Table EMP-2: Environment Impact and Mitigation Measures during Pre-construction, Construction, and Operation Phases Item Potential
impacts / issues Mitigation measures Implement Supervise
A. DESIGN AND PRE-CONSTRUCTION FOR ALL SOUM INVESTMENTS
COVID-19 Management
Control and Prevention of Spread
• The draft COVID-19 management plan in Appendix C of IEE will be reviewed by MOFALI and the Ministry of Health and COVID-19 epidemiologists and then finalized with their input
• Prior to the arrival of all external project personnel (e.g., workers and consultants), the PMU with support from MOFALI will implement government-approved safety procedures and screening to ensure that all staff are tested negative for COVID-19 and do not pose a threat to local human populations. This will include: (i) requirement that all project personnel is tested negative for COVID-19, (ii) external workers and consultants confirm their COVID-19 – free status to PMU prior to arrival, and (iii) project safety and sanitation measures are distributed to all personnel and are included as contractual requirements for all staff
ESS, PMU
• Reconfirm with MET; (i) that a DEIA is not required for the project investments in the four project aimags; and (ii) that the environmental protection conditions specified by the General EIA (GEIA) Letters issued by the MET still stand as is
• Confirm with MET whether an additional Environmental Baseline Assessment (EBA) is required for the finalized project investments
• No civil works for any investment will proceed until all domestic environmental approvals are completed which are submitted to ADB
ESS, PMU IA, EA, MET
Environmental Baseline Assessments
• Prepare additional EBA(s) if required by the MET
• Ensure GEIA Letters are issued for the EBAs
• Submit General EIA Letters to ESS
Recruited EIA
firm ESS, MET
Site selection criteria
The specific location of the project facilities will be finalized as part of the detailed engineering designs. Sites will be selected to fully comply with the following criteria:
• All activities will be strictly limited to modified lands already used for livestock grazing (for livestock grazing, fodder plots, and wells) and rural use (for the office buildings, livestock holding facilities, and cashmere sorting facilities). The project will not involve any land conversion or the establishment of new pasture lands.
• No project activities, including new wells, will be located in any protected areas – whether national- or local-level, or other sites of designated environmental or cultural significance, including documented Important Bird and Biodiversity Areas, Ramsar wetlands, and UNESCO Biosphere Reserves, even if these sites are not officially designated by government.
• No clearance or damage of natural habitats.
• New wells will be located in areas where the groundwater supply has been demonstrated by the follow-up aquifer assessments (to be conducted during project implementation) to be sustainable. No sites for wells and/or aquifers will be used in which the hydrological surveys indicate a risk of unsustainability, especially when
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impacts / issues Mitigation measures Implement Supervise
cumulative use (existing demand) and projected declines in aquifer recharge because of climate change are considered.
• Siting of the office buildings, livestock holding facilities, cashmere sorting facilities, and new wells will not be located upslope of physical cultural resources and sacred sites, including the documented sites listed in Section IV.H of the IEE, to minimize direct or indirect disturbance and to avoid potential cultural disrespect. Exceptions to this criterion will only be accepted if based on clear documentation of public consultations agreeing to such exception, accompanied by government endorsement.
• For the livestock holding facilities, these will be located at least 500 m and downwind from the nearest residences, to minimize odor-related disturbance.
Detailed
• Prepare detailed engineering designs for final soum investments and locations. The final selected sites for all project facilities will meet the selection criteria above
• The completed report shall be submitted to the Government and ADB for review
• Recruit licensed EIA firm to prepare DEIA if a DEIA is necessary
• Conduct the DEIA as required
Design
• Update the IEE and EMP to (i) meet detailed designs of finalized soum investments, (ii) include any additional environmental mitigation measures developed in the domestic Detailed EIAs
• Confirm that conditions of final GEIA letters are included in updated EMP
• Submit the updated IEE and EMP to ADB for review
• Ensure the updated EMP is included in all construction tender documents
• Update the training plan for the EMP
• Include results of final investment site selection, and requirements for adequate waste management and groundwater sustainability determined during pre-construction phase
accordance with the EMP monitoring plan PMU ESS IA
Bidding and contract documents
• Incorporate EMP mitigation measures into all bidding documents
• Define spoil disposal sites and borrow pit locations in the construction tender documents
• Bidding documents are sent to ADB for review
• Ensure that the contractors recruited conform with, and implement, the domestic Environmental Safeguard Clauses for Civil Works Contracts; including that each contractor shall have an environment officer on the team qualified for the civil works required for all project investments
• Ensure that the contractors fulfill any additional domestic or community safeguard
PMU ESS PIC
Item Potential
impacts / issues Mitigation measures Implement Supervise
requirements that are not otherwise addressed by EMP
EMP training • Provide training on construction environmental management, implementation, and
supervision to contractors in accordance with the training plan in this EMP PMU ESS PIC
Finalize GRM
• Responsibility for GRM implementation is assigned to PMU ESS and soum ESFs
• All agencies must be aware of, and trained on the GRM, and will know to help support the environmental and social specialists when necessary
• Key contact details for the GRM (phone number, fax, address, e-mail) provided on the MOFALI, PMU, PIUs, and/or soum government public websites, and information boards at construction sites adequacy of construction requirements, sanitation facilities, and to minimize ecological and social impacts, especially to avoid sites along rivers or other environmentally sensitive areas
PIU, contractor PMU
Reconfirm borrow and spoil sites
• Based on the finalized quantities of spoil needed calculated in the DEDs, identify the sites to be used and ensure they have sufficient capacity to provide the volumes needed;
• Obtain Aimag Dept of Environment and soum governments approval for the required material volumes (rock, gravel) and site use
PIU/ contractor PMU, soum government
• Implement completed COVID-19 management which complies with government regulations for COVID-19 prevention and control and be prepared in consultation with public health agencies. Plan will include: (i) measures to record the locations that workers have visited/lived immediately before and during project work; (ii) schedules for disinfecting/cleaning offices, yards, stores and labor camps; (iii) temperature checks and other health checks on-site; (iii) physical distancing measures, particularly in worker camps; (iv) mandatory use of personal protective equipment such as facemasks, and provision of handwashing stations, hand sanitizers, and other appropriate protective measures; (v) information for workers and nearby residents to protect themselves from COVID-19; (vi) procedures in the event a worker is suspected to have COVID-19; and (vii) other COVID-19 prevention and control measures appropriate for the local context
Contractor,
• All construction sites must be surrounded by wind erosion barriers (geotextile cloth, wood) of at least 1.5 m to minimize wind erosion of soils
• Construct peripheral intercepting channels to prevent construction runoff entering any waterway
• Peripheral earthen berms must constructed around civil works sites to prevent runoff-induced erosion from constructions sites
• Divert runoff from sites to sedimentation ponds or existing drainage
Contractor PIU, PMU
Item Potential
impacts / issues Mitigation measures Implement Supervise
• Limit construction and material handling during periods of rains and high winds
• Stabilize embankments, and other erosion-prone areas during works
• Minimize open excavation areas and use compaction techniques for pipe trenches
• Non-surface water-oriented civil works must not occur within 500 m of any surface waters
• Aggregate mining from surface waters must not occur
• Properly store petroleum products, hazardous materials and wastes on impermeable surfaces in secured and covered areas
• Rehabilitate all spoil disposal sites and construction sites
• Site rehabilitation will only use native plant species of local source; and/or sterilized seedlings (to avoid weed invasion)
• Situate construction camps and storage areas to minimize land area required
• Remove construction wastes from the site to the soum-approved disposal sites
• For soil protection: preserve existing soil layer where practicable; if soil removal is required, strip and stockpile topsoil and cover (with geotechnical cloth) in accordance with Mongolian legislation; reuse topsoil for site rehabilitation; seed grass as soon as possible to minimize duration of ground exposure; use only sterilized seedlings (to avoid weed invasion)
• Prohibit or limit construction and material handling during periods of rains and high winds
• Stabilize earthwork areas immediately after earthworks have ceased at the sites
• Completely restore all excavation sites or areas disturbed by civil works sites to original condition with original or local vegetation
• Establish site-specific emergency preparedness and response procedures for each soum investment. This will include: provision of cleanup equipment at each construction site; selection and training of workers to operate this equipment; and disposal of the spilled materials.
Ambient Air
Dust generated by construction activities, gaseous air pollution (SO2, CO, NOx) from construction machinery
• Water will be regularly sprayed on active construction sites in and near the project soums including where fugitive dust is being generated daily, and more frequently during windy days, if settlements will be affected
• Construction vehicles will follow posted and enforced low speed limits in construction sites especially close to settlements
• All truck loads will be covered during transportation to avoid spillage or fugitive dust generation. Fine materials will be transported in fully contained trucks
• Construction site roads will be well maintained and watered and swept on an as needed basis. Construction site road entry points will be equipped with the truck drive through wash ponds
• Transport routes and delivery schedules will be planned to avoid densely populated and sensitive areas and high traffic times in aimags and soums, if
Contractor PIU, PMU
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required
• Store petroleum or other harmful materials in appropriate places and cover to minimize fugitive dust and emission
• Provide regular maintenance to vehicles to limit gaseous emissions (to be done off-site)
• Construction spoil and other construction materials will be temporarily stored using containers, but they may the potential to generate dust. Thus, containers will be covered and/or watered if necessary
• Muddy or dusty materials on public roads outside the exits of works areas will be cleaned immediately
• Dust suppression near sensitive receptors e.g. schools, hospitals, residential areas must occur
• Ensure vehicle and machinery emissions comply with Mongolian standards
• Timely monitoring of TSP, and machinery inspections, during construction
• Regular consultations will be held with residents prior to, and during, works, to discuss the dates and timing of works and to receive feedback on air-related issues
Noise and vibration
Noise generated from construction activities
• Construction activities will be planned in consultation with local authorities and communities so that activities with the greatest potential to generate noise and vibration are planned during periods of the day that will result in the least disturbance
• Construction activities should not occur between 20:00 and 07:00
• When undertaking construction planning, simultaneous high-noise activities will be avoided. High-noise activities will be scheduled during the day rather than evening hours. Similarly, the construction sites will be planned to avoid multiple high-noise activities or equipment from operating at the same location
• Low-noise equipment will be selected as much as possible. Equipment and machinery will be equipped with mufflers and will be properly maintained to minimize noise
• Noise protective equipment will be provided to workers to meet the requirements in occupational exposure limits for hazardous agents in the workplace according to EHS Guidelines
• Transportation routes and delivery schedules will be planned during detailed design to avoid densely populated and sensitive areas and high traffic times
• Vehicles transporting construction materials or waste will slow down and not use their horn when passing through or nearby sensitive locations, such as residential communities, schools and hospitals
• Special attention will be paid to protect sensitive sites near investment sites: high-noise construction activities will be positioned as far away from sensitive sites as possible
Contractor PIU, PMU
Item Potential
impacts / issues Mitigation measures Implement Supervise
• Installation of sound barriers around the construction site will be decided during the detailed design phase for residential areas, if required. During peak construction, daily consultations with residents, led by the Aimag PIU and ESF, and attended by the construction supervision companies and contractors, shall be conducted
• High vibration activities, such as compaction operations will be prohibited at night from 18.00 to 08.00; (ii) communities will be consulted prior to large earthworks to ensure they are informed, and, to avoid sensitive timing e.g. exams at nearby schools or festivals. Vibration impacts are not considered a key risk because of the relatively limited scope of works
Surface water
• Ventilated improved toilets (VIPs) will be established at all works sites. These will be located at least 200 m from the nearest river, stream channel, or wetland. The VIP toilets will meet Mongolia’s Law on Hygiene and relevant Mongolian National Standard (MNS) requirements. VIP toilets are safer and provide better management of sewage compared to simple, unimproved pit latrines, which will not be permitted. For all project works less than 200 m from waterways, portable toilets will be provided. These will be regularly emptied into the VIP toilets.
• Construction wastewater will be disposed at least 300 m from waterways.
• Drainage channels and geotextile barriers will be established around all machine wash-down sites, chemical (e.g. vehicle oils, fuels) and worker camps to capture any pollutant runoff (especially during rainfall) and prevent entry to waterways.
• Construction waste (e.g. cement, discarded materials) will be stockpiled and protected from wind and removed regularly. Domestic waste (e.g. food waste from workers) will be confined to bins and regularly transported to landfill.
• Maintenance of construction equipment and vehicles will only be conducted off-site, at established service shops, to reduce the risk of accidental release of pollutants to soil and water.
• Oil traps will be installed at parking areas. Oil-water separators will be installed for oil-containing wastewater, if required.
• Storage facilities for fuels, oil, and other hazardous materials will be within secured areas on impermeable surfaces. Storage sites will be contained within bunds and cleanup kits will be installed at each site in the event of leakage.
• Contractors’ fuel suppliers will be properly licensed, follow proper protocol for
• Temporary spoil storage sites will be identified, designed, and operated to minimize impacts. Spoil sites will be restored after storage activities.
• Spoil will be reused on-site to the maximum extent feasible as fill. Excess spoil that cannot be used on-site will be transported to soum-approved landfills which are confirmed to have the capacity to receive the spoil; or, will be provided to other construction projects within the soum as approved by soum government.
Contractor PIU, PMU
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impacts / issues Mitigation measures Implement Supervise
• Waste construction material (e.g. residual concrete, asphalt) will be reused or recycled to the extent possible.
• Excavated soil will be backfilled on-site.
• Littering by workers will be prohibited.
• Covered litter bins will be situated at works sites for the collection of food waste and other domestic solid waste.
• Construction waste dumpsters will be provided at all construction sites.
• Domestic solid waste, and construction waste comprising wood, concrete, plastic, or other non-hazardous materials, will be transported by the contractor the nearest soum landfill. Transport will be in sealed containers to avoid spillage.
• Hazardous waste, including waste fuels, oils, vehicle batteries, and other materials, will be managed separately.
• There will be no final waste disposal on-site.
• Contractors will be held responsible for the proper removal and disposal of any significant residual materials, wastes, spoil, that remain on the site after construction.
Hazardous materials
Inappropriate transportation, storage, use and spills
• Hazardous materials for the project will be (i) vehicle fuel and oils used for vehicles by the government, herders, and/or project teams; (ii) small volumes of veterinary medicines for livestock care. The project does not involve the use of agricultural chemicals (pesticides or fertilizers) or any types of poisons.
• A hazardous material handling and disposal protocol that includes spill emergency response will be prepared and implemented.
• Storage facilities for fuels, oil, chemicals, and other hazardous materials will be within secured areas on impermeable surfaces provided with dikes with a 110%
volume, and at least 200 m from drainage structures and important water bodies.
A standalone site within the storage facility will be designated for hazardous wastes.
• Signs will be placed at chemicals and hazardous materials storage sites to provide information on the type and name of chemicals and hazardous materials (paint, solvent, lubricants).
• Suppliers of chemicals and hazardous materials must hold proper licenses and follow all relevant protocols and Mongolian regulations and requirements.
• For hazardous waste disposal, implement the following actions before works begin:
prepare list of hazardous materials and waste to be used or generated from the investment works; install on-site equipment and worker safety clothing to collect the waste; provide sealed containers on-site to transport the waste; identify the waste disposal site; alert the disposal site in advance before delivering waste materials; and, confirm these procedures with the aimag and soum environment inspectors.
Contractor PIU, PMU
Item Potential
impacts / issues Mitigation measures Implement Supervise
• The project does not involve the use of agricultural chemicals i.e. pesticides or fertilizers.
Ecological
values Protection of flora and fauna
• No project works will be conducted in any protected areas (either national or local) or other sites of environmental, cultural, and/or heritage significance, including Ramsar sites, Biosphere Reserves, Important Bird and Biodiversity Areas.
• Project works will be located in existing modified lands already used for livestock grazing. In the event any project activities involve the clearance of habitats, this will be subject to preparation of Detailed EIAs as per domestic requirements. In such case, detailed designs and works will not proceed until endorsement is provided by the EA and ADB.
• Construction machinery and construction workers shall be strictly assigned to work areas and access corridors as part of site planning and without occupying land randomly.
• Construction machinery and construction materials will not be placed in naturally vegetated areas.
• Construction materials (e.g. brick, stone, sand, cement) shall be transported to the work site in batches to meet demand so that stockpiles do not overflow onto naturally vegetated areas.
• After completion of works, cleaning and greening work shall be carried out.
• Prior to any works, on-site inspections will be made to check for presence of any terrestrial fauna, especially burrows of Siberian Marmot. If this species is detected within or near a work site: (a) clearly demarcate the site; (b) delay, or halt, any works in the vicinity; (c) report the observation to the ESF/PIU who will follow-up
• Prior to any works, on-site inspections will be made to check for presence of any terrestrial fauna, especially burrows of Siberian Marmot. If this species is detected within or near a work site: (a) clearly demarcate the site; (b) delay, or halt, any works in the vicinity; (c) report the observation to the ESF/PIU who will follow-up