Based on IFC’s review and the ESIA, no risks and adverse impacts of the project that need to be managed consistent with PS6 (Biodiversity Conservation and Sustainable Management of Living Natural Resources), PS7 (Indigenous Peoples) and PS8 (Cultural Heritage) were identified. 

If IFC’s investment proceeds, IFC will periodically review the project’s ongoing compliance with the PSs

This is a Category B project according to IFC’s Policy on Environmental and Social Sustainability, as it is expected to have limited adverse environmental or social risks and/ or impacts that are limited in scale, few in number, generally site-specific and readily addressed through mitigation measures, by adhering to good international industry practice (GIIP) procedures, guidelines and design criteria, as described in the following sections. [The project will use GIIP, meeting requirements established under the applicable WBG Guidelines for MSW and ISW incineration.]

Key risks and impacts include the economic displacement of 116 households, limited scale environmental impacts associated with emissions (including emissions to air, odor, greenhouse gases, and noise), leachate generation, waste and hazardous material management, occupational and community health and safety, labor working conditions, transportation safety, and potential for historical groundwater and soil pollution from TT’s existing waste incinerator operations.

Environmental and Social Assessment and Management System

T&J Green Energy Company Limited (T&J) does not yet have in place a corporate or project level ESMS and organization. TT has an EHS organization, including occupational health and safety and emergency response. JFEE has adopted an E&S policy and strategies from JFE Holdings, and maintains a comprehensive ESMS that is maintained and supervised by the corporate social responsibility organization (CSR System). The JFEE ’s CSR System is composed of committees for compliance, occupational health and safety (OHS), environment and disaster prevention with dedicated staff. T&J will, as mentioned at ESAP #1, develop and implement a construction stage E&S management plan (ESMP) and an operation stage ESMS that meet IFC Performance Standards (PSs).

Identification of Risks and Impacts

T&J prepared an environmental impact assessment (EIA) to meet national requirements and the project obtained the required environmental approval.  Subsequently, the company commissioned an external consultant to undertake a gap analysis of the EIA with respect to IFC PSs and applicable and relevant WBG EHS Guidelines and prepared a PS-compliant ESIA, covering project’s area of influence, including affected communities, such as households affected by land acquisition, identified E&S impacts and mitigation measures for the construction, operation and decommissioning of the project. Key risks, impacts, and mitigation measures for construction, operation and decommissioning stages are addressed in the ESIA and summarized below under the subsequent sections of this ESRS.

The ESIA includes a climate change risk assessment (both physical and transition risks) for the project during construction and operation phases. Risks associated with increased frequency of cyclone/severe storms were assessed as being of high significance during construction, while the other risks were assessed as being of low significance given the short construction period. During the operation phase of about 50 years, physical climate risks and potential impacts identified as of high significance include increased heat-related illness among workers, increased energy demand due to increased cooling requirements and air conditioning, and impacts associated with more frequent and severe area flooding. Overall, the impact of climate change was assessed as medium significance and relevant mitigations included in the design. 

An alternatives analysis was undertaken as part of the ESIA, including the no project scenario, siting justification for the plant, design alternatives for transmission line (overhead vs underground) and alternative waste treatment technologies. The underground transmission line was selected, although more costly, as it is less prone to external damage, it is safer for the nearby residents, and because of its minimal visual and environmental impact.

An evaluation of relevant valued environmental components (VECs) was undertaken as part of the rapid cumulative impact assessment (RCIA) included in the ESIA. Key VECs include air quality, noise and vibration, greenhouse gases (GHG), surface water quality, hydrology, hazardous waste, soil and groundwater, transportation, ecosystem services and socio-economic conditions particularly demography, land values, employment patterns, health and cultural norms and values. Quantitative assessment of cumulative impact on ambient air quality, noise, greenhouse gas (GHG), fly ash and bottom ash (FABA), and traffic taking into account the existing TT plant was undertaken as part of the RCIA. Impact from other projects/developments in the vicinity of the Project was assessed qualitatively due to unavailability of detailed data for quantitative assessment.  The CIA concluded that the cumulative impact significance for most of the VECs is moderate and identified several mitigation measures to be undertaken by the project.

Management Program

The ESIA includes Environmental and Social Management and Monitoring Plans (ESMMPs) including: outline of various plans to be developed by the EPC contractor and T&J as the O&M company as required by the project ESMP and T&J’s ESMS (under ESAP #1); institutional arrangements and capacity building; and monitoring and reporting requirements. T&J in its capacity as the O&M company, will contractually require the EPC contractors to develop and implement the management plans, consistent with the E&S risks and impacts identified by the ESIA to meet IFC’s PS.

Organizational Capacity and Competency

While TT and JFEE have adequate experience and capacity for the operations to be undertaken by the project, T&J will assign, as mentioned in ESAP # 2, a suitably qualified and dedicated health, safety and environment (HSE) manager and a community relations manager to manage the implementation of the ESMP during construction and ESMS during operation stage including for stakeholder engagement, grievance redress and livelihood restoration, and to oversee the implementation of the contractors’ management plans. An E&S training and capacity building program will be part of ESMP and ESMS mentioned as part of ESAP # 1.

During construction phase, JFEE will appoint at least one HSE manager for overall HSE management at the site supported by a two member HSE staff team for day-to-day supervision and monitoring of implementation of the ESMP.

Monitoring and Review

Outline of a monitoring program has been provided in the ESIA, which will be developed into full monitoring and reporting plans under the ESMP and ESMS for construction and operation phases respectively. The EPC company will be responsible for implementing the monitoring plan during construction with T&J oversight, and T&J will be responsible for monitoring during operation stage. Internal and third-party audit program, comprised of bi-annual internal and third-party audits during construction stage and annual internal audits and for the first two years of operation, third-party audits during O&M stage, will be developed as part of the ESMP and ESMS respectively. E&S performance will be reported to T&J senior management and Board as part of project review during construction and at least bi-annually during O&M phase. A formal management review process will be put in place to periodically review and update the ESMP and ESMS based on the monitoring and reporting outcomes.

        The project is expected to employ about 300 persons during construction including those working for contractors and subcontractors; of this total, 10 to 30 people are from the local area. The workforce during operations will comprise about 40-50 persons.

Human Resources (HR) Policies and Procedures

T&J’s HR policy is not in place but will be developed based on the discussions and agreement between TT and JFEE. For some positions currently employed by T&J during the project preparation phase, the working terms and conditions are in accordance with JFEE’s policy. JFEE has a corporate level Human Resources (HR) policy applicable to all direct employees across all its global business lines and project companies including other joint venture companies. As set forth in ESAP #3, T&J will develop HR policies, procedures, and employee manuals, that meet local regulatory requirements, IFC’s Performance Standard 2 and JFEE’s HR policy. The policy and procedures will cover and ensure compliance with the relevant requirements for the following: (i) nondiscrimination, equal rights and equal pay; (ii) prevention of child labor and forced labor; (iii) freedom of association and right to collective bargaining; (iv) contractor management; (v) terms of employment including recruitment, hours of work, overtime arrangements and overtime compensation, rights to refuse overtime requests; (vi) commitment to apply zero tolerance for any proven case of gender based violence (GBV) and workplace harassment including sexual harassment and bullying; and (vii) a formal grievance mechanism. The HR policies and requirements will be included in all employment contracts. The HR Policy will be communicated to all employees working within the company and will have provisions for workers engaged through third parties (i.e., construction contractor and subcontractors). 

Non-discrimination and Equal Opportunity

JFEE’s HR policy recognizes the principles of non-discrimination and equal opportunity. JFEE has a gender policy and an anti-harassment policy. T&J will also develop a non-discrimination and equal opportunity policy which is aligned to national law and IFC PS2 as part of its HR Policy to be developed as per ESAP #3 above. Also, as part of the HR Policy to be adopted as per ESAP #3, the company will include employment terms and conditions with zero-tolerance approach for proven case of GBVH and shall include a mechanism for receiving and investigation of complaints with provision for confidentiality, identity protection, survivor centered approach and remediation in accordance with the HR policies and procedures and national regulations.  

JFEE policies respect the right of employees to freedom of association and to collective bargaining agreements. Policies and procedures to ensure freedom of association and collective bargaining will be included in T&J’s HR policies.

Retrenchment

The existing Thuan Thanh Plant will cease operation when the proposed WTE plant begins to operate. The number of current employees at the existing plant is approximately 94 who will be reassigned to other plants and departments of TT while some will be re-trained and transferred to work in the T&J project. As part of ESAP #4, the company will work with TT to understand: whether any workers are to be retrenched; if not where and how they will be redeployed; if workers have to be retrenched, whether the retrenchment plan to be prepared, considers all viable alternatives, is developed in consultation with the workers to address the adverse impacts on workers, and is in compliance with national laws and IFC PS2. In case retrenchment is necessary, the plan will address alternatives to retrenchment; schedule of dismissals; retrenchment methods and procedures; selection criteria; severance payments; offers of alternative employment or assistance in retraining efforts; and support such as assisting with the preparation of CVs, reference letters and other counselling on job placement.

Grievance Mechanism

A worker grievance mechanism will be developed as part of the ESMS and HR procedures (ESAP #1) and will ensure that all workers, including the company employees, contractors and subcontractors, are made aware of it and trained in accessing it, such that worker grievances are systematically recorded, tracked, addressed and feedback given to aggrieved. The grievance procedure will enable employees to raise anonymous complaints, and will have provisions for protection of confidentiality, non-retribution and protection against retaliation. The EPC contractor will be required to either adopt the company’s worker grievance mechanism or develop their own version in line with national and IFC requirements. The worker grievance mechanism shall provide a prompt, understandable and transparent process that provides timely feedback to those concerned, without fear of retribution, and allow for anonymous grievances. The worker grievance mechanism will be designed to receive GBV and sexual harassment complaints that protects the identity of the complainants, investigates the complaints based on a “survivor centered” approach, and applies remediation in accordance with the HR policies and procedures and national regulations, with assigned and trained personnel. The company will provide training to the workforce and contractors, including during induction on the policy, procedures and grievance mechanism to address GBV and sexual harassment. The EPC contractor will be required to appoint contact persons for receiving, documenting and responding to worker complaints and this will be reported on a regular basis under the ESMP. The grievance mechanism shall be made available in appropriate local languages and disseminated verbally at health and safety meetings and on notice boards. The company will periodically monitor the effectiveness of its and the EPC contractor’s grievance mechanism through interviews with workers.

Protection of Workforce

T&J and JFEE, as EPC contractor, will implement a process for checking and recording age of employees and contract workers to prevent child labor on its project sites. T&J will, as part of its HR Policy and Procedures Manual (ESAP #3), put in place policies and procedures relating to prevention of child labor and forced labor, consistent with the national requirements as well as IFC PS2. These policies will be applicable to T&J, the EPC contractor, and their sub-contractors hired for the project.

Occupational Health and Safety (OHS)

T&J’s OHS Management System (OHSMS) is not in place but will be developed based on the discussions and agreement between TT and JFEE, and the company is planning to put in place an OHSMS, which will be aligned with the requirements of ISO 45001. At the corporate level, JFEE has a detailed OHS Management System Manual which shall be further developed and adopted by T&J specifically for this project as part of the ESMP and ESMS mentioned at ESAP #1.

During construction, JFEE, in its role as EPC, will implement their ISO 45001/OHSAS 18001 certified OHS Management System for the project. The President of JFEE’s is overall responsible for OHS supported by the OHS Committee. JFEE has procedures for safety inspections and patrols by senior managers and engagement with labor union on OHS through its OHS Committee. JFEE monitors OHS statistics in all its projects globally in the form of leading and lagging indicators including lost workdays; injury/accident frequency and severity rates; health and safety training, employee health data; and publicly reports summary statistics through its CSR reports. In TT, an OHS team comprised of three staff is responsible for oversight of: OHS performance of the plant; compliance with OHS procedures and standards; review of the OHSMS; and development of additional OHS measures as needed. All employees in TT and JFEE undergo OHS training at induction and subsequently as relevant to their job activity. T&J employees shall also undergo OHS training at induction and based on their job profile.

Workers Engaged by Third Parties and Workers Accommodations

During construction, no workers’ accommodation camp on site is envisaged and workers will be provided with rented housing arrangements.  As part of the ESMP mentioned at ESAP #1, JFEE will ensure that the accommodation provided to its workers or subcontractors workers during construction, whether onsite or offsite, meets construction labor camp guidelines in accordance with PS2 provisions including related to: appropriate construction material for the accommodation and protection from extreme weather; adequate space and facilities; ventilation; amenities and utilities provided; access to electricity; access to water supply and sanitation; safe cooking place; protection against vector- borne diseases; facilities to meet the needs and safety of women workers/women family members of workers; handling, treatment and disposal of waste, wastewater and sewage from the accommodation; fire safety and emergency response; hygiene, disease prevention and vector control; access to medical facilities; avoidance of conflict with host communities including training on GBV issues; transportation to work, if accommodation is offsite; and safety and security. 

               Resource Efficiency and Greenhouse Gas (GHG)

Total estimated GHG emissions during the operational phase of the project is estimated at 64,167 tCO2e per year.

Water Consumption

During construction, piped municipal water will be provided for construction and domestic uses by workers.  During the operation, about 246 m3 of municipal water will be used per day, of which about 24 m3 will be required for domestic use for site workers, while 222 m3 will be first supplied to de-min water tank for boiler process and wastewater treatment plant for treatment after daily general usage (e.g., utility station, green watering, platform washing, car washing).

Pollution Prevention and Control during Construction

The environmental impacts from construction activities for the project are those typical of most construction sites and include: dust generation; soil erosion and sediment loading increases; noise; waste management; potential spills of hazardous and other material; construction debris disposal; domestic solid waste and wastewater from construction camps; increased water usage; and construction vehicle traffic. The ESMP will detail plans that are in line with good engineering and industry practices to address these impacts.

Pollution Prevention and Control during Operation

Air emissions - The primary source of air emissions is the incinerator flue gas and odoriferous emissions from waste storage area. The project is designed such that the incinerators emissions meet the EU emission levels detailed in WBG EHS Guideline for waste management except for HCl emissions, which will meet the US-EPA levels also detailed in the WBG EHS Guidelines. Mitigation and management measures including the injection of urea sodium bicarbonate, activated carbon and into the exhaust stream to remove oxides of nitrogen, dioxins, Hydrochloric acid and heavy metals and the use of a bag filter to remove particulate matter have been outlined in the ESIA to address air emissions in line with GIIP. Baseline air quality was measured as part of the ESIA studies and air emission dispersion modeling was carried out based on the design emission levels to determine maximum ground level concentrations and ground level concentrations at the receptors within the project’s area of influence. Incremental impact of air emissions on ambient air quality, as modeled in the ESIA, will be within WBG EHS Guideline values and will meet national standards. An air emission and air quality monitoring plan will be developed and implemented in line with GIIP.

Noise and Vibrations - Based on the modeling carried out as part of the ESIA, during the operation, it is predicted that a marginal exceedance of 1 dB(A) against the Vietnamese standard benchmark of 55dBA at night-time at Thu Doi, the nearest village located 530 m away from the project site. However, according to the model, the incremental noise on account of the project will meet WBG EHS Guideline requirement of 3 dB(A). A noise management and monitoring plan will be developed and will present mitigation measures including: procurement of equipment with lower noise levels; placing equipment indoor or within an enclosure to the extent possible; regular maintenance of the equipment; and delivery trucks to turn off their engines when waiting/idling. Noise monitoring at representative locations with respect to the nearest receptors will be conducted during construction and during operations. No significant vibrations are expected based on the analysis carried out by the ESIA.  Vibrations monitoring will be included in the plan.

Wastewater Treatment - The wastewater treatment facility has a capacity of 52 m3/day. The wastewater would mainly comprise platform cleaning wastewater, vehicle wash water, boiler blowdown, cooling water blowdown and plant service water. Wastewater will be collected in a tank before being directed into the wastewater treatment facility. The treated wastewater quality shall comply with national standards and limits set by WBG EHS guidelines for Waste Management Facilities and will be reused for plant operation and cleaning activities. A leachate collection pit with a sealed structure and pipeline to connect to incinerator shall be installed to avoid potential contamination, as part of the Waste Management Plan to be prepared for the project. Leachate will be directed into the incinerator for evaporation.

Domestic wastewater volume of the project is expected to be 20 m3/day, which will be treated in an onsite sewage treatment plant. The treated domestic wastewater will meet national standards and WBG General EHS Guideline before discharge.

Solid Waste Management - 90kg of solid waste is estimated to be generated every day from the project. The main composition of waste is organic wastes (vegetables, fruits, excessive foods, wasted paper, etc.) and inorganic waste (nylon bags, cans, glass, etc.). Organic wastes that are collected into the waste bunker, will be used in the plant. Inorganic waste shall be disposed through authorized agency.

Hazardous Materials and Wastes - Hazardous materials used as part of the operations of the WTE plant will include hydrochloric acid, sodium hydroxide, biocide, antiscalant and also a large volume of mineral oil and fuel.

It is estimated that about 80 tons/day of bottom ash and about 15 tons/day fly ash will be generated by the WTE plant operations. Bottom ash is non-hazardous while fly ash is hazardous waste. Fly ash will be stored in the fly ash silo and disposed in TT’s existing hazardous waste treatment plant. Bottom ash will be reused for brick production or sale to local vendors for ground levelling. During the operation, stormwater runoff and ambient air could be contaminated with fly ash, if not well managed. As part of the Waste Management Plan, mitigation measures to protect surface water body, ground water sources and air quality will be implemented including proper delivery from fly ash conveyor and proper storage before it can be transferred to external disposal. 

Other small quantities of hazardous waste are expected to be generated including waste ink, used neon light, spent batteries, electronic equipment, greases, wastewater treatment plant sludge and oily rags. Hazardous wastes will be collected and treated as per national regulations and consistent with PS3. All hazardous wastes will be collected in segregated containers with labels. The company will, as part of the ESMS, implement procedures to segregate, label and store hazardous wastes within contained areas and dispose them through authorized entities for treatment, reuse/recycling or disposal. T&J will implement duty of care procedures to confirm that the hazardous material/waste operators are transporting, handling, storing, treating and disposing of the materials/wastes appropriately in line with GIIP.

         Traffic related impacts

During the construction phase, the estimated increase in traffic is about 100 earth moving trucks per day for 60 days, and 20 construction material trucks per day for 300 days. During the operation phase, there will be approximately 12 trucks per hour that will enter and leave the facility each day. This has the potential to impact traffic and road safety and infrastructure near the project site including: road damage; traffic congestion; dust, noise, and vibration related impacts; and safety risks to third party road users and local community members. The company will, as part of the construction ESMP and operations ESMS (ESAP #1), develop a transportation and traffic management plan. In addition, the contractors will be required to inform nearest receptors and communities in advance of any significant activities that may cause traffic related disruptions and impacts.

Community Exposure to Disease

The company will require the EPC contractor to maximize local hiring but there will be an influx of about 300 workers at the project site during construction. To minimize the risk of increased incidence of communicable diseases (including COVID-19), health check-up of all workers will be undertaken and access to medical assistance/facility will be enabled while minimizing interactions with communities. The workers’ accommodation will meet IFC standards as discussed above and worker awareness programs will be implemented including on worker code of conduct. 

Underground transmission line will be laid for power evacuation to mitigate electromagnetic field related impacts. The waste reception, storage and handling area will be under negative pressure to address odor related impacts. Further, for incineration shut down periods, a separate odoriferous air extraction and treatment system with activated carbon is planned to be put in place.

Emergency Response Plan

Potential risks to the community include those from the operation of the WTE facility as well as those from the transportation and handling of MSW and ISW. As set forth in ESAP #1, as part of the ESMS, the project company will develop a set of project-level detailed emergency preparedness and response (EPR) operating procedures which: (i) specifies roles and responsibilities including chains of command during emergencies; (ii) ensures appropriate response equipment and materials are in place; (iii) includes a set of procedures to be followed to minimize harm from any unplanned release of potentially toxic gases or leachate beyond the plant boundaries due to irregular plant operations or an accident at the facility, or during transportation of material destined for the facility. The company will hold communication sessions and develop scheduled plans for scenario-based emergency evacuation drills with local communities and stakeholders, using locally accessible methods and tools of communication, to convey key elements of all aspects of emergency preparedness and planning.

Security Personnel

The company will, as part of ESMP and ESMS (ESAP #1), undertake a security risk assessment and, based on that, determine the security arrangements. The company will integrate the Security Management Plan in line with IFC PS4 as part of the ESMP and ESMS, which will include procedures for ensuring that: past records of security personnel employed are screened; permissible and impermissible actions including in relation to firearms are laid out; security personnel are trained in avoidance of human rights violations including among other aspects related to sexual harassment, gender based violence, community and employee interactions; bona fide complaints against security personnel are investigated/disciplinary actions implemented. The company will make reasonable inquiries to ensure that those providing security are not implicated in past abuses; will train them adequately in the use of force (and firearms), and appropriate conduct towards workers and affected communities; and required them to act within applicable law. The company will not sanction any use of force except when used for preventive and defensive purposes in proportion to the nature and extent of the threat.