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Provincial Water Sanitation Project Cambodia
Provincial Water Sanitation Project Cambodia
June 2019
Prepared by the Ministry of Public Works and Transport for the Asian Development Bank.
This updated environmental management plan is a document of the borrower. The views
expressed herein do not necessarily represent those of ADB's Board of Directors, Management,
or staff, and may be preliminary in nature.
In preparing any country program or strategy, financing any project, or by making any designation
of or reference to a particular territory or geographic area in this document, the Asian
Development Bank does not intend to make any judgments as to the legal or other status of any
territory or area.
Ministry of Public Works and Transport, Kingdom of Cambodia
Cambodia: Provincial Water Supply and Sanitation Project (Wastewater Subproject)
CURRENCY EQUIVALENTS
(10 Aug. 2018)
Currency Unit - Riel R
R1.00 = $0.00025
$1.00 = R4,000
ABBREVIATIONS
NOTE
This environmental management plan is a document of the borrower. The views expressed herein
do not necessarily represent those of ADB's Board of Directors, Management, or staff, and may
be preliminary in nature. Your attention is directed to the “terms of use” section of this website.
In preparing any country program or strategy, financing any project, or by making any designation
of or reference to a particular territory or geographic area in this document, the Asian
Development Bank does not intend to make any judgments as to the legal or other status of any
territory or area.
CONTENT
ABBREVIATIONS 2
I. INTRODUCTION 6
A. SUBPROJECT COMPONENTS 7
B. CONSTRUCTION SCHEDULE 13
C. EMP AIMS AND STRUCTURE 15
II. INSTITUTIONAL ARRANGEMENTS & RESPONSIBILITIES 16
III. SUMMARY OF POTENTIAL ENVIRONMENTAL IMPACTS 19
A. ENVIRONMENTAL IMPACTS 19
B. PUBLIC CONSULTATION PROCESS 24
C. GRIEVANCE REDRESS MECHANISM 26
IV. ENVIRONMENTAL IMPACT MITIGATION PLAN 29
V. MONITORING PLAN 38
A. MONITORING ACTIVITIES AND RESPONSIBILITIES 38
B. REPORTING 43
VI. BUDGET FOR EMP IMPLEMENTATION 45
VII. EMERGENCY RESPONSE PLAN 45
A. ALERT PROCEDURES 47
B. EMERGENCY RESPONSE SITUATIONS 48
VIII. INSTITUTIONAL CAPACITY REVIEW AND NEEDS 50
LIST OF TABLES
TABLE 1: SCOPE OF CONSTRUCTION WORKS ................................................................................................................8
TABLE 2: LIST OF MATERIAL .........................................................................................................................................10
TABLE 3: LIST OF EQUIPMENT AND VEHICLE ...............................................................................................................11
TABLE 4: CONSTRUCTION ACTIVITIES SCHEDULE ........................................................................................................13
TABLE 5: ROLES AND RESPONSIBILITIES FOR ENVIRONMENTAL MANAGEMENT .......................................................17
TABLE 6: SUMMARY OF POTENTIAL ENVIRONMENTAL IMPACTS ...............................................................................19
TABLE 7: PUBLIC CONSULTATION PROCESS.................................................................................................................24
TABLE 8: PROVINCIAL GRIEVANCE REDRESS COMMITTEE (GRC) ................................................................................26
TABLE 9: ENVIRONMENTAL IMPACT MITIGATION PLAN .............................................................................................29
TABLE 10: ENVIRONMENTAL MONITORING PLANS .....................................................................................................39
TABLE 11: PERFORMANCE MONITORING INDICATORS ...............................................................................................43
TABLE 12: ROLES AND RESPONSIBILITIES IN EMERGENCY INCIDENT RESPONSE ........................................................45
TABLE 13: EVACUATION PROCEDURE ..........................................................................................................................48
TABLE 14: RESPONSE PROCEDURE DURING MEDICAL EMERGENCY ...........................................................................48
TABLE 15: RESPONSE PROCEDURE IN CASE OF FIRE ....................................................................................................49
LIST OF FIGURES
LIST OF ANNEXES
I. INTRODUCTION
1. This environmental management plan (EMP) sets out the environmental management
requirements for the Siem Reap Replacement Interceptor Sewer Subproject of the Provincial
Water Supply and Sanitation Project (PWSSP) during the pre-construction, construction and
operation phase in line with the requirements of the Royal Government of Cambodia (RGC) and
the ADB Safeguard Policy Statement (SPS, 2009).
2. An initial environmental evaluation (IEE) covering wastewater subprojects, including the
Siem Reap subproject was disclosed on ADB website during project preparation in June 2017.
Siem Reap subproject was awarded as a Design and Build Contract. An outline EMP, based on
the IEE was developed in August 2018 and included as part of the bid invitation document and
contract of the construction contractor. The contractor further submitted its EMP during
construction (CEMP) in April 2019, which was finalized and approved on the 6th of June 2019.
3. The updated EMP based on detailed engineering design (DED) should have been cleared
by ADB prior to civil works commencing. This June 2019 updated version of the EMP takes into
account the detailed engineering design completed by the contractor in February 2019 and
approved in early April 2019, the CEMP and public consultations that took place in May 2019 for
additional screening of potential impacts prior to the start of construction and has been prepared
to bring the project back into compliance. The updated EMP includes detailed information on
design, sensitive receptors, impacts and mitigation in lieu of a separate update to IEE prepared
for wastewater subprojects.
4. The existing 3.7 km long pipeline was designed and installed to collect wastewater from
the center of Siem Reap over an area of 2.4 km2. This pipeline is made of glass fiber reinforced
plastic (GRP) sewage drainage pipes with diameters of 600 mm and 700 mm. The pipeline has
failed and collapsed at five locations between 2011 and 2014 and at two more locations since.
Based on the recent geotechnical investigations and test pit excavations, the cause of failure is
highly likely to be a combination inadequate compaction during backfilling of the trench and poor
quality pipes leading to frequent cyclic loads on the pipes which eventually resulted in material
fatigue and collapse. At present, the pipeline is not functioning, preventing wastewater in a central
part of the town from reaching the pump station and ultimately the wastewater treatment plant.
5. From an environmental perspective, the periodic settling or collapsing of the road is a
traffic hazard and so a public safety risk. The blocked sewage pipeline overflows to the adjacent
irrigation canal at selected locations which too is a public health risk as well as environmental
degradation even though the water quality in the canal is already very poor.
6. The purpose of the Siem Reap subproject is to replace the existing interceptor sewer with
a stronger pipeline and thereby not only enable it to function again but also improve the urban
environment though reduction of the above mentioned hazards. The project area includes Sivatha
Road from the intersection with National Highway 6 to the Y-junction and roundabout near
Pokambor Avenue then along the narrow BBU Road to the main pump station (see Project locality
map in). The road goes through the city’s bustling street (Central Market, Old Market), intersects
the town center drainage channel and drains on both sides. The existing pipeline will be replaced
by DN1000 (external diameter 1173 mm) ductile cast iron pipes using trenchless technology to
minimize disruptions to traffic and pedestrians through the bustling city center.
A. SUBPROJECT COMPONENTS
7. The depth of the existing pipeline ranges from 3.5 m (to pipe invert) at the upstream end
to 7.5 m at the pump station. The new pipeline will be similar as it will connect into the upstream
and downstream manholes. In addition, 37 manholes will be installed along the new pipeline to
allow each of the existing manholes to be cross-connected to the new pipeline. At loan preparation
it was envisaged that trenchless technology will be used to lay the new pipeline to avoid lengthy
road openings and sheet piling. However the actual technology was left to the bidders with a
choice of either micro-tunneling and pipe jacking or pipe splitting and bursting. The two techniques
are illustrated in Figure 2 and Figure 3 respectively.
8. The eventual contractor elected to use micro-tunneling method to ensure that the existing
pipe could be operational at all times and also due to the uncertainty about the condition of the
existing pipe.
9. Main works under the subproject broadly include (i) excavation of working jacking and
receiving pits sufficiently large to enable the boring and jacking machines to be lowered and
retrieved, (ii) pipeline construction using jacking, (iii) construct of new manholes for access and
maintenance, cross-connection to the existing manholes, and (iv) resealing of the road. Details of
the scope of the main work tasks are presented in Table 1.
10. Construction method: Detailed methodology for the execution of the tasks is presented
below:
12. Equipment and vehicle for the subproject are presented in Table 3.
I Equipment
1 Pipe jacking machine Set 2
2 Slurry separation machine item 2
3 Electric generator item 2
4 Submersible pump item 12
II Vehicle
1 Forklift 1
2 Excavator 2
3 16-tonne Crane 2
4 Soil unload truck 6
5 Piling machine for steel sheet piles 2
6 Flatbed truck 1
13. Associated facilities include worker camp, material storage areas, and disposal areas as
follows:
• Workers’ camp
- Location: Borey Perfect, 7 Road 66, No.3, Taphul Village, Sangkat Svay Dangkum,
Siem Reap City
- Capacity/size: 30 persons
• Pre-cast Site: The pump station at the downstream ending point will be used as the
temporary site for the production of pre-cast components
• Material Storage Areas:
- The construction materials: are stored at the wastewater treatment plant compound
(an area of about 1,500 m2 has been set aside) with only what is being used being
stored temporarily at the working pit enclosure during construction. As the excavation
and pipe laying moves to the upstream end (along Sivatha Road), temporary storage
along the river bank will be permitted by the PIU.
- The plant and equipment are generally stored at site on Country Road Wat Chowk
about 900 m west of the pump station. The site area is around 2,000 m2.
• Disposal Areas: The disposal of excavated material and area will be used for filling in
with waste material, spoils from the construction process. Some of the excavated material
is given to nearby villagers who request it for general site fill on their properties and it is
also being used for road improvement at the request of village heads. A small amount of
excavated material may also stockpiled temporarily at the same site as the plant and
equipment.
B. CONSTRUCTION SCHEDULE
14. The construction phase of the Subproject is expected to last for a period of 18 months
from April 2019 to August 2020 following the detail schedule presented Table 4 below:
15. This updated EMP is based on detailed engineering design and sets out measures based
on identified impacts in the IEE to avoid or mitigate the negative impacts on environment.
Measures covers the different phases of the subproject as follow: pre-construction, construction
and operation. It outlines mitigation and other measures that will be undertaken to ensure
compliance with ADB SPS and national environmental regulations to reduce or eliminate adverse
impacts.
16. The EMP has been structured, in accordance with ADB’s format as follows:
- Section 1: Introduction
- Section 2: Institutional Arrangement and Responsibility
- Section 3: Summary of Potential Environmental Impacts (incl. Public Consultation and
GRM)
- Section 4: Environmental Impact Mitigation Plan
- Section 5: Monitoring Plan
- Section 6: Budget for EMP implementation
- Section 7: Emergency response plan
- Section 8: Institutional capacity review and needs
- Annexes
the construction contract, that the EMP is implemented, and that the contractor(s) abide by the
EMP.
29. The ADB is responsible for monitoring to ensure subproject meets the environmental
safeguards of the SPS (2009). ADB is to review the project’s progress reports and semi-annual
environmental safeguards monitoring reports and undertaking review missions to ensure the
project is implemented in line with project environmental safeguard requirements, SPS (2009)
and Royal Government of Cambodia regulations and guidelines.
30. The PIU supported by the PIAC Environment Consultants will provide environmental
inputs for the quarterly project progress reports and prepare semi-annual safeguard monitoring
reports. The PMU is responsible for submittal of reports to the EA and ADB.
31. The roles and responsibilities for Environmental Management as presented in the PAM
are summarized in Table 5 below:
PIAC i. For works procured as Design and Build contracts, review designs in detail, checking
for compliance with requirements in the EMPs, and advise PMU of any necessary
revisions to the IEE and EMP prior to approval;
ii. Support PMUs with update of IEEs/EMPs following detailed engineering design;
iii. Check Bill of Quantities to ensure Contractors made adequate provisions for
environmental mitigation and monitoring;
iv. On behalf of PMUs and working with PIUs supervise the civil works packages and
implementation of EMP mitigation and monitoring measures.
PIAC i. Review the detailed designs prepared for each subproject for compliance with the
Environment EMPs prepared during the PPTA. Update the IEEs and EMPs to reflect changes,
Specialists modifications and additions that have potential impacts during construction and
(International operation phases of the subprojects.
and National) ii. Examine the CEMPs prepared by contractors for compliance with the EMP and advise
PMU of revisions that need to be incorporated prior to approval and commencement of
civil works;
iii. Ensure that all associated project facilities have the required permits prior to
commencement of civil works;
iv. Brief PIAC engineering and PIU supervision staff on EMP provisions and provide
checklists to ensure that they will be able to adequately supervise on a day-to-day
basis the contractors and subcontractors about proper and timely implementation of
mitigation measures specified in the EMP;
v. Monitor implementation of environmental mitigation measures and environmental
performance of contractors based on the EMP schedule and assist MPWT in the
preparation of semi-annual environmental monitoring reports for submission to ADB;
vi. Undertake training for the MPWT/PMU and PIU staff on environmental management
and monitoring, to build their capacity in these areas. The training will be implemented
through on-the-job training and workshops based on the provisions of the EMP; and
vii. Ensure that the affected stakeholders and sensitive receptors (e.g. hospitals, schools,
and temples) are regularly updated on project activities and are aware of the multiple
entry points to the project safeguards GRM.
Construction i. Prepare detailed designs for the subproject in compliance with the EMPs
Contractor ii. Appoint an Environment, Health and Safety Officer to manage, monitor and report on
EMP implementation;
iii. Prepare site-specific CEMP containing the method statements for compliance with
environmental management standards in the EMPs;
iv. Allocate sufficient funding for proper and timely implementation of environmental
mitigation and monitoring measures;
v. Conduct daily inspection of the site and ensure the implementation of the CEMP during
the construction phase;
vi. Prepare/submit monthly reports on mitigation and monitoring activities to the PMUs
through the PIAC; and
vii. Act as the local entry point for the project GRM, conduct immediate investigation of any
complaint, report all complaints and their resolution to the PMUs. Ensure the timely
and appropriate resolution of the complaint or incident in accordance with the GRM.
ADB i. Monitor and supervise the overall environmental performance of the project, review the
semi-annual environmental monitoring reports and disclose the reports on ADB
website in accordance with ADB Public Communications Policy (2011); and
ii. Conduct missions to review environmental compliance and provide advice on
corrective actions.
A. ENVIRONMENTAL IMPACTS
32. The potential impacts of the Siem Reap Replacement Interceptor Sewer Subproject from
the IEE are summarized in the Table below. The IEE indicates that potential environmental
impacts of the infrastructure developments are primarily construction related and can be
effectively mitigated.
33. Sensitive areas: There is no protected areas and no cultural heritage locate near the
project, there are some sensitive areas located in along the project alignment, which may be
affected by the subproject are as follows (significant aspects in brackets):
• Old Market: located between manhole No 6, No 7 and No 8 (access and dust)
• School: Gold primary school locates near manhole No 18-19, and Build Bright university
locates near manhole No. 16-17 (access, noise, and dust)
• Service Station: Depot Tela service station is located on the right site at manhole No. 25,
and Tata service station is located near manhole No. 21 (access)
• Drainage canal: the canal runs along the subproject alignment from manhole No. 15 to
No. 27 (water quality – silt/sediments, accidental spill)
• Pagoda: Chowk Pagoda located near manhole No. 27 (access, noise, and dust).
Spoils Moderate ▪ Total excavated soil and mud is about 115,174 m3.
3
generation ▪ This spoil will be transported by truck to the disposal areas.
Moderate ▪ Domestic waste from worker camp: Domestic waste
generated from workers’ camps usually includes organic
waste, paper, carton box, fecal waste. There is an
Generation of estimated workforce of 30 people estimated to generate 15
4
solid waste kg of domestic waste a day. This should be collected and
managed by a registered service provider and disposed at
a licensed dumpsite to avoid water, soil pollution and
sanitation issues in surrounding worker camps.
7 Water quality ▪ Waste water from worker camp: Total waste water per day
will be around 2,400 liters. This waste water has a high
organic substance. However, this campsite is located in
the Siem Reap city and its wastewater will be collected by
the collection system of the city.
Existing Moderate ▪ Existing structures/facilities such as underground
facilities structures, above-ground structures near the trenches,
trees, power transmission poles, telecom poles,
underground pipelines, etc. may affected by the
construction activities.
8
▪ Some public assets including electric pole (2), electric line
(3 places), electric underground, drainage (3), water
supply pipe (underground), telecommunication line
(underground) will be affected during the civil work for
working pit.
Moderate ▪ Traffic congestion caused by: construction works crossing
of main roads with high density traffic flow, equipment and
Traffic vehicles coming in and out from the construction sites,
9 congestion material storage areas and casting yards, and excavations.
and road safety ▪ Road safety might be affected due to changes in road
conditions, loss of roadside furniture, warning systems and
lightning.
Moderate ▪ Electricity use: The subproject will install power
The risks of
transformers in the areas to supply electricity for
occupational
construction activities including casting, cutting and
10 and community
welding. Electric equipment, line system and electric line at
health and
the site are often very complicated, it shall easily cause
safety due to
electrifying or leaking out and lead to electric shock to
1 Seminar on Management and Maintenance for the Inland Waterways from 28-30/01/2015 organised by Vietnam
Inland Waterways Administration under Northern Delta Transport Development Project (NDTDP) funded by World
Bank
C Operation phase
Risk of failure Moderate ▪ Risk of failure of sewage pipes would cause release of
or defects untreated sewage and release into waterways, entailing
1 causing release human health hazards.
of effluent from
the pipe
Pollution of
Moderate ▪ Risk of pollution due to lack of trainings in O&M,
groundwater,
inspections of the sites, obstruction to access for
land, or surface
2 inspections
waters from
leaking pipes
Construction phase
Disseminate Community, Informing communities During the Covered by the
information to PMU, PIU, about construction construction counterpart
local community local activities, works phase fund (PMU is
via public environmental schedules, potential responsible for
loudspeakers, officers, negative payment).
announcements Contractors impacts on
on environment,
newspapers environmental
management
measures and how to
use the
community grievance
line.
Community Community, PMU, PIU and
redress PMU, PIU, Contractors shall have
mechanism is Contractors to reply to during the
established by all complaints,
the PMU questions or concerns
of local construction
communities, faculties
and students about the
phase
works.
35. The stakeholder consultation strategy was developed as part of the IEE submitted in June
2017. Consultations took place at PPTA stage (June 2017) and conceptual design stage
(September 2018) as well as at the detailed engineering design stage (May 2019) and since
Construction started (June 2019).
36. Consultation began early in the project preparation stage with visits to the subproject sites
and discussions with the provincial officers relating to the consultants who prepared the pre-
engineering designs. Consultations were organized to occur in an atmosphere free of intimidation
or coercion, was gender inclusive and enabled the incorporation of all relevant views into the
project design and arrangements for implementation. The consultation involved Ministry of Public
Works and Transport (MPWT) and their provincial agencies and utility operators, and local
municipal and sangkat/commune officials and village representatives.
37. Transparent consultation processes were also adopted for public village meetings during
the socio-economic surveys (SES) and focus group discussions (FGDs) and during subsequent
public meetings to explain the pre-engineering designs and for disclosure of land acquisition and
resettlement and the likely environmental and social impacts. The environmental considerations
have therefore been identified with the provincial authorities, the commune/sangkat authorities
and their communities. The information made available includes the specific activities, schedules,
anticipated environment and social impacts and mitigation measures and monitoring processes.
Comment received during the village meetings and the other discussions with respect to
environmental concerns have been incorporated into the mitigation measures proposed for
detailed design and implementation. All persons met have been informed about the subproject in
general and the environmental aspects in particular. House to house consultants with the local
residents and interviews with Sangkat Councils and relevant provincial department were held
during field visits in September 2018 by the Study Team together with the MPWT and DPWT
representatives.
38. For the Siem Reap subproject, at preliminary design stage, the main concerns expressed
in the socio-economic surveys (during which interviewed 253 people, including 150 men and 103
women) related to disruption to business and livelihood, traffic congestion and disruption to
property access as follows: (i) road access (6%); (ii) affected business (20%); (iii) problems with
traffic (12%); (iv) difficulty in accessing road (8%); (v) difficulties in managing business (3%); and,
(vi) difficulty in moving back and forth.
39. The Environmental Safeguard Specialist and the Social Safeguards and Resettlement
Specialist conducted another round of consultations in May 2019. These included (1) house to
house consult with residents of the project area, (2) face to face interviews with chief of sangkat,
sankat councils and chief of village, (3) public consultation meeting with Sangkat, chief of all
village (Svay Dangkum Sangkat), relevant provincial department and AHs.
40. The primary concern of the public of the subproject in Siem Reap that were highlighted
during the third round of consultation (May 2019) related to traffic jam, business disruption, noise
and public assets disturbances (i.e. electric lines, water supply pipes, telecommunication line
etc..).these will be carefully considered and any complaints handled during construction. .
41. Consultations will continue to take place throughout construction, and operation of
completed subproject components in Siem Reap and any concern will be reported upon in the
environmental and social safeguards monitoring reports (monthly, quarterly, semi-annual).
42. The detailed engineering design of the sewage system was completed in February 2019
and was followed in May 2019 by a third round of public consultation (including information
meetings, discussion with relevant departments and local authorities, house-to-house
consultation with residents living along both sides of the alignment areas etc.). The main concerns
that were raised related to traffic jam, business disruption, noise and public assets disturbances
(i.e. electric lines, water supply pipes, telecommunication line etc.).
43. The GRM comprises: (i) a set of clear procedures for the project to receive, record, and
address any concerns which are raised; (ii) specific contact details for individuals at the commune
chief, PMUs, PIUs or contractors. The objective the Grievance Redress Mechanism is to resolve
complaints as quickly as possible and at the local level through a process of conciliation; and, if
that is not possible, to provide clear and transparent procedures for appeal. This section presents
the information and arrangement appeal procedures regarding eligibility and entitlements.
44. Grievance redress mechanism addresses both informally and formally raised grievances.
Informally, an AP can approach the Contractor (during construction) or the Operator (during
operation) directly to lodge complaint either by him/herself or with assistance from a third party of
his/her choice.
45. A Provincial grievance redress committee (PGRC) is established for the Siem Reap
province and in charge of any GRM for the subproject. The committee’s contact details are
included in Table 8. The PGRC has the power, at the administrative level, to make binding
decisions on the resolution of eligible complaints. Details of the GRC are included in the Project
Information Booklets (PIBs) and distributed to affected communities during the consultations. The
GRM guidelines, including procedures and forms in Khmer language are distributed as an
attachment to the PIB. The PGRC comprises the members presented in the following table.
46. The graph in Figure 4 explains the flow from AP lodging of a complaint and the different
steps depending on the response given by competent authorities/institutions.
47. The grievances will be handled thorough a 4 Step formal approach detailed below.
First Step (Village or Commune Level): APs/ AHs can present their complaints or
grievances verbally or in writing to the Village or Commune Chief or Contractor and project
directly. The Village or Commune Chief will be obliged to provide immediate written
confirmation of receiving the complaint and also to advise project. If after 15 days the
aggrieved APs do not hear from the Village or Commune Chief, or if they are not satisfied
with the decision taken by the first stage, they may bring the complaint to the District Office.
Second Step (District Level): The District office has 15 days within which to resolve the
complaint to the satisfaction of all concerned. If the complaints cannot be solved in this
stage, the district office will bring the case to the Provincial Grievance Redress Committee.
Third Step (Provincial Level): The Provincial Grievance Redress Committee meets with
the aggrieved party and tries to resolve the complaint. Within 30 days of the submission
of the grievance, the Committee must make a written decision and submit a copy of the
same to the project, and the AH.
Fourth step (Court of Law): If the complainant does not hear from the PGRC or is not
satisfied, he/she can bring the case to Provincial Court. The Court will make a written
decision and submit copies to the executing agency. If any party is still unsatisfied with the
Provincial Court judgment, he/she can bring the case to a higher-level court. However,
MPWT where is the project located are responsible for participating/witnessing in all steps.
48. At any time, an AP may contact ADB (Southeast Asia Department) directly, including the
ADB Cambodia Resident Mission.
49. If the above steps are unsuccessful, persons who are, or may in the future be, adversely
affected by the project may submit complaints to ADB’s Accountability Mechanism2. The
Accountability Mechanism provides an independent forum and process whereby people
adversely affected by ADB-assisted projects can voice, and seek a resolution of their problems,
as well as report alleged violations of ADB operational policies and procedures. The
Accountability Mechanism is a last resort mechanism. Project-affected persons are encouraged
to first address the issue with available grievance mechanisms at the project level, and they are
required to make good faith efforts to address the issue with the relevant ADB operations
department prior to submitting complaints to the Accountability Mechanism.
50. In addition, the grievance redress mechanism dealing with the environmental impacts
during construction will also be established with grievance logs maintained at the contractor’s
office and records kept on the grievances received per type and their status. The information
about both mechanisms will be circulated during various consultation events throughout the
project cycle, including those that will be conducted during the detailed design stage.
2 https://www.adb.org/site/accountability-mechanism/how-file-complaint
51. The EMP mitigation measures are specified in Table 9. The plan identifies potential environmental impacts, proposed mitigation
measures, responsible parties, location, and timing for Pre-construction, construction and operation phases for the Siem Reap
subproject.
Potential Responsibility
Subproject Activity
Environmenta Proposed Mitigation Measures Location Timing
Activity Reporting
l Impacts Supervision Implementation
PRE-CONSTRUCTION PHASE
Material storage Resettlement - Material Before Monthly PIA, PMU Contractor
1. The Contractor will coordinate with related
areas, worker temporary storages constructio
authority and local people to undertake inventory
camp areas, n
for the loss of land and asset;
Worker
2. The Contractor will negotiate with local people camp,
for compensation base on the loss and time for
occupation.
Equipment Threat to Constructio Before daily PIA, PMU Contractor
3. Provide warning signs indicating the works
transportation Public safety n area, constructio
with 500 m distance from worksite.
connection n, during
4. Provide signals and/or flag controls, roads constructio
adequate lighting, fencing, signage and road n
diversions.
5. Contractor responsible for maintaining
uninterrupted access by always keeping at least
one lane open
UXO survey, & Threats to All Beginning Once EA/GoC Contractor GoC
6. Consultation with local authorities, municipality
removal surrounding constructio of and CMAC
or government agencies, Sangkat, and village
communities n sites. subproject
chiefs has not identified any potential risk of
and workers UXO. Where unexpected UXO are encountered
safety work is to cease and clearance and
decontamination is to be undertaken by a
registered agency / Cambodia Maine Action
Center (CMAC) to conduct demining survey.
Potential Responsibility
Subproject Activity
Environmenta Proposed Mitigation Measures Location Timing
Activity Reporting
l Impacts Supervision Implementation
CONSTRUCTION PHASE
Air quality and Constructio During daily PIAC, PMU, PIU Contractor
dust 7. When entering and exiting the construction area,
n areas, constructio
emissions the contractors has to wash vehicles at
material n
appropriate location.
storage
8. Dust suppression by water spraying: the areas
Contractor will frequently spray water on the
access road to reduce dust concentration in
the air, in particular in dry weather and to
dampen all materials during dry and windy
weather. Due attention to sensitive receptors
Transportation (incl. Old Market, Gold Primary School,
construction Chowk Pagoda).
material and 9. Establish dust screens around construction
spoils; pits and manholes and at sensitive receptors
(incl. Old Market, Gold Primary School,
Produce Chowk Pagoda).
construction
materials; 10. Dump trucks transporting raw materials to
and from the site shall be covered by
Construction tarpaulins, or other acceptable types of
activities; cover, to prevent debris and/or materials
falling from or being blown off the vehicle(s).
Operation 11. Position any stationary emission sources (e.g.,
construction portable diesel generators, compressors, etc.) is
equipment and about 100 m far from sensitive receptors
vehicle including school and residential area;
12. Conduct periodic checking of all equipment
and machinery on site and make all
necessary corrections and/or repair to
ensure compliance with safety and air
pollution requirements and properly record
checking, correction results.
13. Provide sufficient personal safety devices
such as face mask, gloves and protective
clothes to protect workers.
Construction Impact on local Along the During daily PIAC, PMU, PIU Contractor
51. Selecting the reasonable working time, when the
activities occupation and project constructio
construction is passing through sensitive areas
income alignment n
such as: market, restaurant, hospital, and
school. Should be not constructed in (peak hours
or more activities).
52. Ensure daily access to markets, guesthouses,
restaurants for reduce impact on their income.
Ensure access is maintained throughout the
construction period to Gold Primary School,
Depot Tela Service Station, and Chowk
Pagoda.
53. Try to finish construction works as soon as the
construction work can do, when sections are
blocked.
54. Provide construction work job opportunities to
local people, especially affected people.
55. Contractor responsible to ensure business and
residents have daily access.
Potential Responsibility
Subproject Activity
Environmenta Proposed Mitigation Measures Location Timing
Activity Reporting
l Impacts Supervision Implementation
OPERATION PHASE
Operation of Operator 56. Operators trained to recognize risks and hazards Wastewate Fulltime Biannual PDPWT
Wastewater occupational when entering for maintenance operations (i.e. r
system health and confined space training). operators trained to Manageme
safety recognize risks and hazards when entering for nt in Siem
maintenance operations (i.e. confined space Reap
training, etc.).
57. Personal safety equipment (PPE) issued and
Community
worn. Health and safety recognized as primary
health and
employer responsibility.
safety hazards
V. MONITORING PLAN
52. Environmental monitoring activities of the civil work include: (1) monitoring the EMP
compliance, and (2) monitoring of environmental impacts caused by the Sub-project activities.
Environmental impact monitoring will be implemented with major concentration on the
construction phase.
(i) Environmental Performance Monitoring is conducted to evaluate compliance with
standard operating procedures, national standards on environment and technical
specifications. The main purpose of environmental performance monitoring is to
ensure that all proposed mitigation measure will be applied by the contractors
during the construction time.
(ii) Environmental impact monitoring is conducted to evaluate the impacts by the sub-
project activities on ambient environmental quality.
53. Responsibilities and budget for environmental impact monitoring during the construction
and operation phases are identified as follows.
▪ Construction phase
- All mitigation measures that belong to the contractor's responsibilities shall be
implemented by the Contractor. The costs are included in the civil contract between
construction contractor and PMU.
- The contractor shall bear the costs for environmental monitoring required to document
compliance with environmental standards during the construction phase, including
sample taking and analysis, and preparing reports.
▪ Operation phase
- During the operation and maintenance phase, the works operation and management unit
will provide budget for implementing mitigation measures, capacity strengthening
training, and staff salary.
54. The environmental monitoring plan for the EMP is provided in the Table 11 below. The
purpose of the monitoring plan is to determine the effectiveness of the impact mitigations, and to
document any unexpected positive or negative environmental impacts of the subproject. The
monitoring plan focuses on the construction and post construction operation of the subproject
components, and consists of environmental indicators, the sampling locations & frequency,
method of data collection, and responsible parties, and estimated costs are tabled separately.
The first response to any complaint or issue will be enforcement of management and mitigation
measures. If an issue persists monitoring by the Ministry of Environment will be commissioned by
the PIAC at the expense of the contractor.
2. Relocation of Public Work area Site visit, Prior to start of For each event PIAC Contractor
Facilities Assets confirmation with work
coordinated with relevant
relevant departments departments
3. Affected surface Rivers or streams Field sampling In response to For each event PIAC Contractor
water quality TSS, close to Using field and complaints and in
heavy metals (As, Cd, construction/workers analytical cases of discharge
Pb,) total & fecal camp methods adopt the following
coliform, pH, DO, COD, approved by procedures. First
BOD5, temperature, MOE; upstream response:
NH3, and other nutrient and enforcement of
forms of N & P downstream. management and
compared to standards mitigation
specified in Sub-decree measures
on Water Pollution If issue persists
Control, 1999 (No. 27 monitoring by
ANK.BK) Ministry of
Environment
commissioned by
the PIAC at the
expense of the
Contractor.
4. Implementation of Work area Site visit, Quarterly (on a For each event PIAC Contractor
construction phase interviews with regular basis)
Responsibility
Environmental Means of Supervision /
Location Frequency Reporting
Indicators Monitoring Implementation
Supervision Implementation
environmental local residents, Random checks
mitigation measures coordination and to validate
Note: Implementation of with concerned complaints
EMP measures agencies
monitoring should be (e.g. MCAFA,
done at least weekly local traffic
by the contractors, and authorities, etc.)
monthly by
PIAC/SEU
5. Disclosure of GRM, All project sites Confirm GRM, Prior to Once PIAC Contractor
updated IEE/EMP and updated commencement of
construction activities IEE/EMP and works
and schedules construction
schedules are
disclosed to the
public
6. Noise in dB(A) Work area Noise In response to For each event PIAC Contractor
compared to standards measurement complaints adopt
specified in Sub decree the following
on the Control of Air procedures. First
Pollution and Noise response:
Disturbance, 2000 (No. Enforcement of
42 ANK.BK) management and
mitigation
measures enforced
If issue persists
monitoring by
Ministry of
Environment
commissioned by
the PIAC at the
expense of the
Contractor.
Responsibility
Environmental Means of Supervision /
Location Frequency Reporting
Indicators Monitoring Implementation
Supervision Implementation
7. Total suspended Work area Field sampling In response to For each event PIAC Contractor
particulate/dust complaints adopt
compared to standard the following
specified in Sub decree procedures. Initial
on the Control of Air response:
Pollution and Noise Management and
Disturbance, 2000 Mitigation
(No.42 ANK.BK) measures enforced
If issue persists
monitoring by
Ministry of
Environment
commissioned by
the PIAC at the
expense of the
Contractor.
8. Other parameters to Locations to validate Field sampling In response to For each event PIAC Contractor
be sampled, as complaints or where complaints
appropriate, to validate pollution occurred
complaints and due to the project
pollution event(s) due to (e.g., fuel spill)
project activities
Responsibility
Environmental Means of Supervision /
Location Frequency Reporting
Indicators Monitoring Implementation
Supervision Implementation
B) regular
reporting by
contractors/PMU
Operation of Sewer System
1. Workers and public On properly of Regular record Continuously For each event Siem Reap Wastewater
injury associated with wastewater keeping
wastewater treatment treatment plant and
plant and pipeline pipeline
2. Wastewater At finalized effluent Using field and Continuously Annual Siem Reap Wastewater
discharge quality: TSS, discharges analytical
heavy metals (As, Cd, methods
Pb) oil and grease, total approved by
& fecal coliform, pH, MOE
DO, COD, BOD5,
temperature, TDS, NH3,
NH4, other nutrient
forms of N & P, sulfides
surfactants.
B. REPORTING
3 Contractor Environmental Management Plan developed from EMP in contractor bidding document
57. Supervision of EMP Implementation by PIAC: The cost for PIAC to supervise EMP
implementation in accordance with the EMP and the project bidding and contractual documents
is integrated in the contract package with the PIAC.
58. Implementation of EMP by Contractor: The cost for organization, training,
dissemination, procurement, operation of equipment, and labor for implementation of mitigation
measures in and out of the site in accordance with the EMP and project bidding and contractual
document requirements is integrated in the construction package.
59. Environmental protection and monitoring of compliance with the Environmental
management Plan (EMP) for the proposed works including the preparation, approval and
application of Contractor’s Environmental Management Plan (CEMP) is $77,300 as part of the
Contractor’s contract4. Any required control monitoring by the Ministry of Environment to
document compliance with Environmental Standards in case of complaints, will be commissioned
by the PIAC at the expense of the Contractor.
60. The Contractor must develop emergency or incident response procedures during
construction. In the operational phase the operator/civil authorities will have responsibility for any
emergencies or serious incidents. The construction phase should ensure:
(i) Emergency Response Team (ERT) of the Contractor as initial responder;
(ii) The Town fire and police departments, emergency medical service, the Department of
Public Health (DPH), collectively referred to as the External Emergency Response Team
(EERT), as ultimate responders.
61. The Contractor will provide and sustain the required technical, human and financial
resources for quick response during construction. The roles and responsibilities for emergency
incident repose are presented in
62. Table 12.
63. The ERT will be led by the senior Contractor engineer (designated ERTL) on site with a
suitably trained foreman or junior engineer as deputy. Trained first-aiders and security crew will
be the core members of the ERT. The Contractor will ensure that ERT members are physically,
technically and psychologically fit for their emergency response roles and responsibilities.
Contractor Resources
• Provide and sustain the people, equipment, tools & funds
necessary to ensure Subproject’s quick response to emergency
situations.
• Maintain good communication lines with the EERT to ensure
prompt help response & adequate protection, by keeping them
informed of Subproject progress.
64. Prior to the mobilization of civil works, the Contractor, through its Construction Manager,
ERTL, in coordination with the PMU/PCU, will meet with the ultimate response institutions to
discuss the overall construction process, including, but not limited to:
i. Subproject sites;
ii. construction time frame and phasing;
i. any special construction techniques and equipment that will be used;
ii. any hazardous materials that will be brought to and stored in the construction premise
and details on their applications and handling/management system;
iii. The Contractor’s Emergency Management Plan
iv. Names and contact details of the ERT members.
65. The objective of this meeting is to provide the ultimate response institutions the context
for:
i) Their comments on the adequacy of the respective Emergency Management Plans
ii) Their own assessment of what types, likely magnitude and likely incidence rate of
potential hazards are anticipated
iii) The arrangements for coordination and collaboration.
66. To ensure effective emergency response, prior to mobilization of civil works, the
Contractor will:
i) set up the ERT;
ii) Set up all support equipment and facilities in working condition
iii) Made arrangements with the EERT;
iv) Conduct proper training of ERT members, and encouraged and trained volunteers
from the work force;
v) Conducted orientation to all construction workers on the emergency response
procedures and facilities, particularly evacuation procedures, evacuation routes,
evacuation assembly points, and self-first response, among others; and
vi) conducted drills for different possible situations.
response mechanism, the emergency response equipment, tools, facilities and supplies. Drills
and reminders will take place regularly, the former at least every two months and the latter at least
every month.
A. ALERT PROCEDURES
68. Means of communicating, reporting and alerting an emergency situation may be any
combination of the following: i) audible alarm (siren, bell or gong); ii) visual alarm (blinking/rotating
red light or orange safety flag); iii) telephone (landline); iv) mobile phone; v) two-way radio; and
vi) public address system/loud speakers. Some rules relative to communicating/alerting will be:
(i) Whoever detects an emergency situation first shall immediately:
• call the attention of other people in the emergency site,
• sound the nearest alarm and/or
• Report/communicate the emergency situation to the ERT.
(ii) Only the ERTL and, if ERTL is not available, the Deputy ERTL are authorized to
communicate with the EERT. Exceptional cases to this rule may be necessary and
should be defined in the Emergency Management Plans.
(iii) When communicating/alerting an emergency to the EERT, it is important to provide
them with at least: i) the type of emergency situation; ii) correct location of the
emergency; ii) estimated magnitude of the situation; iii) estimated persons harmed;
iv) time it happened; v) in case of a spill, which hazardous substance spilled; and
vi) in case of fire and explosion, what caused it. Such details would allow the EERT
to prepare for the appropriate response actions.
(ii) All Subproject sites should have good access to any combination of audible and visual
alarms, landline phones, mobile phones and two-way radio communication at all
times.
(iii) Contractor’s construction vehicles should also be equipped with the appropriate
communication facilities.
70. Table 13, Table 14 and Table 15 suggest general procedures that will be refined in the
final EMP during detailed design and described in more detail in the Emergency Management
Plans of the Contractor.
71. The IEE reviewed the capacities for environmental management broadly and made the
below observations.
72. Environmental management within the General Department of Public Works within
MPWT: a) There is no strong mandate for environmental management in the department, other
than the responsibilities flowing from, but limited to specific projects, b) The MPWT now has a
Social and Environmental Office, established with support of recent transport sector projects, c)
Technical staff do have some capacity to manage infrastructure on a broad, strategic level as well
as on a day to day level, d) To be able to review environmental assessments, technical staff
members need to acquire an understanding of the principles and processes of environmental
assessment.
73. Capacities relating to environmental management during construction: MPWT staff have
some experience or capacity in the implementation of EMPs, been acquired mainly on past or
ongoing projects in the sector, but few staff are familiar with the requirements. Support for EMP
implementation, including inspection of ongoing and completed work to check for compliance with
EMP provisions and preparation of progress reports to government and ADB, will be provided by
the implementation consultants. In order to be able to undertake these functions, technical staff
from each ministry need to have an understanding of contractual arrangements for construction,
and the provisions under each EMP.
74. Few contracting firms in Cambodia have experience of environmental management,
particularly preparation and implementation of CEMPs. Guidance in CEMP preparation can be
provided to contractors by the implementation consultants.
75. Capacities relating to operation and maintenance of infrastructure: Adequate operation
and maintenance of water and sanitation infrastructure has not taken place to the standard and
extent necessary to keep sanitation infrastructure in operable condition. This is one of the reasons
that the proposed subprojects are necessary. The ministry requires assistance in ensuring
competent operation, regular and periodic maintenance and phased replacement and upgrading
of assets.
76. In accordance with the PAM, the PMU will include the following staff of relevance to
environmental and social management: Social Safeguards Officer, Environmental Safeguards
Officer, and Gender Officer. The PIUs will according to the PAM include a Social and
Environmental Safeguards Officer.
Table 1: Water Quality Standard in Public Water Areas for Bio-Diversity Conservation
No Parameter Unit Standard Value
A. River
1 pH mg/L 6.5 – 8.5
2 BOD5 mg/L 1 – 10
3 Suspended solid mg/L 25 – 100
4 Dissolved oxygen mg/L 2.0 - 7.5
5 Coli-form MPN/100 mL < 5000
B. Lakes and Reservoirs
1 pH mg/L 6.5 – 8.5
2 COD mg/L 1–8
3 Suspended solid mg/L 1 – 15
4 Dissolved oxygen mg/l 2.0 - 7.5
5 Coliform MPN/100 mL < 1000
6 Total nitrogen mg/L 0.1 – 0.6
7 Total phosphorus mg/L 0.005 – 0.05
C. Coastal water
1 pH mg/L 7.0 – 8.3
2 COD mg/L 2–8
3 Dissolved oxygen mg/L 2 – 7.5
4 Coliform MPN/100 mL < 1000
5 Oil content mg/L 0
6 Total nitrogen mg/L 0.2 – 1.0
7 Total phosphorus mg/L 0.02 – 0.09
Note: l = liter; mg = milligram; ml = milliliter
Source: Annex 4 of Sub-decree on Water Pollution Control, 1999
5
Note: This standard applied to evaluation of ambient air quality and to monitoring of air pollution status.
Table 3: Maximum permitted noise level in public and residential area (dB)
Period
No Location
06:00 to 18:00 18:00 to 22:00 22:00 to 06:00
Silence Area
1 - Hospital
2 - Library
45 40 35
3 - School
4 - Nursery
Resident Area
1 - Hotel
2 - Administration place 60 50 45
3 - House
Commercial, services areas and 70 65 50
mixed small industrial factories
Intermingling in residential areas 75 70 50
Table 5: Effluent Standard for Pollution Sources Discharging Wastewater to Public Water
Areas or Sewer
Allowable Limits for Pollutant
Substance Discharging to
Parameters Unit
No. Protected Public Public Water Area
Water Area and Sewer
°
1 Temperature C <45 <45
2 pH mg/L 6-9 5-9
3 BOD5 ( 5 days at 20 °C) mg/L <30 <80
4 COD mg/L <50 <100
5 Total suspended solids mg/L <50 <80
6 Total dissolved solids mg/L <1000 <2000
This report is to be completed by the PIU with assistance from Project implementation assistance
consultant and PMU. The report forms part of the regular reporting of PIU to PMU and ultimately
the EA and ADB.
Summary:
c. Other activities
b. Public Safety
Responsibility and
Issue Required Action Resolution
Timing
Old Issues from Previous Reports
Summary:
• Number of new grievances, if any, since last monitoring period: ____
• Number of grievances resolved: _____
• Number of outstanding grievances: _____
6. Conclusion
7. Attachments
• Consents / permits
• Monitoring data (water quality, air quality, etc.)
• Photographs
• Maps