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Initial Environmental Examination
Project Number: 44321-013 November 2019
Cambodia: Climate Resilient Rice Commercialization
Sector Development Program Loans 3006/3007/8271-CAM
Grants 0349/0350-CAM
Prepared by Ministry of Economy and Finance for the Royal Government of Cambodia and the
Asian Development Bank.
This initial environmental examination 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.
KINGDOM OF CAMBODIA
Nation Religion King
Ministry of Economy and Finance
Climate-Resilient Rice Commercialization Sector
Development Program ADB Loans 3006/3007/8271 and Grants 0349/0350-CAM
Initial Environmental Examination for
Establishment of Paddy Drying and Storage
Facility at Phou Poy Rice Mill in Chumnik
Village, Anlong Vil Commune, Sangkae District,
Battambang Province
November 2019
Page | ii
CURRENCY EQUIVALENTS (November 2019)
Currency Unit – riel (KR)
KR1.00 = $0.00025 $1.00 = KR4, 000
ABBREVIATIONS
ADB Asian Development Bank
CLAC Commune Land Acquisition Committee
DD & CS Detailed Design and Construction Supervision
EHS Environmental, Health and Safety
EIA Environmental Impact Assessment
EMP Environmental Management Plan
EQS Environmental Quality Standard
IEE Initial Environmental Examination
IEIA Initial Environmental Impact Assessment
IRC Inter-ministerial Resettlement Committee
MAFF Ministry of Agriculture, Forestry and Fisheries
MEF Ministry of Economy and Finance
MOE Ministry of Environment
MOWRAM Ministry of Water Resources and Meteorology
PDA Provincial Department of Agriculture
PDOE Provincial Department of Environment
PDOLVT Provincial Department of Labor and Vocational Training
PDLMUPC Provincial Department of Land Management, Urban Planning
and Construction
PDS Paddy Drying and Storage Facility
PGRC Provincial Grievance Redress Committee
PIO Provincial Implementation Office
PMO Program Management Office
PRC Procurement Review Committee
RDB Rural Development Bank
RGC Royal Government of Cambodia
RWG Resettlement Working Group
SPS Safeguard Policy Statement
TPD tons per day
UXO Unexploded Ordnance
WEIGHTS AND MEASURES Km – kilometer Kg – kilogram Ha – hectare
m2– square meter
mm – millimeter
Page | iii
TABLE OF CONTENTS
EXECUTIVE SUMMARY ....................................................................................................... vi I. INTRODUCTION .............................................................................................................. 1 II. POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK ................................................. 1 A. Government Environment Policy and Regulation ............................................................ 1
1. Law on Environmental Protection and Natural Resource Management ...................... 1 2. Environmental Impact Assessment Process Sub-Decree .......................................... 2
B. Evaluation Standards ..................................................................................................... 3 C. ADB Environment Requirement ...................................................................................... 5 D. Environmental, Health, and Safety Guidelines ................................................................. 7 III. DESCRIPTION OF THE SUBPROJECT AND PROJECT DESIGN ................................... 7 A. Subproject Provinces .................................................................................................... 7 B. Subproject Scope.......................................................................................................... 8 C. Subproject Context........................................................................................................ 9 IV. DESCRIPTION OF THE ENVIRONMENT ....................................................................... 10 A. Physical Resources ...................................................................................................... 10
1. Topography, Geology and Soils .............................................................................. 10 2. Climate ................................................................................................................... 10 3. Water Resources .................................................................................................... 12
B. Biological / Ecological Resources ................................................................................... 12
C. Socio-economic Resources ............................................................................................ 13 1. Items of Historical and Archaeological Significance ................................................. 13 2. Human and Economic Development ....................................................................... 13
1) Livelihoods ..................................................................................................... 13
2) Poverty Levels ............................................................................................... 14
3) Health ............................................................................................................ 15
4) Unexploded Ordinance ................................................................................... 15 V. ANTICIPATED ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES ............... 15 A. Method of Assessment ................................................................................................. 15 B. Environmental Impacts Related to Location ................................................................. 15 C. Environmental Impacts Related to Construction ............................................................ 16 D. Environmental Impacts Related to Operation ................................................................ 17 E. Global, Trans-boundary and Cumulative Impacts .......................................................... 18 VI. ANALYSIS OF ALTERNATIVES ...................................................................................... 18 VII. INFORMATION DISCLOSURE, CONSULTATION AND PARTICIPATION ...................... 19 A. Consultations and Information Disclosure during design ............................................... 19 B. Further Information Disclosure ...................................................................................... 21 VIII. GRIEVANCE REDRESS MECHANISM ......................................................................... 21 IX. ENVIRONMENTAL MANAGEMENT PLAN ..................................................................... 23 A. Responsibilities for Environmental Management ........................................................... 23 B. Environmental Monitoring ............................................................................................. 24
1. Monitoring for Compliance with EMPs ..................................................................... 24
2. Testing for Noise and Dust Control ........................................................................ 24
C. Environmental Monitoring Reports ................................................................................ 25
D. Institutional Arrangement and Responsibilities .............................................................. 25 X. CONCLUSION AND RECOMMENDATIONS ................................................................... 25 XI. REFERENCES ................................................................................................................. 26 XII. ANNEXES ....................................................................................................................... 27
Annex 1: Agreement of Phou Poy Rice Mill with PDOE, Battambang .................................... 27
Annex 2: Water Quality Standard in Public Water Areas for Bio-Diversity Conservation ..... 29
Annex 3: Land Title of Phou Poy Rice Mill Issued by PDLMUPC ........................................... 30
Page | iv
Annex 4: Existing Location of Phou Poy Rice Mill ................................................................. 33
Annex 5: Detail Design of PDS facility for Phou Poy Rice Mill ............................................... 34
Annex 6: Calculation of Capacity Including Raw Materials for PDS facility at Phou Poy Rice Mill ............................................................................................................................................. 35
Annex 7: Total Annual and Average Monthly Rainfall from 2011-2018 in Battambang ............ 36
Annex 8: Rapid Environmental Assessment (REA) Checklist........................................................ 37
Annex 9: Environmental Management Plan Summary) ............................................................... 42
Annex 10: Environmental Monitoring Plan .................................................................................. 49
Annex 11: List of participants in the consultation meeting ............................................................. 59
Page | v
LIST OF TABLES
Table 1: Annex of Sub-Decree No 72 ANRK. BK. (SA II-A7) (Dated: 11 August 199) ............. 2
Table 2: Drinking Water Standards (2004) ...................................................................................... 4
Table 3: Ambient Air Quality Standard .............................................................................................. 5
Table 4: Maximum Permitted Noise Level at Workshop, Factory and Industry Area (dB) ....... 5
Table 5: Rice Crop Production by Season ........................................................................... 13
Table 6: Poverty levels (2010-2017) by district in Battambang ................................................... 14
LIST OF FIGURES
Figure 1: Location of Project Provinces .............................................................................................. 7
Figure 2: Location of Phou Poy Rice Mill ........................................................................................... 8
Figure 3: Annual Rainfall from 2011-2018 at Battambang .................................................. 11
Figure 4: Average Monthly Rainfall from 2011-2018 at Battambang .......................................... 11
Figure 5: Photo of consultations meeting with relevant stakeholder ....................................... 20
Figure 6: Grievance redress mechanism ............................................................................... 22
Page | vi
EXECUTIVE SUMMARY
1. The establishment of paddy drying and storage (PDS) facilities are one of the key
activities under the Climate-Resilient Rice Commercialization Sector Development Program
(Rice-SDP) to help accommodate paddy supplies at peak periods after harvest to ensure better
quality for processing and retained added value in Cambodia. The Ministry of Economy and
Finance (MEF) is the Executing Agency (EA) of the Rice-SDP and has established a Program
Management office (PMO). The PMO has established a PDS Selection Committee in
cooperation with the Ministry of Agriculture, Forestry and Fisheries/National Implementation
Office (MAFF/NIO) and the Provincial Implementation Offices (PIOs) at three target provinces,
Battambang, Kampong Thom and Prey Veng, who will participate in the entire PDS
procurement process. The funds for the construction of the PDS facilities will be made available
through concessional loans to the Rice Millers and the Rural Development Bank (RDB) will be
involved as a representative of the MEF to collect the loan from the Rice Millers in accordance
with a loan agreement to be signed between RDB and Rice Millers.
2. The Rice Millers eligible to avail the concessional loans from Rice-SDP to establish the
PDS Facilities are selected following a cumbersome process. Upon receipt of the expression
of interest (EOIs) from the Rice Millers, the PMO conducted a feasibility study through
engaging an independent firm, assessed the Rice Millers’ PDS business proposals, and came
up with a Final Ranking of the Rice Millers before employing a detailed design and construction
supervision (DD & CS) consulting firm (IRE) to support the Rice Millers. The final ranking of
the Rice Millers was endorsed by the PDS Selection Committee. The Phou Poy Development
Import Export Co., Ltd (Phou Poy Rice Mill) is ranked first in Battambang province and
therefore got selected to avail the concessional loan for establishment of PDS Facility. After
the ranking, both the PMO and the DD & CS consultants worked with the Phou Poy Rice Mill
and completed the initial survey for detailed design, verification of the proposed location, site
layout for construction, system and process design, machine layout drawings, detailed design
and specifications of equipment, and budget estimates for the Facility. Following the detailed
design of the Facility, a Public Consultation Meeting on environmental and social safeguards
impact assessment for the proposed PDS Facility was conducted by a Rice-SDP technical
team comprising of MEF/PMO officials and consultants, MAFF/NIO officials and consultants,
and DD&CS consultants together with the provincial officials. The main focus of the
assessment was to avoid risks and support the Rice Miller to strengthen his/her safeguard
systems and develop the capacity to manage environmental and social risks.
3. The feasibility study and subsequently the detailed design present a proposal for
establishment of a PDS Facility within the existing business compound of the Phou Poy Rice
Mill located in Chumnik village, Anlong Vil commune, Sangkae district, Battambang province.
The Phou Poy Rice Mill owns about 60 hectares of a single piece of land including rice mill
compound and adjoining farm land in the location, and the proposal proposes establishment of
a PDS Facility on an area of 2,880m2 (around 0.29ha) within the existing rice mill compound of
the Phou Poy Rice Mill. The proposed Facility will have a drying capacity of 300-800 tons per
day (TPD) of wet paddy.
4. The proposed Facility is not environmentally critical and not within or adjacent to
environmentally sensitive areas and regarded as Category B for environmental impact (according
to ADB project framework criteria). The proposed works will mainly involve construction of a PDS
facility with the dryer size being 24 m x 60 m x 21 m (Width x Length x Height) and storage
building size being 24 m x 60 m x 17 m (Width x Length x Height). The activities will not be
critically harmful to the environment. The few adverse direct impacts during construction are
expected to be local, temporary and short-term and most likely to occur during working hour of
Page | vii
the construction period. These will not be sufficient to threaten or weaken the surrounding natural
resources. The Rice Miller has applied and received the Environmental Protection Agreement
from Provincial Department of Environment (PDOE) as part of establishing the PDS Facility and
improving the business operation performance to fulfill the Government’s requirements. The
specific environmental management plan (EMP) addressing adequate mitigation measures to be
implemented by the contractor especially during the construction of the PDS Facility is in place.
5. Overall, the proposed PDS Facility will significantly contribute to a qualitative improvement
in the villagers living standards as they will get opportunity to expand their rice business as the
Rice Miller will buy more paddy from them than earlier times, farmers will be able to save on
transportation cost as they do not have to transport the paddy very far, and also they can work
as labor at the Facility to earn income. The Facility is considered both socially and technically
feasible and is recommended for proceeding to the next (procurement) stage.
Rice-SDP - Initial Environmental Examination- PDS Facility_ Phou Poy Rice Mill
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I. INTRODUCTION
6. The Climate Resilient Rice Commercialization Sector Development Program (Rice-
SDP) will finance policy support, infrastructure, information management and capacity
development investments to enhance the production of quality rice, consistent with the Royal
Government of Cambodia (RGC)’s Strategy on Agriculture and Water 2010-2013 and its Policy
on the Promotion of Paddy Production and Rice Export (the Rice Policy). The Program will
support infrastructure development through subprojects in the participating provinces of
Battambang, Kampong Thom and Prey Veng. Infrastructure subprojects will include the
construction or rehabilitation of irrigation systems, on-farm water conservation structures, paddy
drying and storage (PDS) facilities, or other types of infrastructure that are likely to contribute to
the program impact and outcome, based on selection criteria agreed with key stakeholders
(Supplementary Appendix IV section II.B.3). Infrastructure improvements will be complemented
by soft interventions such as targeted agricultural extension, land leveling, famer water user
community (FWUC) support and other initiatives that add benefit to the investment in civil works
under the subproject.
7. Furthermore, the Agricultural Sector Strategic Development Plan 2014-2018 was
prepared basically in line with the RGC’s Policy Paper on “the promotion of paddy production
and rice export” which was promulgated on August 17th, 2010 by the RGC and relevant
documents for the agricultural sector development, with the aim of transforming Cambodia as a
leading rice exporting country in the region. Presently, the agricultural sector has been
supported through the improvement of irrigation, dissemination of new technology and other
endeavors, especially agricultural research and development to adapt to climate change.
8. The proposed PDS facility for Phou Poy Rice Mill includes social and environmental
safeguards assessment and management plan. The purpose of the Facility is to increase
paddy drying capacity by 300-800 tons per day (TPD), disseminate new technology, and reduce
the flow of wet paddy to neighboring countries. The Phou Poy Rice Mill owns about 60 hectares
of a single piece of land including rice mill compound and adjoining farm land in the location (land
title issued by Provincial Department of Land Management and Urban Planning-“PDLMUPC”,
Battambang, on 31 July 2006), and the proposed Facility will be established on an area of
2,880m2 (around 0.29ha) within the existing rice mill compound of the Phou Poy Rice Mill.
9. This initial environmental examination (IEE) is based on the consultation with relevant
stakeholders and prepared according to the guidance provided in the EARF and the ADB’s
Safeguard Policy Statement of June 2009 and the RGC Law on Environmental Protection
and Natural Resource Management (December 1996) with further guidance from the Sub-
decree on Environmental Impact Assessment (1999).
II. POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK
A. Government Environment Policy and Regulation
1. Law on Environmental Protection and Natural Resource Management 10. The Law on Environmental Protection and Natural Resources Management was
enacted by the National Assembly and launched by the Preah Reach Kram/NS-RKM-1296/36
on December 24th, 1996. This law has the following objectives:
(i) To protect and promote environment quality and public health through
prevention, reduction and control of pollution;
Rice-SDP - Initial Environmental Examination- PDS Facility_ Phou Poy Rice Mill
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(ii) To assess the environmental impacts of all proposed projects prior to the issuance
of a decision by the Government;
(iii) To ensure the rational and sustainable conservation, development, management
and use of the natural resources of the Kingdom of Cambodia;
(iv) To encourage and provide possibilities for the public to participate in the protection
of environment and the management of the natural resources; and
(v) To suppress any acts that cause harm to the environment.
11. Under this law the developers or project owners need to prepare an Initial Environmental
Impact Assessment (IEIA) or a full Environmental Impact Assessment (EIA) report for their
proposed or existing development projects.
2. Environmental Impact Assessment Process Sub-Decree
12. The sub-decree No. 72 ANRK.BK on Environmental Impact Assessment Process
dated August 11th, 1999 sets out EIA procedures. The main objectives of this sub-decree are:
(i) To determine an Environmental Impact Assessment (EIA) for every private and
public project or activity, and it must be reviewed by the MOE, prior to the
submission for a decision from the Government.
(ii) To determine the type and size of the proposed project(s) and activities,
including existing and ongoing activities in both private and public sector prior to
undertaking the process of EIA.
(iii) To encourage public participation in the implementation of the EIA process and
take into account their input and suggestions for re-consideration prior to the
implementation of any project.
13. The sub-decree includes an annex which provides information on development
projects requiring EIA or IEIA. An excerpt for relevant projects is provide in Table 1 below.
Table 1: Annex of Sub-Decree No 72 ANRK. BK. (Dated: 11 August 1999)
List of Projects Requiring an IEIA or EIA
No. Type and activities of the projects Size /Capacity
A. INDUSTRIAL I. Foods, Drinks, Tobacco
1 Food processing and caned ≥ 500 Tones/year
2 All fruit drinks manufacturing ≥ 1,500 Litres / day
3 Fruit manufacturing ≥ 500 ones/year
4
Orange Juice manufacturing All sizes
5 Wine manufacturing All sizes
6
Alcohol and Beer brewery All sizes
7
Water supply ≥ 10,000 Users
8 Tobacco manufacturing ≥ 10,000 Boxes/day
9 Tobacco leave processing ≥ 350 Tones/ year
10 Sugar refinery ≥ 3,000 Tones / year
Rice-SDP - Initial Environmental Examination- PDS Facility_ Phou Poy Rice Mill
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11 Rice mill and cereal grains ≥ 3,000 Tones / year
12 Fish, soy bean, chili, tomato sources ≥ 500,000 Litres/ year
B. AGRICULTURE
1 Concession forest ≥ 10,000 Hectares
2 Logging ≥ 500 Hectares
3 Land covered by forest ≥ 500 Hectares
4 Agriculture and agro-industrial land ≥ 10,000 Hectares
5 Flooded and coastal forest All sizes
6 Irrigation systems ≥ 5,000 Hectares
7 Drainage systems ≥ 5,000 Hectares
8 Fishing ports All sizes
14. Since this PDS Facility involves agriculture and agro-industrial land much less
than that prescribed above (Table 1), it is not required to do the environmental impact
assessment based on sub-decree No 72 ANRK.BK. However, as the Facility comes under
the rice mill and cereal grains industrial activities, the Phou Poy Rice Mill has applied and
received the Environmental Protection Agreement from Provincial Department of
Environment (PDOE) as part of establishing the PDS Facility and improving the business
operation performance to fulfill the Government’s requirements (see Annex 1). The
proposed Facility will be constructed within the existing rice mill compound owned by the
Phou Poy Rice Mill and will be monitored by PDOE as mentioned in the Environmental
Protection Agreement.
B. Evaluation Standards
1) Law on Water Resources Management 15. The Law on Water Resources Management was adopted by the National Assembly on
22 May, 2007. This law provides procedures for the management of water resources within
Cambodia. The purpose of the law is to foster the effective management of the water
resources of the Kingdom of Cambodia to attain socio-economic development and the welfare
of communities.
16. The Law shall determine:
(i) The rights and obligations of water users;
(ii) The fundamental principles of water resources management;
(iii) The institutions in charge of its implementation and enforcement; and
(iv) The participation of users and their associations in the sustainable
development of water resources.
17. Under this law, MOWRAM may declare any basin, sub-basin or aquifer as Water Law
Implementation Area when within that basin, sub-basin, ground water or aquifer there are
likely to be conflicts among water users, problems of water pollution or watershed degradation.
Rice-SDP - Initial Environmental Examination- PDS Facility_ Phou Poy Rice Mill
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2) Water pollution control sub-decree 18. The sub-decree No 27 ANRK.BK dated April 6th, 1999 is on Water Pollution Control. The
purpose of this sub-decree is to regulate water pollution in order to prevent and reduce water
pollution of public water bodies so that protection of human health and conservation of bio-
diversity can be ensured. This sub-decree applies to all sources of pollution and all activities
causing pollution of public water bodies. The sub-decree also provides the pollution types,
effluent standards, and water quality standards in different areas. Water quality standards
are stipulated in this sub- decree for public water (see Annex 2).
3) Drinking Water Quality Standards 19. For well water used for domestic purposes, including drinking, the Ministry of Industry Mines and Energy (MIME) Drinking Water Quality Standards of January 2004 is the evaluation standard. These are summarized in Table 2 below.
Table 2: Drinking Water Standards (2004)
No Parameter Unit Standard Value 1 pH mg/l 6.5 – 8.5 2 Turbidity NTU 5 3 Arsenic mg/l 0.05 4 Iron 0.03 5 Total Dissolved Solid mg/l 800 6 Chlorine mg/l 0.2-0.5 7 Copper mg/l 1 8 Sulphate mg/l 250 9 Nitrite mg/l 3 10 Nitrate mg/l 50 11 Lead mg/l 0.01 12 Mercury mg/l 0.001 13 Coliform CFU/100ml 0
4) Solid waste management sub-decree
20. The sub-decree No 36 ANRK.BK dated April 27th, 1999 is on Solid Waste
Management. The purpose of this sub-decree is to regulate solid waste in order to ensure
protection of human health and conservation of bio-diversity. This sub-decree applies to all
activities related to disposal, storage, collection, transport, recycling, dumping of garbage
and hazardous waste.
5) Air pollution control sub-decree
21. The sub-decree No 42 ANRK.BK dated July 10th
, 2000 is on Air Pollution Control and
Noise Disturbance. The purpose of this sub-decree is to protect quality of environment and
public health from air pollutants and noise pollution. This sub-decree applies to all mobile and
stationary sources of air and noise pollution. These are summarized in Table 3 and Table 4
below.
Rice-SDP - Initial Environmental Examination- PDS Facility_ Phou Poy Rice Mill
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Table 3: Ambient Air Quality Standard1
No
Parameters
Period 1h Average
(mg/m3)
Period 8h Average
(mg/m3)
Period 24h Average
(mg/m3)
Period 1year Average
(mg/m3)
1 Carbon monoxide (CO) 40 20 - - 2 Nitrogen dioxide (NO2) 0.3 - 0.1 -
3 Sulfur dioxide (SO2) 0.5 - 0.3 0.1
4 Ozone (O3) 0.2 - - -
5 Lead (Pb) - - 0.005 - 6 Total
Suspended - - 0.33
0.1
Source: Annex1 of Sub-Decree on Air Pollution Control and Noise Disturbance, 2000.
Table 4: Maximum Permitted Noise Level at Workshop, Factory and Industry Area (dB) 2
Noise Level (dB (A)) Maximum Period of Time Level
75 32 Ear protection equipment shall be provided to worker who works at a location with noise level over 80dB(A)
80 16
85 8
90 4
95 2
100 1
105 0.5
110 0.25
115 0.125
Source: Annex 7 of the Sub-decree on Air Pollution and Noise Disturbance (2000)
C. ADB Environment Requirement
22. Safeguard Policy Statement was overarching Statement on ADB’s Commitment
and Policy Principles. ADB affirms that environmental and social sustainability is a cornerstone
of economic growth and poverty reduction in Asia and the Pacific. ADB’s Strategy 2020
therefore emphasizes assisting DMCs to pursue environmentally sustainable and inclusive
economic growth. In addition, ADB is committed to ensuring the social and environmental
sustainability of the projects it supports. In this context, the goal of the Safeguard Policy
Statement is to promote the sustainability of project outcomes by protecting environment and
people from project potential adverse impacts. The objectives of ADB’s safeguards are to:
(i) Avoid adverse impacts of projects on the environment and affected people, where
possible;
(ii) Minimize, mitigate, and/or compensate for adverse project impacts on the
environment and affected people when avoidance is not possible; and
(iii) Help borrowers/clients to strengthen their safeguard systems and develop the
capacity to manage environmental and social risks.
1 Note: This standard is applied to evaluate ambient air quality and to monitor air pollution status. 2 Note: This standard is applied to control noise level in location of workshop, industries and factories.
Rice-SDP - Initial Environmental Examination- PDS Facility_ Phou Poy Rice Mill
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23. ADB adheres to the objectives of the safeguards and their delivery. ADB assumes the
responsibility for conducting due diligence and for reviewing, monitoring, and supervising
projects throughout the ADB’s project cycle in conformity with the principles and requirements
embodied in the Safeguard Policy Statement. By adhering to its social and environmental
safeguards, ADB enhances the predictability, transparency, and accountability of its actions
and decision making; helps borrowers/clients manage social and environmental impacts and
risks; and promotes the long- term sustainability of investments. Transforming this
commitment into results on the ground depends on shared, but differentiated, efforts by ADB
and its borrowers/clients. ADB’s Safeguard Policy Statement sets out the policy objectives,
scope and triggers, and principles for three key safeguard areas:
(i) Environmental safeguards, (ii) Involuntary resettlement safeguards, and (iii) Indigenous Peoples safeguards.
24. On basis of subproject screening in the feasibility stage, using a rapid environmental
checklist, this PDS Facility has been determined to be Category B for environmental impact
during the feasibility study. This category entails environmental impacts that can be mitigated.
This consolidated IEE has been prepared under the provisions of the ADB’s Safeguard
Policy Statement 2009 which requires a number of critical considerations, including: (i)
project level grievance redress mechanism, including documentation in the environmental
management plan (EMP); (ii) physical cultural resources damage prevention analysis; (iii)
climate change mitigation and adaptation; (iv) occupational and community health and
safety requirements, including emergency preparedness and response; (v) economic
displacement that is not part of land acquisition; (vii) meaningful consultation and participation;
and (viii) an EMP which comprises implementation schedule and (measurable) performance
indicators.
25. Relevant ADB Environmental policies and guidelines used in the preparation of this
IEE are:
(i) Safeguard Policy Statement. ADB, 2009.
(ii) Operation Manual Bank Policies (BP) on Safeguard Policy Statement. ADB, 2009.
(iii) Environment Policy of the Asian Development Bank, November 2002.
(iv) Environmental Assessment Guidelines, 2003 – Annex 3: Content and Format of
Initial Environmental Examination (IEE).
(v) Environmental Guidelines for Selected Agricultural and Natural Resources
Development Projects (November 1991).
(vi) Rapid Environmental Checklist. ADB, 2013.
26. The main purpose of the Rapid Environmental Checklist is to screen the potential environmental impacts of the proposed PDS Facility for Phou Poy Rice Mill that may occur during project design, construction, and operation phase. The environmental study is undertaken through field investigations and screening of potential impacts both negative and positive and developing of mitigation measures for each negative impact are made. Based on the results of the environmental and social field investigations and recommendation from relevant stakeholders and local communities in the project area, the potential environmental impacts that are expected to occur due to the project activities during pre-construction, construction, and operation phases are noted and their mitigation measures established. The results of Rapid Environmental Assessment are described in Annex 8.
Rice-SDP - Initial Environmental Examination- PDS Facility_ Phou Poy Rice Mill
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D. Environmental, Health, and Safety Guidelines 27. ADB’s Safeguard Policy Statement applies pollution prevention and control
technologies and practices consistent with international good practices as reflected in
internationally recognized standards such as the World Bank Group’s Environmental, Health
and Safety Guidelines. The Guidelines provide the context of international best practice and
contribute to establishing targets for environmental performance. The air and noise standards
in the EHS guidelines will be used to complement the Government standards in this document
where needed. Occupational and community health and safety, as laid out in the EHS
Guidelines, will be a cross-cutting assessment for the Facility.
III. DESCRIPTION OF THE SUBPROJECT AND PROJECT DESIGN
A. Subproject Provinces 28. All the PDS facilities to be established under the Rice-SDP will be located in three
target provinces of Kampong Thom, Battambang and Prey Veng. These 3 provinces were
selected for project investment as these are the largest rice producers in Cambodia. In an
effort to increase paddy for export, these provinces have prioritized (i) improving efficiency of
land and water, (ii) increasing postharvest handling capacities, and (iii) enhancing resilience
of the rice ecosystems. All three provinces are located along the GMS Southern Economic
Corridor along which rice can be conveniently transported to Thailand, Viet Nam, and all
provinces in Cambodia. By focusing on these provinces, there are good opportunities to
enhance national food security by improving availability of milled rice for both export and
potentially addressing domestic demand and supply imbalances. The three project provinces
are shown in Figure 1 below. The proposed PDS facility for Phou Poy Rice Mill is located in
Battambang province.
Figure 1: Location of Project Provinces
29. Battambang is located in the Northwest of Cambodia and borders Banteay
Meanchey to the north, Pursat to the south-east and south, Siem Reap to the northeast,
Rice-SDP - Initial Environmental Examination- PDS Facility_ Phou Poy Rice Mill
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Pailin to the west, and Tonle Sap to the east. The western boundary of the province forms a
part of the international border with Thailand. The area of the province is 11,872 square
kilometers (Source: NCDD, updated 30 May 2015). The northeast part bordering the Tonle
Sap Lake has floodplain areas. Battambang is one of the provinces included in the Tonle Sap
Biosphere Reserve. The province has mostly lowland paddy fields and the fertile rice fields
have led to a mostly agricultural economy giving rise to the moniker “the Rice Bowl of
Cambodia”. The estimated population is 1,173,414 persons of which 588,724 are female. The
people of Battambang province live in 14 districts composed of 102 communes and 799
villages and the population density is 100/km2 (Source: Battambang Development Plan 2016-
2018).
B. Subproject Scope
30. The proposed PDS Facility for Phou Poy Rice Mill will be constructed within the existing
Rice Mill compound situated on the National Road No. 5, Chumnik Village, Anlong Vil
commune, Sangkae District in Battambang province. The existing Rice Mill started its operation
since 1990 and running for the last 29 years. Thus, the Rice Miller has vast experience in rice
milling industry. The Rice Mill is located on a single piece of 60 ha of land owned by the Rice
Miller of which around 10 ha has been fenced (land title issued by PDLMUPC, Battambang,
on 31 July 2006 is attached as Annex 3). The Rice Mill front boundary borders National Road
No.5 and across the road there are residential area and behind the settlements are private rice
lands. In the back of the Rice Mill, adjacent to the backyard boundary are rice farms belonging
to the Rice Mill. In the left, adjacent to the left side boundary, there is Department of
Transportation and to the right, adjacent to the right side boundary, there is one small
abandoned rice mill. (see Figure 2 below and Annex 4). The current milling capacity of the Rice
Mill is 5-6 tons per hour (i.e. 43,000 tons paddy per year). Existing drying type is Batch columnar
recirculation type for a volume of 180 TPD. The Rice Miller has currently engaged 25 workers of
which 13 are women.
Figure 2: Location of Phou Poy Rice Mill
31. The proposed PDS Facility will be built on a plot of about 2,880 m² inside the existing
Rice Mill compound. The proposed works will mainly involve construction of a PDS facility with
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the dryer size being 24 m x 60 m x 21 m (Width x Length x Height) and storage building size
being 24 m x 60 m x 17 m (Width x Length x Height). The proposed Facility will have a drying
capacity of 300-800 TPD of wet paddy. Some of the salient features of the Facility to be
established are:
Drying system: Modern drying plant will be installed which will start from Paddy
intake – Precleaning – Weighing – 1st Stage Fluidized Bed Drying (Fast drying) –
Conditioning – 2nd Stage Louisiana State University (LSU) Drying – Weighing and Storing. All immature grains and dust will be sent to storage room.
Bulk handling system: During drying process, wet paddy will be conveyed by bucket elevators and dried paddy will be conveyed by overhead belt conveyor to storage
room.
Biomass furnace: This direct heat furnace will be a Cyclonic type which will use mainly husk as biomass fuel. The amount of husk used will be 25 TPD (≥ 1,500-2,000 tons per year) which will be collected from the rice mill. Currently the Rice Miller also uses husk as biomass fuel for their furnace/burner.
The amount of ash generated per day will be 1 TPD (≥ 60 ton per year) but no ash/smoke will be released to the environment as the Cyclonic type furnace has no exhaust stack. The Cyclonic furnace collects ash at the bottom and then conveys to the ash room. Ash will be collected at the ash room and use as fertilizer by the Rice Miller himself or may sell to farmers to generate extra income.
Storage system: Warehouse type with aeration system including some bag storage for different varieties of paddy.
Construction: Construction work will use a small amount of water only as readymade mixed concrete from supplier will mainly be used. Contractor will install onsite WC for their workers. Noise proof materials for housing will be used to reduce noise from ash room, dust room and machinery. Noise from hammering (for temporary period only) initially during construction period will be monitored and managed through use of new motor or good maintenance.
Operation: No waste water from this type of drying process is generated as moisture from wet paddy will evaporate. Noise from blower and its drivers i.e. electric motor will be monitored and managed through good maintenance.
32. The detailed design of the PDS Facility for Phou Poy Rice Mill in brief can be found in
Annex 5 while the complete sets of drawings along with full description of the detailed design
can be found in the bidding documents. The detailed calculation of the capacity of the Facility
including use of raw materials, generation of husk and ash can be found in Annex 6.
C. Subproject Context
33. The lack of adequate number of wet paddy drying facilities within ready reach of farm
enterprises is identified as a serious constraint for the in-country handling of the increasing
volume of wet paddy, quality rice production, and retained added value inside the country. The
lack of drying facilities is also forcing many Cambodian farmers to sell their wet paddy directly
to buyers from neighboring countries where modern facilities are available. Most of the
processing facilities in the country are rudimentary, featuring significant crop losses, non-
uniform drying, higher proportions of cracked grains and higher risks of fungal growth. The
development of drying and storage facilities accessible to cooperatives are given priority by the
RGC for the implementation of the rice policy.
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34. The Phou Poy Rice Mill is located about 7 km from Battambang town along road No. 5
to Phnom Penh. The establishment of PDS facilities at Phou Poy Rice Mill will expand the
current capacity of drying wet paddy by 300-800 TPD thereby improve the quality and quantity
of domestically milled rice, increase the capacity for paddy storage in Battambang,
accommodate paddy supplies at peak periods after harvest, reduce the movement of
unprocessed paddy across the border to Thailand and Viet Nam immediately after harvest,
ensure better quality for processing and retained added value in Cambodia. The improvement
in the Facilities will also help the Rice Miller achieve a fully satisfactory performance of the rice
mill by ensuring its durability and economic efficiency. In the immediate setting, the surrounding
villages will benefit greatly from establishment of the Facility as most of the villagers cultivate
paddy and the Rice Miller can buy more paddy from them than earlier times, farmers will be
able to save on transportation cost as they do not have to transport far, and their
sons/daughters could work as labor at the Facility to earn income. After the completion of the
facilities, the Rice Mill may employ double the number of villagers it is employing currently to
work in the mill.
35. In addition to the establishment of PDS facilities, associated activities will form part of
the investment to (i) strengthen the technical extension services directed at quality seed
production to agriculture cooperatives (ACs), (ii) contract farming between the Rice Millers and
ACs, (iii) business matching between RDB/Financial Institutions - Rice Millers - ACs, and (iv)
technical, financial and managerial capacity building of Rice Millers as well as ACs including
access to credit.
IV. DESCRIPTION OF THE ENVIRONMENT
A. Physical Resources
1. Topography, Geology and Soils 36. Cambodia is divided into three distinct topographic regions: the central plains, the flat
coastal areas, and the mountain ranges with high plateaus. The proposed PDS Facility is
situated on flat land, characteristic of much of the floodplain of the lower Mekong Basin. The
land has been formed by sedimentation during the Pleistocene epoch (between 10,000 and
2.5 million years ago)3, causing a layer of deposits in the order of 100 m deep, over the largely
sandstone parent rock beneath.4 Soils in much of the area are clays (unconsolidated, relatively
fertile soils deposited during the formation of the lake that have developed under saturated
conditions), and hydromorphic soils (saturated soils that have developed under conditions of
poor drainage), both of which are suitable for rice production.
2. Climate 37. Cambodia has a moist tropical climate, classified as equatorial monsoonal5,
consistent with its location 10-13 degrees latitude north of the equator. The climate features
warm to hot temperatures throughout the year and an annual monsoon cycle of alternating
wet and dry seasons. The main wet season, the Southwest monsoon, occurs between June
and October, when reduced air pressures over Central Asia cause air to be drawn landward
from the Indian Ocean. Project Management and Contractors need to be aware that there
has been considerable change in the incidence of drought and late arrival of wet season rains
3Rice-SDP Supplementary Appendix IV - Initial Environmental Examination, Svay Antor Paddy Drying and Storage Subproject. 4 Seng, V., R.W. Bell, P.F. White, N. Schoknecht, S. Hin and W. Vance, (2007) Sandy Soils of Cambodia in Management of Tropical Sandy Soils for Sustainable Agriculture. FAO, Rome. 5 Peel, M. C., Finlayson, B. L., and McMahon, T. A, (2007), Updated world map of the Köppen-Geiger climate.
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across Cambodia. Approximately 80% of all rainfall occurs during this season. Conversely,
during the cooler months between November and January, air flows over Cambodia originate
from Central Asia and are drier, resulting in cooler and less rainy weather. It is projected that
as a result of Climate Change, the amount of rain fall in the wet season will increase, the
duration of the wet season will be shorter and periods of dry spell will occur within the wet
season. The dry season is expected to be longer.
38. Flooding data has been recorded in every Sangkat (commune) of Battambang
municipality during the rainy season from June to December. In 2013, serious floods affected
the whole province (flooding occurred mostly in October to December). The highest level of
flooding occurred in Svay Por and Preak Sdach Sangkats with water depth ranging from one to
two meters
39. The Battambang weather station managed by the PDWRAM, Battambang is
situated near the proposed PDS Facility for Phou Poy Rice Mill. The detailed design for the
proposed Facility considered the last 8 years rainfall data i.e. from the year 2011 to 2018. The
annual rainfall during 2011 to 2018 at Battambang weather station varied from 885 mm to 1,657
mm with the average being 1230 mm. (Annex 7 & Figure 3 below).
Figure 3: Annual Rainfall from 2011-2018 at Battambang
Source: Provincial Department of Water Resources and Meteorology
40. The wet-season in Cambodia starts from May to October. Peak levels of rainfall are up
to 96.8 mm in a day found in March 2017 and 191 mm in one day in July 2014 may be return
storm period. The average monthly rainfall recorded during 2011 to 2018 at Battambang weather
station varied from 8.5 mm in January to 226.4 mm in September. (see Annex 7.1 & Figure 4
below).
Figure 4: Average Monthly Rainfall from 2011-2018 at Battambang
Source: Provincial Department of Water Resources and Meteorology
-
500.0
1,000.0
1,500.0
2,000.0
2011 2012 2013 2014 2015 2016 2017 2018
Ra
infa
ll,
mm
Year
Annual rainfall year 2011-2018
Jan FebMa
rApr
Ma
yJun Jul Aug Sep Oct Nov Dec
Rainfall(mm) 8.5 8.7 40.4 60.0 109. 138. 157. 116. 226. 220. 71.2 11.9
0.050.0
100.0150.0200.0250.0
Ra
infa
ll,
mm
Month
Average Monthly rainfall (Year 2011-2018)
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3. Water Resources
41. The proposed PDS Facility area, and much of Cambodia, is within the Lower
Mekong Basin where flooding takes place regularly. People and farming systems are
vulnerable to variability in flood levels and this vulnerability is heightened by the effects of
climate change. The Inter-governmental Panel on Climate Change predicts increasing
difficulties to lives and livelihoods caused by more frequent storm events and extreme weather
conditions in the Mekong sub-region.6 The Lower Mekong Basin has suffered successions
and combinations of droughts and floods over the last two decades as well as in the
more distant past. Flooding that occurred in 2000 is believed to be the most severe in
Cambodia in 70 years, while severe flooding also occurred in 1996, 2001, 2002, 2011 and
2013.
42. Groundwater occurs in aquifers in the Pleistocene deposits and is used in the proposed
PDS Facility area for domestic purposes. Deeper, more substantial aquifers may occur in rock
layers but extensive geophysical and drilling exploration is needed to assess the potential of
groundwater for use. Along with ground water, water supplied by district water supply in the
Facility area is mainly used for domestic purposes. The Toul Sangke River is about 7km
from the Phou Poy Rice Mill. The Rice Mill has 2 private water ponds (30m x 50m) which
harvests rain water and used for cultivation purposes.
B. Biological / Ecological Resources
43. Based on Royal Decree (Preah Reach Kret) on the Establishment and Designation of
Protected Areas of November 01, 1993, there are 23 Protected Areas, of which 4 natural
protection areas are located in Battambang province:
(i) 59,000 ha of Phnom Samkos Wildlife Sanctuary situated in Samlot and Koskralor district.
(ii) 400 ha of Dounsam wildlife protection area in small forest of Kamreang,
Phnomprek, Sampovloun and Barvil district.
(iii) 20,000 ha of Samlot Multiple Use Area (forest protection area) situated in Samlot
district
(iv) 20,000 ha of Prektorl flooded forest protection area situated in Aekphnom and
Sangkae district
44. The proposed PDS Facility for Phou Poy Rice Mill is located far away from these
protected areas. It’s about 7km from Sangkae River. The flooded forest and forest surrounding
Battambang province are reportedly have been destroyed for commercial and family rice
farming affecting the habitats of fisheries and birds (source: Battambang Development Plan,
2016-2018).
45. The aquatic ecosystems that occur in the Battambang include seasonally flooded
fields and small streams and are important habitats to fish, aquatic reptiles and
amphibians. At least 500 fish species recorded in the Cambodia’s Mekong River (the Lower
Mekong basin encompasses at least 1,200 fish species). Within the above figure, 296 fish
6 M.L. Parry, O.F. Canziani, J.P. Palutikof, P.J. van der Linden and C.E. Hanson, Eds (2007). Climate Change 2007: Impacts, Adaptation and Vulnerability. Contribution of Working Group II to the Fourth Assessment Report of the Intergovernmental Panel on Climate Change, Cambridge University Press, Cambridge, UK.
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species are from Tonle Sap Lake. So both Mekong River and Tonle Sap Lake have great
diversity of fish species in Cambodia (Source: So Nam, 2010).
46. The RGC has implemented fisheries reforms to promote small-scale fishing. In
Battambang province some 22 species are commonly caught from paddy fields and streams,
and some 29 species are commonly caught in family scale fishing from lake and river. Based
on first semiannual report of 2016 by Battambang Fisheries Administration Cantonment, family
scale fishing and paddy fields catch quantities were 6,687.8 tons and 2,625.61 tons,
respectively.
C. Socio-economic Resources
1. Items of Historical and Archaeological Significance
47. Ancient structures, mainly temples and shrines but sometimes bridges and water
storage or control structures are common over the Cambodian landscape, with the major
cluster in the Angkor temple complex within Siem Reap. However, no ancient structures, no
temples or shrines are located around the proposed PDS Facility.
2. Human and Economic Development
1) Livelihoods
48. Rural livelihoods are predominantly based on agriculture. Battambang is long renown
for quality rice, fruit and vegetable production. Farming is the main source of income for the
majority of households in the subproject area, while other income is obtained from off-farm
employment in construction, other industries, government employment, and trading. A minority
of rural households derive income from fishing, though this activity is merely a supplementary
activity for part of the year.
49. Rice production is the mainstay of the rural economy in most areas. The total paddy
production in Battambang province in 2014 was about 836,925 tons out of which wet season
production was 796,059 tons and that of the dry season was 40,866 tons. 30% rice crop
production in Battambang province depended on natural irrigation and irrigation, and 70%
depended on rain water. Rice crop production has changed from traditional farming to
mechanized farming through the use of modern agricultural equipment, rice seed, chemical
fertilizer and pesticide, even though the increase in seasonal rice crop production is limited
due to absence of irrigation facility (Source: Battambang Development Plan 2016-2018).
Table 5: Rice Crop Production by Season in 2014
Rice Production
Indicator
National
(Wet Season)
National
(Dry Season)
Battambang
(Wet Season)
Battambang
(Dry Season)
Area Cultivated- ha. 2,564,572 490,935 279,123 10,500
Area Harvested- ha. 2,537,976 490,860 279,123 10,500
Paddy Production -T 7,143,520 2,180,896 796,059 40,866
Yield-T/ha. 2,815 4,443 2,852 3,892
Source: MAFF 2014 and Battambang Development Plan 2016-2018
50. Aquatic ecosystems are vulnerable to the effects of agrochemical use, particularly
pesticides. The pesticides in use in the area included products that are known to contain
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compounds that are classified as persistent, such as 2 4-Dichlorophenoxyacetic acid (2 4-D),
or methyl parathion, the active ingredient in the product Folidol.7 While these compounds
progressively break down on release, fish and other aquatic organisms can be harmed,
particularly as a result of improper, uninformed or irresponsible use or methods of container
disposal. The proposed PDS Facility does not deal with the pesticides and hence will have no
negative effect on aquatic ecosystem. However, the project through associated activities (as
mentioned in para 35), will strengthen the technical extension services directed at farmers and
ACs on the use of pesticides.
51. Many small and marginal farmers do not have regular cash incomes, either because of
access constraints, lack of landholdings and shortage of employment opportunities. Many
families are dependent on remittances by family members working away from home, most
often in the construction, garment, industries and overseas migrant workers.
2) Poverty Levels 52. Although, Cambodia is a country rich in natural resources, it remains one of the world’s
poor nations, in part the legacy of decades of war, internal conflict and corruption. An additional
legacy of war is the huge amount of unexploded ordinance which contributes to ongoing
maiming and injury of the nation’s rural poor. In 2008, alleviating poverty became RGC’s
highest priority according to its Millennium Development Goals. Thereafter, sustained efforts
by the RGC led to the decrease in poverty rate from 47.8% in 2007 to 13.5% in 2014. But the
rural poverty incidence where 90% of the poor live fell from 24.6% in 2009 to 20% in 2012.
53. Based on the Battambang Development Plan, the poverty level in Sangkae district of
Battambang province has reduced from 22.98% in 2010 to 18.99% in 2017(see Table 6
below). In the Anlong Vil Commune of Sangkae District, where the proposed PDS Facility is
located, the poverty rate has decreased from 32.50% in 2004 to 17.30% in 2012 (Ministry of
Planning, 2012). The proposed PDS Facility will significantly contribute to a qualitative
improvement in the villagers living standards as they will get opportunity to expand their rice
business as the Rice Miller will buy more paddy from them than earlier times, farmers will be
able to save on transportation cost as they do not have to transport the paddy very far, and
also they can work as labor at the Facility to earn income.
Table 6: Poverty rates by districts of Battambang province (from 2010-2017)
No. Districts 2010 2011 2012 2013 2014 2015 2016 2017
1 Banan 28.61 26.63 23.37 24.07 24.22 23.46 21.85 22.71
2 Thma Koul 21.02 18.55 22.34 22.05 21.91 21.16 20.56 20.24
3 Krong Battambang 8.76 8.20 17.08 17.14 16.51 16.39 16.47 16.61
4 Bavel 31.74 31.69 31.43 25.21 28.11 26.43 23.23 23.16
5 Aek Phnum 23.58 22.91 22.60 22.86 21.63 21.61 21.38 22.48
6 Moun Ruessei 28.52 26.65 24.96 24.63 24.07 22.94 22.92 22.10
7 Rotonak Mondol 34.91 30.01 29.06 28.36 25.75 24.85 22.49 22.04
8 Sangkae 22.98 21.08 21.97 20.54 19.50 19.16 19.92 18.99
9 Samlout 28.60 24.29 23.30 24.07 21.10 21.41 21.32 20.42
10 Sampov Lum 27.32 26.30 26.03 25.23 22.99 21.73 20.17 22.25
11 Phnom Proek 28.65 25.64 23.37 24.08 22.64 21.80 21.43 21.92
12 Kamrieng 27.57 25.19 24.06 24.16 22.01 22.00 21.10 20.60
13 Koas Krala 35.97 31.56 28.73 27.78 26.30 25.37 23.75 24.01
14 Rukhak Kiri 37.37 32.54 27.01 27.57 25.28 25.12 22.35 21.77
Source: Battambang Provincial Department of Planning (PDP-BTB),2018
7 Ministry of the Environment / UNEP (2009), Cambodia Environment Outlook.
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3) Health
54. Public health in the subproject area is influenced by the standard of water supply,
and of the standard of sanitary living conditions. The incidence of water related diseases
is high. And a significant portion of the population does not have access to piped water supply
and fewer have access to improved sanitation. Pesticides pose a severe health risk if they
are applied incorrectly and without the use of protective clothing. Part of the problem has
been a lack of instruction on how to handle and use pesticides. The law now requires that
pesticides are packaged and sold with clear instructions in Khmer word and this is enforced
by staff of the Provincial Department of Agriculture.
55. Battambang province has 6 referral hospitals, 77 health centers, 365 private clinics, 13
laboratories and 213 pharmacies (Source: Battambang Development Plan 2016-2018). In the
Sangkae district where the proposed PDS Facility is located there is one district referral
hospital and nine health centers including one in Anlong Vil commune.
4) Unexploded Ordinance
56. Unexploded ordnance (UXO) remaining from civil conflict is evident in Battambang,
resulting from both aerial drops and from ground fighting. However, the proposed PDS Facility
site and its surrounding area have been actively cultivated since the years of conflict, and
respondents and relevant stakeholders participated in the consultation meeting confirmed that
they did not come across with any UXO in proposed area. Based on Battambang UXO report
2015, Battambang mine clearance was made by CMAC which aims at bringing about the
personal security and safety of the people, safety of land and community living in mine affected
areas in Battambang province. Sangkae district was also cleared by CMAC. The safety
guarantee certificate will be obtained from CMAC to make sure no mine and UXO present in
subproject area.
V. ANTICIPATED ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES
A. Method of Assessment
57. Following the sub-decree No. 72 ANRK.BK on Environmental Impact Assessment (see
para 12 & 13 above), potential impacts have been assessed through site visits, consultation
meetings with stakeholders, and a review of secondary sources of information. To identify
potential impacts related to location, construction and operation, stakeholders were consulted,
suitable mitigation measures and an environmental management plan (EMP) developed.
B. Environmental Impacts Related to Location and Pre-construction
58. The proposed PDS Facility is located barely 7km from Battambang town that is
expanding following improvements to the national road network. The site has good road access
for both the construction and operation phases. The Facility will be constructed on a plot of
about 2,880 m² inside the existing Rice Mill compound which is elevated from the ground level.
However, if needed, the surface level of the ground may further be raised. A Land Acquisition
and Resettlement Plan for the Facility is not relevant as the land is privately owned.
59. The area is on a floodplain, susceptible to floods. Flooding causes risks of release of
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waste from the grain handling process and from toilets within the facility. These can be
mitigated by the construction of building and treatment ponds on raised platforms and inclusion
of provisions for drainage of a specification sufficient for safe draining of flood water.
60. There are no buildings, temples or items of cultural significance that will be affected by
the works. There are no salinity issues expected at the site as ground water will not be used,
and soil erosion will be avoided through proper compaction.
61. Environmental Health and Safety (EHS) Manual under the Facility implementation i s
recommended to develop to avoid or reduce any anticipated impact on workers or community.
Discussion with stakeholders on the specific roles and responsibilities focused on
environmental health and safety accountabilities of the working labor law. Authorities are made
responsible to document any impact on the project participants (workers, staff and community
people) during the Facility operation. The bidding document for contractor consideration and
discussion focused on: (i) The plan for performing the tasks on behalf of the client; (ii) The
action that has to be taken and/or procedures that has to be followed; (iii) Significant
environmental health and safety aspects/hazards that shall be documented after risk
assessments; and (iv) Accident that could have been due to the Facility shall be investigated
in a timely manner.
C. Environmental Impacts Related to Construction
62. Construction activities will cause environmental impacts that are potentially significant,
although in most cases they can be mitigated and in all cases, effects are temporary.
Mitigation measures are stipulated in an EMP which is to be included in bid documents,
allowing bidding contractors to include the cost of mitigation in their pricing.
63. The preparation of foundations for the building will involve excavation/drilling (albeit upon
a filled area). Excavation operations may result in the release of silt and dust. Some or all of the
material produced by the excavations will be used on site to create a raised platform for treatment
ponds. Silt trap will be used wherever there is scope for run-off water from the site to carry silt to
surrounding location. 64. Dust will be released from building construction and equipment installation. However,
the construction activities will take place well within the private land owned by the Rice Miller
and dust is not expected to cause nuisance or hazard to local people. And when excavation
takes place during dry conditions, excavated surfaces and stockpiled material shall be sprayed
with water to prevent the release of dust
65. Vehicle and excavators’ activity will take place away from peoples’ homes and
nuisance and health effects of exhaust emissions will not be significant. For the same
reasons, noise nuisance is not expected to be significant. Site manager shall ensure all
excavators and vehicles are kept in a secure and appropriate location, based on contractor’s
campsite (outside or inside the Rice Mill compound). The drivers or users of excavators and
vehicles shall be trained operators and where appropriate shall have license for operating them.
66. Much of the labor and some of the skilled labor required for the work will be obtained
locally, however contractors are likely to bring staff from other parts of Cambodia, who will
be accommodated locally during construction, either in rented accommodation or in temporary
housing. Interactions with local residents can potentially lead to the spread of communicable
diseases, social disturbance and the release of raw sewage from temporary toilets. Potential
effects will be mitigated by (i) maximizing employment form local residents, to the extent
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practicable, (ii) construction of suitable toilets such as pit latrines on sites identified by local
communities, and arrangements for grey water treatment and discharge, such as soakage pits,
to minimize the release of pollutants into waterways, (iii) arrangements for collection of solid
waste, (iv) briefing of workers and awareness raising of the local population on potential risks
of infection and communicable diseases, including advice on avoidance of such problems,
and (v) allocation of responsibility to an on-site member of the contractor’s staff to ensure that
these measures are observed continuously.
67. Site works may pose potential hazards to workers and villagers. Personal Protective
Equipment (PPE) shall be issued to workers wherever appropriate including helmet, steel
toe-capped boots and hand protection when working on excavations, and dust masks when
working in dusty conditions. Provision shall be made for safe storage and use of hazardous
materials such as fuels and lubricants. Each contractor shall prepare a site safety plan and
obtain approval for it from the supervising agency prior to the start of works. An on-site
member of the contractor’s staff shall be responsible for the implementation of the safety plan.
D. Environmental Impacts Related to Operation 68. The facility will be housed in a large industrial scale building constructed for the purpose
and will contain storage and transfer bays and specially designed high capacity machinery for
processing functions. Potential health and safety hazards to workers include accidental contact
with moving parts, noise nuisance and respiratory problems from dusty conditions. These risks
are mitigated by the inclusion of safety railings, and by training and instruction to workers.
69. Power generation by means of a gasifier fed with rice husk will produce exhaust gas.
The gasification process causes the organic material of which the husk is formed to be
converted to a producer gas, which is a clean fuel, which is then burned to produce electrical
power. Gasification results in more complete breakdown of the organic material, and minimal
release of particulate pollutants. The feasibility of using gasification depends on the quality and
volume of husk produced, and availability of skilled technical services for periodical
maintenance of the gasifier plant. A small amount of dust is produced by the gasification
process, which shall be collected during regular cleaning of the plant and used by the Rice
Miller or provided to local farmers to make use of its nutrient content.
70. In the event that a gasifier does not prove feasible, a diesel generation plant shall be
installed. Any diesel generation plant will conform to Electricity Authority of Cambodia
standards, will be fitted with exhaust baffles, exhaust fumes shall be released at a height of
not less than 15 m above the ground and at least 20 m away from any raised working platform,
and shall be subject to regular routine maintenance.
71. Dust produced by the drying process will be collected by passing dust laden air from
the dryer into a chamber where water is introduced by a series of sprayers. The water spray
causes the dust to collect and form a slurry which is non-toxic and can be provided to famers
for re-use as a soil conditioner. The dust removal system is expected to bring ambient dust
levels within the plant to acceptable levels. However, dust masks will be made available for
workers, and dust levels will be monitored. Should dust levels within the plant exceed the
national standard (less than 0.33 mg/m3 of total suspended particles in ambient air) the use of
dust masks by workers will be made mandatory.
72. Water from the dust removal plant will be combined with condensate from the dryer
and will be treated in settling ponds, to enable organic matter to be extracted, and used by the
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Rice Miller or provided to farmers as a slurry. The settling ponds shall be on a raised platform,
at least 0.5 m above the height of 10-year flood levels.
73. Noise within the facility will be reduced by the inclusion of noise baffles on machinery
and ear protection is provided where necessary.
74. To ensure sanitary conditions in and around the facility, an on-site system of treatment
of sewerage from workers’ toilets will be provided. An assessment of the adequacy of the water
supply will be made to test the water quality and quantity. If water from the supply is not potable
or available in adequate quantity, alternative sources of water shall be investigated, which may
include the collection and storage of rain water (as a partial supply), or use of groundwater.
Provision shall be made for treatment for use to render it safe for washing purposes, while
potable water shall be obtained from a supply approved by the Ministry of Industry, Mines and
Energy.
75. The site will be prone to periods of intense rainfall during storm events and may be
subject to occasional flooding. The design of the building will therefore include provision for
drainage of a specification sufficient to handle storm-water flows, and safe draining of receding
flood water when this occurs. The drainage system will be sufficient to prevent the formation
of ponds and muddy patches within the facility compound. Adequate fill is proposed to raise
the ground level to a height that poses little risk from flooding.
E. Global, Trans-boundary and Cumulative Impacts
76. The proposed PDS Facility will contribute to expanding the cumulative paddy drying
and storage capacity in Cambodia thereby alleviating the current disadvantage to Cambodian
farmers whereby they are forced to sell wet paddy to buyers from neighboring countries.
77. The successful installation of dust control and worker safety measures will provide
examples of good practice in providing replicable examples of healthy working environments
in an industrial setting around the country. Similar measures may be taken up by other
industries.
78. The wider availability of safe and high standard grain drying facilities will mean fewer
farmers have to resort to on-farm drying, which can be problematic when crops are exposed
to contamination by vehicle fumes and similar, and drying is often uneven through the crop,
creating most pockets where fungus can develop.
79. Reducing dependence on drying and storage facilities in neighboring countries will
have an impact on trans-boundary trade. However, no trans-boundary environmental impacts
are envisaged.
VI. ANALYSIS OF ALTERNATIVES
80. The alternative means of ensuring access by farmers to PDS facilities are (i) allowing
the existing situation, where facilities in neighboring countries are used, (ii) promotion of on
farm drying, and (iii) provision of fewer, larger scale facilities. The existing situation would
allow current constraints on profitability to remain, where price is controlled by buyers from
neighboring countries, and less thorough on-farm and ad hoc drying continues. The promotion
of on-farm drying offers little scope to improve current practices, as many farmers have
insufficient land to use for drying surfaces and are nonagricultural flat areas such as road
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verges, where the crop is subject to contamination by vehicle fumes and pathogens on the
ground, as well as uneven drying and the potential for fungal infestation to develop.
81. The “no project” alternative would mean either, the substitution of the subproject with an
alternative eligible subproject, or continued reliance on foreign facilities or on-farm facilities.
Private companies may take advantage of the opportunity to provide paddy drying, but this may
develop over a protracted period in the absence of the subproject which, as a pilot will replicable
example of a well designed and constructed facility.
VII. INFORMATION DISCLOSURE, CONSULTATION AND PARTICIPATION
A. Consultations and Information Disclosure during design
82. Consultations were conducted from early subproject preparation stage relating to
preliminary engineering designs prepared by the consultants and other items concerning to the
subproject implementation through visits to the subproject site, commune and PIO during
February-March 2019. The subproject was discussed with the Governor’s office, and with the
director and staff of the provincial department of agriculture (PDA) in the province.
83. A public consultation meeting was conducted on 24 May 2019 at the subproject site to
undertake subproject screening and design tasks through discussions with relevant
stakeholders including Rice Miller, villagers including those who have land boundaries with the
proposed subproject site, village chief, commune chief, district governor, PIO director, PDOE
director, PDAFF staff, PDLMUPC staff, provincial gender focal point, etc. and with the
participation of MAFF officials, PMO officials & consultants, and DD& CS consultant for PDS
Facilities. A total of 22 participants including 5 women participated in the consultation meeting.
(See Annex 11).
84. In the consultation meeting, subproject plans were outlined and stakeholders were
asked if they had any concerns or other points to raise. The discussion with stakeholders
particularly villagers surrounding the rice mill was conducted focusing on potential
environmental impact of the proposed Facility. Rapid Environmental Assessment Checklist
(REA), EMP, and Grievance Redress Mechanism (GRM) were discussed and agreed upon
during consultation process. The results of the public consultation meetings concluded that
villagers and authorities at all levels have welcomed the proposed PDS Facility. All of them
understand that the proposed Facility will give more benefit to the people in Anlong Vil
commune. Furthermore, the participants whole heartedly welcomed and supported the
subproject as the proposed PDS Facility will provide opportunity to them to expand their rice
business as the Rice Miller will buy more paddy from them than earlier times, farmers will be
able to save on transportation cost as they do not have to transport the paddy very far, and
also they can work as labor at the Facility to earn income. The public consultation was organized
in an atmosphere free of intimidation or coercion ensuring gender inclusiveness and enabled the
incorporation of all relevant views into the project design and arrangements for implementation.
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Figure 5: Consultation meeting with relevant stakeholders and visit to proposed PDS Facility location
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B. Further Information Disclosure
85. A summary of this IEE will be presented to commune officials and the public, and to the
PIO/PDA/ PDOE in Battambang. Copies will be left for review and during construction and
operation, communities in and around the subproject area will be kept informed of construction
activities that are likely to cause noise and dust nuisance, or disruption to irrigation flows or
roads and pathways. Project profile and progress report will be posted in project website.
VIII. GRIEVANCE REDRESS MECHANISM
86. People living close to a development site may experience some adverse impact during
the subproject implementation period. People who may be affected by the subproject or
concerned about its environmental impacts are entitled to lodge complaints regarding any
aspect of the preparation and implementation of the subproject.
87. The objective of 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.
88. A well-defined grievance redress and resolution mechanism is established to resolve
grievances and complaints in a timely and satisfactory manner. The PMO has informed and
discussed about it with the villagers during the public consultation meeting. All affected persons
will be made fully aware of their rights, and the detailed grievance redress procedures will be
publicized through an effective public information campaign. The grievance redress process
applies to potential environmental issues and includes four steps of which three are followed
before complaints may be elevated to a court of law as a last resort, as follows (see Figure 6
below):
(i) 1st step: Complaints and grievances will be provided verbally or in writing to the village chief and/or commune chief. The receiving agent will provide immediate written confirmation of receiving the complaint. If after 15 days the complainant does not hear from the village chief and/or commune chief or if he/she is not satisfied with the decision taken in the first stage, the complaint may be brought to the District Office.
(ii) 2nd step: The District Office in cooperation with the Provincial Implementation Office
(PIO) representative and PDAFF officials has 15 days within which to resolve the
complaint to the satisfaction of all concerned. If the complaint cannot be solved at this
stage, the District Office will bring the case to the Provincial Governor Office (PIO)
and/or Provincial Grievance Redress Committee (PGRC) and has to inform the
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complainant.
(iii) 3rd step: The PIO/PGRC in cooperation with the PMO Program Manager/Program
Director meets with the aggrieved party and tries to resolve the situation within 30 days
of receiving the complaint and to the satisfaction of all concerned. The PIO/PGRC
will make a written decision and submit copies to the executing and implementing
agency (MEF/PMO).
(iv) 4th step: If the aggrieved person does not hear from the PIO/PGRC or is not satisfied,
s/he can bring the case to Provincial Court. The Court will make a written decision and
submit copies to the executing agency and implementing agency. If any party is still
unsatisfied with the Provincial Court judgment, he/she can bring the case to a higher-
level court.
Figure 6: Grievance Redress Mechanism
Complainant-APs and stakeholder inform Village Chief, Commune Chief, Site Manager of the Contractor (before elevate to the District)
Meeting of the complainant-APs with Village Chief, Commune Chief and Site Manager of the Contractor (if no result elevate to District level)
Provincial court
Next Higher Court
Provincial Governor Office (PIO), PDAFF and/or Provincial Grievance Redress Committee (PGRC) with participation from PMO Program Manager/ Program Director. (if no result elevate to ……)
Meeting of the complainant with District Governor, Provincial Implementation Office (PIO) Representative, PDAFF officials, Commune Chief, and Representative of the Contractor (if no result elevate to Province level)
Resolution of Complaint
YES
YES
YES
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89. It is recognized that, in many cases, people with a grievance may not have the writing
skills or be able to express their grievances verbally, however, complainants are encouraged to
seek assistance from other family members, villagers, village heads or community chiefs to have
their grievances recorded in writing and to have access to project documentation to ensure that
where disputes do occur all the details have been recorded accurately enabling all parties to be
treated fairly.
90. The Program Management Office (PMO) under the Program will shoulder all
administrative costs incurred in the resolution of grievances and complaints within the
project-level grievance redress mechanism. If the complainant seeks grievance redress
through local or country-level judicial and administrative mechanisms, the requirements and
procedures applicable to the relevant jurisdiction shall apply. 91. All complaints and resolutions will be properly documented in a logbook by the
concerned project officials including representative of the contractor and DD & CS firm and be
available for the public and review for monitoring purposes. The logbook will be kept in a place
accessible to all relevant stakeholders to record complaints and action taken properly during
the subproject implementation.
92. Environmental monitoring reports will include the following aspects pertaining to
progress on grievances: (i) number of cases registered with the PIO/PGRC, level of
jurisdiction (first, second, and third tiers), number of hearings held, decisions made, and the
status of pending cases; and (ii) lists of cases in process and already decided upon may be
prepared with details such as name, identification with unique serial number, date of notice,
date of application, date of hearing, decisions, remarks, actions taken to resolve issues, and
status of grievance (i.e. open, closed, and pending).
IX. ENVIRONMENTAL MANAGEMENT PLAN
A. Responsibilities for Environmental Management 93. The environmental management plan (EMP) covers all phases of core subproject
implementation from preparation through commissioning and operation, and it aims to
ensure the monitoring of environmental impacts and activation of environmental mitigation
measures. Relevant parts of the EMP will be incorporated into the construction, operation,
and management of subproject. Environmental protection measures will (i) avoid, and (ii)
where avoidance is not possible, mitigate environmental impacts, and (iii) achieve
compliance with national environmental regulations and ADB safeguard Policy statement
2009.
94. The mitigation measures required for the design and preconstruction, construction and
operation phases of the improved infrastructure are described in Annex 9, where the allocation
of responsibility for costs of mitigation are detailed. The PMO has overall responsibility for
implementing the EMPs and during the design and construction phases, will be supported by
the Provincial Implementation Office (PIO) located at Governor’s office in the province. The
PMO will be fully supported by the Detailed Design and Construction Supervision (DD&CS)
consultant on safeguard implementation, monitoring and reporting activities. The cross
sectorial implementation consultants based at PMO will provide necessary backstopping in
review and finalization of reports and recommendation of mitigation measures based on
EMP.
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95. The EMP should form part of the contract documentation so that the contractor in
each case incorporates the cost of mitigation into the bid price, including provision of staff
and equipment necessary to carry out all mitigation tasks in full. Preparation of the environment
section in the Terms of Reference for bidders for construction contracts and environmental
contract clauses for contractors, namely the special conditions (referencing the EMP and
monitoring plan) will be prepared and included. The contractor shall review the EMP and shall
within 30 calendar days from the date of the Letter of Acceptance submit for approval of the
Project Manager the Construction Environmental Management Plan (CEMP) to include any
additional or varied environmental management or mitigation measures that the Contractor
wishes to apply or considers are desirable. Subject to the approval and amendments required
by the Project Manager, the CEMP will be incorporated into the Contract documents, and will
be finalized ahead of any contract works commencing.
96. During PDS facility operation, responsibility for mitigation rests primarily with the Rice
Miller supported by relevant provincial departments. The summary of environmental management
plan is in Annex 9.
B. Environmental Monitoring
97. Environmental issues associated with the subproject that potentially warrant monitoring
are: (i) compliance with EMPs during construction and operation to ensure that the required
monitoring takes place, (ii) noise and dust nuisance during construction, and (iii) noise, dust
and safety issues during operation. See the detail environmental monitoring plan in Annex 10.
98. Construction impacts will be limited, partly because construction site is distant from
homes, and also because effects will be short lived and, if EMPs are properly implemented,
significantly mitigated. No monitoring other than for compliance with EMPs is recommended.
99. It is therefore recommended that monitoring is confined to monitoring for compliance
with EMPs and basic testing for noise and dust levels.
1. Monitoring for Compliance with EMPs
100. To ensure that potential environmental problems are detected and addressed
appropriately, environmental monitoring will take place during construction and operation of
each subproject. During construction, the key tasks are monitoring the compliance with
environmental mitigation measures in the EMP for the subproject, which shall be done by the
construction supervision team. During operation, responsibility for monitoring shall rest with the
provincial departments.
2. Testing for Noise and Dust Levels
101. The ambient air within grain drying and handling plant will be tested to measure total
suspended particles. The required standard is less than 0.33 mg/m3 of total suspended
particles, given in Annex 1 of the Sub-decree on Air Pollution and Noise Disturbance (2000).
(see Table 3). Tests will be carried out once per year during operation, at each plant.
102. Noise levels will be determined with an integrating noise meter. The maximum noise
level in a workshop, factory and industry as specified in Annex 7 of the Sub-decree on Air
Pollution and Noise Disturbance (2000) is 85 dB(A). This should be taken as the continuous
noise equivalent level of 85 dB(A) Leq, and determined by using an integrating noise meter.
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Readings and analysis will be undertaken once per year during operation, at each plant.
C. Environmental Monitoring Reports
103. To ensure proper and timely implementation of the EMP and adherence to the agreed
environmental covenants, the PMO will submit semi-annual environmental monitoring report
to the ADB including environmental performance based on the monitoring and inspections
data and the report will be disclosed on the ADB website.
D. Institutional Arrangement and Responsibilities
104. At the feasibility stage of the PDS Facilities following a revised implementation approach the
primary management framework overseeing the implementation of the EMP was defined by: 1)
the MEF who is the executing agency and has established a PMO to oversee implementation
of the subprojects in Battambang, Kampong Thom and Prey Veng provinces; and 2) the PIO
located at Governor’s office in these provinces will support and assist the PMO in
implementation of these subprojects. The PMO has established a PDS Selection Committee in
cooperation with the Ministry of Agriculture, Forestry and Fisheries/National Implementation
Office (MAFF/NIO) and the three Provincial Implementation Offices (PIOs) who will participate
in the PDS procurement process.
105. The PMO will shoulder all administrative costs incurred in the resolution of
grievances and complaints within the project-level grievance redress mechanism and is
responsible for implementing the EMPs. During the design and construction phases, the PMO
will be supported by the PIOs. The winning contractor shall prepare the CEMP and upon
endorsement by the Program Manager will be fully responsible for its implementation. The
PMO will be supported by the DD&CS consultants on safeguard implementation, monitoring
and reporting activities. The environmental specia l is t and other cross sectorial
implementation consultants of the program will provide necessary backstopping in review
and finalization of reports and recommendation of mitigation measures based on EMP.
During PDS facility operation, responsibility for mitigation w i l l rest primarily with the Rice
Miller supported by relevant provincial departments (PDOE/PDOLVT).
X. CONCLUSION AND RECOMMENDATIONS
106. This IEE process has found that the subproject will not cause significant negative
environmental impacts. Potential negative impacts relate mainly to the construction phase
and can be managed and brought to acceptable levels through the implementation of the EMP.
The Rice Miller has applied and received the Environmental Protection Agreement from PDOE
as part of establishing the PDS Facility and improving the business operation performance as
attached in Annex 1.
107. The subproject is therefore being classified as Category B according to the
environmental assessment and ADB’s classification system. This refers to subprojects that are
judged to have some adverse environmental impacts, but can be mitigated by specific EMP.
The subproject specific EMP as attached in Annex 9 and environmental monitoring plan as
attached in Annex 10 will be implemented to mitigate negative impacts during or after
subproject implementation.
108. During consultation meeting and field observation all relevant stakeholders confirmed
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that the proposed PDS Facility site and its surrounding area have been actively cultivated since
the years of conflict, and they did not come across with any UXO in the proposed area. The
safety guarantee certificate will be obtained from CMAC to make sure no mine and UXO present
in subproject area.
109. It is recommended that the EMP is included in contract document for works contracts.
110. PMO will monitor and supervise the subproject under the technical support by the Detail
Design (DD) and CS consultants to ensure contractors are properly implementing all
environmental mitigation measures during construction stage as set out in the IEE and other
environmental safeguards. The PMO will also deploy the cross sectorial implementation
consultants based at PMO to provide necessary backstopping in monitoring and supervision
of the subproject.
XI. REFERENCES
Royal Government of Cambodia Sub-Decree No 72 ANRK. BK. (Dated 11 August 1999).
Water Quality Standard in Public Water Areas for Bio-Diversity Conservation. Annex
4 of Sub-decree on Water Pollution Control, 1999.
Average annual and monthly Rainfall 2011-2018. Provincial Department of Water
Resources and Meteorology.
Ambient Air Quality Standard. Annex1 and Annex 7 of Sub-Decree on Air Pollution
Control and Noise Disturbance, 2000.
Name of villages, communes and districts of provinces. Minister Interior. 2015.
Water Testing Parameters and Maximum Value. Directorate General of Environmental
Protection Laboratory, MOE.
IFReDI.2010. Fisheries Resources in Cambodia-Current Status, Key Issues and
Direction. Dr. So Nam.
First Semiannual Report, 2016. Battambang Fisheries Administration Cantonment.
Battambang Development Plan, 2016-2018.
Solid waste management sub-decree No 36 ANRK.BK. Da t e d 2 7 April 1999.
Law on Environmental Protection and Natural Resources Management. The Preah
Reach Kram/NS-RKM-1296/36. Dated 24 December 1996.
The sub-decree No 27 ANRK.BK on Water Pollution Control. Dated 6 April 1999.
Ministry of Planning, Poverty Reduction by Capital, Provinces, Municipalities,
Districts, Khans, and Communes, Sangkats, Based on Commune Database
(CDB) 2004-2012
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XII. ANNEXES
Annex 1: Agreement of Phou Poy Rice Mill with PDOE, Battambang
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Kingdom of Cambodia Nation Religion King
Environmental Protection Agreement
I am Ith Michael, age 36 years old, Cambodia Nationality, ID Card: 170565814 dated 26 January 2011; Expire date: 26 January 2021, Permanent Address: 20 Uksaphea Village, Sangkat Prek Preah Sdach, Krong Battambang, Battambang Province, Representative of Phou Poy Rice Mill. To: Director of Battambang Provincial Department of Environment To contribute to environmental protection in the process of social development, I do the following environmental commitments to Battambang Provincial Department of Environment for Phou Poy Rice Mill business operation that is located in Chumnik Village, Anlong Vil Commune, Sangkae District, Battambang Province, as below: Provision1.
Ensure management of liquid waste storage tanks, and properly manage sediment discharge from the storage tank before releasing it to authorized areas or the public sewer system.
Provision2. Ensure the management of garbage, do not dispose off the garbage in public places or areas near the source of water thereby affecting the public order, aesthetic and also people who have residences nearby.
Provision3. Ensure minimization of noise, vibration, dust, and odor release due to rice mill operation and avoid health hazards to workers and people living nearby due to the release.
Provision4. Allow Environmental Officer from Battambang Provincial Department of Environment who has valid mission letter to inspect the rice mill site every 30 days to advise on pollution control in the environment.
Provision5. In case the department or the Ministry of Environment requires me to modify any environmental techniques to comply with the new guidelines and standards, I would completely agree to the guidelines.
Provision6. Volunteer to contribute some funds as environment fee to Battambang Provincial Department of Environment every year.
Provision7. This agreement is valid for one year from the date of this agreement. 30 days prior to the expiry of this agreement, I will submit a request for renewing the agreement to Battambang Provincial Department of Environment for the new term.
Provision8. In the case that I failed to comply with any provision or contrary to this agreement, I shall be fully responsible under the relevant Cambodian Laws, especially Environmental Protection and Natural Resources Law.
BTB Date: 29.04.2019 Thumb Print
Ith Michael
Seen and Verified To Director of PDOE
BTB Date: 29.04.2019 Chief of Environmental
Protection Office
No. 162/Bor.Sor.khor.Bor Seen and Approved
BTB Date: 29.04.2019 Director of PDOE
Un-official Translation
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Annex 2: Water Quality Standard in Public Water Areas for Bio-Diversity
Conservation
No Parameter Unit Standard Value A. River
1 pH mg 6.5 – 8.5
2 BOD5 mg
1 – 3 Suspended Solid mg 25 – 100
4 Dissolved Oxygen mg 2.0 - 7.5 5 Coli-form MPN/100ml <
B. Lakes and Reservoirs 1 pH mg 6.5 – 8.5 2 COD mg 1 3 Suspended Solid mg 1 – 4 Dissolved Oxygen mg 2.0 - 7.5 5 Coliform MPN/100ml < 6 Total Nitrogen mg 0.1 – 0.6 7 Total Phosphorus mg 0.005 – 0.05
C. Coastal water 1 pH mg 7.0 – 8.3 2 COD mg 2 3 Dissolved Oxygen mg 2 – 4 Coliform MPN/100ml < 5 Oil content mg 0 6 Total Nitrogen mg 0.2 – 1.0 7 Total Phosphorus mg 0.02 – 0.09
Note: l = liter; mg = milligram; ml = milliliter
Source: Annex 4 of Sub-decree on Water Pollution Control, 1999
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Annex 3: Land Title of Phou Poy Rice Mill Issued by PDLMUPC
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Annex 4: Existing Location of Phou Poy Rice Mill
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Annex 5: Detail Design of PDS facility for Phou Poy Rice Mill
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Annex 6: Calculation of Capacity Including Raw Materials for PDS facility at Phou Poy Rice Mill
BATTAMBANG
RAW MATERIAL CALCULATIONWet Paddy ( avg. 30% M.C. ) : 10,000T
Harvest duration in 1 season : 30Days
Drying Capacity : 333 TPD
DRYING PLANTWet Paddy ( avg. 30% M.C. ) : 333TPD
Loss 4% Impurities : -13TPD
Loss 16% M.C. : -53TPD
Dried Paddy ( avg. 14% M.C. ) : 266 TPD
PADDY STORAGEDried Paddy ( avg. 14% M.C. ) : 266TPD
Harvest duration in 1 season : 30Days
Dried Paddy storage per season : 7,992 T
MILLING PLANTMilling capacity : 6TPH / 144TPD
Capacity of paddy storage per season : 56 Days
16% + 4%
PHOU POY DEVELOPMENT
10,000T Paddy per season (30% M.C.)
Water + Immature Grain 25 TPD
HUSK
66 TPDDRYING PLANT
CAPACITY 333 TPD
266 TPD
RICE MILL
CAPACITY 96 TPD
10000 ÷ 30 =
266 � 30 =
DRIED PADDY
STORAGE~8000 T
Burner ASH
1 TPD
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Annex 7: Total Annual Rainfall from 2011-2018 in Battambang Province
Year 2011 2012 2013 2014 2015 2016 2017 2018 Average
Rainfall(mm) 1,656.9 1,337.8 1,374.0 885.3 1,095.1 960.1 1,350.7 1,181.2 1230.14
Source: Provincial Department of Water Resources and Meteorology, Battambang province.
Annex 7.1: Average Monthly Rainfall from 2011-2018 in Battambang Province
Year/ Month
Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec
2011 -
50.8
35.1
152.7
151.5
107.0
186.8
253.2
289.1
392.2
34.3
4.2
2012
16.2
46.8
57.8
56.3 166.2
73.7
133.6
93.2
356.7
249.4
87.9 -
2013 - -
21.6
35.6 90.1
277.4
152.4
86.4
311.5
275.9
94.3
28.8
2014 -
0.4
2.4
84.1 46.9
69.6
191.0
146.8
88.9
208.7
39.8
6.7
2015
0.3
9.4
6.9
31.0 66.0
147.9
174.9
72.9
281.5
214.2
90.1 -
2016
15.9
1.0
1.2
17.4 115.0
100.4
157.1
95.5
197.0
179.4
65.6
14.6
2017
18.8
0.1
96.8
107.6 118.9
190.9
133.9
184.8
145.0
246.7
100.7
6.5
2018
8.5
3.2
96.0
88.0 165.1
109.3
156.0
137.3
204.3
167.1
19.7
26.7 Average Rainfall
(mm) 8.5 8.7 40.4 60.0 109.7 138.5 157.0 116.7 226.4 220.2 71.2 11.9
Source: Provincial Department of Water Resources and Meteorology, Battambang province.
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Annex 8: Rapid Environmental Assessment Checklist Screening Questions Yes No Remarks
A. Project Siting Is the Project area adjacent to or within any of the following environmentally sensitive areas?
Cultural heritage site
x No cultural heritage sites are adjacent to or within the subproject area.
Protected Area x There are no environmentally sensitive areas within the subproject area.
Wetland
x
Mangrove
x
Estuarine
x
Buffer zone of protected area
x
Special area for protecting biodiversity
x
Bay
x
B. Potential Environmental Impacts Will the Project cause…
Ecological disturbances arising from the establishment of a plant or facility complex in or near sensitive habitats?
x The proposed PDS Facility is to be built on privately owned land and it is not in or nearby any sensitive habitats. Respondents did not express any concerns about any loss of ecological values by construction and operation of the Facility.
Eventual degradation of water bodies due to discharge of wastes and other effluents from plant or facility complex?
x The design of the Facility includes sewage treatment ponds to be constructed on a raised platform. Water from the dust removal plant will be combined with condensate from the dryer and will be treated in settling ponds, to enable organic matter to be extracted, and used by the Rice Miller or provided to farmers as a slurry for re-use as a soil conditioner. The settling ponds shall be on a raised platform, at least 0.5 m above the height of 10-year flood levels. The silt produced by the excavations will be used on site to create a raised platform for treatment ponds. Silt trap will be used wherever there is scope for run-off water from the site to carry silt to surrounding location.
Serious contamination of soil and groundwater?
x Not expected as construction work will use a small amount of water only as readymade mixed concrete from supplier will mainly be used. There are also no salinity issues expected at any sites as ground water will not be used. Provision shall be made for safe storage and use of hazardous materials such as fuels and lubricants. An on-site member of the contractor’s staff shall be responsible for the implementation of the safety plan.
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Screening Questions Yes No Remarks
Aggravation of solid waste problems in the area?
x Solid wastes from the Facility will be treated in the treatment ponds and organic matter will be extracted, and use as fertilizer by the Rice Miller himself or may sell to farmers to generate extra income. The Contractor will install onsite WC for their workers. To ensure sanitary conditions in and around the facility, an on-site system of treatment of sewerage from workers’ toilets will be provided.
Public health risks from discharge of wastes and poor air quality; noise and foul odor from plant emissions?
x The proposed Facility will be far from local residents and nuisance and health effects of exhaust emissions and noise will not be significant. The proposed Facility will be constructed on a small plot of land inside the existing Rice Mill compound which is constructed on a 60 ha of single parcel of land owned by the Rice Miller. Responded did not express any concern on the discharge of wastes, noise and foul odor from the current Rice Mill. The proposed Facility will use Cyclonic type furnace which has no exhaust stack and hence no ash/smoke will be released to the environment. No waste water from this type of drying process is generated as moisture from wet paddy will evaporate. Noise from blower and its drivers i.e. electric motor will be monitored and managed through good maintenance Noise proof materials for housing will be used to reduce noise from ash room, dust room and machinery.
Short-term construction impacts (e.g. soil erosion, deterioration of water and air quality, noise and vibration from construction equipment?
x Construction work will use a small amount of water only and no ground water will be used for construction. Contractor will install onsite WC for their workers. Noise and vibration from hammering (for temporary period and short duration only) during construction period will be monitored and managed through use of new motor or good maintenance. When excavation takes place during dry conditions, excavated surfaces and stockpiled material shall be sprayed with water to prevent the release of dust. The silt produced by the excavations will be used on site to create a raised platform for treatment ponds. Silt trap will be used wherever there is scope for run-off water from the site to carry silt to surrounding location. Good construction practices to mitigate noise, soil erosion, dust to be specified in the EMP and specifications. In addition, most construction activities will be far from local residents and nuisance and health effects of exhaust emissions will not be significant. For the same reasons, noise nuisance is not expected to be significant.
Dislocation or involuntary resettlement of people?
x Not Applicable as the proposed Facility will be constructed on a small plot of land (about 2,880 m²) inside the existing Rice Mill compound which is constructed on a 60 ha of single parcel of land owned by the Rice Miller of which around 10 ha has been fenced. (land title issued by PDLMUPC, Battambang, on 31 July 2006 is attached as Annex 3 to the IEE).
Disproportionate impacts on the poor, women and children, Indigenous Peoples or other vulnerable groups?
x The Facility will not impact poor, women and children, or other
vulnerable groups negatively. Currently, the Rice Mill employs 25
villagers including 13 women and after the completion of the
Facility, the Rice Mill may employ double number of villagers to
work in the mill. The Rice Miller has good reputation of treating
men and women equally and paying same rate for the same task.
Contractors will be made aware and proper monitoring and
supervision will be done to make sure no child labor is employed
during the construction. However, if people are not happy they
can complain through the GRM process.
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Screening Questions Yes No Remarks
Environmental degradation (e.g. erosion, soil and water contamination, loss of soil fertility, disruption of wildlife habitat) from intensification of agricultural land use to supply raw materials for plant operation; and modification of natural species diversity as a result of the transformation to monoculture practices?
x Rice cultivation is the predominant land use in the proposed PDS Facility area. The lack of drying facilities is forcing many farmers to sell their wet paddy directly to buyers from neighboring countries where modern facilities are available. The surrounding villages will benefit greatly from establishment of the Facility as the Rice Miller can accommodate more wet paddy from them than earlier times. The Facility will neither alter agricultural land use nor modify natural species diversity.
Water pollution from discharge of liquid effluents?
x No waste water from this type of drying process is generated as moisture from wet paddy will evaporate. The design of the Facility includes sewage treatment ponds to be constructed on a raised platform. Water from the dust removal plant will be combined with condensate from the dryer and will be treated in settling ponds, to enable organic matter to be extracted, and used by the Rice Miller or provided to farmers as a slurry.
Air pollution from all plant operations?
x When excavation takes place during dry conditions, excavated surfaces and stockpiled material shall be sprayed with water to prevent the release of dust. The proposed Facility will use Cyclonic type furnace which has no exhaust stack and hence no ash/smoke will be released to the environment. Dust produced by the drying process will be collected by passing dust laden air from the dryer into a chamber where water is introduced by a series of sprayers. The water spray causes the dust to collect and form a slurry which is non-toxic and can be provided to famers for re-use as a soil conditioner.
Gaseous and odor emissions to the atmosphere from processing operations?
x Power generation by means of a gasifier fed with rice husk will produce exhaust gas. The gas is a clean fuel which will be used to produce electrical power. No ash/smoke will be released to the environment as the Cyclonic type furnace will be utilized which has no exhaust stack. The Cyclonic furnace collects ash at the bottom and then conveys to the ash room. Ash will be collected at the ash room and use as fertilizer by the Rice Miller himself or may sell to farmers to generate extra income.
Accidental release of potentially hazardous solvents, acidic and alkaline materials?
x Provision shall be made for careful loading and unloading, safe storage and use of hazardous materials such as fuels and lubricants. Each contractor shall prepare a site safety plan and obtain approval for it from the supervising agency prior to the start of works. An on-site member of the contractor’s staff shall be responsible for the implementation of the safety plan. The drivers or users of excavators and vehicles shall be trained operators and where appropriate shall have license for operating them.
Uncontrolled in-migration with opening of roads to forest area and overloading of social infrastructure?
x Not Applicable as the proposed Facility is located next to the National Highway no. 5 and will be constructed on a small plot of land inside the existing Rice Mill compound which is constructed on a 60 ha of single parcel of private land owned by the Rice Miller.
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Screening Questions Yes No Remarks
Occupational health hazards due to fugitive dust, materials handling, noise, or other process operations?
x Protective clothing shall be issued to workers wherever appropriate when working on excavations, and dust masks when working in dusty conditions. Noise proof materials for housing will be used to reduce noise from ash room, dust room and machinery. Noise from blower and its drivers will be monitored and managed through good maintenance. Noise within the facility will be reduced by the inclusion of noise baffles on machinery and ear protection is provided where necessary. Risks due to material handlings will be mitigated by the inclusion of safety railings, and by training and instruction to workers.
Disruption of transit patterns, creation of noise and congestion, and pedestrian hazards aggravated by heavy trucks?
x The proposed Facility is located next to the National Highway no. 5. The Facility will be constructed on a small plot of land inside the existing Rice Mill compound which is constructed on a 60 ha of single parcel of private land owned by the Rice Miller. However, safety precautions such as flagman to regulate traffic will be provided as specified in the EMP.
Disease transmission from inadequate waste disposal?
x The Contractor will install onsite WC for their workers. To ensure sanitary conditions in and around the facility, an on-site system of treatment of sewerage from workers’ toilets will be provided. The Rice Miller has and will continue to carry out regular fumigation around the compound to destroy temporary breeding places for diseases such as those transmitted by mosquitoes and rodents.
Risks and vulnerabilities related to occupational health and safety due to physical, chemical, and biological hazards during project construction and operation?
x No chemical, biological and radiological hazards are expected during construction and operation. For physical safety, PPE and pit latrines will be provided to all workers. Contractor will provide orientation to all workers about using PPE, first aids kit, etc. To prevent pollution of soil and water surface/ groundwater: (i) storage facilities for fuels, oil, cement, and chemicals will be
within secured areas on impermeable surfaces, provided with bunds and cleanup installations.
(ii) The contractor will not use the spilled materials related to the vehicle, machinery, and equipment that affects the soil and water sources.
(iii) fuel storage and refilling areas will be located at least 50 m from the construction sites and will be protected by temporary drainage bunds to contain spills.
(iv) During construction, care will be taken while loading and unloading of fuel stored at the campsite.
During operation, the Rice miller will continue to provide PPE, first Aids kit, etc. and training courses to workers on safety standard; carry out proper fumigation around the compound; follow the laid out regulations by the PDOLVT related to health and labor policy;
and follow the EMP and agreement with PDOE.
Large population increase during project construction and operation that cause increased burden on social infrastructure and services (such as water supply and sanitation systems)?
x The number of non-local workers will be small in number. If necessary, construction contractors will be required to provide a worker’s camp with independent basic facilities. The Rice Miller has currently employed 25 workers including 13 women which is expected to double after the new Facility becomes operational. Currently, the Rice Miller has accommodation facilities/bedrooms and 16 bathrooms including toilets, carries out monthly fumigation around the compound, provides sanitation orientation to the workers, assured pipe water from district water supply agency ensuring enough water supply to all people working in the rice mill, and provides filter water for drinking and cooking purposes. During the public consultation meeting, the Rice Miller mentioned that he is willing to construct more basic facilities if the need
arises.
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Screening Questions Yes No Remarks
Social conflicts if workers from other regions or countries are hired?
x Priority in labor employment will be given to local residents and non-local workers will be small in number.
Community health and safety risks due to the transport, storage, and use and/or disposal of materials likely to create physical, chemical and biological hazards during construction, operation and decommissioning?
x Construction area will be clearly demarcated and access controlled. Safety warnings and diversion signboards will be employed. Borrow pits will be filled back and first aids kit will be provided for the workers, project staff and stakeholders.
A Checklist for Preliminary Climate Risk Screening
Screening Questions Score Remarks
Location and Design of project
Is siting and/or routing of the project (or its components) likely to be affected by climate conditions including extreme weather related events such as floods, droughts, storms, landslides?
0 The Facility will be constructed inside the existing Rice Mill compound which is elevated from the ground level. The proposed location has never been flooded even during the big flood in 2013. The level of water was about 0.3m lower than the ground level. However, the design of the Facility includes provision for drainage of a specification sufficient to handle storm-water flows, and safe draining of receding flood water if this occurs. The drainage system will be sufficient to prevent the formation of ponds and muddy patches within the facility compound. Adequate fill is proposed to raise the ground level to a height that poses little risk from flooding. The settling ponds shall be on a raised platform, at least 0.5 m above the height of 10-year flood levels.
Would the project design (e.g. the clearance for bridges) need to consider any hydro-meteorological parameters (e.g., sea-level, peak river flow, reliable water level, peak wind speed etc.)?
0 Not applicable.
Materials and Maintenance
Would weather, current and likely future climate conditions (e.g. prevailing humidity level, temperature contrast between hot summer days and cold winter days, exposure to wind and humidity hydro-meteorological parameters likely affect the selection of project inputs over the life of project outputs (e.g. construction material)?
0 Not applicable.
Would weather, current and likely future climate conditions, and related extreme events likely affect the maintenance (scheduling and cost) of project output(s)?
0 Not applicable.
Performance of project outputs
Would weather/climate conditions and related extreme events likely affect the performance (e.g. annual power production) of project output(s) (e.g. hydro-power generation facilities) throughout their design life time?
1 Climate extreme events may affect the supply of paddy to the Facility thereby affecting the performance of the Facility.
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Annex 9: Environmental Management Plan Summary
Potential Environmental Impact
Mitigation measure(s) Cost Allocation
Responsibility for Implementation
Supervising Agency
Design and Preconstruction
Risk of flooding The Facility will be constructed inside the existing Rice Mill compound which is elevated from the ground level. The proposed location has never been flooded even during the big flood in 2013. The level of water was about 0.3m lower than the ground level. However, adequate fill is proposed to raise the ground level to a height that poses little risk from flooding. The settling ponds shall be on a raised platform, at least 0.5 m above the height of 10-year flood levels.
Include in construction
budget
DDCS Firm (IRE) MEF/PMO
Lack of mechanism to address environmental complaints
Establish and function a grievance redress mechanism (GRM), as described in the IEE (Section 8).
PMO budget PMO /PIO MEF/PMO
Make public the existence of the GRM through public awareness campaigns and display poster of GRM at the subproject site.
PMO budget DDCS firm (IRE)/ PIO/PMO
MEF/PMO
Ensure that names and contact numbers of representatives (Contractor site Manager, Village -Commune Chief, PIO and MEF/PMO representative) are placed on the notice boards outside the construction site and at local government offices (e.g., provincial and commune levels).
PMO budget Contractor/DDCS firm (IRE)/ PIO/PMO
MEF/PMO
Build capacity of the contractor on implementation and monitoring of EMP PMO budget PMO MEF/PMO
Prepare a logbook and put at a place accessible to all relevant stakeholders to record complaints and action taken properly during the subproject implementation.
Include in construction Budget
Contractor/DDCS firm (IRE)/ PIO/PMO
MEF/PMO
Effects on homes and Property.
A Land Acquisition and Resettlement Plan for the Facility is not relevant as the land is
privately owned. The Facility will be built well within the privately owned land and there will
be no need for any compensation.
Rice Miller Rice Miller
MEF/PMO/PIO
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Potential Environmental Impact
Mitigation measure(s) Cost Allocation
Responsibility for Implementation
Supervising Agency
Environmental, Health and Safety (EHS)
Measures to ensure occupational health and safety will include:
- Contractor shall be required by the PMO to ensure that their workers and other staff engaged in the proposed constructions are in a safe environment.
- Contractor shall ensure that (i) all reasonable steps are taken to protect any person on the site from health and safety risks; (ii) the construction site is a safe and healthy workplace; (iii) machineries and equipment are safe; (iv) adequate training or instruction for occupational health and safety is provided; (v) adequate supervision of safe work systems is implemented; and (vi) means of access to and egress from the site are without risk to health and safety.
- Contractor shall ensure that all workers are equipped with, and use Personal Protective Equipment (PPE)
- Contractor will provide sufficient signage giving occupational health and safety warnings and information disclosure within all construction sites.
- Contractor shall provide details of weekly/monthly toolbox meetings (safety briefings)
Community health and safety will be safeguarded by:
- Planning construction activities so as to minimize disturbances to residents, utilities and services. Temporary land occupation will be planned well ahead of construction to minimize its impact. Land will be re-instated to its original condition after construction.
- Implementing safety measures around the construction sites to protect the public, including warning signs to alert the public to potential safety hazards, and barriers to prevent public access to construction sites.
- Maximizing employment of local residents to the extent practicable.
Include in construction
budget
Contractor DDCS firm (IRE)/ MEF/PMO
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Potential Environmental Impact
Mitigation measure(s) Cost Allocation
Responsibility for Implementation
Supervising Agency
Construction Environmental Management Plan
(CEMP)
The selected contractor shall review the EMP and submit to the Project Manager the
CEMP to include any additional or varied environmental management or mitigation
measures such as (i) safety of workers and local population at construction site and
campsite; (ii) pprovision of adequate PPE and orientation on safety to workers, (iii) safe
storage and use of hazardous materials such as fuels and lubricants, (iv) maximizing
employment from local residents, (v) construction of suitable toilets such as pit latrines,
and arrangements for grey water treatment and discharge, such as soakage pits, (vi)
arrangements for collection of solid waste, (vii) provision of adequate clean water for
drinking and electricity for the worker staying overnight in the campsite, (viii) provision
of primary health care, sanitation and welfare to all workers and senior staff to ensure workers
safety and health, (ix) awareness raising of workers and local population on potential
risks of infection and communicable diseases, and (x) allocation of responsibility to an
on-site member of the contractor’s staff to ensure that these measures are observed
continuously.
Include in construction
budget
Contractor DDCS firm (IRE)/ MEF/PMO
Construction Phase
Effects associated with the use of excavated soil and/or laterite for PDS Facilities construction.
(i) Re-use excavated material to the extent practicable, (ii) Obtain materials from licensed quarries, (iii) Enter in to appropriate agreements with landowners for borrow sites, and landscaping
works to use borrow sites, in accordance with the agreements made with landowners,
(iv) Not be allowed to dispose the excavated soil into water body or other free land without local authority permit.
Include in construction
budge
Contractor DDCS firm (IRE)/ MEF/PMO
Release of silt from the site excavated due to the subproject implementation
(i) Adequate supervision of the works, (ii) Discretionary use of silt traps where warranted, (iii) Careful placing of excavated material, and (iv) Clean the silt after daily work.
Include in construction
budget
Contractor DDCS firm (IRE)/ MEF/PMO
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Potential Environmental Impact
Mitigation measure(s) Cost Allocation
Responsibility for Implementation
Supervising Agency
Water / Pollution from
construction waste water.
(i) Wastewater from the camp sites discharged by building latrine with good septic tank, (ii) Transporting waste residue to dispose a t approved dumpsites by authority to avoid
contamination of the people household, agricultural land and waterways surrounding the location, and
(iii) Provide regular truck maintenance to improve the condition and store the oil properly
Include in construction
budget
Contractor DDCS firm (IRE)/ MEF/PMO
Risk of contamination of nearby waterways
The Contractor will install onsite WC for their workers. To ensure sanitary conditions in and around the facility, an on-site system of treatment of sewerage from workers’ toilets will be provided. The design of the Facility includes provision for drainage of a specification sufficient to handle storm-water flows, and safe draining of storm water if this occurs.
Include in construction
budget
Contractor DDCS firm (IRE)/ MEF/PMO
Health risks to worker from dust pollution
When excavation takes place during dry conditions, excavated surfaces and stockpiled material shall be sprayed with water to prevent the release of dust. The proposed Facility will use Cyclonic type furnace which has no exhaust stack and hence no ash/smoke will be released to the environment. Dust produced by the drying process will be collected by passing dust laden air from the dryer into a chamber where water is introduced by a series of sprayers. The water spray causes the dust to collect and form a slurry which is non-toxic and can be provided to famers for re-use as a soil conditioner. Protective clothing s u c h a s dust masks shall be issued to workers when working in dusty conditions.
Include in construction
budget
Contractor DDCS firm (IRE)/ MEF/PMO
Risks of unsanitary working and grain storage conditions during flood events
The Facility will be constructed inside the existing Rice Mill compound which is elevated from the ground level. The proposed location has never been flooded even during the big flood in 2013. However, adequate fill is proposed to raise the ground level to a height that poses little risk from flooding. The settling ponds shall be on a raised platform, at least 0.5 m above the height of 10-year flood levels. The Contractor will install onsite WC for their workers. To ensure sanitary conditions in and around the facility, an on-site system of treatment of sewerage from workers’ toilets will be provided.
Include in construction
budget
Contractor DDCS firm (IRE)/ MEF/PMO
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Potential Environmental Impact
Mitigation measure(s) Cost Allocation
Responsibility for Implementation
Supervising Agency
Hazardous materials during subproject implementation
To prevent pollution of soil and water surface/groundwater: (i) Storage facilities for fuels, oil, cement, and chemicals will be within secured areas
on impermeable surfaces, provided with bunds and cleanup installations. (ii) The contractor will not use the spilled materials related to the vehicle, machinery,
and equipment that is going to affect soil and water sources. (iii) Fuel storage and refilling areas will be located at least 50m from construction sites
and will be protected by temporary drainage bunds to contain spills. (iv) Be careful in loading and unloading fuel during the construction activities.
Include in construction
budget
Contractor DDCS firm (IRE)/ MEF/PMO
Air quality
(i) Equipment will be maintained to a high standard to ensure efficient running and fuel-burning.
(ii) High- horsepower equipment will be provided with tail gas purifiers. (iii) All vehicle emissions will be in compliance of with relevant Cambodian emission
standards.
Include in construction
budget
Contractor DDCS firm (IRE)/ MEF/PMO
Dust control (i) Good practices on dust control during and after the operation such as material stockpiles, concrete mixing equipment will be equipped with dust shrouds.
(ii) Water spraying for suppression soil dust or any other particulates and maintenance of driving surfaces will be standard site management practices.
(iii) Vehicles carrying soil, sand or other fine materials to and from the construction sites will be covered.
Include in construction
budget
Contractor DDCS firm (IRE)/ MEF/PMO
Noise and Vibration/ Noise impacts on sensitive receivers
Construction during night time within 280m of residences shall be strictly prohibited. During daytime construction, contractor will ensure that: (i) Sites for concrete- mixing plants and similar activities will be located at least 1 km away
from residences and schools; and (ii) Temporary anti-noise barriers will be installed to shield any schools or residences within
100m of the construction site.
Include in construction
budget
Contractor DDCS firm (IRE)/ MEF/PMO
Borrow pit /quarry for getting soil for subproject construction
Contractor have to include orientation to all workers on borrow pit protection to avoid the danger (i.e. prevent cattle and people – specifically children falling into the borrow pit during and after construction activities). Contractor will ensure to:
• Install fence around the pit and put up warning signboard during the construction activities, and
• Back fill with soil after construction activities are completed.
Include in construction
budget
Contractor DDCS firm (IRE)/ MEF/PMO
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Potential Environmental Impact
Mitigation measure(s) Cost Allocation
Responsibility for Implementation
Supervising Agency
Use of land for storage and campsite
(i) Contractor will provide compensation to landowners by early in a month. (ii) In cases where landowners temporarily provide their land to the contractor to
build camp site, it will be based on a contract agreement (details will be stated in contract agreement)
(iii) After completing works, contractor will carry out restoration of land to former condition or better, according to agreements formed with landowners.
Include in construction
budget
Contractor DDCS firm (IRE)/ MEF/PMO
Effects of vehicle access related to daily operational management
Although the construction will take place inside privately owned land but the contractor has to carry out: (i) careful supervision of vehicle movements to ensure minimal damage to farmland and vegetation, etc. if any and (ii) minimal disturbances to human beings, children going to school and animal.
Include in construction
budget
Contractor DDCS firm (IRE)/ MEF/PMO
Effects of the temporary worker populations staying in a camp site
(i) Assigning the responsibility of the contractor’s staff, workers and local people’s welfare to a senior member of the contractor’s staff
(ii) Maximizing employment of local residents to the extent practicable. (iii) Construction of suitable toilets such as pit latrines on sites. (iv) Providing electricity to all workers staying overnight. (v) Providing primary health care, sanitation and welfare to all workers and senior staff
to ensure workers safety and health. (vi) Arrangements for grey water treatment and discharge, such as soakage pits, to
minimize release of pollutants into waterways. (vii) Orientation to the workers on dangers of communicable diseases.
Include in construction
budget
Contractor DDCS firm (IRE)/ MEF/PMO
Safety hazards to workers and local people during construction
Contractor work plan have to include allocation of responsibility for site safety to the contractor’s site supervisors staff to ensure all reasonable safety measures, have been taken up.
(i) Prepare and provide enough safety protection clothing and equipment, flagman, sign boards, etc. and place hazard warnings.
(ii) Provide adequate and quality drinking water to the workers. (iii) Provide enough first aids kit. (iv) Provide adequate orientation on using PPE to all workers and contractor’s site
supervisors staff.
Include in construction
budget
Contractor DDCS firm (IRE)/ MEF/PMO
Occurrence of water related diseases
Contractor work plan during construction have to include raising awareness to the workers on hazards posed by poor sanitation and use of untreated water for drinking and bathing.
Include in construction
budget
Contractor DDCS firm (IRE)/
MEF/PMO
Operation phase
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Potential Environmental Impact
Mitigation measure(s) Cost Allocation
Responsibility for Implementation
Supervising Agency
Maintenance of equipment and avoiding damage to the assets
Contractor work plan have to include orientation to all stakeholders involved on work routine and periodic maintenance, quality of equipment, and raw material to be used based on contract document
Include in construction
budget
Contractor DDCS firm (IRE)/
MEF/PMO
Water pollution from discharge of liquid effluents
No waste water from this type of drying process is generated as moisture from wet paddy will evaporate. The design of the Facility includes sewage treatment ponds to be constructed on a raised platform. Water from the dust removal plant will be combined with condensate from the dryer and will be treated in settling ponds, to enable organic matter to be extracted, and used by the Rice Miller or provided to farmers as a slurry.
Rice Miller Rice Miller PDOE, MEF/ PMO/PIO
Dust control The proposed Facility will use Cyclonic type furnace which has no exhaust stack and hence no ash/smoke will be released to the environment. Dust produced by the drying process will be collected by passing dust laden air from the dryer into a chamber where water is introduced by a series of sprayers. The water spray causes the dust to collect and form a slurry which is non-toxic and can be provided to famers for re-use as a soil conditioner. Protective clothing s u c h a s dust masks shall be issued to workers when working in dusty conditions.
Rice Miller Rice Miller PDOE, MEF/ PMO/PIO
Noise and Vibration/ Noise impacts on sensitive receivers
Noise proof materials for housing will be used to reduce noise from ash room, dust room and machinery. Noise from blower and its drivers will be monitored and managed through good maintenance. Noise within the facility will be reduced by the inclusion of noise baffles on machinery and ear protection is provided where necessary.
Rice Miller Rice Miller PDOE, MEF/ PMO/PIO
Risks and vulnerabilities related to occupational health and safety during operation
Rice miller will continue to provide PPE, first aids kit, etc. and training courses to workers on safety standard; include safety railings to mitigate risks due to material handlings and provide training and instruction to workers; carry out proper fumigation around the compound; follow the laid out regulations by the PDOLVT related to health and labor policy; and follow the EMP and agreement with PDOE.
Rice Miller Rice Miller PDOLVT/PDOE/MEF/PMO/
PIO
Residue of husk (Ash)/Waste
Cyclonic furnace collects ash at the bottom and then conveys to the ash room. i. Ash will be collected at the ash room and use as fertilizer by the Rice Miller himself
or may sell to farmers to generate extra income ii. Husk will be used as biomass fuel by the Rice Miller for their furnace/burner. iii. Ash will not be allowed to dispose into water bodies
Rice Miller Rice Miller PDOE/MEF/ PMO/PIO
Garbage/Waste generation by workers
i. Provide specific basket or bucket for kitchen garbage disposal ii. Make arrangements for collection of solid waste iii. Make arrangements for grey water treatment and discharge, such as soakage pits iv. Assign specific role and responsibility and clear schedule for maintenance and
collection of all waste
Rice Miller Rice Miller PDOE/MEF/ PMO/PIO
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Annex 10: Environmental Monitoring Plan Impact to be
Monitored
Parameters Location Means of
Monitoring
Frequency Responsibilities Cost
Estimate
Design and Preconstruction Phase
Risk of flooding The Facility will be constructed inside the existing Rice Mill compound which is elevated from the ground level. The proposed location has never been flooded even during the big flood in 2013. The level of water was about 0.3m lower than the ground level. However, adequate fill is proposed to raise the ground level to a height that poses little risk from flooding. The settling ponds shall be on a raised platform, at least 0.5 m above the height of 10-year flood levels.
Phou Poy Rice Mill located in Chumnik Village, Anlong Vil commune, Sangkae district, Battambang.
Detailed design
and
construction
supervision.
Quarterly -
follow up
record and
report
Resident
Engineer
Include in construction Budget
Lack of mechanism to address environmental Complaints
Establish and function a grievance redress mechanism (GRM), as described in the IEE (Section 8).
Phou Poy Rice Mill located in Chumnik Village, Anlong Vil commune, Sangkae district, Battambang.
Public
information
booklet.
Quarterly
follow up
record and
report
Environment
Specialist,
Resident
Engineer and
Site Manager
of the
contractor
PMO budget
Make public the existence of the GRM through public awareness campaigns and display poster of GRM at the subproject site.
Ensure that names and contact numbers of representatives (Contractor site Manager, Village -Commune Chief, PIO and MEF/PMO representative) are placed on the notice boards outside the construction site and at local government offices (e.g., provincial and commune levels).
List of contact
person and
participant list
Build capacity of the contractor on implementation and monitoring of EMP
Training document and Training program Prepare a logbook and put at a place accessible to all relevant
stakeholders to record complaints and action taken properly during the subproject implementation.
Logbook Include in construction
Budget
Effects on homes and Property.
A Land Acquisition and Resettlement Plan for the Facility is not
relevant as the land is privately owned. The Facility will be built well
within the privately owned land and there will be no need for any
compensation.
Phou Poy Rice Mill located in Chumnik Village, Anlong Vil commune, Sangkae district, Battambang.
Land title and
observation
Quarterly –
follow up
record and
report
Site Manager
of the
contractor and
Resident
Engineer.
Include in construction
Budget
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Impact to be
Monitored
Parameters Location Means of
Monitoring
Frequency Responsibilities Cost
Estimate
EHS Measures to ensure occupational health and safety will include:
- Contractor shall be required by the PMO to ensure that their workers and other staff engaged in the proposed constructions are in a safe environment.
- Contractor shall ensure that (i) all reasonable steps are taken to protect any person on the site from health and safety risks; (ii) the construction site is a safe and healthy workplace; (iii) machineries and equipment are safe; (iv) adequate training or instruction for occupational health and safety is provided; (v) adequate supervision of safe work systems is implemented; and (vi) means of access to and egress from the site are without risk to health and safety.
- Contractor shall ensure that all workers are equipped with, and use Personal Protective Equipment (PPE)
- Contractor will provide sufficient signage giving occupational health and safety warnings and information disclosure within all construction sites.
- Contractor shall provide details of weekly/monthly toolbox meetings (safety briefings)
Community health and safety will be safeguarded by:
- Planning construction activities so as to minimize disturbances to residents, utilities and services. Temporary land occupation will be planned well ahead of construction to minimize its impact. Land will be re-instated to its original condition after construction.
- Implementing safety measures around the construction sites to protect the public, including warning signs to alert the public to potential safety hazards, and barriers to prevent public access to construction sites.
- Maximizing employment of local residents to the extent practicable.
Phou Poy Rice Mill located in Chumnik Village, Anlong Vil
commune, Sangkae district, Battambang.
List of skilled
labor and
worker, list of
equipment for
contract
implementation,
water basin or
bucket,
first aid kit
Monthly and
quarterly –
follow up
report
Site Manager of
the contractor
and Resident
Engineer.
Include in construction Budget
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Impact to be
Monitored
Parameters Location Means of
Monitoring
Frequency Responsibilities Cost
Estimate
Construction Environmental Management Plan
(CEMP)
The selected contractor shall review the EMP and submit to the Project Manager the CEMP to include any additional or varied environmental management or mitigation measures such as (i) safety of workers and local population at construction site and campsite; (ii) provision of adequate PPE and orientation on safety to workers, (iii) safe storage and use of hazardous materials such as fuels and lubricants, (iv) maximizing employment from local residents, (v) construction of suitable toilets such as pit latrines, and arrangements for grey water treatment and discharge, such as soakage pits, (vi) arrangements for collection of solid waste, (vii) provision of adequate clean water for drinking and electricity for the worker staying overnight in the campsite, (viii) provision of primary health care, sanitation and welfare to all workers and senior staff to ensure workers safety and health, (ix) awareness raising of workers and local population on potential risks of infection and communicable diseases, and (x) allocation of responsibility to an on-site member of the contractor’s staff to ensure that these measures are observed continuously.
- Phou Poy Rice Mill
area or within 5km
of site earth work.
Construction
schedule and
bill of quantity
Daily and
Monthly
records
Site Manager
of the
contractor and
Resident
Engineer
Include in construction Budget
Construction Phase
Effects
associated
with the use of
excavated soil
and/or laterite
for PDS
Facilities
construction.
(i) Re-use excavated material to the extent practicable, (ii) Obtain materials from licensed quarries, (iii) Enter in to appropriate agreements with landowners for borrow
sites, and landscaping works to use borrow sites, in accordance
with the agreements made with landowners,
(iv) Not be allowed to dispose the excavated soil into water body or other free land without local authority permit.
- Phou Poy Rice Mill
area or within 5km
of site earth work.
-List of construction
material
Construction
schedule and
bill of
quantity
Daily and
Monthly
records
Site Manager of
the contractor and
Resident
Engineer
Bill of
quantity in
the contract
award
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Impact to be
Monitored
Parameters Location Means of
Monitoring
Frequency Responsibilities Cost
Estimate
Release of silt from the site excavated due to the subproject implementation
( i ) Adequate supervision of the works, ( i i ) Discretionary use of silt traps where warranted, (iii) Careful placing of excavated material, and (iv) Clean the silt after daily work.
Phou Poy Rice Mill,
Chumnik Village,
Anlong Vil
commune, Sangkae
district, Battambang.
Observation,
cross
checking with
Rice Miller and
stakeholders
Daily and
Monthly
records based
on the specific
construction
schedule
Site Manager of the
contractor and
Resident Engineer
Bill of quantity
in the contract
award
Water / Pollution from
construction wastewater
i. Wastewater from the camp sites discharged by building latrine with good septic tank.
ii. Transporting waste residue to dispose at approved dump sites by authority to avoid contamination of the people household, agricultural land and waterways
iii. Provide regular truck maintenance to improve the condition and store the oil properly
Phou Poy Rice Mill, Chumnik Village, Anlong Vil commune, Sangkae district, Battambang.
Observation,
cross
checking with
Rice Miller and
stakeholders
Monthly records based on the specific work
Site Manager of
the contractor,
Resident
Engineer, Rice
Miller and Village
Chief
Bill of quantity
in the contract
award
Risk of
contamination
of nearby
waterways
The Contractor will install onsite WC for their workers. To ensure sanitary conditions in and around the facility, an on-site system of treatment of sewerage from workers’ toilets will be provided. The design of the Facility includes provision for drainage of a specification sufficient to handle storm-water flows, and safe draining of storm water if this occurs.
Phou Poy Rice Mill, Chumnik Village, Anlong Vil commune, Sangkae district, Battambang
Observation, cross checking with Rice Miller and stakeholders
Monthly records based on the specific work
Site Manager of
the contractor,
Resident
Engineer, Rice
Miller and Village
Chief
Bill of quantity in the
contract
award
Health risks to
worker from
dust pollution
When excavation takes place during dry conditions, excavated surfaces and stockpiled material shall be sprayed with water to prevent the release of dust. The proposed Facility will use Cyclonic type furnace which has no exhaust stack and hence no ash/smoke will be released to the environment. Dust produced by the drying process will be collected by passing dust laden air from the dryer into a chamber where water is introduced by a series of sprayers. The water spray causes the dust to collect and form a slurry which is non-toxic and can be provided to famers for re-use as a soil conditioner. Protective clothing s u c h a s dust masks shall be issued to workers when working in dusty conditions.
Phou Poy Rice Mill, Chumnik Village, Anlong Vil commune, Sangkae district, Battambang
Observation, cross checking with Rice Miller and stakeholders
Monthly records based on the specific work
Site Manager of
the contractor,
Resident
Engineer, Rice
Miller and Village
Chief
Bill of quantity in the
contract
award
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Impact to be
Monitored
Parameters Location Means of
Monitoring
Frequency Responsibilities Cost
Estimate
Risks of
unsanitary
working and
grain storage
conditions
during flood
events
The Facility will be constructed inside the existing Rice Mill compound which is elevated from the ground level. The proposed location has never been flooded even during the big flood in 2013. However, adequate fill is proposed to raise the ground level to a height that poses little risk from flooding. The settling ponds shall be on a raised platform, at least 0.5 m above the height of 10-year flood levels. The Contractor will install onsite WC for their workers. To ensure sanitary conditions in and around the facility, an on-site system of treatment of sewerage from workers’ toilets will be provided.
Phou Poy Rice Mill, Chumnik Village, Anlong Vil commune, Sangkae district, Battambang
Observation, cross checking with Rice Miller and stakeholders
Monthly records based on the specific work
Site Manager of
the contractor,
Resident
Engineer, Rice
Miller and Village
Chief
Bill of quantity in the
contract
award
Hazardous
materials during
subproject
implementation
To prevent pollution of soil and water surface/groundwater: (i) Storage facilities for fuels, oil, cement, and chemicals will be
within secured areas on impermeable surfaces, provided with bunds and cleanup installations.
(ii) The contractor will not use the spilled materials related to the vehicle, machinery, and equipment that is going to affect to soil and water sources.
(iii) Fuel storage and refilling areas will be located at least 50m from construction sites that will be protected by temporary drainage bunds to contain spills.
(iv) Be careful in loading and unloading fuel during the construction activities.
Phou Poy Rice Mill or surrounding location of the subproject, Chumnik Village, Anlong Vil commune, Sangkae district, Battambang.
Observation, cross
checking
with Rice
Miller and
stakeholders
Monthly records based on the specific work
Site Manager of
the contractor,
Resident
Engineer, Rice
Miller and Village
Chief
Bill of
quantity in
the contract
award
Air quality
(i) Equipment will be maintained to a high standard to ensure efficient running and fuel-burning.
(ii) High- horsepower equipment will be provided with tail gas purifiers.
(iii) All vehicle emissions will be in compliance of with relevant Cambodian emission standards.
Phou Poy Rice Mill or
surrounding location
of the subproject,
Chumnik Village,
Anlong Vil
commune, Sangkae
district, Battambang.
Observation, cross
checking with
Rice Miller and
stakeholders
Monthly records based on the specific work
Site Manager of
the contractor,
Resident
Engineer, Rice
Miller and Village
Chief
Bill of
quantity in
the contract
award
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Impact to be
Monitored
Parameters Location Means of
Monitoring
Frequency Responsibilities Cost
Estimate
Dust control (i) Good practices on dust control during and after the operation such as material stockpiles, concrete mixing equipment will be equipped with dust shrouds.
(ii) Water spraying, at least 2 times per day, for suppression soil dust or any other particulates and maintenance of driving surfaces will be standard site management practices.
(iii) Vehicles carrying soil, sand or other fine materials to and from the construction sites will be covered.
Phou Poy Rice Mill or surrounding location of the subproject, Chumnik Village, Anlong Vil commune, Sangkae district, Battambang.
Observation, record, cross checking with Rice Miller and stakeholders
Daily and Monthly records based on the specific work
Site Manager of the contractor, Resident Engineer, Rice Miller and Village Chief
Bill of quantity in the contract award
Noise and Vibration/ Noise impacts on sensitive receivers
Construction during night time within 280m of residences shall be strictly prohibited. During daytime construction, contractor will ensure that: (i) Sites for concrete- mixing plants and similar activities will be
located at least 1 km away from residences and schools; and (ii) Temporary anti-noise barriers will be installed to shield any
schools or residences within 100m of the construction site.
Phou Poy Rice Mill or surrounding location of the subproject, Chumnik Village, Anlong Vil commune, Sangkae district, Battambang.
Observation, record, cross checking with Rice Miller and stakeholders
Daily and Monthly
records based on the specific
work
Site Manager of the contractor,
Resident Engineer, Rice
Miller and Village Chief
Bill of quantity in the
contract award
Borrow pit /quarry for getting soil for subproject construction
Contractor have to include orientation to all workers on borrow pit protection to avoid the danger (i.e. prevent cattle and people – specifically children falling into the borrow pit during and after construction activities). Contractor will ensure to:
• Install fence around the pit and put up warning signboard during the construction activities, and
• Back fill with soil after construction activities are completed.
Location of soil
collections.
Observation, record, cross checking with
Rice Miller/ Land owner and
stakeholders
Monthly and quarter records
Site Manager of the contractor, Resident Engineer, Rice Miller/ Land owner and Village Chief
Bill of quantity in the contract award
Use of land for storage and campsite
(i) Contractor will provide compensation to landowners by early in a month.
(ii) In cases where landowners temporarily provide their land to the contractor to build camp site, it will be based on a contract agreement (details will be stated in contract agreement)
(iii) After completing works, contractor will carry out restoration of land to former condition or better, according to agreements formed with landowners.
Phou Poy Rice Mill or
surrounding location
of the subproject,
Chumnik Village,
Anlong Vil
commune, Sangkae
district, Battambang.
Contract
agreement
between
contractor and
landowner
Monthly
payment report
Site Manager of the Contractor
Bill of quantity
in the contract
award
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Impact to be
Monitored
Parameters Location Means of
Monitoring
Frequency Responsibilities Cost
Estimate
Effects of vehicle access related to daily operational management
Although the construction will take place inside privately owned land but the contractor has to carry out: (i) careful supervision of vehicle movements to ensure minimal damage to farmland and vegetation, etc. if any and (ii) minimal disturbances to human beings, children going to school and animal.
Phou Poy Rice Mill or
surrounding location
of the subproject,
Chumnik Village,
Anlong Vil
commune, Sangkae
district, Battambang.
Check to verify
The
contractor
rule book
and license
of driving
Monthly and Quarterly report
Site Manager of the contractor and Resident Engineer, Rice Miller and Village Chief
Bill of quantity
in the contract
award
Effects of the temporary worker populations staying in a camp site .
(i) Assigning the responsibility of the contractor’s staff, workers and local people’s welfare to a senior member of the contractor’s staff
(ii) Maximizing employment of local residents to the extent practicable.
(iii) Construction of suitable toilets such as pit latrines on sites (iv) Providing electricity to all workers staying overnight. (v) Providing primary health care, sanitation and welfare to all
workers and senior staff to ensure workers safety and health. (vi) Arrangements for grey water treatment and discharge, such
as soakage pits, to minimize release of pollutants into waterways.
(vii) Orientation to the workers on dangers of communicable diseases.
Existing workers
campsite and the
worker from the
villages.
Observation on site operation including list and CV of the worker
Quarterly and based on the
operation status
Site Manager of the contractor and Resident Engineer, Rice Miller and Village Chief
Bill of quantity in the contract
award
Safety Hazards to workers and local people during construction
Contractor work plan have to include allocation of responsibility for site safety to the contractor’s site supervisors staff to ensure all reasonable safety measures, have b een tak en up .
(i) Prepare and provide enough safety protection clothing and equipment, flagman, sign boards, etc. and place hazard warnings.
(ii) Provide adequate and quality drinking water to the workers. (iii) Provide enough first aids kit. (iv) Provide adequate orientation on using PPE to all workers and
contractor’s site supervisors staff.
Existing workers
campsite and the
worker from the
villages.
Labor Law in
1999 of Royal
Government
Cambodia
Quarterly and
based on the
operation
status
Site Manager of the contractor and Resident Engineer Rice Miller and Village Chief
Bill of quantity
in the contract
award
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Impact to be
Monitored
Parameters Location Means of
Monitoring
Frequency Responsibilities Cost
Estimate
Occurrence of water related diseases
Contractor work plan during construction have to include raising awareness to the workers on hazards posed by poor sanitation and use of untreated water for drinking and bathing.
Phou Poy Rice Mill or surrounding location of the subproject, Chumnik Village, Anlong Vil commune, Sangkae district, Battambang.
Specific water
company or
shop address
and list of
patient.
Collection of
sample and
laboratory
analysis.
Based on the
diseases
occurred
Contractor, Commune
Chief, health
centers, village
chief, Rice Miller,
PIO and other
stakeholders
Include in construction Budget
Operation phase
Maintenance of equipment and avoiding damage to the assets
Contractor work plan have to include orientation to all stakeholders involved on work routine and periodic maintenance, quality of equipment, and raw material to be used based on contract document.
Phou Poy Rice Mill, Chumnik Village, Anlong Vil commune, Sangkae district, Battambang.
Operation and
maintenance
schedule
Quarterly report
Site Manager of the contractor, Resident Engineer, Rice Miller, and other stakeholder
Include in construction
Budget
Water pollution from discharge
of liquid effluents
No waste water from this type of drying process is generated as moisture from wet paddy will evaporate. The design of the Facility includes sewage treatment ponds to be constructed on a raised platform. Water from the dust removal plant will be combined with condensate from the dryer and will be treated in settling ponds, to enable organic matter to be extracted, and used by the Rice Miller or provided to farmers as a slurry.
Phou Poy Rice Mill or surrounding location of the subproject, Chumnik Village, Anlong Vil commune, Sangkae district, Battambang.
Operation and maintenance schedule
Quarterly report
Rice Miller, PDOE/ MEF/PMO/PIO
Rice Miller
Dust control The proposed Facility will use Cyclonic type furnace which has no exhaust stack and hence no ash/smoke will be released to the environment. Dust produced by the drying process will be collected by passing dust laden air from the dryer into a chamber where water is introduced by a series of sprayers. The water spray causes the dust to collect and form a slurry which is non-toxic and can be provided to famers for re-use as a soil conditioner. Protective clothing s u c h a s dust masks shall be issued to workers when working in dusty conditions.
Phou Poy Rice Mill or surrounding location of the subproject, Chumnik Village, Anlong Vil commune, Sangkae district, Battambang.
Operation and maintenance schedule
Quarterly report
Rice Miller, PDOE/ MEF/PMO/PIO
Rice Miller
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Impact to be
Monitored
Parameters Location Means of
Monitoring
Frequency Responsibilities Cost
Estimate
Noise and Vibration/ Noise impacts on sensitive receivers
Noise proof materials for housing will be used to reduce noise from ash room, dust room and machinery. Noise from blower and its drivers will be monitored and managed through good maintenance. Noise within the facility will be reduced by the inclusion of noise baffles on machinery and ear protection is provided where necessary.
Phou Poy Rice Mill or surrounding location of the subproject, Chumnik Village, Anlong Vil commune, Sangkae district, Battambang.
Operation and maintenance
schedule
Quarterly report
Rice Miller, PDOE/ MEF/PMO/PIO
Rice Miller
Risks and vulnerabilities related to occupational health and safety during operation
Rice miller will continue to provide PPE, first aids kit, etc. and training courses to workers on safety standard; include safety railings to mitigate risks due to material handlings and provide training and instruction to workers; carry out proper fumigation around the compound; follow the laid out regulations by the PDOLVT related to health and labor policy; and follow the EMP and agreement with PDOE.
Phou Poy Rice Mill, Chumnik Village, Anlong Vil commune, Sangkae district, Battambang.
Operation and maintenance
schedule
Quarterly report
Rice Miller, PDOLVT/PDOE/ MEF/PMO/PIO
Rice Miller
Residue of husk (Ash)/Waste
Cyclonic furnace collects ash at the bottom and then conveys to the ash room.
i. Ash will be collected at the ash room and use as fertilizer by the Rice Miller himself or may sell to farmers to generate extra income
ii. Husk will be used as biomass fuel by the Rice Miller for their furnace/burner.
iii. Ash will not be allowed to dispose into water bodies
Phou Poy Rice Mill, Chumnik Village, Anlong Vil commune, Sangkae district, Battambang.
Operation and maintenance schedule
Quarterly report
Rice Miller, PDOE/ MEF/PMO/PIO
Rice Miller
Garbage/Waste generation by workers
i. Provide specific basket or bucket for kitchen garbage disposal
ii. Make arrangements for collection of solid waste iii. Make arrangements for grey water treatment and discharge,
such as soakage pits iv. Assign specific role and responsibility and clear schedule for
maintenance and collection of all waste
Phou Poy Rice Mill, Chumnik Village, Anlong Vil commune, Sangkae district, Battambang.
Operation and maintenance schedule
Quarterly report
Rice Miller, PDOE/ MEF/PMO/PIO
Rice Miller
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Training program:
A training program is set out in below table which address the safeguard reporting and implementation requirements during construction. The engagement of national Environmental Specialist/project implementation specialists will be ensured to build the capacity of the PIO staff and to ensure monitoring and reporting are managed effectively during implementation.
Training for EMP Implementation. The proposed training required for project implementation is set out in Table below
Capacity Building and Training Requirements
Subject/Content Participants Trainer Frequency
EMP adjustment and implementation – Development and adjustment of the EMP, roles and responsibilities, monitoring, supervision and reporting
PMO, PIO, Contractors national Environmental Specialist/project implementation specialists
Once prior to construction
Grievance Redress Mechanism – roles and responsibilities
PMO, PIO, Contractors, District, Commune councils
national Environmental Specialist/project implementation specialists
Once prior to construction
Environmental Protection Pollution control on construction sites (air, noise, wastewater, solid waste……….)
PMO, PIO, Contractors national Environmental Specialist/project implementation specialists
Once during the project construction
Environmental Monitoring – monitoring methods, data collection and processing, reporting systems
PMO, PIO, Contractors national Environmental Specialist/project implementation specialists
Once prior to construction
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Annex 11: List of participants of the public consultation meeting
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