--------








-27

bull bull

bull bull

II1II







28 bullbull

--

---




-




-





29



IIbull









30 iii bull

-bull -

--















31

bullbull







FREQUENCY



I

I IIbull

32 II








1 pH 6-85 TCVN 6194 - 1996 68

2 Color TCU 15 TCVN 6185 -1996 0


Non founded




7 NH4 mgI 3 TCVN 5998 bull 1995 0

8 As mgI 001 TCVN 6626 - 2000 0



II Fe mgll 05 TCVN 6177-1996 005




0


0

---




94 meter)

1 pH 6-85 TCVN 6194middot1996 67



Non founded

-11




I 7 NH4 mgI 3 TCVN 5998 - 1995 0

I 8 As mgI 001 TCVN 6626 - 2000 0

9 Florua mgI 15 TCVN 6195 - 1996 0







bull

bull







12

--








in






13


Key Activities









(Annex 1)





3 Operation phase





bull bullbull bull

bull

bullIi

14

III

--

---

--- -
















15



Or Regulations









Monitoring

cost will be

part ofthe

normal

operating cost




begin operation








23212009nt1BTC dated 911212009 of

MOF


Total 975000

16

bull

bullbull

bull


-












-- 17




















bullIf


Ibull 18




Remarks




By end July 2011






-






--



During construction

During construction





Iconsultant planned

shy

-19

bull bull

III


Table of Contents






bull bull ~

r III

bullbull

I bull

I

titshy20

bullW

~

-----

------







-





-21

(b) Contractor





22 bull

-







-- 23










bull24 II
















25

bull bull


A7 Prohibitions II







IIII26

--

-

-

--------








-27

bull bull

bull bull

II1II







28 bullbull

--

---




-




-





29



IIbull









30 iii bull

-bull -

--















31

bullbull







FREQUENCY



I

I IIbull

32 II




I 7 NH4 mgI 3 TCVN 5998 - 1995 0

I 8 As mgI 001 TCVN 6626 - 2000 0

9 Florua mgI 15 TCVN 6195 - 1996 0







bull

bull







12

--








in






13


Key Activities









(Annex 1)





3 Operation phase





bull bullbull bull

bull

bullIi

14

III

--

---

--- -
















15



Or Regulations









Monitoring

cost will be

part ofthe

normal

operating cost




begin operation








23212009nt1BTC dated 911212009 of

MOF


Total 975000

16

bull

bullbull

bull


-












-- 17




















bullIf


Ibull 18




Remarks




By end July 2011






-






--



During construction

During construction





Iconsultant planned

shy

-19

bull bull

III


Table of Contents






bull bull ~

r III

bullbull

I bull

I

titshy20

bullW

~

-----

------







-





-21

(b) Contractor





22 bull

-







-- 23










bull24 II
















25

bull bull


A7 Prohibitions II







IIII26

--

-

-

--------








-27

bull bull

bull bull

II1II







28 bullbull

--

---




-




-





29



IIbull









30 iii bull

-bull -

--















31

bullbull







FREQUENCY



I

I IIbull

32 II

--








in






13


Key Activities









(Annex 1)





3 Operation phase





bull bullbull bull

bull

bullIi

14

III

--

---

--- -
















15



Or Regulations









Monitoring

cost will be

part ofthe

normal

operating cost




begin operation








23212009nt1BTC dated 911212009 of

MOF


Total 975000

16

bull

bullbull

bull


-












-- 17




















bullIf


Ibull 18




Remarks




By end July 2011






-






--



During construction

During construction





Iconsultant planned

shy

-19

bull bull

III


Table of Contents






bull bull ~

r III

bullbull

I bull

I

titshy20

bullW

~

-----

------







-





-21

(b) Contractor





22 bull

-







-- 23










bull24 II
















25

bull bull


A7 Prohibitions II







IIII26

--

-

-

--------








-27

bull bull

bull bull

II1II







28 bullbull

--

---




-




-





29



IIbull









30 iii bull

-bull -

--















31

bullbull







FREQUENCY



I

I IIbull

32 II


Key Activities









(Annex 1)





3 Operation phase





bull bullbull bull

bull

bullIi

14

III

--

---

--- -
















15



Or Regulations









Monitoring

cost will be

part ofthe

normal

operating cost




begin operation








23212009nt1BTC dated 911212009 of

MOF


Total 975000

16

bull

bullbull

bull


-












-- 17




















bullIf


Ibull 18




Remarks




By end July 2011






-






--



During construction

During construction





Iconsultant planned

shy

-19

bull bull

III


Table of Contents






bull bull ~

r III

bullbull

I bull

I

titshy20

bullW

~

-----

------







-





-21

(b) Contractor





22 bull

-







-- 23










bull24 II
















25

bull bull


A7 Prohibitions II







IIII26

--

-

-

--------








-27

bull bull

bull bull

II1II







28 bullbull

--

---




-




-





29



IIbull









30 iii bull

-bull -

--















31

bullbull







FREQUENCY



I

I IIbull

32 II

--

---

--- -
















15



Or Regulations









Monitoring

cost will be

part ofthe

normal

operating cost




begin operation








23212009nt1BTC dated 911212009 of

MOF


Total 975000

16

bull

bullbull

bull


-












-- 17




















bullIf


Ibull 18




Remarks




By end July 2011






-






--



During construction

During construction





Iconsultant planned

shy

-19

bull bull

III


Table of Contents






bull bull ~

r III

bullbull

I bull

I

titshy20

bullW

~

-----

------







-





-21

(b) Contractor





22 bull

-







-- 23










bull24 II
















25

bull bull


A7 Prohibitions II







IIII26

--

-

-

--------








-27

bull bull

bull bull

II1II







28 bullbull

--

---




-




-





29



IIbull









30 iii bull

-bull -

--















31

bullbull







FREQUENCY



I

I IIbull

32 II



Or Regulations









Monitoring

cost will be

part ofthe

normal

operating cost




begin operation








23212009nt1BTC dated 911212009 of

MOF


Total 975000

16

bull

bullbull

bull


-












-- 17




















bullIf


Ibull 18




Remarks




By end July 2011






-






--



During construction

During construction





Iconsultant planned

shy

-19

bull bull

III


Table of Contents






bull bull ~

r III

bullbull

I bull

I

titshy20

bullW

~

-----

------







-





-21

(b) Contractor





22 bull

-







-- 23










bull24 II
















25

bull bull


A7 Prohibitions II







IIII26

--

-

-

--------








-27

bull bull

bull bull

II1II







28 bullbull

--

---




-




-





29



IIbull









30 iii bull

-bull -

--















31

bullbull







FREQUENCY



I

I IIbull

32 II

-












-- 17




















bullIf


Ibull 18




Remarks




By end July 2011






-






--



During construction

During construction





Iconsultant planned

shy

-19

bull bull

III


Table of Contents






bull bull ~

r III

bullbull

I bull

I

titshy20

bullW

~

-----

------







-





-21

(b) Contractor





22 bull

-







-- 23










bull24 II
















25

bull bull


A7 Prohibitions II







IIII26

--

-

-

--------








-27

bull bull

bull bull

II1II







28 bullbull

--

---




-




-





29



IIbull









30 iii bull

-bull -

--















31

bullbull







FREQUENCY



I

I IIbull

32 II




















bullIf


Ibull 18




Remarks




By end July 2011






-






--



During construction

During construction





Iconsultant planned

shy

-19

bull bull

III


Table of Contents






bull bull ~

r III

bullbull

I bull

I

titshy20

bullW

~

-----

------







-





-21

(b) Contractor





22 bull

-







-- 23










bull24 II
















25

bull bull


A7 Prohibitions II







IIII26

--

-

-

--------








-27

bull bull

bull bull

II1II







28 bullbull

--

---




-




-





29



IIbull









30 iii bull

-bull -

--















31

bullbull







FREQUENCY



I

I IIbull

32 II




Remarks




By end July 2011






-






--



During construction

During construction





Iconsultant planned

shy

-19

bull bull

III


Table of Contents






bull bull ~

r III

bullbull

I bull

I

titshy20

bullW

~

-----

------







-





-21

(b) Contractor





22 bull

-







-- 23










bull24 II
















25

bull bull


A7 Prohibitions II







IIII26

--

-

-

--------








-27

bull bull

bull bull

II1II







28 bullbull

--

---




-




-





29



IIbull









30 iii bull

-bull -

--















31

bullbull







FREQUENCY



I

I IIbull

32 II

bull bull

III


Table of Contents






bull bull ~

r III

bullbull

I bull

I

titshy20

bullW

~

-----

------







-





-21

(b) Contractor





22 bull

-







-- 23










bull24 II
















25

bull bull


A7 Prohibitions II







IIII26

--

-

-

--------








-27

bull bull

bull bull

II1II







28 bullbull

--

---




-




-





29



IIbull









30 iii bull

-bull -

--















31

bullbull







FREQUENCY



I

I IIbull

32 II

-----

------







-





-21

(b) Contractor





22 bull

-







-- 23










bull24 II
















25

bull bull


A7 Prohibitions II







IIII26

--

-

-

--------








-27

bull bull

bull bull

II1II







28 bullbull

--

---




-




-





29



IIbull









30 iii bull

-bull -

--















31

bullbull







FREQUENCY



I

I IIbull

32 II

(b) Contractor





22 bull

-







-- 23










bull24 II
















25

bull bull


A7 Prohibitions II







IIII26

--

-

-

--------








-27

bull bull

bull bull

II1II







28 bullbull

--

---




-




-





29



IIbull









30 iii bull

-bull -

--















31

bullbull







FREQUENCY



I

I IIbull

32 II

-







-- 23










bull24 II
















25

bull bull


A7 Prohibitions II







IIII26

--

-

-

--------








-27

bull bull

bull bull

II1II







28 bullbull

--

---




-




-





29



IIbull









30 iii bull

-bull -

--















31

bullbull







FREQUENCY



I

I IIbull

32 II










bull24 II
















25

bull bull


A7 Prohibitions II







IIII26

--

-

-

--------








-27

bull bull

bull bull

II1II







28 bullbull

--

---




-




-





29



IIbull









30 iii bull

-bull -

--















31

bullbull







FREQUENCY



I

I IIbull

32 II
















25

bull bull


A7 Prohibitions II







IIII26

--

-

-

--------








-27

bull bull

bull bull

II1II







28 bullbull

--

---




-




-





29



IIbull









30 iii bull

-bull -

--















31

bullbull







FREQUENCY



I

I IIbull

32 II

bull bull


A7 Prohibitions II







IIII26

--

-

-

--------








-27

bull bull

bull bull

II1II







28 bullbull

--

---




-




-





29



IIbull









30 iii bull

-bull -

--















31

bullbull







FREQUENCY



I

I IIbull

32 II

--

-

-

--------








-27

bull bull

bull bull

II1II







28 bullbull

--

---




-




-





29



IIbull









30 iii bull

-bull -

--















31

bullbull







FREQUENCY



I

I IIbull

32 II

bull bull

bull bull

II1II







28 bullbull

--

---




-




-





29



IIbull









30 iii bull

-bull -

--















31

bullbull







FREQUENCY



I

I IIbull

32 II

--

---




-




-





29



IIbull









30 iii bull

-bull -

--















31

bullbull







FREQUENCY



I

I IIbull

32 II



IIbull









30 iii bull

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--















31

bullbull







FREQUENCY



I

I IIbull

32 II

-bull -

--















31

bullbull







FREQUENCY



I

I IIbull

32 II

bullbull







FREQUENCY



I

I IIbull

32 II

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