Environment Management Monthly Monitoring Report of January 2015
Transcription
Environment Management Monthly Monitoring Report of January 2015
\ NAM NGIEP 1 HYDROPOWER PROJECT: ROAD CONSTRUCTION MONITORING MONTHLY MONITORING REPORT January 2015 Final Prepared for Nam NGIEP 1 Power Company By EARTH SYSTEMS Environment | Water | Sustainability Nam Ngiep 1 Hydropower Project Road Monitoring Monthly Report, January 2015 Contents Acronyms ....................................................................................................................... ii 1 2 INTRODUCTION .................................................................................................... 1 1.1 Project Overview..................................................................................................................... 1 1.2 Construction Status ............................................................................................................... 1 MONITORING RESULTS ....................................................................................... 5 2.1 Construction Monitoring ........................................................................................................ 5 2.1.1 SS-ESMMP Review ............................................................................................................................. 5 2.1.2 Weekly Inspections .............................................................................................................................. 5 2.2 Independent Monitoring Missions ........................................................................................ 9 2.3 Community Grievance Monitoring ........................................................................................ 9 2.3.1 Community consultation ..................................................................................................................... 9 2.3.2 Grievances .............................................................................................................................................. 9 2.4 Water Quality......................................................................................................................... 10 2.4.1 Water Quality Monitoring Sites ....................................................................................................... 10 2.4.2 Effluent Discharge Monitoring ......................................................................................................... 11 2.5 3 Accident or Incidents ........................................................................................................... 15 Non-compliance reporting ................................................................................. 16 3.1 Introduction ........................................................................................................................... 16 3.2 Summary of Non-Compliance Levels ................................................................................. 16 3.3 Status of Non-Compliance Issues ...................................................................................... 16 4 Capacity Building Activities ............................................................................... 18 5 February 2015 Activities..................................................................................... 19 6 CONCLUSIONS & RECOMMENDATIONS ......................................................... 20 6.1 Recommendations ............................................................................................................... 21 APPENDICES ............................................................................................................... 22 Appendix A: Document Register ................................................................................................... 23 Appendix B: Issues and Compliance Register ............................................................................ 24 NNHP1146_Monthly Report in January 2015_Eng version_GoL CONFIDENTIAL i EARTH SYSTEMS Nam Ngiep 1 Hydropower Project Road Monitoring Monthly Report, January 2015 Environment | Water | Sustainability Acronyms Acronyms Definition ADB Asian Development Bank BOD Biological Oxygen Demand CA Concession Agreement COD Chemical Oxygen Demand DB01 Monitoring Database dB(A) A-weighted decibels DO Dissolved Oxygen EC Electrical Conductivity EMO Environmental Management Office ES Earth Systems ESD Environment and Social Division ESMMP-CP Environmental and Social Monitoring and Management Plan for access road construction and other preliminary works FM01 Weekly Site Inspection Form GRM Grievance Redress Mechanism IAP Independent Advisory Panel Lamsay Lamsay Construction Company MVDC Meuang Vang Development Company NN1PC Nam Ngiep 1 Power Company NN1 Nam Ngiep – Dam Site (upstream) NN2 Nam Ngiep –upstream of N. Xao NN3 Nam Ngiep – downstream of N. Xao OC Obayashi Contractor ORP Oxidation Reduction Potential pH potential of Hydrogen PKC Phoukhong Construction Sole Company NTP Notice to Proceed SECC State Enterprise of Communication Construction SMO Social Management Office NNHP1146_Monthly Report in January 2015_Eng version_GoL CONFIDENTIAL ii EARTH SYSTEMS Environment | Water | Sustainability Nam Ngiep 1 Hydropower Project Road Monitoring Monthly Report, January 2015 Acronyms Definition SOP Standard Operating Procedure SS-ESMMP Site Specific Environmental and Social Management and Monitoring Plan TCM TCM Engineering Company TD Technical Department TSS Total Suspended Solid WQ Water Quality X1 Nam Xao – upstream X2 Nam Xao – downstream NNHP1146_Monthly Report in January 2015_Eng version_GoL CONFIDENTIAL iii EARTH SYSTEMS Environment | Water | Sustainability Nam Ngiep 1 Hydropower Project Road Monitoring Monthly Report, January 2015 1 INTRODUCTION This report provides information on the implementation of environmental and social management and monitoring measures of road construction works (not including land acquisition and compensation) for the Nam Ngiep Hydropower Project between 1st and 31st January, 2015. The report has been prepared by Earth Systems (ES), an environmental and social consulting firm, for the Nam Ngiep 1 Power Company (NNP1PC) and is intended to provide a basis for the Company’s monthly environmental and social progress reporting requirements to the Government of Lao PDR. 1.1 Project Overview Nam Ngiep 1 Power Company Limited has received a concession agreement (CA) from the Government of the Lao PDR to build and operate the “Nam Ngiep 1 Hydropower Project” in Central Lao PDR. Early works for the Project include the construction of the main Project access road, from Ban Nonsomboun to the entrance of the main dam via Ban Hat Gniun Village (29 km) including: upgrade of an existing road from Ban Nonsomboun to Ban Hatsaykham, (21.2 km + 3.9 km); and construction of a new access road from Ban Hatsaykham to the entrance of the main dam (3.9 km). Other roads include an access road to the powerhouse (permanent); a number of new temporary access roads and the temporary use and rehabilitation of a JICA funded access road. These works are being completed by the Contractor of CWC – Obayashi Corporation. NNP1PC, through its Environment and Social Division (ESD NNP1PC) consisting of an Environmental Management Office (EMO) and Social Management Office (SMO), is required to conduct environmental and social (E&S) monitoring of early works, including road construction and the development of ancillary infrastructure (e.g. workforce accommodation, vehicle laydown areas, etc.). Earth Systems was contracted by NN1PC in January 2014 to support the development and implementation of the E&S road monitoring program until February 2015 and was engaged to join the EMO to assist with weekly monitoring methodology, monthly monitoring and reporting, and capacity building for the EMO. 1.2 Construction Status Table 1-1 provides information on the current status of Project road construction and other ancillary infrastructure as of 31st January 2015. 12 sites are currently under construction; 12 sites have been completed, eleven of which are under operations; Two (2) sites have yet to commence work; Three (3) sites are currently on-hold; Two (2) disposal areas have been developed for other use purposes; Four (4) borrow sites / quarries are not currently being used but may be recommissioned; One (1) site is being decommissioned; and Four (6) sites have been decommissioned. The overall temporary and permanent road construction layout map is provided in Figure 1-1. NNHP1146_Monthly Report in January 2015_Eng version_GoL CONFIDENTIAL 1 EARTH SYSTEMS Nam Ngiep 1 Hydropower Project Road Monitoring Monthly Report, January 2015 Environment | Water | Sustainability Table 1-1 Status of Project Construction – updated January 2015 # 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 20 21 22 23 25 24 26 Site ID JR A1 P1 P2 T1 T2 T3 T4 T5 T6 T7 T8 T9 T10 T11 T12 T13 PKC MVDC MVDC TCM TCM Crusher SECC Lamsay Camp Temp Bridge Expected Decommissio n / Rehab Date Expected Construction Commence Date Expected Construction Completion Date Construction Status 12/2013 01/2014 Completed N/A Road Road P1 Road P2 Road T1 Road T2 Road T3 Road T4 Road T5 Road T6 Road T7 Road T8 Road T9 Road T10 Road T11 Road T12 Road T13 PKC Workers Camp MVDC Temp Camp MVDC New Camp TCM Workers Camp TCM Mobile Crusher SECC Temporary Workers Camp 01/2014 01/2014 01/2014 09/2013 12/2013 07/2014 01/2014 01/2014 03/2014 04/2014 05/2014 05/2014 12/2014 12/2014 12/2013 03/2014 12/2013 01/2014 07/2014 03/2014 04/2014 03/2014 07/2014 02/2014 02/2014 02/2014 06/2014 12/2014 10/2014 01/2014 04/2014 12/2014 12/2014 12/2015 Unknown Unknown 04/2014 08/2014 Unknown 01/2014 Unknown Unknown Unknown - Under construction Under construction Under construction Completed Completed Not yet commence Under construction, T4B Completed Not yet commence Under construction Under construction Under construction Under construction Under construction Decommissioned Completed Under operations Decommissioned Preparing for decommisioning Operating Decommisioned Decommissioned Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown 07/2014 Unknown 2016* 07/2014 2016* 2018 Unknown 08/2014 15-Jan-14 30-Dec-13 20-Feb-14 3-Feb-14 3-Feb-14 Not yet approved 20-Feb-14 20-Feb-14 Not yet approved 27-May-14 12-May-14 21-Apr-14 Not yet approved Not yet approved Not yet approved 20-Feb-14 3-Feb-14 3-Feb-14 Not yet approved 3-Feb-14 Not yet approved Not yet approved Lamsay Temporary Workers Camp 03/2014 Unknown Decommissioned 12/2014 Not yet approved Temporary Bridge 03/2014 Unknown Completed Unknown 27-Feb-14 Site Name JICA Road A% NNHP1146_Monthly Report in January 2015_Eng version_GoL CONFIDENTIAL 2 SS-ESSMP NTP_01 EARTH SYSTEMS Nam Ngiep 1 Hydropower Project Road Monitoring Monthly Report, January 2015 Environment | Water | Sustainability # % Site ID Site Name Expected Construction Commence Date Expected Construction Completion Date 27 28 29 30 31 32 33 34 35 36 37 Temp Stock OC Camp NNP1 Camp D1 D2 D3 D4 D5 D6 D7 D8 Temporary Stockyard Obayashi Contractor Camp Owner base camp Disposal Area 1 Disposal Area 2 Disposal Area 3 Disposal Area 4 Disposal Area 5 Disposal Area 6 (Right bank) Disposal Area 7 (Right bank) Disposal Area 8 03/2014 09/2014 09/2014 03/2014 07/2014 07/2014 04/2014 04/2014 04/2014 04/2014 02/2014 11/201 Unknown Unknown 12/2014 12/2015 12/2014 12/2014 12/2014 01/2019 11/2014 09/2014 38 B1 Borrow Pit 1 (Road P1, Km 21+400) N/A N/A 39 B2 Borrow Pit 2 (Road P1, Km 22+300) N/A N/A 40 B3 Borrow Pit 3 (Regulation Dam) 02/2014 04/2014 41 42 43 Q1 Q2 Q3 Quarry 1 (Road A, Km 9+400) Quarry 2 (Road A, Km 15+900) Quarry 3 (Road A, Km 16+000) 02/2014 Unknown Unknown 12/2014 Unknown Unknown Construction Status Decommissioned Under construction Building works started in Dec Developped for other purpose of use Under operations Under operations On - hold On - hold Under operations Under operations Developped for Sinno hydro camp Not in use and might not be used in the future Not in use and might not be used in the future No longer in use, but to be constructed as part of the regulating dam On-hold Will not operate Topsoil removal The PPA section of road A1 is being constructed and is expected to finish in 01/2015. * Subject to extension NNHP1146_Monthly Report in January 2015_Eng version_GoL CONFIDENTIAL 3 Expected Decommissio n / Rehab Date Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown 27-Feb-14 27-Mar-14 8-May-14 Not yet approved Not yet approved Not yet approved Not yet approved Not yet approved Not yet approved Not yet approved 17-Mar-14 N/A N/A N/A N/A N/A Not yet approved Unknown Unknown Unknown Not yet approved Not yet approved Not yet approved SS-ESSMP NTP_01 EARTH SYSTEMS Nam Ngiep 1 Hydropower Project Road Monitoring Monthly Report, January 2015 Environment | Water | Sustainability Figure 1-1 Layout of Temporary and Permanent Roads and Project Sites NNHP1146_Monthly Report in January 2015_Eng version_GoL CONFIDENTIAL 4 EARTH SYSTEMS Nam Ngiep 1 Hydropower Project Road Monitoring Monthly Report, January 2015 Environment | Water | Sustainability 2 MONITORING RESULTS 2.1 Construction Monitoring 2.1.1 SS-ESMMP Review The EMO NN1PC did not receive any SS-ESMMP’s for road construction / ancillary facilities from the Contractor of CWC for review during the reporting period. 2.1.2 Weekly Inspections Two bi-weeking joint site inspection exercises were conducted on 6th and 20th January 2015 by the EMO, TD site inspection teams, and Obayashi. An additional site inspection was carried out by EMO and Earth Systems on 27th January to focus specifically on access roads and other relevant facilities. Monitoring sites are summarised in Table 2-1. Table 2-1 Weekly Inspections, January 2015 Monitoring Dates Sites 6th January 2015 MVDC camp, PKC camp, and TCM camp. 20th January 2015 MVDC camp, PKC camp and Spoil Disposal No 2. 27th January 2015 MVDC camp, PKC camp, TCM camp, Ramsay camp, MVDC stockyard and parking area, Road A1, P1, T4, T5, T9, T10, Spoil disposal No. 2, 4 and 7, The January 2015 status of key issues identified during previous reporting period (December 2014) is summarized in Table 2-2. Key new issues identified during EMO / ES inspections on 27th January 2015 are outlined in Table 2-3. Further information is provided in Appendix B: Issues and Compliance Register. Table 2-2 Summary of January status regarding issues identified in December 2014 Site Description of issues Comments / recommendation Status in January 2015 PKC Camp Lack of camp sanitary facilities maintenance, resulted in grey water being direct discharged: Refer to SSESMMP for worker camp; Clause 4.3: Water availability and pollution control, and Clause 5.1: Contractor environmental compliance monitoring; SP02: Water availability and pollution control. Re-connect the drainage system and maintain seepage system to ensure it functions effectively. This issue has been resolved. Discharge drainage pipes have been repaired and grey water from kitchen retained in close sediment pond. Refer to SSEMMP for workers camp; Clause 4.9: Solid waste management and Clause 4.10: Hazardous material management Remove the hazardous waste to designated hazardous storage area accordingly for proper disposal. Hazardous waste materials have been separated. Mixed scrap metals were being kept in the drums as these can be reused. 1). Grey water from kitchen discharged without treatment. 2). Disconnected PVC pipe behind the bathing area. 3). PVC pipe disconnected from labour cooking area. 1). Contaminated materials stored in the recycling storage. 2). Mixed scrap metals and hazardous waste such as oil filters and other contaminated materials stored in the same bin/drum. NNHP1146_Monthly Report in January 2015_Eng version_GoL CONFIDENTIAL 5 EARTH SYSTEMS Nam Ngiep 1 Hydropower Project Road Monitoring Monthly Report, January 2015 Environment | Water | Sustainability Site Description of issues Comments / recommendation Status in January 2015 There is evidence of contaminated soil / sand dumped on the ground without appropriate management. Refer to SSESMMP for worker camp; Clause 4.10: hazardous waste management, SP06. Contaminated soil/sand has been collected and stored in hazardous storage area, waiting for proper disposal. 1). Collect contaminated soil / sand and store in designated hazardous storage area for proper disposal. 2). OC needs to introduce and train their contractors to understand and implement the Project’s hazardous material / waste management requirements, to prevent recurring issues. General 1). Evidence of used / emptied cement bags disposed outside the camp area. 1). Collect the emptied cement bags and manage properly (i.e. recycle, bury and / or sell). 2). A number of used tires stored behind the workshop. 2). Remove the used tires to specified used tires storage area. A joint Hazmat audit and Hazmat inventory was conducted at PKC, MV.DC Parking and TCM Camp on 16th December 2014. The EMO focused on Hazmat inventory while ES followed up Hazmat management systems from previous inspection through document checks. Key issues include: lack of documentation, labelling of materials, procedures and staff training. Relevant documentation on hazardous materials needs to be maintained; Hazardous materials require labelling Appropriate procedures for storage, management and use of hazardous materials need to be further developed and maintained All staff responsible for storage, management and use of hazardous materials are required to be formally trained. 1). Used cement bags have been collected and sold out to local charcoal producer for reuse. 2). All used tires have been removed to a specified used tired storage area next to the fence of the camp. Joint hazardous materials and waste inventory inspections being conducted by EMO monthly. Table 2-3 Summary of key issues identified during site inspections on 27th January 2015 Issues / Sites Roads Erosion and sediment Description Road A1 The construction of Road A1 (about 200 m to Thaheua village) cuts off a village track that they used to access rice fields and forests. P1 Slope embankments (STA: 3+200; and STA: 3+600) are sensitive to erosion during raining season. The slope of the road embankments is more than 30% and just adjacent to seasonal watercourse. Suitable erosion control measures (e.g. revegetation, ripraps, etc) shall be progressively installed prior to wet season. T9 and T10 These roads are under construction and there is inadequate management of on-site spoil including a) large amounts of spoil (topsoil, rocks and spoil vegetation) pushed down steep slope towards Nam Ngiep River; and b) limited / poor removal of spoil. A number of sensitive areas of roads (i.e. T9, T10, T13 and some sections of P1) and disposal areas still lack of erosion and sediment control measures. Significant loads of spoil (soil, rock and vegetation) have been pushed downhill to Nam Ngiep River. No mitigation measures have been implemented. NNHP1146_Monthly Report in January 2015_Eng version_GoL CONFIDENTIAL 6 EARTH SYSTEMS Environment | Water | Sustainability Nam Ngiep 1 Hydropower Project Road Monitoring Monthly Report, January 2015 Issues / Sites Description Camps and ancillary facilities Spoil Disposal No 2 Spoil Disposal Area 2 is being constructed. The height of spoil stockpiles with berms are too high and without proper compaction and landscaping. Spoil Disposal No 4 The construction of Spoil Disposal area No 4 (along the Road P1) is nearly completed. The spoil stockpiles have been compacted but retaining walls (or revegetation) and proper drainage are required to prevent erosion. Spoil Disposal No 7 Disposal area 7 is currently being operated. This disposal area is located too close to Nam Ngiep River (<10 m) and at risk of flooding during wetseason. Erosion and sediment control measures have not been implemented. There is high potential of sediment being transported to the Nam Ngiep River during rainy events (refer to ESMMP-CP SP11: Spoil Disposal). TCM The sediment pond behind the TCM Camp has been emptied. Wastewater was pumped out and spread in bush around the sediment pond without EMO’s approval. EMO was given notice few days prior to the emptying activity happened. Lamsey Camp Ramsey camp (behind the TCM Camp) was demolished in December 2014 without any decommissioning plan and notice to EMO. Few toilet bores, concrete water tank and grey water pond have been left behind without proper rehabilitation. MV.DC Camp MVDC Stockyard Parking Area PKC & MVDC camp is being demolished without prior approval or decommissioning plan. EMO has requested HC to submit the decommissioning plan on 6th January but have not been provided this yet. About 30 men remain in the camp. MVDC Stockyard and Parking is being demolished without decommissioning plan. Maintenance of dump trucks outside concrete/bunded area without spill trays and spill response kits. Potential risk for oil spill on the ground. Few sections of PVC pipe (at parking area) to supply water for the camp were observed to be leaking. With refer to ESMMP-CP SP17: Project Personnel Health Program – provide adequate and reliable water supply for drinking, cooking and washing purposes at the workers’ camps. T4 & T5 Evidence of many signboards not written in Lao language. Reference to ESMMP-CP SP15 Traffic and Access and SP18 Public Safety: “all roads within the construction area will be signposted to facilitate traffic movement, provide directions to various components of the construction activities and provide safety advice and warnings in Lao and English. Plate 2-1: Construction of Road A1 cuts off village track that they used to access rice fields and forests. Plate 2-2: Slope embankment of P1 (STA:3+200) where erosion control measures have not been implemented. NNHP1146_Monthly Report in January 2015_Eng version_GoL CONFIDENTIAL 7 EARTH SYSTEMS Environment | Water | Sustainability Nam Ngiep 1 Hydropower Project Road Monitoring Monthly Report, January 2015 Plate 2-3: Inadequate management of on-site removal of spoils resulting in massive rocks and soils were pushed down to NN River. Plate 2-4: Disposal Area No 7 is close to NN River and inappropriate management of spoil stockpiles. Plate 2-5: Toilet bores are left without proper decommissioned at Ramsey camp. Plate 2-6: Evidence of signpost is not written in Lao language 2.1.3 Hazardous materials and waste inventory inspection A joint hazardous materials and waste inventory at the main construction sites and sub-contractor camps was conducted between the EMO, OC and sub-contractors on 14 January 2015. Hazardous materials were found at five sites: PKC camp, MVDC workshop, TCM 1&2 camps, Songda camp and the Right Tunnel camp (RT workshop). In January, hazardous waste, such as seven batteries were missing at the TCM workshop. EMO had been told that old batteries were sent back to the main company in Vientiane. EMO will continue conducting the hazardous materials and waste inventory every month and will seek to improve contractor records and management regarding the control of hazardous materials and waste inventory. EMO’s hazardous waste registration is presented in Annex C. NNHP1146_Monthly Report in January 2015_Eng version_GoL CONFIDENTIAL 8 EARTH SYSTEMS Nam Ngiep 1 Hydropower Project Road Monitoring Monthly Report, January 2015 Environment | Water | Sustainability 2.2 Independent Monitoring Missions Independent monitoring mission was conducted by the Lender Technical Adviser (LTA). The EMO, with support from Earth Systems, presented on the current status of compliance monitoring and accompanied the independent monitors on joint site inspections of the facilities. Issues including noncompliancy and project management plan deficiencies were pointed out during the site visit. 2.3 Community Grievance Monitoring 2.3.1 Community consultation In January 2015 village consultation, the EMO NN1PC and ES team conducted village consultation in the four (4) affected villages. Records of village consultation are summarized in Table 2-4. Table 2-4 Village Consultations, January 2015 Date Village Hat Saykham 27th Hat Gniun January 2015 Thahuea Nonsomboun Purpose Participants Village consultation: any grievance on road construction and safety, status of village GRM Villagers, EMO and ES *Note: Does not include consultations conducted by SMO or the RMU without EMO involvement. 2.3.2 Grievances Key grievances identified during village consultations are summarised in Table 2-5. Most of these grievances relate to road watering to control dust and request for update on status of village access road upgrades. Table 2-5 Village Grievances, January 2015 Village Grievance / Required Action Progress Hat Saykham No grievance reported in January 2015. The village access road upgrading in December created lots of dust in. It has been now been sealed with a sub-base. Hat Gniun Speeding of vehicles through the village is still an issue which has potential risk of accident. TD and EMO will coordinate with contractor in order to regulate speeding of trucks. Thaheua A truck hit a cow near the village without compensation because the owner could not identify the truck that caused accident. The village authority reported to the contractor but no compensation has been provided. The cow owner did not report grievance to village GRM to follow up the issue. Road paving has completed in village area but speeding of trucks and cars either related or not related to the Project has potential risk of accident. The road construction cuts off the track NNHP1146_Monthly Report in January 2015_Eng version_GoL NA TD and EMO will coordinate with contractor in order to regulate speeding of trucks. The contractor pledged to repair the track that villagers used to access their rice paddies after finish the road construction. CONFIDENTIAL 9 EARTH SYSTEMS Nam Ngiep 1 Hydropower Project Road Monitoring Monthly Report, January 2015 Environment | Water | Sustainability Village Grievance / Required Action Progress that local people used to go to their rice fields. Nonsomboun The upgrade of village access road has been implemented. Request for upgrade village access roads has not been implemented. The village access road was damaged during wet season as many trucks of Project construction passed through. The village chief submitted request to TD and HC to consider for upgrade village access roads but no response yet. 2.4 Water Quality 2.4.1 Water Quality Monitoring Sites Five (5) sampling stations are designated for routine monthly monitoring: three locations on the Nam Ngiep River (NN1, NN2, and NN3) and two locations on the Nam Xao River (X1 and X2). NN1 and X1 are upstream monitoring stations, to determine ambient conditions upstream of Project construction. The remainder of the locations have been selected to assess whether Project activities are affecting the quality of the Nam Ngiep and Nam Xao. Refer to Figure 2-1 for water quality monitoring locations. January 2015 water quality monitoring was sampled for field water quality parameters (temperature, pH, electrical conductivity, and dissolved oxygen concentration) and for laboratory analysis (total suspended solids, oil / grease). Turbidity was conducted on-site and other field parameters were conducted through in-situ analysis. Additional parameters including BOD, COD, total coliforms and faecal coliforms were tested in the laboratory for Nam Ngiep upstream (NN1) and downstream (NN2) to bolster the understanding of baseline conditions and potential Project impacts. Refer to Table 2-6 for results. Plate 2-7: X2 WQ Monitoring, January 2015 Plate 2-8: NN3 WQ Monitoring, January 2015 NNHP1146_Monthly Report in January 2015_Eng version_GoL CONFIDENTIAL 10 EARTH SYSTEMS Environment | Water | Sustainability Plate 2-9: X1 WQ Monitoring, January 2015 Nam Ngiep 1 Hydropower Project Road Monitoring Monthly Report, January 2015 Plate 2-10: NN2 WQ Monitoring, January 2015 Water Quality Results Results for January 2015 water quality monitoring indicated that water quality in the Nam Ngiep and Nam Xao is generally of good quality. Temperature, pH, DO, EC and BOD are all within acceptable ranges. Samples collected downstream of construction activity are consistent with upstream (ambient values) for these parameters (refer to Table 2-6). Suspended sediment concentrations / turbidity levels in the Nam Ngiep were slightly higher than in December 2014. But these levels were similar to the downstream concentrations. This indicates that the Nam Ngiep River may be affected by other activities upstream of the Project site which can not be identified. However, the construction of Nam Ngiep 1 Hydropower Project and its ancillary facilities such as Road T9, T10, T13 and other construction activities related to the main dam, regulation dam, and temporary diversion tunnel may have potential risks to erosion and sediment transport to Nam Ngiep River during rain events. TSS and tubidity concentrations in Nam Xao River were primarily lower than recent months. The levels of TSS and turbidity in Nam Xao were below the Project guidelines for drinking water. Samples for oil/grease and COD were provided to MONRE laboratory but could not be analysed. Pathogen levels were reduced compared to the previous month, except for Nam Ngiep downstream where fecal coliforms remained the same (200 MPN/100mL). Upstream total coliform results were again higher than the downstream sample. This indicates that other upstream activities may be contributing to the higher total coliforms in Nam Ngiep upstream. 2.4.2 Effluent Discharge Monitoring Water was not found to be discharging from camps / administrative facilities during January 2015, therefore no effluent monitoring was conducted during the month. NNHP1146_Monthly Report in January 2015_Eng version_GoL CONFIDENTIAL 11 EARTH SYSTEMS Nam Ngiep 1 Hydropower Project Road Monitoring Monthly Report, January 2015 Environment | Water | Sustainability Table 2-6 January 2015 Water Quality Monitoring Results Site NA NA NN1 NN2 NN3 X1 Description Location (Coordinates) pH (units) DO (mg/L) Temp (°C) EC (µs/cm) ORP (mV) TSS (mg/L) Turbidity (NTU) Oil / Grease (mg/l) BOD (mg/L) COD (mg/L) Total Coliforms (MPN/100mL) Fecal Coliforms (MPN/100mL) 6.5-8.5 - 35 <1000 - - <10 - - - <2.2 0 5-9 >6.0 - - - - - 10 1.5 5.0 5,000 1,000 20th Oct 7.3 6.6 22.3 87.9 +191 29.4 49.2 <5 NA NA NA NA Lat: 18.401614 19th Nov 7.9 8.2 22.7 105.0 NA 53.0 20.0 <5 1.85 3.03 <200 200 Long: 103.644887 17th Dec 8.2 9.5 19.6 154.0 NA 12 11.9 0.375 1.36 3.03 1,100 780 14th Jan 15 8.27 10.64 17.4 123 NA 23.42 25 * 0.355 * 930 <180 20th Oct 7.2 7.8 22.2 88.1 +262 36.5 51.2 <5 NA NA NA NA Lat: 18.648827 19th Nov 7.5 7.3 20.0 95.0 +176 20 38 0.125 NA NA NA NA Long: 103.59711 17th Dec 8.5 10.0 20.5 149.0 +192 2.83 19.6 0.5625 0.78 1.51 780 200 14th Jan 15 8.43 11.11 19.11 122 NA 25 25.3 * 0.69 * 450 200 16th Sep 6.7 9.4 24.3 75.3 +195 166.5 198 14.9 NA NA NA NA 20th Oct 7.2 6.6 22.7 88.5 +258 33.7 49.8 <5 NA NA NA NA 19th Nov 7.6 7.0 20.7 84.0 +205 24.4 36.0 0.25 1.16 2.65 1,600 800 17th Dec 8.3 9.8 20.7 139.0 +199 4.8 18.4 0.3125 NA NA NA NA 14th Jan 15 8.4 11.02 19.3 156 NA 19.4 22.7 * NA NA NA NA 20th Oct 7.3 5.5 24.9 111.5 +199 3.8 5.7 <5 NA NA NA NA Monitoring Month Drinking water standards#% Ambient water quality standards@% Nam Ngiep – Dam Site (upstream) Nam Ngiep – upstream of N. Xao Nam Ngiep – downstream of N. Xao Nam Xao – Lat: 18.64125 Long: 103.600811 Lat: 18.549782 NNHP1146_Monthly Report in January 2015_Eng version_GoL CONFIDENTIAL 12 EARTH SYSTEMS Nam Ngiep 1 Hydropower Project Road Monitoring Monthly Report, January 2015 Environment | Water | Sustainability Site NA NA X2 Description Drinking water standards#% Ambient water quality standards@% upstream Nam Xao – downstream Location (Coordinates) pH (units) DO (mg/L) Temp (°C) EC (µs/cm) ORP (mV) TSS (mg/L) Turbidity (NTU) Oil / Grease (mg/l) BOD (mg/L) COD (mg/L) Total Coliforms (MPN/100mL) Fecal Coliforms (MPN/100mL) 6.5-8.5 - 35 <1000 - - <10 - - - <2.2 0 5-9 >6.0 - - - - - 10 1.5 5.0 5,000 1,000 19th Nov 7.4 6.5 21.6 125.8 +241 4 4.5 0.25 NA NA NA NA 17th Dec 8.5 9.2 21.8 224.0 +187 3.11 3.8 0.125 NA NA NA NA 14th Jan 15 8.41 11.49 20.42 166 NA 2.7 4.43 * NA NA NA NA 20th Oct 6.9 6.2 25.0 110.3 +187 6.37 6.8 <5 NA NA NA NA Lat: 18.653593 19th Nov 7.1 9.3 21.2 12.8 +162 5 6.8 0.312 NA NA NA NA Long: 103.601832 17th Dec 8.2 9.4 21.0 233.0 +188 4.81 6.0 0.1875 NA NA NA NA 14th Jan 15 8.24 8.76 18.64 194 NA 2.8 4.94 * NA NA NA NA Long: 103.694392 Monitoring Month # Source: Refer to CA – Annex C – Appendix 2 Standard, 1.8 Drinking Water Quality Standards, Physical-Chemical Parameters Source: Refer to CA- Annex C – Appendix 2 Standard, 1.11 Ambient Surface Water Quality Standards % These values differ from Effluent Standards (Refer to CA – Annex C – Appendix 2 Standards, 1.13 Effluent Standards, that will apply to quarterly monitoring for effluents. * Samples provided to MONRE Lab could not be analysed @ NNHP1146_Monthly Report in January 2015_Eng version_GoL CONFIDENTIAL 13 EARTH SYSTEMS Nam Ngiep 1 Hydropower Project Road Monitoring Monthly Report, January 2015 Environment | Water | Sustainability Figure 2-1 January 2015 water quality monitoring locations (NN1, NN2, NN3, X1, X2). NNHP1146_Monthly Report in January 2015_Eng version_GoL CONFIDENTIAL 14 EARTH SYSTEMS Environment | Water | Sustainability 2.5 Nam Ngiep 1 Hydropower Project Road Monitoring Monthly Report, January 2015 Accident or Incidents No accidents or incidents associated with road or ancillary facilities construction / ancillary occurred in January 2015. NNHP1146_Monthly Report in January 2015_Eng version_GoL CONFIDENTIAL 15 EARTH SYSTEMS Nam Ngiep 1 Hydropower Project Road Monitoring Monthly Report, January 2015 Environment | Water | Sustainability 3 Non-compliance reporting 3.1 Introduction Since the implementation of the Non-Compliance Reporting programme in April 2014, there has been progressive action from the Contractor of CWC in responding to outstanding issues. Discussion and agreement regarding corrective actions, action dates and completion dates required have been undertaken during site inspections between the EMO team and the representatives of the Contractor of CWC. 3.2 Summary of Non-Compliance Levels Issues identified by monitors are assigned a non-compliance level. summarised in Table 3-1. Non-compliance levels are Table 3-1 Non-compliance levels Level Significance 1 Non-compliance issue but not an immediate threat to people or environment 2 Moderate impacts or anticipation of more significant impacts if unattended 3 Significant impacts to people or environment or reasonable expectations of significant impacts ^ Refer to Non-Compliance SOP for a comprehensive list of issues and categorisation. If non-compliance issues are not rectified within the required period (completion date), the level of non-compliance is raised (e.g. a level 1 will be a level 2 issue). Where level 3 non-compliance issues are identified, the issue is addressed at NN1PC and Contractor management level. 3.3 Status of Non-Compliance Issues A total of Twenty-five (25) non-compliance issues are considered open action items (requiring corrective action). Fifteen (15) are non-compliance level 1 issues, Twelve (12) are observation nonconformance issues and there are no non-compliance level 2 and level 3 issue is observed. The toal of Twenty-five (25) issues, eleven (11) are no longer considered open action items. These issues have either been corrected or closed for other reasons and forteen (14) issues are pending corrective action during the reporting period. Table 3-2 January non-compliance status for each construction site Site Observation Non-Compliance Level 1 NonCompliance Level 2 NonCompliance Level 3 MVDC Camp 0 2 0 0 MVDC Parking Area 0 0 0 0 Lamsay Camp 1 0 0 0 PKC Camp 0 4 0 0 NNHP1146_Monthly Report in January 2015_Eng version_GoL CONFIDENTIAL 16 EARTH SYSTEMS Nam Ngiep 1 Hydropower Project Road Monitoring Monthly Report, January 2015 Environment | Water | Sustainability Site Observation Non-Compliance Level 1 NonCompliance Level 2 NonCompliance Level 3 TCM Camp 1 2 0 0 Q1 0 0 0 0 Road A1 0 0 0 0 Road P1 0 0 0 0 Road T4 0 0 0 0 Road T5 0 0 0 0 Road T8 0 0 0 0 Road T9 0 0 0 0 Road T11 0 1 0 0 Road T13 0 0 0 0 Re-regulation dam 1 0 0 0 Right Tunneling Camp 1 1 0 0 Songda 5 1 0 0 V&K 0 0 0 0 Sino Hydro Camp 0 0 0 0 PAKC Camp 2 0 0 0 River Diversion Tunnel 3 0 0 0 CVC Plant 0 0 0 0 Total 14 11 0 0 NNHP1146_Monthly Report in January 2015_Eng version_GoL CONFIDENTIAL 17 EARTH SYSTEMS Nam Ngiep 1 Hydropower Project Road Monitoring Monthly Report, January 2015 Environment | Water | Sustainability 4 Capacity Building Activities January 2015 capacity building activities continued further development and implementation of the EMO Project monitoring and reporting framework. Earth Systems conducted on-the-job training for EMO staff including: Lender Technical Advisor mission preparation; Weekly site inspections; Water quality monitoring; and Village consultation. NNHP1146_Monthly Report in January 2015_Eng version_GoL CONFIDENTIAL 18 EARTH SYSTEMS Nam Ngiep 1 Hydropower Project Road Monitoring Monthly Report, January 2015 Environment | Water | Sustainability 5 February 2015 Activities Anticipated monitoring activities for the next reporting period are outlined in Table 5-1. Table 5-1 Summary of Anticipated Monitoring Activities: February, 2015 No. Topic 1 SS-ESSMP and Pre-works Approvals 2 Construction Monitoring 3 Water Quality Monitoring 4 Village Consultation Task / Responsibility EMO will review outstanding SS ESMMPs and conduct initial site inspections to inform the issuance of retrospective pre-works approvals for sites already being constructed. ES will conduct the final construction monitoring in February 2015. Each active construction area will be surveyed. Follow-up monitoring will be conducted for sites previously monitored. ES will conduct the final monthly sampling and analysis. ES to conduct joint sampling with EMO and Contractor of CWC. ES and EMO will conduct village consultation with all four (4) Project affected villages. EMO will engage with SMO and RMU on recently established village GRCs. 5 End of project monitoring meeting ES will meet with EMO management team to summarize annual progress and end of contract for the access road construction monitoring. NNHP1146_Monthly Report in January 2015_Eng version_GoL CONFIDENTIAL 19 EARTH SYSTEMS Environment | Water | Sustainability 6 Nam Ngiep 1 Hydropower Project Road Monitoring Monthly Report, January 2015 CONCLUSIONS & RECOMMENDATIONS Although the Contractor of CWC has addressed the some of the issues identified during joint site inspections, some key issues identified during the last reporting period remain significant. In summary, these issues include: Management of wastewater – Septic and greywater management and treatment measures have been found to be deficient at TCM Camp as well as disposal of sewage and greywater treatment at MV.DC. While waters were not discharging from camps in December (and therefore water quality monitoring was not conducted for effluent), it is assumed that these issues persist. Operation and management of wastewater systems require further investigation and likely upgrade. Management of hazardous materials - While some measures have been taken to address specific issues concerning the storage, handling and clean-up of hazardous waste, key deficiencies remain including appropriate documentation / record-keeping, inadequate training of personnel, and lack of spill prevention / clean-up materials to handle potential discharges (and adequate identification of associated management in SS-ESMMPs); Waste management – Solid waste management at Project sites continues to be an issue. End-disposal of solid waste is currently managed by Paksan Public Landfill which does not meet Project standards. There are currently limited or no options for recycling solid wastes. However, several recycling waste merchants in Paksan and Vientiane have recently been identified. It is anticipated that the merchants will be available to accept recyclable materials once negotiations have been completed. There are currently no options for disposal of hazardous wastes. Poor road construction practices – Poor practices including side-casting of materials down steep slopes adjacent to watercourses, destruction of slope vegetation, and inadequate erosion control implementation continue to be observed. Other less environmentally damaging construction techniques are not being considered. Issues also identified in the previous reporting period concerning the implementation of the environmental monitoring system are on-going. These include: Non-compliance management - A number of non-compliances identified during joint site inspections are not being recorded on the non-compliance database (e.g. hazmat issues, solid waste management issues; drinking water issues at TCM camp). Escalation of non-compliance issues - There is a tendency for the EMO to mark NC issues as ‘closed’ or ‘completed’ when recommended corrective actions have only been partially completed – thus avoiding further escalation of the issue. Main construction phase monitoring – While this report provides a record of preliminary construction phase (i.e. road construction) environmental monitoring, there is a high degree of cross-over with the main construction monitoring (being conducted independently by EMO) – some of which is not being captured adequately in this report. This is understood to include the issuance of a number of non-compliance and incident reports. Communication / coordination processes – With the rapid expansion of the EMO in recent months, a number of the existing internal / external communication and coordination processes have become inadequate and require review / update. NNHP1146_Monthly Report in January 2015_Eng version_GoL CONFIDENTIAL 20 EARTH SYSTEMS Environment | Water | Sustainability Nam Ngiep 1 Hydropower Project Road Monitoring Monthly Report, January 2015 6.1 Recommendations During February 2015, it is recommended that EMO, as a priority: Review of the current environmental monitoring system to identify current deficiencies and opportunities for strengthening this system for use during the main construction phase of the project. Engage NN1PC management to discuss the key issues and mitigation inadequacies experienced during the 2014 wet-season; root causes of these issues; and ways in which these can be addressed proactively well in advance of the 2015 wet-season to ensure completion of mitigation measures before the commencement of rain. Request the Contractor of CWC to commit to emergency response planning measures identified in this report to ensure that road works are conducted in compliance with applicable environmental and social ESMMP-CP requirements; Engage contractors on the appropriate design and management of septic treatment systems and grey water systems at the TCM. Address issues concerning appropriate disposal of sewage / sludge and contaminated grey water; Ensure that MV.DC is properly decommissioned including receipt / review of decomissioing documents and site inspections; Engage TD and Contractor of CWC concerning poor road construction practices and issues concerning poor spoil management and slope vegetation / integrity; and NNHP1146_Monthly Report in January 2015_Eng version_GoL CONFIDENTIAL 21 EARTH SYSTEMS Environment | Water | Sustainability Nam Ngiep 1 Hydropower Project Road Monitoring Monthly Report, January 2015 APPENDICES NNHP1146_Monthly Report in January 2015_Eng version_GoL CONFIDENTIAL 22 EARTH SYSTEMS Nam Ngiep 1 Hydropower Project Road Monitoring Monthly Report, January 2015 Environment | Water | Sustainability Appendix A: Document Register Date* Author / Organisation Title Version Version Date No documents received from NN1PC in January 2015 NNHP1146_Monthly Report in January 2015_Eng version_GoL CONFIDENTIAL 23 EARTH SYSTEMS Nam Ngiep 1 Hydropower Project Road Monitoring Monthly Report, December 2014 Environment | Water | Sustainability Appendix B: Issues and Compliance Register Table B Non-compliance issues observed during bi-weekly monitoring Non-Compliance Registry # Most Recent Inspectio n Date Station Item Date Issue Identifie d Issue Actions Required Action Date Progr ess (%) Required Completio n Date Curre nt NonCompl iance Level Original NonCompli ance Level Comments Issue Status 1 OC confirmed camp to be demobilized by January 2015 IOpen 1 No septic emptying and disposal observed Closed MV.DC Camp MVDC.NC0033 20.01.201 5 Camp site Camp facilities mainten ance and manage ment 03.12.20 14 Evidence of untreated grey water releasing from underground to the open discharge ditch. Full septic tanks were emptied and material disposed of without approval by NNP1 EMO. MVDC.NC0032 20.01.201 5 Camp site Sanitati on facility manage ment 18.11.20 14 Furthermore, The contractor used a local sub-contractor to empty the sewage for disposal without monitoring and / or follow up of where sewage was dispose of. This has high potential risk of sewage being dumped in an inappropriate location. In December, the EMO team found that the company disposed the sewage in rice fields of local residents. Refer to SSEMMP for Worker camp; Clause 4.3. Water availability and pollution control. The OC and subcontractor are required to upgrade th facility to meet discharge standards or clean-up the facility during camp demobilization in January. N/A 16.12.2014 1 Reference to SSEMMP for Worker camp; Clause 4.3: water availability and pollution control. And clause 4.9: waste management. (i). Stop septic empty and sewage disposal activities without consultation and / or approval by NNP1-EMO. Otherwise NCR will be issued immediately. Note: This issue of septic emptied and disposed sewage will be investigated and find down where is the location that sewage being disposed, (EMO will contact OC to confirm the date and time) Lamsay Camp NNHP1146_Monthly Report in January 2015_Eng version_GoL 16.12.2014 CONFIDENTIAL 24 Immediate 0% ASAP 0 EARTH SYSTEMS Nam Ngiep 1 Hydropower Project Road Monitoring Monthly Report, December 2014 Environment | Water | Sustainability Non-Compliance Registry # SI-0003 Most Recent Inspectio n Date 27.01.201 5 Station Camp area Item Landsc aping and Revegetati on Date Issue Identifie d 06.01.20 15 Issue The camp was decommissioned with left be behind of: (i). Septic tanks (ii). Camp facilities structures (iii). Garbage Actions Required Action Date Progr ess (%) No mitigation measure prepared. However, prior the contractor/sub-contractor is demobilized, a site decommissioning plan needs to be prepared and submitted to EMO in providing information of what and how to deal with: (i). Structure facilities decommissioning (ii). Where to dispose and how to manage with discard things (i.e. scrap wooden, concrete waste, hazardous waste, sewage…etc.) (iii) Environmental site restoration (i.e. landscaping and revegetation) Required Completio n Date Curre nt NonCompl iance Level Original NonCompli ance Level Comments Issue Status ASAP Issue reinvestigate d Open 15.1.2015 This issue has been resolved. Discharge drainage pipes have been repaired and grey water from kitchen retained in close sediment pond. Completed PKC Camp Lack of camp sanitary facilities maintenance, resulted in grey water being direct discharged: PKC.NC0036 27.1.2015 Kitchen, bathing and labor's cooking areas Effluent 16.12.20 14 1). Grey water from kitchen has diverted from existing channel 2). Disconnected PVC pipe behind of the bathing area is discharging Reference to SSEMMP for worker camp; Clause 4.3: Water availability and pollution control, and Clause 5.1: Contractor environmental compliance monitoring; SP02: Water availability and pollution control. Re-connect the drain system and maintain seepage system to ensure effective function 3). Disconnected of PVC pipe from labor cooking area (photo C) NNHP1146_Monthly Report in January 2015_Eng version_GoL CONFIDENTIAL 25 20.12.201 5 100% - 1 EARTH SYSTEMS Nam Ngiep 1 Hydropower Project Road Monitoring Monthly Report, December 2014 Environment | Water | Sustainability Non-Compliance Registry # PKC.NC0037 PKC.NC0038 PKC.NC0039 Most Recent Inspectio n Date 27.1.2015 27.1.2015 27.1.2015 Station Item Worksh op Hazard ous waste and nonhazardo us wwaste manage ment Beside the worksho p and batching plant Outside fence of the camp Hazrdo us waste manage ment Waste manage ment Date Issue Identifie d Issue 16.12.20 14 1). Contaminated stuff are stored in the recycling storage (photo A) 2), Mixed scrap metals and hazardous waste such oil filter and other contaminated stuffs stored into same bin/drum (photo B) Reference to SSEMMP for worker camp; Clause 4.9: Solid waste management and Clause 4.10: Hazardous material management Remove the hazardous waste to designated hazardous storage area accordingly for proper disposal 16.12.20 14 There is evidence of contaminated soil / sand thrown on the ground. Without appropriate controlling and proper management , this has potential risk of effects on environment Reference to SSESMMP for worker camp; Clause 4.10: hazardous waste management, SP06. 1). Collect the contaminated soil / sand completely and store in designated hazardous storage area, for properly / environmentally disposal /elimination. 2). OC needs to introduce and train their contractor to understand and acknowledge the project’s hazardous material / waste management orientation, to prevent this over and over repeating. 16.12.20 14 1). Evidence of used/ emptied cement bags disposed outside the camp area. 2). Number of used tires left behind NNHP1146_Monthly Report in January 2015_Eng version_GoL Actions Required 1). Collect the cement bag and manage properly (i.e. burn, bury and / or sell). 2). Remove the used tires to specified used tires storage area CONFIDENTIAL 26 Action Date Immediate Immediate Immediate Progr ess (%) 100% 100% 100% Required Completio n Date 31.12.2014 Immediatel y 31.12.2014 Curre nt NonCompl iance Level - - - Original NonCompli ance Level Comments Issue Status 1 Hazardous waste materials have been separated. Mixed scrap metals were being kept in the drums as these can be reused. Completed 1 Contaminate d soil/sand has been collected and stored in hazardous storage area, waiting for proper disposal. Completed 1 1). Used cement bags have been collected and sold out to local charcoal producer for reuse. 2). All used tires have been removed to a specified used tired storage area next to the fence of the Completed EARTH SYSTEMS Nam Ngiep 1 Hydropower Project Road Monitoring Monthly Report, December 2014 Environment | Water | Sustainability Non-Compliance Registry # Most Recent Inspectio n Date Station Item Date Issue Identifie d Issue Actions Required Action Date Progr ess (%) Required Completio n Date Curre nt NonCompl iance Level Original NonCompli ance Level Comments Issue Status camp. TCM Camp TC.NC0044 TC.NC0042 27.1.2015 16.12.201 4 Toilet area Parking area 03.12.20 14 Spill respons e 03.12.20 14 Sewage disposal without EMO consultation or approval Heavy equipment maintenance on outside the workshop without spillage protection facilities. Resulted in hydrocarbon spilt on the ground is observed Consult with NN1PC EMO prior to sewage disposal to determine appropriate management and disposal area n/a Immediate 0 1 Closed 1 The subcontractor stopped maintenance outside the workshop Closed Reference to SSEMMP for worker camp; Clause 4.10: Hazardous material management, paragraph 18 and Clause 5.1: Contractor construction compliance monitoring; SP06: Hazardous material management (i). Any mobile maintenance activities outside the workshop should be provided with steel tray, drip tray to protect from spills. Otherwise maintenance inside the workshop only is allowed. (ii). Clean up the spilt hydrocarbon and store properly. NNHP1146_Monthly Report in January 2015_Eng version_GoL 28.12.2014 Temporary sewage disposal area and dipsoal procedure have identified. CONFIDENTIAL 27 16.12.2014 n/a 16.12.2014 0 EARTH SYSTEMS Nam Ngiep 1 Hydropower Project Road Monitoring Monthly Report, December 2014 Environment | Water | Sustainability Non-Compliance Registry # SI-0004 Most Recent Inspectio n Date 20.01.201 5 Station Sedime ntation pond Item BAT & Best Practice Date Issue Identifie d 06.01.20 15 Issue Actions Required Reference to previously site inspection report dated 07 / 10 / 2014 and 21 / 10 / 2014. Issue ref; TC.NC0038, for issue of non-compliance of waste water discharge. Temporary improvement such extended the sediment pond, stopped discharge and apply with EM to the waste water have conducted by the sub-contractor. So far, there is no permanent solution being implemented and the waste water in the sediment pond has trend to be full soon. Last bi-weekly joint site inspection and discussion dated 16 /12/2014, OC representative agreed to try and continue effective put EM to the wastewater and subsequently sampling and testing whether or not EM effective and wastewater complied for discharging. Required Completio n Date Curre nt NonCompl iance Level Original NonCompli ance Level Comments Issue Status OC to coordinate with the sub-contractor and prepare corrective action plan such: (i) procedure for put EM, (ii) locations, (iii) frequency of put EM (iv) including time schedule and submit to EMO for review and recommendation. Then EMO will assign staff(s) to participate the process to certify the results and solution. Presently, decision made and agreed by management level during the weekly coordination meeting dated 13 /02 / 2015. Recommendation was raised and deadline gave to the contractor for solving the issue within 2 (two) weeks. Additionally, during this week’s weekly joint site inspection. ES-DMD recommended the contractor to: (ii) Calculate the flow rate and evaluate pollutant load which it shall support to have an appropriate wastewater treatment system re-design. So far, the agreed process not yet been conducted /implemented. Temporary Bridge and Stockyard None Quarry 1 None Road A1 None Road P1 NNHP1146_Monthly Report in January 2015_Eng version_GoL Action Date Progr ess (%) CONFIDENTIAL 28 Open EARTH SYSTEMS Nam Ngiep 1 Hydropower Project Road Monitoring Monthly Report, December 2014 Environment | Water | Sustainability Non-Compliance Registry # Most Recent Inspectio n Date Station Item Date Issue Identifie d Issue Actions Required Action Date Progr ess (%) Required Completio n Date Curre nt NonCompl iance Level Original NonCompli ance Level Comments Issue Status 1 The road excavation had been completed Closed None Road T4 None Road T5 None Road T8 None Road T9 None Road T11 T11.NC0001 18.11.201 4 Road Accom modatio n and camp facilities There is inadequate of environmental protection and mitigation measure being practiced on site (i.e. impact to natural forest outside of planned boundaries, inadequate erosion protection). 18.11.20 14 Rocks and soil were pushed down to the steep slope below the road, which effected: i). Vegetation (ii). Potential risk of erosion and sediment loads / land slide to the Nam Ngiep river in the next wet season. Reference to construction contract; Clause 8.3: Sub-Plan detail for T11; SP01: Erosion and sedimentation control, SP07: Vegetation clearing and SP11: Spoil disposal. The contractor and sub-contractor needs to responsible for reasonable mitigation measures (check dike, supervision and instruction…etc.) to avoid of pushing and protect rock and soil falling down to the steep slope at below of the road which (i) creates damage / destroying to vegetation (ii) high erosion and sediment load to the river. Road T12 None Road T13 None NNHP1146_Monthly Report in January 2015_Eng version_GoL CONFIDENTIAL 29 06.01.2015 n/a 31.01.2015 0 EARTH SYSTEMS Nam Ngiep 1 Hydropower Project Road Monitoring Monthly Report, December 2014 Environment | Water | Sustainability Non-Compliance Registry # SI-0020 Most Recent Inspectio n Date 17.02.201 5 Station Reregulati on dam Item BAT & Best Practice Date Issue Identifie d 03.02.20 15 Issue There was not insufficient of waste bins to support the waste disposal activities at the Re-regulation Dam’s workshop; it might has a potential for waste mixing into the same bin. Actions Required Reference to SSESMMP for worker camp Clause 4.9: Solid waste management, Clause 4.15: Contruction work camp and, Clause 5.1 contractor environmental compliance monitoring. SP14 Contruction work camp, and SP05: Waste management. Curre nt NonCompl iance Level Original NonCompli ance Level Action Date Progr ess (%) Required Completio n Date 17.02.2015 100% 31.03.2015 Completed Close d 06.01.2015 Closed, new issue item created (ref, SI0007) 70% 31.03.2015 Comments Issue Status Provide with sufficient amount of waste bins (at least 2-3 bins/locations on-site for waste segregation and choose the location for the temporary storage for the next proper disposal. Please separate the hazardous RT Camp RT.NC0002 SI-0007 20.01.201 5 20.01.201 5 Industir al area (at soil disposal 1) Industri al area (spoil disposal 1) Industri al support facilities constru ction / installati on BAT & Best Practice 07.10.20 14 06.01.20 15 There is an industrial area establishing on site without environmental mitigation measure / management plan being prepared and proposed (i.e. SSEMMP). Additional, head contractor’s environmental team has no information of what and which facilities to be established and operated in this site. Reference to pending issue ref; RT.NC0002, previously opened dated 07/10/2014. So far, there is lacked of proper site development such compaction, leveling and internal site drainage system. Without proper site development and improvement, this has potential risk of site muddy, stagnant water and other health and Visual amenity issues created during the wet season coming. Reference to construction contract; Clause 4.19: Protection of environment. Please prepare and submit the site specific environmental management plan to NNP1-EMO for review and approval. 0 1 There is inadequate management plan and mitigation measures being prepared and submitted, (ref; SSESMMP for inlet and outlet diversion tunnel). However, before many heavy equipment stored on site and, to prevent of environmental issue(s) created during the wet season coming. 1). The site location conditions needs to be improved (i) leveling / grading, (ii) compact, provide with proper internal site drainage and specific location for material and equipment storage properly. 2). Update site layout and relating facilities (i.e. septic tank…etc.) details design to the SSESMMP and submit to EMO for review and approval. Songda Camp NNHP1146_Monthly Report in January 2015_Eng version_GoL 20.01.2015 CONFIDENTIAL 30 Open EARTH SYSTEMS Nam Ngiep 1 Hydropower Project Road Monitoring Monthly Report, December 2014 Environment | Water | Sustainability Non-Compliance Registry # Sd.NC0004 SI-0008 SI-0009 Most Recent Inspectio n Date Station 20.01.201 5 Worksh op (at spoil disposal 1) 20.01.201 5 Worksh op (at spoil disposal area 1) 20.01.201 5 Camp area Item Site and hazardo us material manage ment BAT & Best Practice BAT & Best Practice Date Issue Identifie d 03.12.20 14 06.01.20 15 20.01.20 15 SI-0010 20.01.201 5 Camp area BAT & Best Practice 20.01.20 15 SI-0011 20.01.201 5 Camp area BAT & Best Practice 20.01.20 15 Issue 1). Improper hazardous material storage, a used oil drum stored on the expose ground without spillage protection facilities. 2). Poor workshop condition and no design detail of workshop and management plan being prepared and submitted. 3). Evidence of hydrocarbon spilt on the ground from mobile maintenance activities without cleans up properly. There is no proper and / or best environmental practice being implemented on site. (i). No site environmental management plan being prepared and submitted. (ii). Improper / poor quality of workshop/maintenance area There are insufficient waste bins provided on site. Resulted in garbage scattered at the site, and mix disposed into same waste bin. Evidence of disconnected PVC pipe from septic tanks, resulting in waste water direct releasing to the open ditch is observed during the time of site inspection. This has potential risk of bacteria release to the environment. There is indentified that internal drainage in the camp is inappropriate slop to allow waste flow well, resulting in evidence of stagnant gray water in the drainage. This has potential risk of mosquito breeding and future may became odour. NNHP1146_Monthly Report in January 2015_Eng version_GoL Actions Required No management plan and / or mitigation measure being prepared and submitted.However, reference to project ESMMP, sub-plan 06: Hazardous material management. (i). Remove the used oil drum to designated hazardous storage area. (ii). Prepare and submit this site management plan including design details of workshop to EMO for review and approval. (iii). Clean up the spilt hydrocarbon completely and store in designated hazardous storage area properly. 1). Prepare and submit site environmental management plan with details design (septic tank, workshop and hazardous material storage including oil traps / oil separator to EMO for review and approval. Action Date 20.01.2015 Progr ess (%) Required Completio n Date 16.12.2014 Curre nt NonCompl iance Level 0 Original NonCompli ance Level 1 Comments Issue Status Closed with new issue item created (ref; SI0008 below) ASAP Open 03.02.2015 Open Immediatel y Open ASAP Open 2). Improve the site condition in Reference to SSESMMP for worked camp, Clause 4.9 solid waste management and clause 4.15: contruction worked camp, Clause 5.1: contractor environmental compliance monintoring; SP05: Waste management At least three ( 03) waste bins need to be provided where sensitive locations. In order to facilitate for temporary onsite waste collection. Reference to SSESMMP for worked camp. Clause 4.3: Water availability and pollution control and Clause 5.1: contractor environmental compliance monitoring. SP02, Water Availability and Pollution Control. Immediately reconnect the PVC pipe to stop of waste water direct release to the open ditch. Reference to SSESMMP for worked camp. Clause 4.15: Construction work camp and clause 4.16: occupational health and safety and Clause 5.1: Contractor environmental compliance monitoring. Sunplan 14: Construction work camp and Subplan 17: Project personal health programe. Either improve drainage system properly to allow CONFIDENTIAL 31 EARTH SYSTEMS Nam Ngiep 1 Hydropower Project Road Monitoring Monthly Report, December 2014 Environment | Water | Sustainability Non-Compliance Registry # Most Recent Inspectio n Date Station Item Date Issue Identifie d Issue Actions Required Action Date Progr ess (%) Required Completio n Date Curre nt NonCompl iance Level Original NonCompli ance Level Comments Issue Status water free flow and clean up drainages regulary. SI-0012 20.01.201 5 Camp area BAT and Best Practic 20.01.20 15 1. There is identified that gray water in the sediment pond, became strong of un-pleasance odour and the sub – contractor confirmed to inport Bio-Chemical from Vientnam to use and dilute odour. 2. EMO/WQ team concerned that this grey water has high potential of containing high bacterial and certainly to be discharge and/or over flow during wet season due incorporated with storm water. Reference to SSESMMP for worked camp. Clause 4.3: Water availabity and Pollution control and Clause 5.1: Contractor environmental monitoring compliance.=; SP02: Water availability and pollution control. (I.) The MSDS of proposed inport Bio-Chimecal mentioned (item N*1 in a bove) need to be submitted to EMO for approval prior using. (II.) The contractor and sub-contractor need to plan on what and how to deal with a bove item N*2 (i.e.. Separate between grey water system and storm drainage…..etc). ASAP Open 20.01.2015 Open 03.02.2015 Open V&K Camp None Sinno Hydro None PAKC Camp SI-0005 SI-0015 20.01.201 5 20.01.201 5 Owner base camp Owner base camp BAT & Best Practice BAT & Best Practice 06.01.20 15 20.01.20 15 There is identified that a sediment pond provided for the grey water from cooking and bathing areas has insufficient size. Resulting in grey water has been discharging to the adjacent natural creek which a local farm located 200 m at downstream. This has potential risk of effect on natural water quality and complain from local farmer. There is insufficient number of waste bins provided in camp; resulting in garbage mix disposed into same waste bin, No SSESMMP and mitigation measures prepared. However, neither provide with addition sufficient size of sediment pond to stop discharge and / or a seepage to treat the grey water prior discharge to the environment. Reference to SSESMMP for worker camp Clause 4.9: Solid waste management, Clause 4.15: Contruction work camp and, Clause 5.1 contractor environmental compliance monitoring. SP14 Contruction work camp , and SP05: Waste management Provide with sufficient number of waste bins ( at least 2-3 bins / locations for on-site waste NNHP1146_Monthly Report in January 2015_Eng version_GoL CONFIDENTIAL 32 EARTH SYSTEMS Nam Ngiep 1 Hydropower Project Road Monitoring Monthly Report, December 2014 Environment | Water | Sustainability Non-Compliance Registry # Most Recent Inspectio n Date Station Item Date Issue Identifie d Issue Actions Required Action Date Progr ess (%) Required Completio n Date Curre nt NonCompl iance Level Original NonCompli ance Level Comments Issue Status segregation and temporary collection for proper disposal. River Diversion Tunnel SI-0006 20.01.201 5 Outlet BAT & Best Practice 06.01.20 15 There is insufficient sediment pond being provided on site for construction waste water treatment at the present time. Only one small sediment pond has provided, resulting in inadequate effective and high turbidity water being discharging to the Namgniep river. Additional, the surface of wastewater in the sediment pond has covered with oil film without cleaning up. This has potential risk of being releases to the natural water. SI-0017 20.01.201 5 SI-0018 20.01.201 5 Reference to SSESMMP for “River Diversion Tunnel Excavation Work”, Clause 8.3: Sub-plan detail; SP01: Erosion and sedimentation control and SP02: Water availability and pollution control. And Appendix 9.21: Turbid Water Treatment Facility Plan. 13.01.2015 Open Immediatel y Open 03.02.2015 Open OC has confirmed that the proposed turbid treatment plant will be operated by next Monday (12/01/2015). Otherwise, additional sedimentation pond with sufficient size will need to be provided and oil film is necessary to be collected properly. Reference to SSESMMP for river diversion tunnel work. Clause 8.3: Sub-plan detail for tunnel excavation – environmental; SP02: Water availability and pollution control. Inlet Waste Water Dischar ge 20.01.20 15 The septic tank for temporary toilet onsite is full and over flow with out mitigation measure. Inlet BAT & Best Practice 20.01.20 15 There is insufficient and improper waste bins provided. Garbage and explosive material are mix stored in same bins and same location. OC need to take immediately action to resolve the issue to stop black water discharge- over flow. If the septic tank is nessary to be emptied, dispose location and procedure need to compliance with current EMO provided method statement. Other wise NRC will be issued immediately. Reference to SSESMMP for river diversion tunnel work. Clause 8.3: Sub-plan detail for tunnel excavation – environmental and SP05: waste management and SP20: Emergency preparedness. (i.) Provide sufficient waste bins on site for waste collection. (ii.) Separated location for waste accomudation and store of explosive material. CVC Plant None NNHP1146_Monthly Report in January 2015_Eng version_GoL CONFIDENTIAL 33 EARTH SYSTEMS Nam Ngiep 1 Hydropower Project Road Monitoring Monthly Report, December 2014 Environment | Water | Sustainability Table C Non-compliance issues observed during HazMat monitoring Most Recent Inspection Date Station Item Date Issue Identified Issue Actions Required Action Date Progress (%) Required Completion Date Current NonCompliance Level Original NonCompliance Level ASAP 0% 15.01.2015 1 1 Comments Issue Status PKC Camp Outstanding Issues PKC.NC0031 18.11.2014 PKC.NC0024 18.11.2014 PKC.NC0007 PKC.NC0008 PKC.NC0032 PKC.NC0033 18.11.2014 18.11.2014 18.11.2014 18.11.2014 Workshop Labelling Workshop Safety and spill response Fuel station & storage Labelling 17.06.2014 - No label of "Hazardous waste" - No content description - No initial accummulation date - No hazard description - No MSDS Ensure labels of - "Hazardous waste" - Content description - Initial accummulation date - Hazard description - MSDS 7.04.2014 - Spill kit box exits but no spill response (i.e. absorbent sheet, sand / sawdust) - Make sure spill response is in place and adequate ASAP 0% 19.02.2014 - No MSDS Ensure MSDS present ASAP 0% 19.02.2014 - No refueling procedure enforced Make sure the following are in place: Refueling procedure enforced Fuel station & storage Fuel use Workshop Temporary used oil storage 18.11.2014 Inadequate bunding capacity Workshop Safety and spill response 18.11.2014 - No procedure for HazMat handling posted - No procedure for NNHP1146_Monthly Report in January 2015_Eng version_GoL is Ensure used oil be removed to the fuel storage (to minimize the volume stored in the temporary storage Ensure the following are in place: - Procedure for HazMat handling 15.01.2015 15.01.2015 Required reinvestigation 1 1 This issue was not resolved but closed on 7.04.2014 as new issue item created with more detail 1 1 MSDS existed during 20.05.2014 inspection Required reinvestigation OC was asked to provide off-site fueling procedures and this issue was closed in 7.04.2014 for some reason Required reinvestigation Required reinvestigation ASAP 0% 15.01.2015 1 1 ASAP 0% 15.01.2015 1 1 Inspection required ASAP 0% 15.01.2015 1 1 Inspection required CONFIDENTIAL 34 EARTH SYSTEMS Nam Ngiep 1 Hydropower Project Road Monitoring Monthly Report, December 2014 Environment | Water | Sustainability Most Recent Inspection Date PKC.NC0034 PKC.NC0035 PKC.NC0036 18.11.2014 18.11.2014 18.11.2014 Station General Fuel station & storage Fuel station & storage Item Documentation Signate Labelling NNHP1146_Monthly Report in January 2015_Eng version_GoL Date Issue Identified Current NonCompliance Level Original NonCompliance Level 15.01.2015 1 1 Inspection required 0% 15.01.2015 1 1 Inspection required 0% 15.01.2015 1 1 Inspection required Action Date Progress (%) Make sure the following documents are in place: - Up-to-date HazMat register - HazMat mannual with SOP's and emergency response - Training register for HazMat handling and emergency response - SOP for introduction of new substances to storage area ASAP 0% 18.11.2014 - No restricted access sign outside facility - No sign for areas designated for use of PPE - Make sure the restricted access sign is in place - Make sure sign for areas designated for use of PPE is in place ASAP 18.11.2014 - No label of "Hazardous waste" - No content description - No initial accummulation date Ensure labels of - "Hazardous waste" - Content description - Initial accummulation date ASAP 18.11.2014 Issue Actions Required emergency response posted - No training for HazMat handling & spill response (including traning register) - No water accessible near storage area Need to inspect / sight the following documents: - Up-to-date HazMat register - HazMat mannual with SOP's and emergency response - Training register for HazMat handling and emergency response - SOP for introduction of new substances to storage area - Procedure for emergency response - Training (inc. register) for HazMat handling & spill response - Water tap installed nearby and near oil trap CONFIDENTIAL 35 Required Completion Date Comments Issue Status EARTH SYSTEMS Nam Ngiep 1 Hydropower Project Road Monitoring Monthly Report, December 2014 Environment | Water | Sustainability Most Recent Inspection Date PKC.NC0037 PKC.NC0038 18.11.2014 18.11.2014 Station Fuel station & storage Fuel station & storage Item Safety and spill response Fuel use Date Issue Identified 18.11.2014 18.11.2014 Issue - No procedure for HazMat handling posted - No procedure for emergency response posted - No training for HazMat handling & spill response (including traning register) - No spill response kit available - No safe storage for contaminated material after spill response - No water accessible near storage area - No refueling procedure enforced - No spill response kit - No detailed upto-date registration of movements of fuel Actions Required Action Date Progress (%) Ensure the following are in place: - Procedure for HazMat handling - Procedure for emergency response - Training (inc. register) for HazMat handling & spill response - Safe storage available for contaminated material after spill response - Water tap installed nearby and near oil trap ASAP 0% Make sure the following are in place: - Refueling procedure enforced - Spill response kit - Detailed up-to-date registration of movements of fuel ASAP 0% Current NonCompliance Level Original NonCompliance Level 15.01.2015 1 1 Inspection required 15.01.2015 1 1 Inspection required Required Completion Date Comments Issue Status TCM Camp Oustanding Issues TCM.NC0050 TCM.NC0051 18.11.2014 18.11.2014 Fuel station Fuel station Signage Documentation NNHP1146_Monthly Report in January 2015_Eng version_GoL 18.11.2014 - No restricted access sign outside facility - Make sure the restricted access sign is in place ASAP 0% 15.01.2015 1 1 Inspection required 18.11.2014 Need to inspect / sight the following documents: - Up-to-date HazMat register - Training register Make sure the following documents are in place: - Up-to-date HazMat register - Training register for ASAP 0% 15.01.2015 1 1 Inspection required CONFIDENTIAL 36 EARTH SYSTEMS Nam Ngiep 1 Hydropower Project Road Monitoring Monthly Report, December 2014 Environment | Water | Sustainability Most Recent Inspection Date TCM.NC0052 TCM.NC0053 TCM.NC0054 18.11.2014 18.11.2014 18.11.2014 Station Fuel station Fuel station Fuel station Item Fuel use Labelling Safety and spill response NNHP1146_Monthly Report in January 2015_Eng version_GoL Date Issue Identified 18.11.2014 18.11.2014 18.11.2014 Action Date Progress (%) Required Completion Date Current NonCompliance Level Original NonCompliance Level Make sure the following are in place: - Refueling procedure enforced - Spill response kit - Detailed up-to-date registration of movements of fuel ASAP 0% 15.01.2015 1 1 Inspection required Ensure labels of - "Hazardous waste" - Content description - Initial accummulation date - Hazard description - MSDS ASAP 0% 15.01.2015 1 1 Inspection required Ensure the following are in place: - Procedure for HazMat handling - Procedure for emergency response - Training (inc. register) for HazMat handling & spill response - Spill response kit and safe storage available for contaminated material after spill response ASAP 0% 15.01.2015 1 1 Inspection required Issue Actions Required for HazMat handling and emergency response - SOP for introduction of new substances to storage area - No refueling procedure enforced - No spill response kit - No detailed upto-date registration of movements of fuel - No label of "Hazardous waste" - No content description - No initial accummulation date - No hazard description - No MSDS - No procedure for HazMat handling posted - No procedure for emergency response posted - No training for HazMat handling & spill response (including traning register) - No spill response kit available - No safe storage for contaminated material after spill HazMat handling and emergency response - SOP for introduction of new substances to storage area CONFIDENTIAL 37 Comments Issue Status EARTH SYSTEMS Nam Ngiep 1 Hydropower Project Road Monitoring Monthly Report, December 2014 Environment | Water | Sustainability Most Recent Inspection Date Station Item Date Issue Identified Issue Actions Required Action Date Progress (%) Required Completion Date Current NonCompliance Level Original NonCompliance Level - Make sure the restricted access sign is in place - No sign for areas designated for use of PPE ASAP 0% 15.01.2015 1 1 Inspection required Make sure the following documents are in place: - Up-to-date HazMat register - Training register for HazMat handling and emergency response - SOP for introduction of new substances to storage area ASAP 0% 15.01.2015 1 1 Inspection required Ensure: - Used oil contained in appropriate containers - Containers closed unless material added or used ASAP 0% 15.01.2015 1 1 Inspection required Ensure labels of - "Hazardous waste" - Initial accummulation date - Hazard description - MSDS ASAP 0% 15.01.2015 1 1 Inspection required Comments Issue Status response TCM.NC0055 TCM.NC0056 TCM.NC0057 TCM.NC0058 18.11.2014 18.11.2014 18.11.2014 18.11.2014 HazMat storage HazMat storage HazMat storage HazMat storage Signate Documentation Containers Labelling NNHP1146_Monthly Report in January 2015_Eng version_GoL 18.11.2014 18.11.2014 18.11.2014 18.11.2014 - No restricted access sign outside facility - No sign for areas designated for use of PPE Need to inspect / sight the following documents: - Up-to-date HazMat register - Training register for HazMat handling and emergency response - SOP for introduction of new substances to storage area - Used oil contained in drinking water bottles - Containers not closed unless material added or used - No label of "Hazardous waste" - No initial accummulation date - No hazard description - No MSDS CONFIDENTIAL 38 EARTH SYSTEMS Nam Ngiep 1 Hydropower Project Road Monitoring Monthly Report, December 2014 Environment | Water | Sustainability Most Recent Inspection Date TCM.NC0059 18.11.2014 Station HazMat storage Item Safety and spill response Date Issue Identified Issue 18.11.2014 - No procedure for HazMat handling posted - No procedure for emergency response posted - No training for HazMat handling & spill response (including traning register) - No spill response kit available - No safe storage for contaminated material after spill response - Firefighting equipment not available and is not sited for ease of access Actions Required Action Date Progress (%) Required Completion Date Current NonCompliance Level Original NonCompliance Level Ensure the following are in place: - Procedure for HazMat handling - Procedure for emergency response - Training (inc. register) for HazMat handling & spill response - Spill response kit and safe storage available for contaminated material after spill response - Firefighting equipment not available and is not sited for ease of access ASAP 0% 15.01.2015 1 1 Inspection required Comments Issue Status Explosives Magazine Outstanding Issues EM.NC0001 EM.NC0002 18.11.2014 18.11.2014 Explosive magazine Explosive magazine Labelling Safety NNHP1146_Monthly Report in January 2015_Eng version_GoL 18.11.2014 18.11.2014 - No content description - No hazard description - No MSDS - No procedure for HazMat handling posted - No procedure for emergency response posted - No training for HazMat handling & spill response (including traning register) Ensure labels of - Content description - Hazard description - MSDS ASAP 0% 15.01.2015 1 1 Inspection required Ensure the following are in place: - Procedure for HazMat handling - Procedure for emergency response - Training (inc. register) for HazMat handling & spill response ASAP 0% 15.01.2015 1 1 Inspection required CONFIDENTIAL 39 EARTH SYSTEMS Nam Ngiep 1 Hydropower Project Road Monitoring Monthly Report, December 2014 Environment | Water | Sustainability Most Recent Inspection Date EM.NC0003 18.11.2014 Station Explosive magazine Item Documentation Date Issue Identified Issue 18.11.2014 Need to inspect / sight the following documents: - Up-to-date HazMat register - Training register for HazMat handling and emergency response - SOP for introduction of new substances to storage area Actions Required Action Date Progress (%) Required Completion Date Current NonCompliance Level Original NonCompliance Level Make sure the following documents are in place: - Up-to-date HazMat register - Training register for HazMat handling and emergency response - SOP for introduction of new substances to storage area ASAP 0% 15.01.2015 1 1 ASAP 0% 15.01.2015 1 1 Site to be decommissioned in Jan 2015 Open ASAP 0% 15.01.2015 1 1 Site to be decommissioned in Jan 2015 Open ASAP 0% 15.01.2015 1 1 Site to be decommissioned in Jan 2015 Open Comments Issue Status Inspection required MVDC Parking Area Additonal Findings MVDCPA. NC0001 MVDCPA. NC0002 MVDCPA. NC0003 20.01.2015 20.01.2015 20.01.2015 Parking area Parking area Parking area HazMat storage Signate Documentation NNHP1146_Monthly Report in January 2015_Eng version_GoL 18.11.2014 - Inadequate bunding capacity - No fence and lock 18.11.2014 - No restricted access sign outside facility - No sign for areas designated for use of PPE 18.11.2014 Need to inspect / sight the following documents: - Up-to-date HazMat register - HazMat mannual with SOP's and emergency response - Training register for HazMat - Ensure bunding has adequate capacity or used oil be disposed to agreed designated location (to minimize the volume stored) - Ensure fence and lock are installed - Make sure the restricted access sign is in place - Make sure sign for areas designated for use of PPE is in place Make sure the following documents are in place: - Up-to-date HazMat register - HazMat mannual with SOP's and emergency response - Training register for HazMat handling and emergency response CONFIDENTIAL 40 EARTH SYSTEMS Nam Ngiep 1 Hydropower Project Road Monitoring Monthly Report, December 2014 Environment | Water | Sustainability Most Recent Inspection Date MVDCPA. NC0004 MVDCPA. NC0005 20.01.2015 20.01.2015 Station Parking area Parking area Item Labelling Safety and spill response NNHP1146_Monthly Report in January 2015_Eng version_GoL Date Issue Identified 18.11.2014 18.11.2014 Issue handling and emergency response - SOP for introduction of new substances to storage area - No label of "Hazardous waste" - No initial accummulation date - No procedure for HazMat handling posted - No procedure for emergency response posted - No training for HazMat handling & spill response (including traning register) - No spill response kit available - No safe storage for contaminated material after spill response - No water accessible near storage area Original NonCompliance Level Comments 1 1 Site to be decommissioned in Jan 2015 Open 1 1 Site to be decommissioned in Jan 2015 Open Action Date Progress (%) Required Completion Date Current NonCompliance Level Ensure labels of - "Hazardous waste" - Initial accummulation date ASAP 0% 15.01.2015 Ensure the following are in place: - Procedure for HazMat handling - Procedure for emergency response - Training (inc. register) for HazMat handling & spill response - Spill response kit and safe storage available for contaminated material after spill response - Water tap installed nearby and near oil trap ASAP 0% 15.01.2015 Actions Required Issue Status - SOP for introduction of new substances to storage area CONFIDENTIAL 41