Philippines - First National Roads Improvement and Management Program Project (Phase 1NRIMP) : environmental assessment (Vol. 5 of 5)

1K ( rUMBCEOM SOCIETE FRANCAISE D'INGENIERIE P.O. Box 68 La Trinidad Municipal Post Office 2601 Km 5, La Trinidad, BENGUET Phone: +63743092750; Fax: +63743092773; E-mail: bceombbb@moicom.com BBB/CA/T-131 &,, AV1&v\0%(V-16A CPH - Pc036t0'Ve< Baguio, Ma5, 2001 MR. SANGSOO KIM E287 Project Manager DAEWOO Construction Philippines, Inc. Volume 5 Camp 30, Barangay Topdac, Atok Benguet Province RECEIVED DATE: b-/cq61 Io Subject: Environmental Management Plan B Y YVKon DAEWOO CORPORATION Dear Sir: Please find attached herewith our comments on the document referenced above. This document must be revised in accordance with the previous provisions stipulated in the agreed EMP between DPWIH-DENR dated July 7, 1999. Unlike a tender document that consists of a listing of intentions, the final document must describe specific actions to be taken in each case. Please be guided by the attached comments in finalizing this Plan. Veryt DE ALLOUCHE Team Leader cc,t tr.M9lrr)Acralt N, pjnne -2 --gcu\19e FiLE COPY SW Penthouse 3, Tow 0 (odloop TOwA" lhad Offic: Place da ?Fru MongIe - 7t286 P.O. Boa 6 Mmiao Pod Officc Amber Awnuc. Of gs ComnP[ Pan COY, PHJ PPIDESE OrYANCOURT Cedcx FRANCE 2601 Km 5, LA Tri, dad, BENOUET Phone: .6326347218 to 20, F= .6326335149 Phone: .3313012430, Fax: .33130121095 Phone: .63743092750, Fax: -63743092M773 E-rang: b1&,t~iqnAn1olI E-maI: bcoaceBbcoonfr E-ng: bccombbb&,w c.m  BCEOM5 BCEOM SOCIETE FRANCAISE D'INGENIERIE P.O Box 68 La Trinidad Municipal Post Office 2601 Km 5, La Trinidad, BENGUET Phone: -+63743092750; Fax: -f63743092773 ; E-mail: bceombbbra)rnozoom.com BBB/CA/T-141 Baguio, May 15, 2001 MS. CRISTE Z. NAVIDA Project Manager II Environmental Impact Assessment Project Office (EIAPO) 5/F DPWH Central Office Bonifacio Drive, Port Area, Manila Reference Construction Supervision Services for the Baguio - Bontoc - Banaue Road (Halsema Highway); La Trinidad - Mount Data Section Subject Contractor's Environmental Management Plan Dear Madame, Please find attached herewith, for your information, a copy of the Contractor's Environmental Management Plan, and of our comments. Your suggestions are welcome to help in finalizing this document. UEALLOUCHE Team Leader cc: Mr. Baliamen Mamainte - Director - IBRD-PMO Mrs. Lynne Reyes-Sauvage - Country Manager - BCEOM File SW Pacwe 3, Tower B Goddloop Towem Head Office: Place des Fnren Monlgoficr - 78286 Amboe Avnue, O;a Compkex P-Eg City, PHILIPPINES GUYANCOURT Cedex FRANCE Phone: +-636347218 to 20; Fax: +6326335149 Phone: .3313012480a, Fax: *33130121095 E-mna blam-lIti-manla E-anil: bccomIt bnokbmf  Comments on the Contractor's EMP A. Environmental Concerns General 1. Rename EMP to Environmental Protection Plan. In order to be consistent with the Supplemental Specification Clause B4.1 and in order to avoid confusion with the project EMP, the Contractor's Plan should be tided Environmental Protection Plan. 2. Need to tailor Daewoo's corporate EMM to suit local conditions. The text following the EMP schedules and the Environmental Management Manual Attachments are taken from the Additional Infornation submitted after the Tender. I am unable to identify any updating to reflect actual site conditions and organization. It is noted that Page 2 specifically states that the EMP will be based on Daewoo's corporate EMM which will be specifically tailored to suit the project's requirements in all respects. This has not been carried out. Therefore, much of this document is a generic document of very limited application to the project. 3. Additional details needed It is understood that complete details on the layout and the description of mechanical procedures and work operations, particularly for the crushing and batching plants are yet to be provided by the Contractor. Such additional details should be duly approved by the Engineer and should form part of the Contractor's EMP document. Likewise, drainage, sewerage and solid waste plans for work camps and offices should also be submitted and hence should also form part of the Contractor's EMP. Finally, duly approved site development plans of spoil areas and other rehabilitation sites should also be included in the Contractor's EMP. 4. Need to set a system on how the Contractor intends to advocate its EMP to its employees and associates. To solicit full support of the Contractor's employees and associates, and hence ensure proper EMP Plan implementation, the Contractor's EMP should include a section describing the strategies which the Contractor intends to execute so that its employees and associates are inforned of the EMP's objectives and contents. 5. Monitoring and coordination procedures. For effective monitoring, it is suggested that the Contractor submits a quarterly environmental compliance report (based on its EMP) to the Engineer and the MMT for validation and verification purposes. 6. The cover page after the Introduction should state "In accordance with the provisions...'" Specific 1. Specific comments on the EMP schedules are as follows: 4.1 Soil erosion The Palew quarry has been identified as the sole direct source of materials. A crusher is in the process of being erected yet no formal submission has been made. The specific measures to avoid soil erosion should be given. Page I of 4  ii. A listing of proposed spoil disposal areas should be agreed with the Engineer and upon his 'no objection,' these should be listed in the EMP. It is important that this is done now for the whole alignment, it order that spoil disposal areas are available in case of landslips during the coming wet season. iii. A materials balance exercise should be carried out based on best available information and related to fill requirements and individual spoil disposal areas. iv. The main risk of soil erosion will be due to storm events and particularly typhoons. The measures to minimize exposure to storm events should be discussed and referenced to phasing of the Works. Your Construction Programme should be consistent with such measures. v. A secondary and significant risk of soil erosion will be due to your sub-contractor's and petty contractors failing to meet specification requirements. You should discuss what measures you will take to ensure compliance. vi. You should discuss your phasing of bio-engineering works. 4.2 Drainage i. More detail on what temporary drainage will be constructed is required. ii. Your indicator of 'zero pollution and nuisance of any kind' is commendable, but unrealistic. Perhaps a better indicator is 'zero tolerance of avoidable nuisance'. iii. 'Sewerage facilities installed and operational' is a little vague. What facilities are planned? iv. Your batching plant is a potential source of pollution, especially if space is confined. What pollution prevention measures are planned? 4.3 Dust Spillage of spoil / fill materials on haul roads due to overloading is normally a significant source of dust nuisance. Appropriate controls should be applied including covering loads if necessary. ii. Batching and crushing plants are potential generators of dust and hence should be included as an area of concern especially if these facilities are proximate to settlement areas. What measures are being considered by the Contractor to mitigate its adverse effects? Page 2 of 4  iii. The demolition of concrete pavement and its subsequent clearing is another potential generator of dust and noise. What measures should the Contractor propose to mitigate their adverse effects especially in highly congested areas. 4.4 Noise i. What are normal working hours? ii. Will public holidays be worked? iii. Is the Contractor aware of any noise standards, which need to be met? 4.5 Solid Waste Disposal i. What legal waste dumps have been identified by the Contractor? ii. The Contractor's EMP mentioned about the proper disposal of fuel/oil and other solvents. Where does the Contractor intend to bring these waste materials once shipped out from the project site? 4.6 Encroachment and Despoilation i. Temporary tent camps are prohibited. The term 'discouraged' is inappropriate. 4.7 Work Camps i. What work camps have been constructed? ii. What work camps are planned? iii. What control will the Contractor have over the siting and operation of sub-contractors and petty contractor's work camps? Page 3 of 4  B. Health and Safety Concerns 1. A column with a heading "Action" has been added for better clarity. Please refer to the enclosed matrix. 2. On the health and medical assistance preparedness, the Contractor should now be definite in its choice of an accredited hospital in Baguio or Benguet. 3. On excavation hazards, the following are recommended: a) Excavations both for earthworks, road works, drainage and walling should be phased to ensure that impacts from adverse weather are minimized; and b) Where potentially unstable excavations are identified, staging of excavation and backfilling will be applied as mitigating measure. 4. On diseases and infections, cost implications on the use of mineral bottled water for staff and labour should be studied. 5. Under the item of forest fire occurrences, further description should be made on water sprayers as fire fighting equipment. Page 4 of 4  DAEWOO ENGINEERING AND CONSTRUCTION CO. Environmental Management Plan (EMP) Halsema Highway Project (Package 1: La Trinidad - Mt. Data) Probable Objectives/Output Target Impact Management Action Indicators Year L Remarks Impacts Activities/Areas (Mitigation Measures & Controls) Acton4_ II. HEALTH AND SAFETY CONCERNS _______ l _ 1 . Work & non- To ensure the safety Project staff & Provide all necessary personal Provide safety & No serious _ Refer to personal work related & protection against labour force. protective equipment (PPE) such protective accidents and no protective illness & . hazards & accidents as, a minimum high visibility vest for equipment to staff more than 2 _ equipment (PPE). accidents of all staff, labour workers directing traffic protective & labourforce. minor injuries Interim policy force and equipment footwear for workmen undertaking er month. instructions. likewise to the concrete mixing work, protective traveling public & the footwear & gloves for workmen local community. performing voluminous paving works, protective footwear, safety _ _ glasses or goggles & filter masks for workmen undertaking screening, crushing or grinding, hard hats, ear protectors, safety ropes & harness, and all others appropriate to the job as required. _ Ensure incidents & Project/work sites Create standard format of Notification & Log-book up to rPIs refer to accidents are notification, investigation & reporting reporting process date. _ notification, reported/ relayed process. followed and I invistigation & through proper recorded in reporting process. notification to accident log book (Interim policy appropriate instruction). authorities. T Ensure all safety Safety forms to be implemented in Forms used, filled Pls refer to safety concerns on the project which would be &filedfor records forms to be used. inspections, appropriate. purposes. evaluations, audits, ____T ____ etc. are properly Monthly site management meetings Monthly site No previously 1 I Pis. refer to recorded, actioned shall be conducted regularly to all management identified safety l l management site and monitored. department concerned. safety meetings problems to safety meetings conducted occur on site. procedures. 1 5/8/01  DAEWOO ENGINEERING AND CONSTRUCTION CO. Environmental Management Plan (EMP) Halsema Highway Project (Package 1: La Trinidad - Mt. Data) Probal betie/upt Target Impact Management Mntrn/oto Impacts Objectives/Outpt Activities/Areas (Mitigation Measures & Controls) Action Indicators Year Remarks 2. Health & To ensure first aide Project work Contractor shall have to provide & Medical clinic Refer to medical Medical attention to staff, force. maintain throughout the duration of established & _ _ evacuation Assistance labour force in times the project a medical clinic with maintained __ _t_ (accident/persona preparedness of illness, natural, examining room & sickbay throughout the _ I injury) man made, calamities necessary supplies & equipment to duration of the & accidents. be established & located at project. contractors field office at Topdak, Atok, Benguet. __T-__T Employ permanently on site one (1) Hired one (I) fully trained medical nurse, with experienced duties mainly to engage medical trained nurse. duties. Sattelite first aide stations in all work Sattelitefirst aide Provide with first camps & work sites shall be stations _ aide kits. maintained, first aide equipment & maintained mediceines shall be available at all time. Contractor also to arrange an Accredited accredited hospital from Baguio or hospital arranged La Trinidad for project workers which requires hospital medical examination & treatment as recommended by the field nurse & approved by the project manager. Costs incurred for injuries & illness Hospitalization & resulting to work related reasons medicine cost at shall be the contractors expense. Contractors _ _______ expense. ____I_I I Medical nurse & safety officer to Sub-contractors No complaints conduct at least once a month need to be notified from workers. medical paramedics refresher of these courses to staff & project labour arrangements. force. 2 5/8/01  DAEWOO ENGINEERING AND CONSTRUCTION CO. Environmental Management Plan (EMP) Halsema Highway Project (Package 1: La Trinidad - Mt. Data) Probable Ojcie/upt Target Impact Management Mntrn/oto Impacts Objectives/Outt Activities/Areas (Mitigation Measures & Controls) Action Indicators Year | Remarks 3 . Potential To ensure all threat, All work sites. Risk assessment shall be conducted Risk assessment Summarized in _ Pis refer to risk Hazards something which & safety action plans shall be done. method __ assessment would cause an prepared & implemented. statements. __ guidelines. accident will be addressed accordingly. . _ 3a Blasting To ensure the safety Blasting Any scheduled blasting activities Notification_ Traffic notification Hazards of work force vehicles operations shall be notified 48 hrs in advance of scheduled signs to be erected & livestock within the the actual day & time of blasting in complied danger determined writing to all concerned. zone. Blasting engineer be always present Blasting engineer during scheduled blasting. present in all blasting activities. Danger zone shall be determined/ Danger zone ensured that personnel vehicles or determined. equipment livestock are clear. Steps to avoid damaged to property Zero damaged from flying rocks by using blasting to property and _ _ _ materials or other suitable life due to flying blanketing materials or controlled rocks. blasting. _ _ _ A well designed traffic plan during TrafficplanI blasting which would be appropriate implemented or adaptable to the blasting site & vicinities shall be implemented in coordination with the blasting engineer & safety officer. _____________ All blasting activities shall be in Comply to specs & accordance with the specifications & EMP. EMP. 3 5/8/01  DAEWOO ENGINEERING AND CONSTRUCTION CO. Environmental Management Plan (EMP) Halsema Highway Project (Package 1: La Trinidad - Mt. Data) MonitorinatControl Probable betieltpt Target Impact Management Mntrn/oto Impacts Objectives/Output ActivitiesAreas (Mitigation Measures & Controls) Action Indicators 1 Year 4 Remarks 3b Excavation To ensure the safety Road re- All excavation hazards shall be Safety action plan Hazards of work force, alignment carried out in accordance with its implemented vehicles, heavy safety action plan. equipments within the Slope excavation Proper manpower & equipment excavation areas & resources shall be enforced. also the riding public/ Spotters shall be fielded where Spotters commuters. dozers, backhoes, etc. are working mobilized to wam operators of incidental falling rocks & debris & the safety of the riding pubic/ motorist. Traffic control & arrangments shall Traffic control be planned & implemented. implemented Safety of all parties shall be Safety first. considered priority, no other else. _____________ 3c Traffic To achieve minimum Specified working Road closure SOPs shall be referred SOPs complied! Hazards disruption to traffic areas. & in accordance with the technical implemented consistent with the specifications & with the approval of safety of pedestrians, the consultants. _____________ _ construction work Motorists, For the safety of motorists, Traffic control force & vehicular pedestrian & pedestrians, workers, all barricades, signt boards, traffic. workers. fences & such other aides as delineators, & required shall be installed. warning lights installed _______________ Lantems shall be illuminated at night time. Rquired signboards, delineators, & warning lights shall be all in placed as required. _____________ _ Utilization of traffic controllers or Providedflagmen flagmen to direct flow of traffic & with reflec- provided with reflectorred vest & torized vest & radio communication facilities. radio equipment acilities. 4 5/8/01  DAEWOO ENGINEERING AND CONSTRUCTION CO. Environmental Management Plan (EMP) Halsema Highway Project (Package 1: La Trinidad - Mt. Data) Probable Oetieltpt Target Impact Management Mntrn/oto Impacts ObjectivesOutput ActivitiesAreas (Mitigation Measures & Controls) Action Indicators Year __ Remarks All designed sidewalks, jeepney Designs & specs stops, bus stops, & speed reducing implementedand arrangements according to the complied design shall be implemented/complied. 4. Diseases & To ensure a healthy Project work force Environmental sanitation & house Zero diseases Infections work force & to keping on all staff & labour camps, & infections. l minimize/ liminate offices, plants, and other working spread of airborn areas shall be enforced. diseases. Camps, offices, Toilet facilities & adequate water Facilities 1 s 1 plants supply shall b provided, installedl garbage/trash drums be provided for complied refuse & rubbish disposal. _______ Adequate supply of safe drinking Safe drinking water for staff & labour to be water provided _ _ provided (mineral bottled water). from approved sources. - = = _ - = Ill. EMEREGNCIES PREPAREDNESS 1 . Natural or To ensure effective Project work sites Organization of disaster control task Organization/ Refer to Man Made response during force to respond to any mrgenciees. personnel trained emergency Calamities times of natural & Thes task forc shall b organizd by & readiness to coordinating manmade clamities & the safty officer, mdical fild nurse in respond I procedures. accidents. coordination with all dept. heads. Stand-by vehicle with driver, kia, 4x4 Availability of pick-up van shall always be vehicles at all operational & available at field office times. for emergency requirements to be use as ambulance to transport to & from site to the nearest hospital .during emrgencies as required. ______________ 5 5/8/01  DAEWOO ENGINEERING AND CONSTRUCTION CO. Environmental Management Plan (EMP) Halsema Highway Project (Package 1: La Trinidad - Mt. Data) Monitoring/Control Probable Objectives/Output Target Impact Management Action Indicators 1 2wYear 4 Remarks Impacts Activities/Areas (Mitigation Measures & Controls)IJ2 314 - Quarterly training & refresher drills Training and to be conducted. Experts from refresher outside group or organization shall courses be tapped as resource speakers as conducted. may be required. 2 . Forest Fire To ensure adequate Contractor take necessary Zero forest fires Pis. Refer to fire Occurencies provision to respond precautions nsure no arisingfrom the _protection to any occurencies of forest/vegetation areas along the works.