Approved EIA Sec 3 EG Trans 28-9-2010 Sec.3-Final

ENVIRONMENTAL IMPACT ASSESSMENT Page 3-1
NGHI SON REFINERY AND PETROCHEMICAL COMPLEX Final Report

NSRP LLC- CPSE/SNC Lavalin June, 2010

Section 3.
ENVIRONMENTAL IMPACT ASSESSMENT

The pre-construction, construction and operation of the Nghi Son Refinery and Petrochemical Complex
are likely to cause significant direct and indirect, positive and negative impacts on the receiving
environment. Many of the negative impacts can be avoided or reduced to acceptable levels, while
benefits derived from the project can be enhanced by adopting good engineering practices and
appropriate mitigation measures during the design, construction and operation periods.

As comment in Section 0 about Scope of the Project, Tinh Gia District PC, NSEZ Management Board
and NSPM are responsible for implementation of activities in pre-construction phase (including site
clearance, compensation and resettlement, capital dredging). In this phase, the material exploitation
activities for first stage of site leveling and stage II of leveling from +3.5m to +6m before constructing
the Complexs infrastructure were approved by NSEZ Management Board, in which there are 01
Environmental Impact Assessment (EIA) report for material exploitation activity and 01 Commitment of
Environment Protection (COEP) report for site leveling activity.

Although the pre-construction phase is out of scope of this EIA report, but according to Safety, Health
and Environment (SHE) requirements of International Finance Corporation (IFC), NSRP LCC has
carried out an investigation survey and prepared a separate Resettlement Due Diligence report for the
Project. Moreover, relocation and resettlement activities will cause long-term effects on the society.
Hence, effects on local community in compensation, relocation and resettlement period are also
mentioned and assessed in detail in this report.

Therefore, this chapter aims to find and assess the direct and indirect impacts that are likely to occur as
a result of construction and operation phases of the Nghi Son Refinery and Petrochemical Complex.

The significance of impact also depends on whether the affected environmental components have
already undergone modifications. Impact significance has been established by using the following
criteria:

The component is recognised by a law, policy, regulation, or official decision (e.g. a park,
ecological reserve, rare or endangered species, habitat for fauna or flora, archaeological site, or
historical site);
The risks to the health, security, and well-being of the population;
Intensity of the impacts (i.e. degree of perturbation of the environment affected and degree of
sensitivity or vulnerability of the component);
Magnitude of the impact (i.e., spatial dimension such length or area);
Duration of the impact (i.e., temporal aspect and reversibility);
Frequency of the impact (e.g., intermittent occurrence);
Probability of the impact;
Indirect effect on other components (i.e., interaction between the affected component and other
components);
Sensitivity or vulnerability of the component;


Uniqueness or rareness of the component;
Durability of the component and the ecosystems;
Value of the component to the population.

This methodology considers the intensity of the impact which is an integration of the components
environmental value with its degree of disturbance used for determining the intensity and significance of
impacts are as follows: The degree of disturbance for a component defines the scope of the changes
that affect the component. The environmental value of a component is the synthesis of its ecosystem-
based value and its social value.

The approach used to assess environmental impacts of the project determines the intensity, extent, and
duration of the anticipated positive or negative impact. The main impact levels used in this report
include:
1. Severe environmental effect: Change in ecosystem or activity leading to long term damage (i.e.
lasting for 10 years and over) with poor potential for recovery to a normal state. Likely effect on
human health; long term loss or change to users or public finance.
2. Major environmental effect: Change in ecosystem or activity over a wide area leading to medium
term damage (lasting for over 2 years) but with the likelihood of recovery within 10 years. Likely
effect on human health; financial loss to users or public.
3. Moderate environmental effect: Change in ecosystem or activity in a localized area for a short
time, with good recovery potential. Similar scale of effect to existing variability but may have
cumulative implications; Potential effect on health but unlikely; may cause a nuisance to some
users.
4. Minor environmental effect: Change, which is within scope of existing variability but can be
monitored and/or noticed; may affect behavior but not a nuisance to users or public.
Areas affected directly by the Project will be limited by (a) the scope of effect of the Project stationary
constructions; (b) the scope of effect of the temporary works used in construction phase (transportation
road, camps, water supply system, waste water treatment system, pipeline, dredging and disposal area,
the harbour); Offsite areas are affected directly by emission of gas, noise, deposition of silt, fire &
explosion, waste water discharge or the traffic occurs beyond the Project area.

3.1 SOURCE OF IMPACT TO THE ENVIRONMENT

Based on project activities, the main sources of impact are defined by 2 phases of the Project as
follows:
Construction/installation phase
Operation phase

3.1.1 Impact Source Relating to Wastes

3.1.1.1 In construction phase

The source of impact during construction phase depends upon the type of construction activities, the
construction methods, construction equipment used, plant equipment fabricated onsite, chemicals /
materials used, source / amount of utilities and duration of work. The impacts in construction phase are
generated from following areas:


Refinery and Petrochemical complex and supported utilities;
Harbor facility;
Onshore product pipeline system;
Seawater intake and outfall facilities including pipelines;
SPM and offshore crude oil pipeline to the Refinery from SPM location.

The quantities/composition of various waste streams such as air emissions, wastewater and solid
wastes will be mentioned in assessment. Therefore, Table 3-1 only identifies the sources, waste types,
and type of impact. In subsequent sections, the emissions with regards to air, wastewater, solid waste,
hazardous wastes, noise and accidental releases have been qualified.

Table 3.1 Impact source related to wastes in construction phase

Generated wastes
No. Source of impact
Emission Wastewater Solid waste
Other impacts
Onshore constructions
1
Activities of construction
equipments and engines
Dust, CO, NOx,
SOx, VOC, CH
4
,
HC
- Residue oil
Noise, vibration, light,
public health
2
Operation of
Constructional equipment
and truck transportion
Dust, CO, NOx,
SOx, VOC, CH
4
,
HC
- Residue oil
Noise, vibration, traffic
safety, public health
3
Complex installation
activities
Dust
-
Empty drums,
papers, wood
scraps, plastic
containers, oily
& chemical
wipers
Noise, vibration, public
health, occupational
health and safety
4 Tank installation Dust, VOC Used materials
Occupational health
and safety
5
Washing facilities surface
before painting (depend
on used methods)
Dust (metal dust) Wastewater
Fe
2
O
3
, SiO
2
,
K
2
O, CaO
Noise, public health,
occupational health
and safety
6 Painting activities
Dust, VOC
-
Used paints,
brushes,
wipers
Occupational health
and safety
7
Welding and cutting
activities
Dust, heat
- Welding rods
Noise, heat,
occupational health
and safety
8
Pipeline trenching and
installation
Dust
- Spoil materials Ecology / Flora and
fauna
9
Non-destructive testing
(NDT)
Radioactive ray -
Occupational health
and safety
10
Onshore cleaning and
hydrotesting (Pipeline &
tank system)
- Wastewater -
Marine environment,
Fisheries
11 Workforce -
Domestic
wastewater
Domestic
waste
Social disruption,
employment, quality of
life, HIV/AIDS, public
health
12 Fuel spills HC Wastewater Oily wastes Occupational health


Generated wastes
No. Source of impact
Emission Wastewater Solid waste
Other impacts
and safety
Offshore constructions
1
Construction equipments
and engines
Dust, CO, NOx,
SOx, VOC, CH
4
,
HC
- -
Noise, Vibration
2
Pilling and construction
activities
Dust, CO, NOx,
SOx, VOC, CH
4
,
HC
Wastewater -
Marine environment,
Fisheries
3
Dredging activities at
intake channel and
breakwater
-
-
Dredged
materials
Coastal water
environment
4
Ship/barge operation for
SPM and crude pipeline
trenching and installation
Dust, CO, NOx,
SOx, VOC, CH
4
,
HC
Wastewater
Marine environment,
Fisheries
5
Pipeline Cleaning and
Hydrotesting
- Wastewater -
Marine environment,
fisheries,
6 Workforce -
Domestic
wastewater
Domestic
waste
Social disruption,
employment, quality of
life, public health

Exhaust gases
In construction phase, exhaust gases are generated from diesel generators, engine-driven machinery
used for site work, welders/cutters and surface coating during equipment fabrication, transport vehicles,
fuel oil storage tanks, transporting truck, excavation, trenching and earthworks.

Waste water
The effluents usually create from vehicle washing, hydrotest water and sewage. In the rainy season, a
significant volume of storm water runoff also generates. In addition, used oil, paints, cleaning solvents,
etc., also form hazardous effluent during construction phase.

The effluent from equipment/vehicle washings contains mainly TSS and oil. Typically, these will be
discharged to the land with preliminary treatment for removing oil and grease. The effluents from
equipment/vehicle washings contain mainly TSS and oil. Typically, these effluents generated during
construction and commissioning phase will be treated and disposed in correct way by EPC Contractor
to ensure that final discharge of effluents is in compliance with Project Discharge Standards.

The cleaning and hydrotesting effluent generated from pipeline and tank-farm cleaning and hydrotesting
process is assumed the biggest volume in construction phase. Depending on cleaning and hydrotesting
alternative (use chemicals or not), estimation of this effluent is assumed based on the volume of biggest
tank and onshore pipeline system.

Estimation of domestic wastewater in the construction phase is based on average manpower of 21,862
(22,000 in round) persons and peak manpower requirements of 32,795 (33,000 in round) persons.
Anticipated construction period to mechanical completion is 36 months which equate to approximately
930 working days, based on a 6-day working week.

Estimation of effluent in the construction phase is given in Table 3.2.


Table 3.2 Estimation of Effluent in Construction Phase

No. Source Volume (m
3
)
1 Raw water for concrete 278,250
2 Cleaning and hydrotesting water for tank testing 500,000
3 Cleaning and hydrotesting water for pipeline routes 187,500
4 Raw water for flushing 375,600
5 Domestic wastewater
Average (22,000 pers x 0.2m
3
/day x 930days) 4,092,000
Peak (33,000 pers x 0.2m
3
/day x 930days) 6,138,000
Source: Technical Doc. 3550-8710-PR-0003, REV A1 provided by FWL in April 2009

The sewage generated from site offices and constructional sites and camps will contain both total
suspended solids (TSS) and biochemical oxygen demand (BOD).

Solid Waste
Solid wastes usually generate from construction debris, excavated soil, packaging materials, scrap
metals from construction and equipment fabrication, vehicle/equipment maintenance waste, etc. The
excavated soil from onshore pipeline route can be used for pipeline backfilled; the others are often
segregated and stored in roll-off containers at waste yards managed by the EPC contractor. Besides,
there is a volume of domestic waste generated by 33,000 workers. The estimation of these wastes is
given in Table 3.3.

Table 3.3 Non-hazardous wastes in construction phase

No. Waste type Generation rate (Ton/year)
1 Sand/Soil from excavation soil 6,141
2 Packing waste card board 50
3 Packaging waste wood 300
4 Packaging waste-thermocol 20
5 Drums/container (uncontaminated) 4
6 Glass 40
7 Used PPE (uncontaminated) 50
8 Paper waste 150
9 Office furniture 5
10 Office electronic wastes 5
11 Compostable food and canteen waste >10,000
12 Domestic sewage 70 m
3
/day
*

Total 16,835
Source: Technical Doc. 3550-8150-PH-0002, REV D1 provided by NSRP LLC in December 18, 2009

Domestic solid waste especially from the camps are collected and stored in waste skips and disposed
to local landfill.

Hazardous waste
Solid and liquid hazardous wastes will be generated from equipment maintenance and lubrication,
surface coating, on-site fabrication, empty containers of paints/solvents/oils and accidental spills. These
wastes typically include used lube oil, batteries, empty drums of paint/solvent/additives, floor sweepings
from material storage yard, oily sludge, contaminated soils from spills, off-specification materials,
electrical and mechanical components, etc. Most of these cannot be recycled or disposed off -site.
Estimation of hazardous wastes in construction phase is listed in Table 3.4.


Table 3.4 Hazardous wastes in construction phase

No. Waste type Description Quantity (Ton/year)
1 Oily waste Engine, transformer oil, waste fuel, waste lube oil, cooking oil 21
2 Oily
container/drum
Oil filters, empty chemical drums, maintenance waste-gease, oil,
cotton waste, rags, etc
9
3 Used batteries/
cartridges
Dry batteries, Li, Cd, batteries, Lead acid batteries/acid, toner, used
photocopy cartridges, used fluorescent tubes, aerosol
containers/cans, used smoke ionic detectors, refrigerant Residues,
Pigging residues,
12
4 Contaminated
materials
Solvents/ paints/ thinners residue, sealants/mastic, spill absorbents,
contaminated soil, contaminated insulation, mineral wool material,
used PPE
33
5 Lab and medical
wastes
Medical /clinical/first aid waste, laboratory waste e.g. expired
chemicals
3
6 Radioactive waste Radioactive waste <1
Source: Technical Doc. 3550-8150-PH-0002, REV D1 provided by NSRP LLC in December, 2009

These wastes will be handled safely and stored in skips, drums and containers at the waste yard. They
are then transferred to the authorized treatment contractor by EPC Contractor in accordance with
Decision No.155/1999/Q-TTg dated 16
th
July 1999 issued by the Government on hazardous waste
management regulation.

Sources of accident
In construction phase, accidental impact sources at construction sites result mainly from oil spills during
routine loading/unloading, transportation and use of hazardous materials. The cleanup of such spills
generates oil-contaminated sands, floor sweepings and general debris. For instance, where
compressed gas cylinders or welding gases are used, there is a likelihood of such impact sources
during storage and transport activities.

3.1.1.2 Source of impact in operation phase

The sources of impact related to wastes in operation phase include air emissions, liquid effluents, solid
wastes and hazardous wastes generated from the process units along with the utilities, tank farm
system and marine facilities.

3.1.1.2.1 Emission gas

Flue gas fromstacks
During the operation phase, air emissions of the Nghi Son Refinery and Petrochemical Complex are
emitted through point source stacks of process units and utilities. There are totally 19 stacks from
various process units and utilities. Based on FEED document [Ref 10], the assumptions and estimated
emission rate from refinery stacks (process headers) are in compliance IFC HSE Guidelines for the
Petroleum refining, emission from stacks located in the aromatic section and naphtha and aromatic
complex are compliance with IFC HSE Guidelines for Large volume petroleum based organic
chemicals manufacturing and boiler and gas turbine stack emission are compliance with IFC HSE
Guidelines for Thermal power plants. In the normal operation, emissions rates of NOx, SO
2
, CO and
PM from point source stacks are given in Table 3-5.


Table 3.5 Emission concentration of pollutants at the point source stacks in the operation phase - NSRP
SOx
(mg/Nm
3
)
NOx
(mg/Nm
3
)
CO
(mg/Nm
3
)
PM
10

(mg/Nm
3
)
No. Source name Fuel type % S
Flue gas
flow (Nm
3
/s)
Project
standard
(1)
Concentration
of SOx at
point source
stack
Project
standard
(1)
Concentration
of NOx at
point source
stack
Project
standard
(1)
Concentration
of CO at point
source stack
Project
standard
(1)
Concentration
of PM
10
at
point source
1 SRU Stack Fuel gas
0.0058 32.57 150 120 450 167 800 150 50 50
2 FGD Stack HSFO
0.909 262 400 65 400 50 800 150 50 50
3 RFCC-Co Boiler Stack HSFO
0.909 133 400 400 400 300 800 800 50 50
4 GT HRSG Stack 1 Diezel+LPG
0.04 193 400 20 152 152 800 150 50 50
5 GT HRSG Stack 2 Diezel+LPG
0.04 193 400 20 152 152 800 150 50 50
6 HMU Reformer Stack Fuel gas
0.0058 69.18 400 20 450 60 800 150 50 50
7 CDU Stack Fuel Oil
0.24 22.28 400 400 450 450 800 150 50 50
8 ETP-Incinerator Fuel gas
0.0058 0.83 400 20 450 167 800 150 50 50
9 RHDS Stack 1 Fuel gas
0.0058 5.07 400 20 450 167 800 150 50 50
10 RHDS Stack 2 Fuel gas
0.0058 5.07 400 20 450 167 800 150 50 50
11 NAC-1-42 H101 Fuel gas
0.0058 39.14 100 20 300 124 800 150 20 20
0.0058 12.54 100 20 300 171 800 150 20 20
0.0058 49.53 100 20 300 171 800 150 20 20
0.0058 5.1 100 20 300 124 800 150 20 20
0.0058 7.14 100 20 300 124 800 150 20 20
0.0058 4.3 100 20 300 171 800 150 20 20
17 KHDS1 Fuel gas
0.0058 1.43 400 20 450 167 800 150 50 50
18 KHDS2 Fuel gas
0.0058 1.82 400 20 450 167 800 150 50 50
19 GOHDS Fuel gas
0.0058 4.11 400 20 450 167 800 150 50 50
Source: Technical Document provided by FWEL, June 2010
Note: (1) Project standards are taken from Section 0 - Table 0.2, this standard is considered and selected strictly between Vietnamese Standard and IFC EHS guideline


The values from Table 3.5 show that all concentrations of pollutants (SOx, NOx, CO and PM10) at the
point source stacks of the NSRP are within project standards which are considered as more stringent
than the Vietnamese standards and IFC EHS guidelines.

Emission gas fromflare system

In the case of general power failure, discharges from all relief valves (except acid gas service) are
routed to the HC flare system. Flaring gas will be routed to the HC purge flare / HC flare by maintaining
the different head in the HC purge flare seal drum and HC flare seal drum. Emission rate from HC flare
/HC purge flare system are given in Table 3-6.

Table 3-6 Emission rate from flare in normal and emergency cases

Emission concentration (mg/Nm
3
)
Flare Name Case
NOx SO
2
CO PM
GPF of Island 1 323 - 1,758 44 HC FLARE ESD
GPF of Island 2 98 - 531 28
GPF of Island 1 214 89,236 1,166 50
GPF of Island 2 97 10,568 528 29
ESD
Max H
2
S release (SRU 3-down) 84 315,076 457 50
HC PURGE FLARE
Normal operation 58 - 316 -
Project standards 450 400 800 50
Source: FWEL, October 2009

In normal operation, there is no emission of SOx and PM10 at HC purge flare. The emission
concentrations of NOx and CO are within the project standards.

In emergency cases, the emission concentrations of NOx and PM10 at both HC flare and HC purge
flare are still within project standards. However, the emission concentrations of SOx and CO exceed
project standards, especially in the case of maximum H
2
S release of SRU 3-down.

VOC fromstorage tank system
The fugitive emissions from NSRP are mainly from the storage tanks. The storage tanks include the
crude oil, intermediate, final product fuel oil and plant inventory storage tanks. The emissions from
these tanks mainly contain VOC and their emission rates are given in Table 3-7.

Table 3-7 Emission rate of VOC from storage tank system

Source Description
Number of
tanks
VOC emission rate
(kg/tank/year)
Refinery FO tank 1 455
Utility fuel oil tank 3 15
Ship loading fuel oil tank 1 15
GO HDS feed tank 4 2,846
RHDS diesel tank 2 4,144
GO premium tank 3 5,723
Vertical fixed roof tank

GO (Ind) tank 2 9,048
FRN tank - CFRT 2 2,846
Desulphurised heavy naphtha 1 1,937
Internal floating roof
tank

Reformate tank 1 2,379


Source Description
Number of
tanks
VOC emission rate
(kg/tank/year)
Light reformate tank 1 1,603
Heavy reformate tank 1 520
Heavy aromatics tank 1 1,192
RC/ DSRC tank 6 192
Crude tanks 8 2,376
Alkylate tank 2 2,057
Heavy FCC naphtha tank 2 394
Gasoline 92 tank 2 8,812
Gasoline 95 tank 2 8,812
SR slop tank 2 4,482
External floating roof
tank

Cracked slop tank 1 2,018
Jet tank 3 111 Ventilated internal
floating roof Kerosene tank 1 111
Total 52 140,511
Source: FWEL, October 2009

3.1.1.2.2 Wastewater

In the operation phase, the process effluents comprise spent caustic, benzene contaminated
wastewater, water from sour water stripper and various overhead receivers, boiler blow down and
backwash from process units, which is collected through the drain system. The continuous oil
contaminated wastewater is collected from oily water equalization tank, equipment areas and tanker
loading areas and is routed to the drain system. The cleaning wastewater comes from various process
and utility areas. Accidentally oil-contaminated surface water (AOC) including surface run-offs (rain
water, wash down) are collected from project areas with a risk of contamination. Therefore, Specific
wastewater streams are collected in dedicated systems before passing to the effluent treatment plant
(ETP), including:
Dedicated collection of benzene contaminated water (BCW) in a closed system to prevent
atmospheric emission of benzene
Dedicated collection of spent caustic effluent for flow balancing and prevention of atmospheric
H
2
S emissions
Water from crude oil tank bottom will be routed to a dedicated API separator to remove gross
oil content.

The sanitary effluent generated from administrative building and offices is collected separately, pre-
treated and routed into the biotreatment stage of the ETP. Total amount of sanitary water is about
14m
3
/h from refinery and 0.7m
3
/h from Jetty area. So, total amount of sanitary water in operation phase
is about 14.7m
3
/h.

The total quantity of process wastewater from various process units including utilities and sanitary is
about 600 m
3
/hour. The ETP consists of a two stage oil/water separation unit along with third stage
biological treatment.

Cooling water will be seawater taken from Nghi Son bay at the coastal. After cooling circulation, about
5-20% of cooling water will be routed to FGD for desulphurisation purpose. The neutralized effluent
from the desalination plant is estimated of 564 m
3
/hour which will also be potentially discharged to the
sea through the outfall facilities.


Estimation volume of effluents generated from refinery complex is summarized in Table 3-8.

Table 3-8 Quantity of NSRP effluents in operation phase

No. Source Flow rate (m
3
/h)
1 Sea water intake 128,200
Total effluent outlet 129,364
- Peak ETP outlet (including industrial effluent and domestic effluent)
600
- Peak RO/IX Reject/Regent
564
- Power FGD outlet
23,000
2
- Cooling water
105,200
Source: Technical Document provided by FWEL, October 2009

3.1.1.2.3 Solid waste

Non-hazardous solid waste

Solid wastes during the operational phase include hazardous and non-hazardous wastes. Non-
hazardous solid wastes include packing materials, used electrical fittings, domestic waste from
residential camp, canteen waste, STP sludge, waste paper, printer cartridges, metal scrap, used spare
parts and cans, drums and containers of non-hazardous materials.

These wastes are stored at designated waste storage areas at the facility and finally disposed off at
approved dumpsites or sold to potential authorized buyers for recycling (e.g. waste paper, packing
materials, metal scrap and printer cartridges). A suitable waste management facility for storage of solid
wastes will be located at the plant boundary.

Hazardous solid waste
When the project comes into operation phase, hazardous wastes from various process units are mainly
spent catalysts, spent absorbents, spent de-sorbents, replacement of inert materials, oily sludge, waste
chemicals, containers of hazardous materials, incineration ash, etc. Liquid hazardous wastes include
spent caustic waste oil / paints / solvents and chemicals. The estimated quantities of significant
hazardous wastes are given in Table 3-9.

Table 3-9 Quantity of hazardous wastes in operation phase

No. Source Unit Quantity Notes
1 Spent catalyst MT 1,110.8 Once in 04-05 years
2 Spent hydrotreater catalyst MT 153.2 Once in 04 years
3 Spent solid phosphoric acid catalyst MT 224.6 Once in 02 years
4 Spent catalyst (CR3S) sulphur recovery unit MT 140 Once in 05 years
5 Spent catalyst (TG 107) from SCOT section MT 70 Once in 05 years
6 Spent adsorbents MT 17.323 Once in 04 years
7 Spent catalyst replacement Ton/year 1,760 Annual


No. Source Unit Quantity Notes
8 Replacement of inert material Ton/year 52 Annual
9 Spent adsorbents Ton 603 Once in 04 years
10 Spent adsorbents Ton 1.3 Annual
11 Spent desorbents Ton 1116 Once in 20 years
12 Spent desorbents Ton 2.63 Annual
13 Spent caustic m
3
/year 1,632 Weekly (34m
3
)
14 Catalyst grading materials (from HDS reactors) Ton 49 Once in 04years
15 Teal oil liquid waste m
3
/year 280 Regular
16 Hydrocarbon drains m
3
/year 146 Regular
17 Spent selective hydrogenation catalyst Ton 10 Once in 04 years
18 Clay treater sludge Ton 154 Every 06 months
19 Clay treater sludge (from BT clay treater) Ton 103.6 Every 02 years
20 ETP sludge Ton/year 5,204 Regular
21 Incineration ash from ETP Ton/year 2,100 Regular
Source: Technical Doc.3550-8150-PH-0002 REV D1 provided by NSRP LLC - December, 2009

Total amount of sludge is about 25,080kg/day in normal case and 57,360kg/day in peak case.

These wastes will be stored in designated and protected hazardous waste storage area of the Refinery.
The hazardous waste storage area will be typically part of the waste management facility, which will be
planned and located at the site for storage of non-hazardous and hazardous wastes.

3.1.1.2.4 Accidental impact sources

Accidental impact sources from the refinery include gaseous and liquid sources. The gaseous impact
sources include fuel gas/LPG leakage from the supply/process pipelines and LPG leak from the storage
tanks due to corrosion or external damage.

The liquid impact sources include spills or leakages from crude oil/intermediates/final products/fuel oil
storage tanks, product export pipelines, oil spills from SPM, crude pipeline and shipping collision.

The significance of the above leaks depends on the quantities (inventory) of material contained, type of
leak (small / medium leak or rupture) and the location of leak (onsite /offsite). The hazard identification
(HAZID) or hazard and operability (HAZOP) studies have been undertaken by FEED consultant for this
project. The quantitative risk assessment (QRA) of potential hazards and consequences of accidental
impact sources is carried out by FEED Contractor.

3.1.2 Impact source not related to wastes

Non-waste impact sources in construction phase are mainly generated by:

Complex construction and installation of equipments;
Tankfarm construction and installation;
Harbor construction (including hard jetty, product jetties, breakwater, turning basin and access
channel through sea route);
Offshore and onshore pipeline construction;


Unload and transport materials and super size & super weight equipments;
Breakwater construction;
Pilling and construction activities harbor;
SPM and Crude pipeline trenching and installation;
Anchoring activities of laying barge and supply vessel.

In the operation phase, main impact sources not related to wastes are generated from following
activities:

Operation of the complex;
Product distribution road;
Crude and product storage area;
Offshore pipeline maintenance;
Offloading crude at SPM;
Loading products at harbour
Shipping activities.

The impact sources not related to wastes from project phases are given in Table 3.10.

Table 3.10 Impact sources not related to wastes from construction and operation phases

Impact sources not related to waste
Refinery Marine facilities
Impact
CONSTRUCTION PHASE
- Foundation treatment and installation of
equipments
- Foundation treatment and tankfarm
installation
- Welding and cutting activities
- Onshore pipeline installation
- Intake and outfall construction

- Breakwater construction
- Pilling and harbor construction activities
- SPM and crude pipeline trenching and
installation
- Anchoring activities of laying barge and
supply vessel
- Social issues
- Noise & vibration
- Seawater environment
- Biological environment
OPERATION PHASE
- Product distribution road
- Onshore pipeline maintenance
- Crude and product storage area
- Pipeline maintenance
- Offloading crude at SPM
- Loading products at jetties
- Shipping activities
- Noise & vibration
- Seawater environment
- Shoreline erosion

The above-mentioned activities will cause impacts to society, noise & vibration, sea water, biology and
shoreline erosion in project phases.



3.2 IMPACTED OBJECTS

3.2.1 CONSTRUCTION, INSTALLATION AND COMMISSIONING PHASE

In order to ensure the efficiency of cost and environmental sustainable development, NSRP LLC has considered safety
and environmental standards since the FEED preparation phase. All design options strictly comply with standards of
Vietnam and World Bank.

According to site philosophy for main project components, process units will be arranged in an optimum way to reduce
used natural resource. From environmental point of view, it shows that:
Arrangement of high heat and pressure process units at the centre of the Plant will mitigate negative impacts
on surrounding residential area;
Crude oil tankfarm, product tankfarm and pipeline joint areas will be located in the Northeast of the Complex.
Product tank and sphere tank area will be in the Eastern fence of the Plant to reduce the length of product
pipeline to the harbor;
Wastewater treatment area is sired between product tank area and process units in order to collect and treat
effluents easily;
Intermediate tank, waste storage, crane and administrative areas are located nearby the West fence of the
Complex and Coc mountain;
The control house is sited close the administrative area and near the process units;
The flare will be put in the Southeast corner of the Complex;
The arrangement of SPM at 33.5 km far from the shore does not need to dredge maintenancely. Crude oil
tanker will approach SPM easier and may go in and out from any directions and especially reduce
environmental impacts on marine resource (coral reef) around Me island;
Crude oil pipeline is installed in the North of Me island and far from coral reef area to mitigate impact during
construction phase and potential risk of oil spillage;
Product berth construction is considered to the stability of the seashore and near the Complex to reduce
product pipeline length and potential risk of marine transport activities;
For Thanh Hoa Province, product berth construction in the East of the Complex will be an advantage for
broaden Nghi Son harbor system in the future. This is safe and easy for management and operation of the
Nghi Son harbor. Especially, the operation of the harbor will not cause any disturbance to the traffic of local
people living in Nghi Son island;
Breakwater construction in the North harbor will reduce effect of sea wave, current and sedimentation loading
in the initial phase of the construction, especially heavy modules transport.

3.2.1.1 ENVIRONMENTAL IMPACTS FOR CONSTRUCTION OF ONSHORE FACILITIES
(REFINERY AND SUPPORTED FACILITIES)

The environmental components affected by the onshore implementation of Nghi Son Refinery and
Petrochemical Complex concern mainly air quality, noise and vibration, water resources, soil quality,
flora and vegetation, fauna and wildlife, aquatic habitat, cultural resources, land and natural resources,
livelihood activities, population, health and safety, etc. In addition, the project impacts on global
environmental issues like greenhouse gases and biodiversity are also considered.


The works assessed in this part include:

The complex site (area B);
Onshore pipeline system (area E) including crude, product, cooling intake, outfall pipelines.

3.2.1.1.1 Air quality

Project activities

During the construction phase, dust will be generated due to earthwork activities and exhaust gases
from constructional equipment and truck movement at site.

Potential impacts

Dust

The potential impacts on air quality during construction phase of the refinery are the generation of dust
from earthwork activities, transportation, site movement of vehicles on unpaved surfaces and the
engine exhaust from construction equipment, vehicles at the construction sites and labor camps.

Dust is considered as major adverse impact due mainly to earthworks for site improvement, site
excavation for foundation and surface polishing of tank system. The movement of 586 equipment
(dump trucks, excavators, bulldozer, roller/compactor, grader, piling, etc.) will create a lot of dusts in the
dry season (December to May) and cause dust pollution to Project area and the vicinity as similar as
mentioned in pre-construction phase. Moreover, people living along provincial road 513 will be also
affected by dust.

The steel welding and cutting activities, polishing tank surface and spraying paint on tank and pipeline
system will generate a great quantity of dust, VOC and oxide metals (Fe
2
O
3
, SiO
2
, K
2
O). These
substances will directly affect on health of on-site workers and local effects to air quality at working site.

In general, dust generated from construction activities of the Complex and supported utilities will directly
impact on on-site workers at the Project area. The Project is located in NSEZ but it is too near
residential area. Therefore, in construction phase, dusts do not only affect on the project area but also
affect on residential area and nearby communes. Impact level is assessed as moderate for 03 years of
construction and installation.

Emission gas

The major exhaust gases consist of PM, NOx, SOx, CO and VOC. Based on number of constructional
equipment, volume of used fuels and constructing time, estimation of exhaust gases are given in table
3.11.



Table 3.11 Estimate exhaust gases from construction equipment in construction phase

Exhaust gases (Ton)
Equipment
Number of
equipment
(pc)
Used fuel
(Ton) TSP
b
CO
c
SO
2
a
NO
X
d
VOC
e

Cranes 40 3,152 13.6 44.1 0.019 220.6 12.7
Mass transportation
buses (60 seats)
122 4,340

18.7

60.8

0.026

303.8

17.4

Heavy equipment 40 2,846 12.2 39.8 0.017 199.2 11.4
Earthmoving equipment 284 17,178 73.9 240.4 0.101 1,202 68.7
Other cars & trucks 100 1,581 6.80 22.1 0.009 110.7 6.3
Total 586 29,096 125.1 407.4 0.175 2,037 116.4
Notes: Used fuel is assumed for 515 working days
Specific weight of Diesel is 0.85 ton/m
3

a: S content is taken of 0,3%W.
b,c,d,e: 4.3; 20S; 70; 14 and 4 for TSP, SO2; NOx; CO and VOC respectively.

Fugitive emissions from earthmoving equipment, crane and heavy machines will release combustion
gases like TSP, NOx, SO
2
, CO and VOC which will impact local ambient air quality. Based on
estimation exhaust gases from 586 construction equipments and vehicles, the total exhaust gases is
estimated to be 2,037tons of NOx, 407tons of CO, 125tons of TSP, 116tons of VOC and 0.175tons of
SO
2
. All these gases created from movement sources will be easily dispersed in an open and flat
terrain. Therefore, the impact of exhaust gases is considered as minor for three construction years.

The painting activity is potential source of VOC release into environment, especially under sunshine in
the dry season. In practice, the painting activity is carried out in different locations of the Complex, so
the VOC will easily disperse into the air with very low concentration and affect insignificantly on the
environment. Moreover, NSRP LLC will suggest the EPC Contractor apply international painting
standards to ensure that VOC concentration comply with Vietnamese and International requirements.
Hence, impact level of painting activity is assessed as minor.

Noise and vibration
Project activities

Noise generated on construction site will come from sources which vary in nature and intensity. The
most significant noises are produced by heavy equipment operating on the site, such as compressors,
pneumatic and hydraulic tools, excavators, loaders, graders, bulldozers, shovels, and hammers. Other
noise sources can include trucks traveling to and from the site, the loading and unloading of materials,
and sirens and backup warning signals. There is also noise produced by engines (i.e., valves, air
cooling and exhaust systems), as well as vibrations generated by tools. Moreover, poor equipment
maintenance (e.g., loose parts and poor lubrication) can create vibrations and, consequently, increase
the noise level. The use of dynamite is also a significant noise source on construction sites.

Primary receptors for construction-related noise and vibrations include site employees and residents
and structures in the communes near to the construction site.

Potential Impacts

Noise is a concern for project workers and local communities, especially in the early morning and
nighttime site work activities. The typical noise levels expected from the various construction machines
are presented in Table 3.12.


Table 3.12 Noise level in construction phase

Noise source Number of equipment
1
Expected noise level
2
(dBA)
Heavy cranes 40 115
Mass transportation 122 75
Heavy equipment 40 125
Earthmoving equipment 284 115
Others 100 72-74
Total 586
Source: 1: FWL, April 2009
2: Refer to Vietnam construction standards

The heavy equipments used in construction and installation works, diesel generators, pilling machines,
roller/compactors, etc. and the road transportation will cause noise impact on the workplace as well as
the vicinity and access roads. It is likely that at certain locations close to the noise sources within the
work site, the noise levels will be in excess of 85dB(A) which is required the personnel on-site to wear
ear protection devices.

The construction activities on-site are likely to affect the ambient noise levels, especially near
residential areas. For construction equipment with a typical level of 85 dBA at 15 m, the expected noise
level is approximately 49 dBA at 1 km distance from the source and 43 dBA at 2 km distance.
Simultaneous operation of multiple pieces of heavy equipment can increase noise level by up to 10
dBA. The noise from a construction work site may have a significant impact on residence located within
1 km of construction activity and could exceed IFC noise guidelines.

Noise levels for a typical haul truck are 85 dBA at 15 m with the average velocity of 80km/h, the
forecasted equivalent noise level is LAeq 1h: 50 dBA at a distance of 400 m from the road, in
compliance with IFC residential daytime noise guidelines but exceeding residential nighttime guidelines.
Noise from transport vehicles will be only transient for a given location and can be considered as a
nuisance during daytime and night-time along the transportation access.

During the night-time when the ambient noise levels are low, the level of perception to noise is more
sensitive and impact more significant.

Moreover, the direct driving a great quantity of concrete piles for foundation consolidating will generate
noise but also cause strong vibrating within the project area. It is noted that the noise and vibration
caused by pilling drivers are most long lasting, stretching and make uncomfortable (reverberation
effect) to local communities within first year of construction period, especially at night-time.

Thus, noise generated from construction equipment will directly affect to health of construction workers
and nearby communities. Impacts level is assessed as moderate and uninterrupted during working
process.



3.2.1.1.2 Surface water

Impact by construction/installation of intake water and outfall effluent system
Project activities

The water intake from the sea is installed at the seashore and located on the north of export jetty.
Related to intake installation, some works, such as installation of crest breakwater, intake channel, will
be implemented.

The outlet location will be 6 km from shoreline. The outlet system consists of main pipeline and diffuser
pipes which have some number of ports. Whole outlet system will be buried under seabed with ports
which are 1 m higher than the surface of seabed.

Potential impacts

Intake channel with 350m in width and 70m in length will be dredged to designed depth in order to ensure supplying
enough sea water for cooling purpose. The dredging activities will impact to 24,500m
2
seabed and generate a significant
quantity of dredged materials.

Wastes from dredging activity and above-mentioned earthwork will be discharged at approved site by the authority or at
disposal site of capital dredging materials in the construction phase.

Turbidity will be increased during intake installation near shore. The construction of outlet system will
strongly cause the seabed disturbance and increasing turbidity of coastal water. However, construction
activities are done in a short time, therefore adverse impact level is considered as short-term and
moderate.

Potential water pollution due to onshore cleaning and hydrotesting activities
Project activities

Cleaning and hydrotesting activities will be undertaken after completing installation tank system and in
plant pipeline system. It is planned to use freshwater and some chemicals as oxygen scavenger,
corrosion inhibitor, biocide and dye. Preliminary estimate shown that hydrotest volume is about
500,000m
3
which will be retained in settling pond to remove particulates and recycle for one by one
tank testing. At last, cleaned and hydrotested wastewater will be treated through on-site effluent
treatment facilities before discharging into the environment.

Potential impact

The discharge of treated cleaning and hydrotest water into coastal water might cause oxygen depletion
and high turbidity around the outfall area. In practice, the hydrotest water will be diluted quickly by
effects of sea waves and tide. Therefore, the impact level is assessed as minor within 1-2 weeks.

Effect of sanitary wastewater discharge
Project activities

During the construction phase, a large number of employees are mobilized to the site. The average
number is about 22,000 persons and the peak period will be 1.5 times higher (33,000 persons).


Approximately 6,600 m
3
of domestic wastewater per day will be generated during the peak period of
construction activity (Table 3.2). This sewage will be treated in a dedicated effluent treatment system
and discharged subject to the storm water channel to the sea.

Potential impact

The potential impacts which may be associated with the sanitary effluent discharge are to reduce water
quality in receiving waters due to high BOD and COD and dissolved oxygen (DO) depletion around
outfalls due to bacterial digestion. This might also cause eutrophication due to increased organic
loading (algal blooms) and resultant localized anoxia.

NSRP LLC will ensure that effluent treatment design standards are set in the environmental design
basis, so that the treated effluent from the construction camps will not be discharged into a highly
sensitive as Lach Bang watershed.

On this basis, the discharge of sanitary effluent from the camps will cause a moderate adverse
environmental impact. Impacts will last throughout the construction phase (3 years), but its magnitude
will be most significant during peak construction operations. Any adverse impacts to local water quality
as a result of the discharge may also be offset by the cessation of raw sewage disposal into water
environment following relocation of discharge site.

Effect of stormwater discharge
Project activities

Large volumes of turbid storm water will be generated at the worksite, particularly following excavation
work, pipeline trenching and backfilling.

Potential impact

At the end of site leveling period, Dap Ngoai canal will be tiredly backfilled. In order to drainage water for the area from
Chuot Chu mountain foot to the road 513, NSEZ management board had constructed a drainage creek along road
513 to Lach Bang river.

According to calculation, maximum volume of runoff storm water at the Plant site is about 143,514 m
3
/h.
In order to prevent inundation to nearby community, the Project has designed a drainage channel in the
North of the plant to drain off all volume of runoff storm water in the surface of the Plant. Runoff storm
water in the South will be drained through a drainage system constructed by NSEZ Management Board
along Road 513. Therefore, all of water run off in the project site as well as rain water around Chuot
Chu mountain foot area will be totally drainaged out and do not cause effect to nearby populated area. Impact
level of runoff storm water is assessed as minor.

3.2.1.1.3 Groundwater

Project activities

The water requirement during the construction phase is taken from Nghi Son water supply plant.
Preliminary quantity of water needed for domestic demand of 33,000 workers in the construction phase
is approximately 6,600 m
3
/day in average and 9,900m
3
/day in peak daily demand. Total average
demand over construction phase (930days) is about 6,138,000 m
3
.


In addition, raw water for mixing concrete, flushing and tank cleaning and hydrotesting are estimated of
1,153,850m
3
. Water used for these activities will be supplied by NSEZ.

If wastewaters generated in the construction phase are not treated properly, it will be a potential risk of causing
groundwater pollution.

Potential impacts

Pipeline trenching, site upgradation and consolidation activities might impact to groundwater regime of
surface layer from Chuot Chu mountain to Lach Bang river. Impact level is assessed as minor due to
trenching depth is in the range of 1m in minimum and 4m in maximum.

The discharge treated hydrotest water to the coastal water is assessed as minor after controlling
content of contaminated substances. The significant potential impact to groundwater contamination in
this phase is from sanitary wastewater due to having peak number of workers. As planned, the EPC
contractor will provide toilets at the site and camps to collect and treat domestic wastewater on site.
Therefore, the impact level to groundwater quality is assessed as small in a short period.

3.2.1.1.4 Soil environment

Project activities

The EPC contractor will implement construction activities such as establishing infrastructure, transport, temporary
storage and installing machines, equipments, works, process units. The contractor will use many materials and
chemicals in construction and pre-commissioning phase. Besides, in the peak of construction phase, the Project may
mobilize maximum workers up to 33,000 persons.

The EPC contractor may need more land to set up camps for workers, assemble and temporarily store a great number
of equipments, materials

Potential impacts

Soil disturbance

Total area for onshore constructions is 394 ha. Most of land acquired for the Project (65%) is low production agricultural
land (1 paddy crop and 1 onland product crop). The Project area is only about 2.2% of total NSEZ area (18,612 ha).
However, foundation treatment activities, building infrastructure and installing units will cause strong disturbance to soil
structure from agricultural to industrial land. Impact level is assessed as moderate in construction phase.

Potential soil pollution caused by wastes

Estimated generation rate of non-hazardous solid wastes in construction and installation phase is about 16,835
tons/year (Table 3.3), in which 59.5% is compostable food and canteen waste (10,000 tons/year), 36.6% is sand/soil
waste from site preparation (6,141 tons/year) and 3.9% is others such as packing waste, glass, furniture, domestic
waste Estimation of domestic sludge generated from construction site and camps is about 70 m
3
/day. This is
potential source of soil pollution if there is not suitable or enough collection and treatment equipments. Therefore, if
mitigation measures for soil environment are applied strictly, impact level is assessed as minor in 3 construction years.



Hazardous wastes generated in construction phase are mainly contaminated materials, oily waste and used
batteries Estimated generation rate of hazardous waste is about 79 tons/year (Table 3.4), in which 41.8% is
contaminated waste (33 tons/year), 38% is oily waste (30 tons/year), 15.2% is used batteries (12 tons/year), 3.8% is
laboratory waste, and less than 1.2% is radioactive waste (less than 1 ton/year). All these wastes will be classified on-
site and stored in safe containers.

Besides, process of cleaning steel plate surface for tank system installation will create a number of metal slags.
Estimated generation rate is about 100 tons/year. Since high pressure cleaning process is often carried out outdoor,
slag will be dispersed on the ground and hardly to be collected absolutely. Especially in rainy season, these slags will
infiltrate into ground to make the soil contamination. Impact level is assessed as moderate during tanks and pipeline
system installation.

3.2.1.1.5 Biological environment

Flora

Project activities

The site clearance, trenching and pipeline installation activities will occupy 30 ha residential, agriculture
land and coastal protective forest. This area will be used for onshore pipelines system including: two
48 crude pipelines, 13 product pipelines, one intake cooling pipeline and one outfall pipeline and other
supported pipelines connecting from Harbor to tank area.

EPC contractor may need more land for their accommodation camps, site gathering, assembling and
temporary storage a large quantity of equipment, materials, etc., so more number ha of vegetation and
flora will be affected.

Potential impact

Based on Biodiversity assessment report for the project area and the vicinity [7] of national biological
specialists, August 2008, approx. 70% of pipeline route area (area E) is residential land with fruit trees
and 30% remained area is protective forestry which is typical by Casuarinas equisetifolia with the age of
5-10 year old. Estimation of affected coastal protective forest is about 35,000 m
2
(3.5ha) and quantity of
cut down trees is approx. 2,916 trees. The onshore pipeline construction will required permanent
vegetation clearance on 30 ha residential area, product land (peanut, sesame) and coastal protective
forest (3.5 ha).

In practice, at onshore pipeline area, there is not any rare species and vegetable cover is mainly fruit
trees and crops. Affected protective forest is limited in a small area (350m in length and 100m in width),
the significance of this impact is assessed as minor.

Fauna and wildlife
Project activities

The site clearance, trenching and pipeline installation activities will occupy 30 ha of residential,
agricultural land and coastal protective forest.



Potential impact

Based on field survey to project site in February 2009, some distributed birds as white herons were
observed in Area N and sub-soil disposed area. The biological survey results for area E and its vicinity
(October 2009) shown that these areas are mainly considered as residential and agricultural
ecosystem. These ecosystems are not supported any threatened species.

The presence of 33,000 workers may affect threatened fauna species through local market food
supplies or restaurant. However, since full accommodation will be provided for most of these workers
and then reduce the potential impact on the threatened fauna species. The significance of this adverse
impact is assessed as minor and short-term.

3.2.1.2 Offshore Construction (Harbor, Breakwater, Pipeline and SPM)

3.2.1.2.1 Air environment

Project activities

It is assumed that the number of equipment mobilized for construction marine facilities will be about
10% of quantity of equipment and trucks estimated for the plant site.

Typical equipment for onshore construction consist of excavator, rock hammer/breaker, bulldozers,
wheel loader, trucks for backfill materials (rock and sand) transport, survey equipment, anchors, winch
or sheaves etc.

During offshore construction/installation of crude pipeline and SPM, approximately 42 vessels or
equipment packages with capacity of 100 to 200 tones and 37 vessels or equipment with capacity over
200 tones will be required.

Offshore construction activities should be completed within a period of 36 months.

Potential Impacts

Site preparation harbor, breakwater, access routes and material transportation activities will cause
negative environmental impacts on air quality, including dust arising from site preparation, construction
activities, transportation and exhaust emission from the operation of diesel generators, construction
equipment and heavy trucks.

1. Dust

Earthworks associated with breakwater and harbor construction will require large quantity of material
including sand. Furthermore, the construction of the harbor and breakwater will be affected by sea
winds, so the activities of site leveling and truck movement for loading spoil sand, stones and
construction materials will generate a significant quantity of dust that will impact on labors working at
the project site and local people living along Tinh Hai and Hai Yen beach.

The fine particulate might affect the respiratory system of Contractor employees at the project site and
can cause asthma, pneumonia and bronchitis. These activities will have a significant direct impact on
project labor and local people living in the vicinity.



In summary, dust generated from constructional activities will cause significant direct impacts on
labours working in the project sites and to local residents living in the vicinity. These impacts will last for
duration of the construction works (36 months). The significance of this impact is considered to be
major during the first two years and will gradually be reduced to minor effect in the third year of the
construction and installation phases.

2. Emission exhaust

The onshore based construction of harbor, breakwater, crude pipeline and SPM system will use typical
construction equipment including excavator, rock hammer/breaker, bulldozers, wheel loader, trucks for
backfill materials transport, survey equipment, anchors, winch or sheaves etc. The operation of these
machines/equipment will emit to the environment significant quantities of exhaust gases.

Based on total number of construction equipment for the whole project and the scope of marine
construction activities, it is assumed that the equipment used for marine construction is about 10% of
the ones used for plant construction. Estimated volume of emission gas generated from equipments
used in harbor and breakwater construction phase is presented in Table 3.13.

Table 3.13 Estimated volume of emission gas generated from equipments used in harbor and
breakwater construction phase

Emission gas (ton)
Equipment Quantity
Used fuel
(ton) TSP
b
CO
c
SO
2
a
NO
X
d
VOC
e

Crane 4 315 1.35 4.41 0.02 22.05 1.26
Truck 12 434 1.87 6.08 0.03 30.38 1.736
Heavy equipment 4 285 1.23 3.99 0.02 19.95 1.14
Soil/stone transport device 28 1,718 7.39 24.05 0.10 120.26 6.872
Others 10 158 0.68 2.21 0.01 11.06 0.632
Total 58 2,910 12.51 40.74 0.17 203.7 11.64
Notes: Used fuel is assumed for 515 working days
Specific weight of Diesel is 0.85 ton/m
3

a: S content is taken of 0,3%W.
b,c,d,e: 4.3; 20S; 70; 14 and 4 for TSP, SO2; NOx; CO and VOC respectively.

Exhaust gases emitted in construction/installation and pre-commissioning phase of the offshore pipeline includes
emission gas of ship engines, generator, welding machine, crane and other equipments on the pipeline installation ship,
pulling ship, pipe carrier and supply boats. Components of exhaust consist of CO, CO
2
, NOx, SOx, dust and unburnt
HC. These exhausts may increase concentration of pollutants in the air.

As planned, there will be 42 ships/devices with capacity of 100 200 tons and 37 ships/devices with capacity of 200
tons. Ships taking part in installation of crude oil pipeline within 12 months include laying barges, pipe carrier and service
vessels. Estimated amount of DO used for laying barge and equipments is about 18 tons/day; pulling ship is 0.85
ton/day; pipe carrier is 0.85 ton/day and supply boats is 0.17 ton/day. Fuel used for ships includes fuel used for ship
engines and fuel used for onboard devices. According to calculation method of United Kingdom Offshore Operators
Association (UKOOA) [17], estimated exhaust from the operation of installation ships is presented in Table 3.14.



Table 3.14 Estimated exhaust gases generated from constructional ships/barges

Amount of exhaust (ton)
Vessel
Used fuel
(ton)
CO
2
b

CO
c

NOx
d

SO
2
a

CH
4
e

VOC
g

Laying barge 5,616 17.971 0.0590 0.223 0.010 0.001 0.007
Pulling ship 265 0.849 0.0028 0.0105 0.0005 0.00003 0.0003
Supply boats 53 0.170 0.0006 0.0021 0.0001 0.00001 0.0001
Pipe carrier 265 0.849 0.0028 0.0105 0.0005 0.0000 0.0003
Total 6,199 19.838 0.065 0.246 0.011 0.001 0.008
Note: Used fuel is assumed for 312 working days (26 day/month x 12 months)
a: S content is taken of 0,3% W.
b, c, d, e,g: 3.2 for CO2; 0.0105 for CO; 0.0397 for NOx; 0.6 for SO2; 0.00011 for CH4 and 0.0013 for VOC

Above results show that:

Exhausts from harbor and breakwater installation equipments are mainly NOx (203.7 tons), CO
(40.7 tons), TSP (12.5 tons), VOC (11.6 tons) and SOx (0.02 ton) for 3 construction years. These
pollutants will disperse quickly at construction sites and do not cause any significant impact on the
air environment.

Amount of exhaust gases from offshore pipeline installation process are small and mainly from
laying barge. This emission may cause some temporary impacts on coastal activities. However,
since due to the natural dispersion on the sea condition, the impact level in offshore pipeline
installation/construction is expected to be a minor.

3. Noise

Project activities

As mentioned in this report, quantity of construction equipments used for marine harbour and breakwater is about 58
including cranes, heavy equipments, transport trucks, etc.

The piling of large numbers of steel and concrete piles by pile hammers and the activities of
excavators, vibro-rollers, vibro-tampers, concrete mixer, and welding machines will generate noise and
vibration during the construction period.

Transportation of material, sands, cement, stones for construction or rehabilitation of road access,
construction of breakwater, jetty and harbor will involve heavy machinery that will impact the population
living near the project area but also the transportation routes.

Potential Impacts

Operation of above machines will cause noise and vibration at harbor area, especially the pile driver.
Excessive noise will cause nuisance, interfere with hearing/ conversation, cause fatigue, increase heart
rate and reduce sleep quality. The direct piling of steel and concrete piles to the seabed will disturb to
local people in the vicinity.



Excessive noise will affect on hearing and nervous system. Noise generated from construction
equipments in radius of 15 m [18] is estimated as follows:

- Bulldozer: 93dB
- Diesel compressor: 80dB
- 1.5-ton pile driver: 75dB
- Concrete mixer: 75dB

If distance from the hearer to the machine increases/decreases twice times, noise level will
increase/decrease 6 dB. Moreover, at spacious area, the noise will increase due to reflex sound from
vicinity works. Effect levels of noise are presented in Table 3.15.

Table 3.15 Effect levels of noise

Noise Effect
45dB on night and 60dB on day Not affected
70 80dB Tired
95 110dB Harmful
120 140dB Potentially causing injury
Source: [18]

Among harbor and breakwater construction equipments, the noise of pile driver lasts longest and is the
most disturbance to local community. That driving concreted piles directly into seabed not only make
noise but also strong vibration at harbor area. Affected area will be defined in radius of 200m around
harbor location. According to [19], the noise from construction activities will cause negative impacts on
the workers if:
Continuous noise (more than 1 hour) is 10dB higher than allowable standard for area and time in
day.
Sudden noise is 15dB higher than allowable standard for area and time in day within less than 1
minute compared with impact threshold.

So, the noise generated from harbor and breakwater construction equipments and varying in range of
75 93 dB will cause direct effect on health of labour force working for the Project and local community
in radius of 200m, especially at night. The impact level of noise is assessed as moderate during
construction phase.

For activities of offshore pipeline and SPM installation, construction machines and engines, operations
of welding, ship engine and crane will make noise and disturb the atmosphere on the ship installing
crude oil pipeline and SPM. Total noise of these equipments in a defined space onboard will directly
affect on workers, cause nervous and tired.

3.2.1.2.2 Surface water

The construction of marine facilities including harbor, breakwater, crude pipelines and the dredging
activities will have significant impacts on the environment and social aspects. The presence of this oil
and gas production and transport facilities on the coast in a relative non-industrial area may be source
of important impacts.



Installation of SPM and crude pipelines

Project activities

Single point mooring (SPM) construction activities include setting up a pipeline end manifold (PLEM)
system on the seabed below the SPM, inter-connecting hoses and two 48" sub-sea crude pipelines
connecting PLEM with the crude oil tank farm.

Potential impacts

The installation of the PLEM system and anchor buoy leg mooring on the seabed will also cause
moderate local disturbance of the sediments as well as obliteration of small areas where the PLEM
system and leg mooring sit on the seabed. The presence of the PLEM and leg mooring will result in
sediment disturbance and redistribution around the facilities. These impacts are expected to reduce
significantly after installation of SPM and pipelines are completed.

During subsea pipeline construction activities, the barge is moored using eight anchors. Each anchor
cable typically consists of wire rope over one kilometer long carried on eight single drum winches. The
pipeline needs to be protected against mechanical damage and for stability reasons. Therefore, the
pipeline shall be buried within a pre-excavated trench. This will ensure that the pipeline will not become
exposed due to erosion, be stable in the surf zone and be protected from fishing vessel or tourist boats.

Two 48" sub-sea crude pipelines run parallel for 33.5km from SPM to landfall point with the interval of
43m. For safety purpose, onshore and coastal pipeline will be buried at least 1m underground.
Supposing that trenching and pipeline installation process will disturb the interval between 2 pipelines
(43m) and their moving toward two sides (25m) and on each 1 km, laying barge must anchor 2 times
with 8 anchors/time and each anchor will create a 3 m
2
hole on the surface of the seabed. Therefore,
total seabed area affected directly by pipeline installation is estimated as about 2,279,608 m
2
.

As above-mentioned, the seabed topography of the project area is relatively flat and its gradually
sloping toward to offshore in which there are some little rough areas. The seabed sediment is mainly
sandy clay. Therefore anchoring of laying barge, pipeline trenching and burring activities will cause
strong disturbance to the seabed and organic matters, make temporary un-stability of bottom
sedimentation loading, and increase considerably of the suspended solid and pollutants within some
kilometers from construction site by sloughing seabed sediment along the pipeline route. Especially for
the shallow water which is considered to be higher sensitive coastline than the offshore. The impact
level is considered as major in the nearshore and moderate in the offshore during construction period.

It is important to note that fishing activities are taken place in Nghi Son bay. The SPM area and pipeline
route beyond the Eastern of Hon Me Island should be an exclusion zone for fishing activities. However,
illegally used explosives in the fishery may form hazards to the pipelines and SPM. Also, mooring
activities of local fishermen may be high potential risk for the SPM. Therefore, the interactions between
fishing and protection activities of marine facilities can be raised due to the need for fishermen to
understand and avoid pipelines in terms of damage liability. Because the potential for gear to become
damaged or miss harped when crossing the pipeline as well as the potential for heavy fishing gears to
damage the weight coat of the pipeline.



Harbor construction

Project activities

It is assumed that about 1,400 piles will be piled.

Harbor construction will be carried out from the shore, progressing seaward to the various berths in
order to take advantage of land bases access and support. Based on the scale of the harbor, a large
quantity of steel and reinforced concrete piles (1,400 piles) will be piled into the seabed to the required
depth on the parent stone (25 to 35.5m). All piles are locked together to prevent soil erosion behind the
harbor and suffered jetties. Concrete piles are installed by temporary bracing system just after finishing
the piling work in order to fix the piles and hold up concrete casing system. Estimation of seabed area
directly affected by piling in front of the harbor is about 41,060 m
2
.

Potential impacts

Impact caused by sand deposition at harbor area

In order to assess deposition at harbor and access channel areas, NSRP LLC has used sedimentation model of the
marine consultant, Royal Haskoning [20], based on reference to mass of deposited silt, change of depth and silt
depositing velocity at access channel area of Nghi Son cement port in the period 2000 2008. Mean water depths of
the approach channel to the cement port show that:

2000: 13 m
2006: 11 m
2008: 10 m

According to these figures, the annual siltation rate varies between 0.3 and 0.5 m/year. With an estimated area of the
cement port approach channel of 1 Mm2, the annual siltation volume would vary between 0.3 and 0.5 Mm3. According
to above data, following estimates of dredging quantities related to the Nghi Son Port (south of the peninsula) is as
follows:

2002: 2,0 million m
3

2006: 0,6 million m
3

2008: 2,0 million m
3
(including a deepening of the approach channel to allow for 30,000 DWT
vessels)

According to these figures 600,000 m
3
of sediment has accumulated in four years in this approach channel, thus on
average 150,000 m
3
per year. With an estimated area of 300,000 m
2
, the annual siltation rate amounts to 0.5 m per
year.

If stable factor is 2.05 and annual volume of deposit is about 100,000 m3/year, estimated volume of
deposit at access channel of NSRP will be about 205,000 m
3
/year (Table 3.16).



Table 3.16 Quantity and deposition rate at NSRP access channel

Run
ID
Sedimentation of cement
port approach channel
[m
3
/yr]
Sedimentation of NSRP
approach channel and
harbour basin [m
3
/yr]
Ratio of NSRP and
cement port approach
channel sedimentation
[%]
1 48,000 99,000 206%
2 69,000 141,000 204%
3 50,000 100,000 200%
4 50,000 97,000 195%
5 68,000 138,000 203%
Source: NSRP-LLC, June 2010

The simulation modeling of deposition at harbour and access channel is carried out with the expansion basin the
harbour in the future. This basin is longer than one in construction phase but the width is the same.

The presence of breakwater will create a barrier that waves cannot pass and current velocity will decrease significantly.
As the result of this, deposition at harbour basin is nearly equal to zero.

Therefore, some conclusions regarding the sedimentation and erosion pattern can be made (Figure 3.1) as follows:

- The majority of the sandy infill of the NSRP approach channel takes place in the shoreward half of it.
- The maximum siltation rate in the approach channel is about 0.2 m/yr, occurring in the bend.
- The siltation of the harbour basin is limited to the southern part at a rate of 0.1m/yr.
- After one year, the ratio of sandy siltation of the NSRP and cement port approach channels is more or less
independent of the parameters settings, viz. varying between 194 and 206%.
- During the year, however, this ratio varies considerably.
- Given a fixed ratio of 205% and an observed annual infill of the cement port approach channel of 100,000
m
3
/yr, the annual sandy siltation of the NSRP approach channel amounts to 205,000 m
3
.
- A scour hole develops over a relatively large area (approximately 11 km2) due to contraction of the current
around the tip of the breakwater. The depth of the scour hole remains restricted to a few decimeters only.

Figure 3.1 Sedimentation (red) and erosion (blue) pattern after one year morphological simulation time


Impacts caused by clay deposition at dredging area
Besides sand/silt deposition, annual deposition of fine particulates is about 0.2 m/year.

A distinction is made between the initial operational phase and a future extension phase. The main difference between
the two is the area of the harbour basin. The harbour basin at the start of operation has an area of approximately 0.7
million m
2
whereas in the future extension phase it will have an approximate area of 1.7 million m
2
(Table 3.17).

Table 3.17 Volume of the annual infill with fines

Phases
Area of the
harbor basin
[million m
2
]
Area
approach
channel
[million m
2
]
Area
subject to
fine infill
[million m
2
]
Siltation
rate
[m/year]
Annual
siltation
volume
[m
3
/year]
Initial operational phase 0.7 1.2 1.3 0.2 260,000
Future extension 1.7 1.2 2.3 0.2 460,000
Source: [20]
With a further extension in the form of the construction of a breakwater south of the NSRP approach channel extending
towards the cement port approach channel the infill with fines will be reduced but will not become zero. Tidal filling of the
port basin will bring considerable amounts of fine suspended material into the harbour basin which will partly settle
around slack water.

It is therefore advised to account in that phase of the project for an infill with fine sediment similar to the infill in the initial
operational phase (140,000 m
3
/yr harbour basin only). Note that this volumetric infill is spread over a much larger area
than in the initial operational phase thus resulting in a smaller siltation rate of about 0.1 m.

The infill of the NSRP dredged areas with fine sediment in the initial operation phase is estimated at 260,000 m
3
/year. In
a future extension phase the harbour basin is enlarged thereby increasing the annual infill with fines to 460,000 m
3
.
These volumetric infill volumes are based on a siltation rate of 0.2 m/year.

In summary, activities of pile driving, harbor construction, harbor and access channel dredging will take
away sea bed sediment layer and make a strong disturbance to water environment at harbor area.
According to research and assessment of sand/silt deposition, it shows that activities of harbor
construction and dredging will make changes of deposition at harbor area and access channel. The
impact level is assessed as major and short-term.

Impacts of breakwater construction
Project activities

Two breakwaters will be built at NSRP harbor, low-crested breakwater and harbor breakwater. The
function of the harbor breakwater is to reduce the downtime for small vessels under operational
conditions. The low-crested breakwater is to create a settlements basin before the water intake
structure and to prevent sediments to enter the intake structure.

The construction of the harbor breakwater will be carried out at the north of the harbor and will have a
total length of 1,800 m. The low crested breakwater for the intake structure will be constructed likewise
the northern breakwater. The seabed levels range approximately from CD -5.5m to CD +1.0m at the
foreshore. The upper elevation of the breakwater structure is +9m height and construction will comprise


of a rock core with a protective rock or concrete layer. The total volume of materials used for
construction of the breakwater is 300,000 m
3
.

Breakwater construction is required soil excavation for toe stability down to -5.5m under the seabed
with area of 110 m in width and 1,800 m in length. Total seabed area affected by breakwater
construction is about 198,000 m
2
.

Potential impacts

Impact of breakwater on current regime
In order to assess impact of breakwater of the harbor on current regime, NSRP LLC has used FINEL2D model to
calculate and simulate current regime at harbor area and its vicinity. This model runs based on wave equations and
average depth of Tokin Gulf and specifically calculates for shallow water area at Nghi Son Gulf (Figure 3.2).

This model is very suitable for modeling current at estuaries, sea and coastal areas. Besides, FINEL2D model also
calculates sediment loading and predict movement of sand, silt or combined model and changes of sea/river bed.

Figure 3.2 FINEL2D model for Tokin Gulf

The computational grid consists of nearly 70,000 elements varying in grid size from 5 km to 500 m.
Model set-up standards are referred from Svasek standard values as follows:

Mesh size: 5 km
2
to 100m
2

Uniform Chezy friction factor: 90 m/s
Eddy viscosity: *Not used *
Density of sea water: 1,030 kg/m
3

Gravitational acceleration: 9,81 m/s
2

Corriolis effect: not applied
Wind force: not applied

Calculations are modeled for a tidal period from spring tide (Figure 3.3) to neap tide (Figure 3.4).


Figure 3.3 Current at spring tide NSRP harbor area

H. A1-1 Current on spring tide - 6 hours before high water H. A1-2 Current on spring tide - 3 hours before high water
H. A1-3 Current on spring tide - high water H. A1-4 Current on spring tide - 03hours after high water


Spring tide
Spring tide - 6 hours before high water (H.A1-1 Figure 3.3): The tide is generally moving in a north-
south direction. There is evidence that the approach channel is causing some refraction to the
currents, but this is not a strong effect.

Inside the harbour the currents are very weak, with a large almost stagnant area stretching from the
root of the main breakwater to the roundhead. South of the quayside there is a slow moving
anticlockwise eddy.

North of the main breakwater, the breakwater gives rise to another slowly moving anticlockwise
circulation, which due to the geometry of the main breakwater. At the intake channel the current
vectors show that the movement of water is into the intake with a velocity of approximately 0.1m/s.

Across the sea area the velocity of the tidal currents ranges from 0.03m/s to 0.3m/s.

Spring tide 3 hours before high water (H.A1-2 Figure 3.3): current speed is about 0.0 0.2m/s. At this
stage in the tide cycle the tide is at or around slack water. The currents across the area have
generally lessened, although there is localized acceleration of flow mid-point and roundhead of the
main breakwater.

The anticlockwise circulation to the south of the harbour is weakening as is the water circulation to
the north of the main breakwater. Water circulation in the harbour is very slow and the current
vectors show no clear directionality.

At high water (H.A1-3 Figure 3.3): the direction of the currents has changed from north to south indicating that
the tide has switched from flood to ebb flow. Within the harbour, just off the roundhead there is a noticeable
clockwise eddy moving at approximately 0.15m/s.

To the north of the main breakwater the currents follow the coastline moving at between 0.1m/s to
0.12m/s. The breakwater alignment causes an acceleration of the currents along its seaward face
with velocities reaching 0.36m/s at the roundhead.

The currents across the area are generally between 0.0m/s and 0.33m/s, with some currents in the south east
corner reaching 0.42m/s. These do not affect the harbour or operation of the intake.

Spring tide 03 hours after high water (H.A1-4 Figure 3.3): modeling strong movement toward the South of
tidal currents. The ebb tide is fully developed, and along the northern face of the main breakwater the currents are
accelerated to between 0.24m/s and 0.33m/s.

The slowly moving/stagnant water in the harbour reduced in size as a result of an increase in the
size of the clockwise circulation to the south of the breakwater roundhead. Across the area the tidal
currents range between 0.0m/s to 0.42m/s.

Spring tide 06 hours after high water: To the north of the main breakwater and intake channel, the
tidal flow has slowed considerably, with only a weak southerly movement along the coastline
illustrated.

Directly in the lee of the main breakwater there is growing area of very slowly moving water with no
clear directionality indicated. The size of the clockwise circulation has also increased. It is also
noted that the harbour approach channel does not appear to affect the currents as they move
across it. Tidal currents do not exceed 0.24m/s.


Figure 3.4 Current at neap tide NSRP harbor area
H. A1-5 Current on neap tide 06 hours before high water H. A1-6 Current on neap tide 03 hours before high water
H. A1-7 Current on neap tide High water H. A1-8 Current on neap tide 03 hours after high water


Neap tide:
Neap tide 06 hours before high water (H.A1-5 Figure 3.4): The tide is moving in a northerly direction
and so is on a rising or flood tide. In contrast to the anticlockwise circulations, the Northern eddy is
located away from the coastline and above the outer half of the main breakwater arm. The eddy
moves faster on its seaward (northward moving) edge, where velocities are approaching 0.1m/s,
whereas the inner (southward moving) edge moves at approximately 0.05m/s. This is because the
breakwater exerts a greater influence over the tidal currents on the neap tide than on the spring tide.

The southerly anticlockwise circulation is of a similar size and form to that of the spring tide,
although the velocities are approximately 50% of those noticed on the spring tide.

In the harbour the current vectors are indistinct, but the general perception is one of a very slowly
moving anticlockwise rotation of the water body. The approach channel to the harbour does not
appear to attract flow, hence the flood tide continues uninterrupted in a northerly direction.

Movement into the intake channel is at a rate of 0.05m/s to 0.1m/s, which is at the lower end of the
design range 0.1m/s 0.5m/s.

Neap tide 3 hours before high water (H.A1-6 Figure 3.4): There is a small anticlockwise circulation
approximately 2 km east south-east of the breakwater round head.

The flow patterns inside the harbour are not well defined and appear to meander north, which is
consistent with this stage of the tide being at or around slack water.

To the north of the main breakwater the anticlockwise rotation has widened. The velocities are
generally less than 0.05m/s. Flow through the intake channel is around 0.06m/s to 0.08m/s.

To the north and south of the main breakwater there are large areas of very slow water movement
that are hugging the coastline. This condition does not last for long as the tidal currents pick up
again towards high water. The lower current velocities on the neap tide are as a result of the
smaller neap tidal range.

Neap tide - At high water (H.A1-7 Figure 3.4): Across the area the current velocities are between
0.01m/s and 0.5m/s. north of the main breakwater the anticlockwise circulation is weakening and
the direction of the current vectors indicates that the tide is changing from flood to ebb.

South of the breakwater the current vectors show a clear change from food to ebb. Velocities in the
intake channel are 0.05m/s to 0.08m/s.
Neap tide 03 hours after high water: The ebb flow is now well established. Where the currents flow
around the breakwater roundhead, the currents are accelerated to approximately 0.12m/s.

In the lee of the breakwater the flow is weak and towards the root of the breakwater, before being
directed south by the alignment of the quay wall (H.A1-8 Figure 3.4): velocities in the intake channel
are 0.06m/s to 0.1m/s.

Neap tide 06 hours after high water: The tidal flow is still strongly moving south, with localized
acceleration of currents around the breakwater roundhead. A small, weak, clockwise eddy is also
present immediately off the roundhead.



From the South of the harbor, there is a large slowly moving body of water hugging the coastline with
velocities no higher than 0.01m/s.

In addition, dredging activity for beakwater construction will generate a significant quantity of dredged materials. Quantity
of dredged materials and diging activities will be determined in detailed basis design stage.

Dredged materials and spoil materials will be discharged at designated site approved by the authority or at dumping site
of capital dredged materials in preconstruction phase.

In general, constructing breakwater will destroy structure of the shoreline and change wave and current regime at
harbor area. Impact level is assessed as moderate and long-term.

Impact of hydrotest water

Project activities

After the pipeline and the installations of all tie-ins completed, the crude pipeline will be cleaned and
hydrotested. Following activities carried out during testing and pre-commissioning:

Flooding and gausing for metering internal pipeline diameter;
Pipeline cleaning and hydrotesting;
Dewatering
Drying and cleaning pipeline.

Sea water will be used for crude pipeline cleaning and hydrotesting. Estimation of cleaning and
hydrotesting volume is about 187,500 m
3
. It is planned to use some chemicals for sea water treatment
with the adequate measured amounts related to the volume of water being pumped by dosing pumps.
The flow rates and volumes pumped for each chemical are measured and recorded.

Oxygen scavenger, to remove dissolved oxygen from the seawater so as to prevent corrosion
inside the pipeline;
Biocide, to prevent the growth of organisms and bacteria;
Corrosion inhibitor(s), to prevent or reduce attack by chlorides and other potentially harmful
components of seawater related to the metallurgy of the pipe (or its lining);
Dye, colored and normally fluorescent under ultra-violet light (such as "fluorescence") which
aids divers in tracing the location of any leaks.

Potential impacts

It assumed that cleaning and hydrotesting water will be treated and then discharged at SPM location
about 33.5 km offshore. The water depth of this site is about -27 m and bottom sediment is sandy clay.
The use oxygen scavenger (as ammonium bisulphate) for cleaning and hydrotesting process will cause
local oxygen depletion phenomenon around discharge site due to the oxidization of sulfite ion (SO
3
2-
)
into sulfate ion (SO
4
-2
). The generation of sulfate ion does not affect to marine environment because it
is available in high content in sea water. During testing, part of biocide and inhibitor will remain inside
the pipe thus amount of chemical discharged following the hydrotest water will be reduced.


The discharge of cleaned and hydrotested water containing seawater and small amount of chemicals
into the marine environment may increase pH value, suspended solid in the water column and disturb
of water surface layer. Considering high dilution ability, the environmental impact is assessed as minor
in the vicinity of the discharge point.

In practice, hydrotest water will be discharged into moving sea water environment and strong mixing
under continuously wave and tidal effects. That means at pipeline outlet, hydrotest water will be
immediately diluted with seawater. So, the hydrotest discharge will cause temporary and local oxygen
reduction at the area surrounding discharge site and the effect level is assessed as small and locally
during the discharge period (about one week).

Domestic Wastes fromBarges/Vessels
Project activities

During crude pipeline construction, it assumes that at least one constructional barge with full equipment
for installing pipeline will be used, one barge for supplying pipes and two supply boats for supporting
fuels, foods and others for pipeline construction barge.

Potential impacts

The solid wastes generated from the offshore pipeline construction activities and redundant materials
such as metals, welding rods, paper, plastic boxes, oily cloths, etc., with small quantity will be collected
separately and transported by support vessels to the shore for further treatment. Moreover, the manual
procedures during installation and transportation will be done in accordance with technical standards
proposed in order to minimize the potential material strewing. The impact related to solid waste coming
from construction activities will be negligible.

All domestic waste from kitchen (such as food, fruit peel) will be collected and discharged directly to the
sea. Indecomposable waste will be collected in separate drums and transported by support vessel to
the shore and disposed at the stipulated disposal site. The significance of domestic waste considering
the technical standards on water quality is assessed as negligible.

The sanitary generation on board is estimated as small and will be collected to septic tank system for
treatment before discharging to the sea. The impact level is assessed as minor to sea water.

3.2.1.2.3 Land and Terrestrial Ecology

Flora

Project activities

Site clearance for onshore harbor will be done on about 36 ha coastal protective forest.

Potential impacts

Predominant tree in the coastal protective forest is Casuarina equisetifolia in the age of 5-10 year old
with diameters in the range of 10-25 cm. The density of the coastal protective forest is about
50trees/100m
2
. The number of Casuarina equisetifolia is estimated at approximately 150,000 trees. The


impact level is considered as moderate since this forest was used for protection and is also a source of
material for Hai Yen Commune.

The construction crude pipeline will be carried out at the distance of 6.7 km far from Hon Me Island and
will not cause any impact to onshore flora on Hon Me island.

Fauna

Project activities

Using 36 ha coastal protective forest may be the source of impacts on coastal fauna ecosystem.

Potential impacts

Based on assessment report of existing biodiversity of terrestrial fauna project area [8], there is
absence of rare and endangered species living in the project area (coastal protective forest). The
species composition of the vertebrate fauna in the project area is relatively poor and most of species
found are common ones (birds, etc.). The construction of the harbor will affect 36 ha of potential fauna
habitat of common species living in coastal forest and sandy beach. These species might migrate to
coastal forest stretching along the coast. Therefore, the significance of this impact is assessed as
minor.

The taking materials from borrow pits and quarry sites for the construction of breakwater, jetty and
harbor platform may affect potential habitat used by rare or endangered species. These species will
move away from the excavation sites to search new habitats nearby. The significance of this impact is
assessed as moderate and permanent.

3.2.1.2.4 Marine ecosystem

Project activities

Activities that will have impacts on the marine environment are the construction of crude pipeline (33.5
km), SPM, breakwater and harbor.

Potential impacts

The trenching, installation and backfilling activities for 33.5km pipelines and SPM will cause disturbance
of 2,279,608 m
2
of seabed area. These activities will scratch the seabed surface and rouse available
pollutants in bottom sediment, change the distribution of the sediment grain size causing the local
disturbance to benthic community.

The soil excavation for breakwater toe stability will take out all seabeds benthic in the area of
198,000m
2
and pilling activities for harbor construction will cause strong seabed disturbance in the area
of 41,060 m
2
. These activities will burry and smother the benthic organisms, even though destroy
bivalve species living in harbor area.


3.2.2 OPERATION PHASE

3.2.2.1 Operation of Onshore Facilities (the Plant and support facilities)


1. Emission from stacks and flares

Project activities

Air quality is affected by various sources of emission such as stacks, incinerator, flare, tanks, etc.

Potential impacts

The emissions from these sources are considered by conducting dispersion modeling for prediction of
impacts on air quality. The following are the sources considered for dispersion modeling:

Process heaters (CDU, HMU, RFCC, GOHDS, KHDS, N&AC, SRU);
RFCC Boilers;
Boiler emission gas treatment system;
Gas turbines;
ETP Incinerator;
Flares.

To satisfy national standards and IFC requirements for stationary point source, FEED consultant has
considered optimum stack height, flare height and emission rate of each pollutant as follows:

Optimum stack height was determined using GIIP, HMIP D1 Method and BREEZE AIR
SCREEN3 developed by the United States Environmental Protection Agency (USEPA). The
stack height selected is in compliance with the ambient air quality standard in isolation from
other emission sources in the area.

Air emissions from refinery stacks (Process heaters) are in compliance with Vietnamese
standards and IFC EHS Guidelines for "Petroleum Refining". Air emissions from the stacks
located in the Aromatic section of Naphtha and Aromatic Complex are compliance with
Vietnamese standards and IFC EHS Guidelines for "Large Volume Petroleum Based Organic
Chemicals Manufacturing". Boiler and GT stack emissions are in compliance with to
Vietnamese standards and IFC EHS Guidelines for "Thermal Power Plants".

In order to meet projects point source emission limits, all gases from RFCC boiler and emission gas
treatment system are routed to DeSOx and DeNOx system before discharged into the atmosphere. Low
and ultra-low NOx burners are recommended for heaters of process units, utilities and waste
incinerator. Therefore, input data of emission rate used for dispersion model are accounted for applying
mitigation measures.
At in start-up and shut-down periods, emission from stack does not meet the project standard,
however it happens in short time so the effect on ambient air quality is negligible. Therefore, in start-up
and shut-down case is not put into consideration of air emission modeling.


To assess air quality, the Atmospheric Dispersion Modeling System (ADMS) from CERC (Cambridge
Environmental Research Consultants) with the United Kingdom Meteorological Office, National Power
plc and University of Surrey is used. The first version of ADMS was released in 1993 and the current
model is ADMS version 4.

Principle of ADMS may be summarized as follows:

The air dispersion modeling was carried out using ADMS 4, a new generation Gaussian plume air
dispersion model capable of modeling dispersion in the atmosphere of passive, buoyant or slightly
dense, continuous or finite duration releases from single or multiple sources.

ADMS uses the atmospheric boundary layer and the reciprocal of the Monin-Obukhov length to
characterise the atmosphere. The boundary layer is defined by measurable physical parameters
obtained from meteorological data, which allows for a more realistic representation of the changing
characteristics of dispersion with height and time. This results in a more soundly based prediction
of the concentration of pollutants than previous generation dispersion models.

The model takes into account emissions from the source, location of nearby buildings, topography
and meteorological data for the local area. The model will then provide a predicted concentration of
the substance of interest at a specified point. The process is re-iterated for a large number of
meteorological conditions and at a large number of receptor points to build up a prediction of the
long-term mean and short-term peak concentrations over the area of interest.

ADMS 4 is a new version of Gauss atmospheric dispersion model with two parameters used to
define characteristic of atmospheric boundary layer as follows:

- The boundary layer depth, and
- The Monin-Obukhov length.

Rather than in terms of the single parameter Pasquill-Gifford class.

Dispersion under convective meteorological conditions uses a skewed Gaussian concentration
distribution (shown by validation studies to be a better representation than a symmetrical Gaussian
expression). The ADMS4 is used in many countries in European, Asia, Australia, North America and
the Middle East.

For the NSRP, ADMS is computed for the maximum ground level concentrations of NOx, SO
2
, CO and
PM10. These emission results will be added with baseline data of each pollutant before assessing the
compliance to project standards.

To verify the compliance with the ambient air quality standards from stacks and flares, a full-scale air
dispersion modeling is studied as follows:

Emission from 19 stacks and combined case for all stacks are considered in the operation
case; and 1 HC flare in normal operation;
Emission from HC flare and HC purge flare in the emergency case;



The emission from each source and combined sources are modeled and the concentrations from
combined sources at specific distances are added together to topography and contour maps to obtain
the overall ground level concentrations.
The ADMS Model requires hourly meteorological data for calculating the ground level concentration of
pollutants. The hourly meteorological input data within three years (2005-2007) from Tinh Gia
Meteorological Station is used for the modeling. This is a National Meteorological Station located at
19.5
o
N; 105.8
o
E which is about 15.65km far from the Nghi Son Refinery Plant toward to North and
Northeast direction.

The complex elevation and impact of all mountains terrain in the radius of 7.5 km for air dispersion is
considered and applied by the Grid dimension 500m x500m as Figure 3.5. All topography data for
computed area with the 7.5km radius are made as input file of the ADMS model.

Figure 3-5 Terrain condition of NSRP in ADMS model

Summary of emission input and output results for point sources system are given in Table 3.18 and
Table 3.19.


Table 3.18 Input data of ADMS model in normal operation case For NSRP
Stack # 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20
Stack
name
SRU
Common
stack
FGD
Stacks for
Boiler
RFCC Co
Boiler
Gas
Turbine
HRSG-1
Gas Turbine
HRSG-2
HMU CDU Stack
ETP
Incinerator
RHDS-1 RHDS-2
NAC-1
Common
NAC-2 NAC-3 NAC-4 NAC-5 NAC-6 KHDS-1 KHDS-2 GOHDS
HC Purge
Flare
DESCRIPTION OF
POINT SOURCE
Ref. # X 601 DeNox 50 H-101
110 A-
001
110 A-002 010-SK-001 190-A-215 20-H-101 20-H-201 42-H-101-4 49H101 44H-201A/B 47H101 46H-101 40-H-101 H-001 H-002 H-01
East 580180 580082 580459
580045 580045
580358
580604
580930 580052 580110 581035 580770 581058 580784 580819 580967 580544 580523 580554 581729 Coordinates of point
source as VN2000
North 2141315 2140371 2140822
2140610 2140625
2140782
2141323
2141050 2141142 2141154 2140748 2140822 2140630 2140775 2140580 2140846 2141116 2141112 2141222 2140824
Fuel used Title/type Fuel gas HSFO HSFO
Diesel/L
PG
Diesel/LPG Fuel Gas Fuel Oil Fuel Gas Fuel Gas Fuel Gas Fuel Gas Fuel Gas Fuel Gas Fuel Gas Fuel Gas Fuel Gas Fuel Gas Fuel Gas Fuel Gas
Sulphur in % 0,0058 0,909 0,909 0,04 0,04 0,0058 0,24 0,0058 0,0058 0,0058 0,0058 0,0058 0,0058 0,0058 0,0058 0,0058 0,0058 0,0058 0,0058
Quantity in Kg/Sec
0,635 18,145 1,061
0,533+0,
08 0,533+0,08 5,689 1,881 0,07 0,417 0,417 3,219 1,059 4,073 0,419 0,587 0,354 0,118 0,15 0,338
HHV Mj/Kg
44,12 39,571 39,571
43 /
46,28 43 / 46,28 44,12 43,053 44,12 44,12 44,12 44,12 44,12 44,12 44,12 44,12 44,12 44,12 44,12 44,12
Fuel
Details
Heat input in MW 28 718 42 155 155 251 81 3 18,4 18,4 142 45,6 179,7 18,5 25,9 15,6 5,2 6,6 14,9
Dry standard
flow
NM3/sec
32,57 262,00 133,00 193,00 193,00 69,18 22,28 0,83 5,07 5,07 39,14 12,54 49,53 5,10 7,14 4,30 1,43 1,82 4,11
Actual flow m
3
/sec 73,00 329,00 176,00 339,00 339,00 125,00 38,00 2,00 11,00 11,00 74,00 22,00 90,00 10,00 13,00 8,00 3,00 4,00 9,00
Exit Vel. m/sec 7 15 7 15 15 7 7 7 7 7 7 7 7 7 7 7 7 7 7 12,7
Temp. in 'K 571 343 338 460 460 423 423 530 500 500 440 440 423 440 440 440 500 500 500 322
Flue gas
Details
Oxygen in % 3 3 3 15 15 3 3 3 3 3 3 3 3 3 3 3 3 3 3
Diameter in m. 3,6 5,3 5,7 5,4 5,4 4,8 2,6 0,6 1,4 1,4 3,7 2,0 4,0 1,3 1,5 1,2 0,7 0,9 1,3 0,58
Stack
details
Recomm.
Height
in m.
50,00 100,00 100,00 65,00 65,00 45,00 50,00 30,00 50,00 50,00 50,00 50,00 50,00 30,00 30,00 30,00 30,00 30,00 30,00 180
mg/NM3 50,00 50,00 50,00 50,00 50,00 50,00 50,00 50,00 50,00 50,00 20,00 20,00 20,00 20,00 20,00 20,00 50,00 50,00 50,00
PM
gm/ sec 1,629 13,100 6,650 9,650 9,650 3,459 1,114 0,041 0,254 0,254 0,783 0,251 0,991 0,102 0,143 0,086 0,072 0,091 0,205 1,00
mg/NM3 120,00 65,00 400,00 20,00 20,00 20,00 400,00 20,00 20,00 20,00 20,00 20,00 20,00 20,00 20,00 20,00 20,00 20,00 20,00
SO2
gm/ sec 3,908 17,030 53,200 3,860 3,860 1,384 8,910 0,017 0,101 0,101 0,783 0,251 0,991 0,102 0,143 0,086 0,029 0,036 0,082 0
mg/NM3 167,00 50,00 300,00 152,00 152,00 60,00 450,00 167,00 167,00 167,00 124,00 171,00 171,00 124,00 124,00 171,00 167,00 167,00 167,00
NOx
gm/ sec 5,439 13,100 40 29,336 29,336 4,151 10,024 0,138 0,847 0,847 4,853 2,144 8,469 0,632 0,885 0,735 0,239 0,304 0,686 3,00
mg/NM3 150,00 150,00 800,00 150,00 150,00 150,00 150,00 150,00 150,00 150,00 150,00 150,00 150,00 150,00 150,00 150,00 150,00 150,00 150,00
Emission
Data
Co
gm/ sec 4,886 39,300 106,400 28,950 28,950 10,377 3,341 0,124 0,761 0,761 5,871 1,881 7,430 0,765 1,071 0,645 0,215 0,273 0,616 14,000
Emissions Control Measures
[1] Low
Nox
Burners

[2] Stack
height =
50m
[1] FGD
System

[2]DeNOx
System

[3] Stack
height =
100m
[1] FGD and
DeNOx

[2] Stack
height =
100m
[1] Low Nox Burners

[2] Stack height = 65m
[1] Ultra -
Low Nox
Burners

[2] Stack
height =
45m
[1] Low
Nox
Burners

[2] Stack
height =
50m
[1] Low
Nox
Burners

[2] Stack
height =
30m
[1] Low
Nox
Burners

[2] Stack
height =
50m
[1] Low
Nox
Burners

[2] Stack
height =
50m
[1] Low
Nox
Burners

[2] Stack
height =
50m
[1] Low
Nox
Burners

[2] Stack
height =
50m
[1] Low
Nox
Burners

[2] Stack
height =
50m
[1] Low
Nox
Burners

[2] Stack
height =
30m
[1] Low
Nox
Burners

[2] Stack
height =
30m
[1] Low
Nox
Burners

[2] Stack
height =
30m
[1] Low
Nox
Burners

[2] Stack
height =
30m
[1] Low
Nox
Burners

[2] Stack
height =
30m
[1] Low
Nox
Burners

[2] Stack
height =
30m
[1] Stack
height =
180m
Source: Document provided by FWL, June 2010.


The stack height stated above are based on emission levels estimated and modeled during the FEED
stage of the Refinery Project. These values shall be re-assessed with the emission information from the
Vendor and the revised height shall ensure the compliance to the Vietnamese and IFC Guideline
requirements. Final stacks height will be determined using updated input data during EPC phase.

Table 3.19 Emission input data of flare system in emergency case

Location
(VN2000)
Emission rate
Source
name
Northing Easting
Case
Total
flue
gas
flow
rate
(Nm3/s)
Velocity
(m/s)
Exit
Temp.
(oK)
Heat
Releases
(BTU/hr)
SO2
g/s
NOx
g/s
CO
g/s
PM10
g/s
GPF OF ISLAND
1
1,064 79 575 44,865,206,523 - 344 1,871 47
HC
FLARE
2140834 581727
GPF OF ISLAND
2
3,774 178 377 47,324,135,403 - 368 2,005 104
GPF OF ISLAND
1
231 154 520 5,780,168,548 20,624 50 269 12
GPF OF ISLAND
2
397 154 377 4,497,203,156 4,196 39 210 12
HC
PURGE
FLARE
2140824 581729
MAX H2S
Release
56.84 38 333 566,919,714 18,225 4.85 26.41 2.78
Source: FWL, November 2009

Impacts frompoint source emission in normal operation

Emission results of NOx, SO
2
, CO and PM from individual stack and combined all stacks in the case of
normal operation are given in Table 3-20.



Table 3-20 Maximum ground level concentrations of air pollutants from point sources in normal operation

Emission Results of SO
2

1 hour
Maximum Ground Level
24 hour
Annual
Point source Source ID
Conc.
(g/m
3
)
Conc.+
baseline
(g/m
3
)
Distance
(m)
Conc.
(g/m
3
)
Conc.+
baseline
(g/m
3
)
Distance
(m)
Conc.
(g/m
3
)
Conc.+
baseline
(g/m
3
)
Distance
(m)
SRU S1 8.66 15.66 697 2.32 9.32 664 0.17 7.17 640
FGD S2 16.88 23.88 1,945 3.60 10.6 2,640 0.26 7.26 2,110
RFCC S3 86.32 93.32 1,309 23.95 30.95 1,512 1.73 8.73 1,010
GT1 S4 2.07 9.07 915 0.38 7.38 1,592 0.03 7.03 4,089
GT2 S5 2.08 9.08 930 0.38 7.38 1,605 0.03 7.03 3,709
HMU S6 3.33 10.33 515 1.04 8.04 482 0.06 7.06 512
CDU S7 55.14 62.14 590 10.81 17.81 389 1.16 8.16 465
ETP S8 0.83 7.83 446 0.17 7.17 446 0.02 7.02 563
RHDS1 S9 1.22 8.22 545 0.35 7.35 328 0.03 7.03 473
RHDS2 S10 1.25 8.25 499 0.31 7.31 272 0.02 7.02 479
NAC-1 42-H-101 S11 2.35 9.35 683 0.66 7.66 654 0.05 7.05 686
NAC-2 49-H-101 S12 2.03 9.03 217 0.45 7.45 331 0.05 7.05 391
NAC-3 44-H-201 S13 2.28 9.28 116 0.84 7.84 541 0.06 7.06 573
NAC-4 47-H-101 S14 2.09 9.09 458 0.62 7.62 387 0.06 7.06 477
NAC-5 46-H-101 S15 2.37 9.37 434 0.82 7.82 352 0.07 7.07 453
NAC-6 40-H-101 S16 2.15 9.15 387 0.60 7.6 387 0.06 7.06 535
KHDS1 S17 1.20 8.2 460 0.27 7.27 460 0.03 7.03 467
KHDS2 S18 1.16 8.16 477 0.25 7.25 477 0.03 7.03 320
GOHDS S19 1.45 8.45 404 0.37 7.37 404 0.04 7.04 392
HC Flare F1 0.00 7 - 0.00 7 - 0.00 7 -
Combined source (*) All 118.41 125.41 7,264 34.21 41.21 1648 2.76 9.76 908
Project Standard 350 125 50
Notes: - Baseline of SO
2
: 7g/m
3

- (*) combined source is the highest concentration in year of 2005, 2006 and 2007.


Emission Results of NOx
1 hour
24 hour
Annual
Conc.
(g/m
3
)
Conc.+
baseline
(g/m
3
)
Distance
(m)
Conc.
(g/m
3
)
Conc.+
baseline
(g/m
3
)
Distance
(m)
Conc.
(g/m
3
)
Conc.+
baseline
(g/m
3
)
Distance
(m)
SRU S1 12.05 21.05 697 3.22 12.22 664 0.23 9.23 641
FGD S2 12.99 21.99 1,945 2.77 11.77 2,641 0.20 9.2 2,111
RFCC S3 64.90 73.9 1,309 18.01 27.01 1,512 1.30 10.3 1,010
GT1 S4 15.72 24.72 915 2.89 11.89 1,592 0.21 9.21 4,088
GT2 S5 15.83 24.83 930 2.88 11.88 1,605 0.20 9.2 3,709
HMU S6 10.00 19 515 3.12 12.12 482 0.18 9.18 512
CDU S7 62.03 71.03 590 12.16 21.16 389 1.30 10.3 465
ETP S8 6.77 15.77 446 1.38 10.38 266 0.62 9.62 563
RHDS1 S9 10.26 19.26 545 2.90 11.9 328 0.21 9.21 473
RHDS2 S10 10.48 19.48 499 2.58 11.58 272 0.21 9.21 479
NAC-1 42-H-101 S11 14.56 23.56 683 4.11 13.11 654 0.32 9.32 686
NAC-2 49-H-101 S12 17.34 26.34 217 3.88 12.88 331 0.40 9.4 391
NAC-3 44-H-201 S13 24.16 33.16 116 7.14 16.14 541 0.50 9.5 573
NAC-4 47-H-101 S14 12.92 21.92 458 3.82 12.82 387 0.40 9.4 474
NAC-5 46-H-101 S15 14.69 23.69 434 5.06 14.06 352 0.46 9.46 453
NAC-6 40-H-101 S16 18.35 27.35 387 5.12 14.12 387 0.52 9.52 535
KHDS1 S17 9.89 18.89 460 2.23 11.23 460 0.25 9.25 467
KHDS2 S18 9.80 18.8 477 2.13 11.13 477 0.23 9.23 320
GOHDS S19 12.17 21.17 404 3.11 12.11 404 0.37 9.37 392
HC Flare F1 17.39 26.39 1541 4.79 13.79 398 0.25 9.25 1,691
Combined source (*) All 175.11 184.11 7264 41.32 50.32 1415 4.55 13.55 931
Project Standard 200 100 40
Notes: - Baseline of NO
2
: 9g/m
3

- (*) combined source is the highest concentration in year of 2005, 2006 and 2007



Emission Results of CO
1 hour
8 hour
24 hour
Conc.
(g/m
3
)
Conc.+
baseline
(g/m
3
)
Distance
(m)
Conc.
(g/m
3
)
Conc.+
baseline
(g/m
3
)
Distance
(m)
Conc.
(g/m
3
)
Conc.+
baseline
(g/m
3
)
Distance
(m)
SRU S1 10.82 3,010.82 697 7.91 3,007.91 635 2.89 3,002.89 664
FGD S2 38.96 3,038.96 1,945 22.84 3,022.84 2,619 8.30 3,008.3 2,641
RFCC S3 172.63 3,172.63 1,309 120.72 3,120.72 789 47.90 3,047.90 1,512
GT1 S4 15.52 3,015.52 915 8.16 3,008.16 2,902 2.85 3,002.85 1,592
GT2 S5 15.62 3,015.62 930 8.17 3,008.17 2,917 2.84 3,002.84 1,605
HMU S6 25.00 3,025 515 18.21 3,018.21 84 7.80 3,007.8 423
CDU S7 20.68 3,020.68 590 13.05 3,013.05 138 4.05 3,004.05 389
ETP S8 6.08 3,006.08 446 4.27 3,004.27 423 1.24 3,001.24 266
RHDS1 S9 9.22 3,009.22 545 6.75 3,006.75 376 2.61 3,002.61 328
RHDS2 S10 9.41 3,009.41 499 6.99 3,006.99 343 2.32 3,002.32 272
NAC-1 42-H-101 S11 17.62 3,017.62 683 13.34 3,013.34 98 4.97 3,004.97 654
NAC-2 49-H-101 S12 15.22 3,015.22 217 11.48 3,011.48 217 3.40 3,003.4 331
NAC-3 44-H-201 S13 21.20 3,021.2 116 15.34 3,015.34 169 6.27 3,006.27 541
NAC-4 47-H-101 S14 15.64 3,015.64 458 11.75 3,011.75 458 4.62 3,004.62 387
NAC-5 46-H-101 S15 17.78 3,017.78 434 15.25 3,015.25 434 6.12 3,006.12 352
NAC-6 40-H-101 S16 16.10 3,016.1 387 11.75 3,011.75 387 4.49 3,004.49 387
KHDS1 S17 8.90 3,008.9 460 6.25 3,006.25 460 2.01 3,002.01 460
KHDS2 S18 8.80 3,008.8 477 6.14 3,006.14 217 1.91 3,001.91 477
GOHDS S19 10.93 3,010.93 404 8.62 3,008.62 222 2.79 3,002.79 404
HC Flare F1 81.15 3,081.15 1,541 52.85 3,052.85 1,147 22.35 3,022.35 398
Combined source (*) All 295.28 3,295.28 7,264 182.81 3,182.81 1,102 73.68 3,073.68 1,648
Project Standard 30,000 10,000 5,000
Notes: - Baseline of CO: 3,000 g/m
3




Emission Results of PM10
24 hour
Annual
Conc.
(g/m
3
)
Conc.+ baseline
(g/m
3
)
Distance
(m)
Conc.
(g/m
3
)
Conc.+ baseline
(g/m
3
)
Distance
(m)
SRU S1 0.97 23.97 664 0.07 23.07 641
FGD S2 2.77 25.77 2,641 0.20 23.2 2,111
RFCC S3 2.99 25.99 1,512 0.22 23.22 1,010
GT1 S4 0.95 23.95 1,592 0.07 23.07 4,088
GT2 S5 0.95 23.95 1,605 0.07 23.07 3,709
HMU S6 2.60 25.6 482 0.15 23.15 512
CDU S7 1.35 24.35 389 0.14 23.14 465
ETP S8 0.41 23.41 266 0.05 23.05 563
RHDS1 S9 0.87 23.87 328 0.06 23.06 473
RHDS2 S10 0.77 23.77 272 0.06 23.06 479
NAC-1 42-H-101 S11 0.66 23.66 654 0.05 23.05 686
NAC-2 49-H-101 S12 0.45 23.45 331 0.05 23.05 391
NAC-3 44-H-201 S13 0.84 23.84 541 0.06 23.06 573
NAC-4 47-H-101 S14 0.62 23.62 387 0.06 23.06 474
NAC-5 46-H-101 S15 0.82 23.82 352 0.07 23.07 453
NAC-6 40-H-101 S16 0.60 23.6 387 0.06 23.06 535
KHDS1 S17 0.67 23.67 460 0.08 23.08 467
KHDS2 S18 0.64 23.64 467 0.07 23.07 320
GOHDS S19 0.93 23.93 404 0.11 23.11 392
HC Purge Flare F1 1.60 24.60 398 0.08 23.08 1,691
Combined source (*) All 9.68 32.68 1,898 0.98 23.98 2,334
Project Standard 150 50
Notes: - Baseline of PM10: 23 g/m
3



The results in Table 3.20 show that:

The higher concentrations from the above modeling calculation are combined with the baseline
concentrations of these pollutants (7g/m
3
of SOx; 9g/m
3
of NOx; 3,000g/m
3
of CO and 23
g/m
3
of PM) to estimate the maximum ground level concentration of the pollutants.

With having FGD and Desulphurisation system, the SOx emission results in 01-hour, 24-hour
and annual of individual stacks are much lower than project standards (PS) of 350 g/m
3
in 1-
hour, 125 g/m
3
in 24-hour and 50 g/m
3
in annual from 4 to 45 times. In combined case, SOx
emission is 3 - 5 times lower than project standards in both 1-hour, 24-hour and annual. The
maximum ground concentration of Sox is in the range of 908 - 7,264 m (Appendix IV, Figure
IV.1 to Figure IV.6).

In normal operation, there is no emission of SO
2
through HC purge flare.

With having Low and ultra-low NOx burners, NOx emission results in 1-hour, 24-hour and
annual of all individual stacks are lower than Project Standards from 2.7 to 12.7 times. NOx
generated for 1-hour, 24-hour and year of HC flare are lower than Project Standards from 4.3
to 7.6 times.

In combined case of 19 stacks and 1 HC Flare, NOx emission results in 1-hour, 24-hour and
annual are lower than Project standards from 1.1 to 3 times. Maximum ground concentration of
NOx in 1-hour (184.11ug/m
3
) is not much lower than allowable limit (200ug/m
3
). Maximum
ground concentration point of NOx locates in range of 931 7,264m from the stack base
(Appendix IV, Figure IV.7 to IV.12)

CO emission results in 1-hour, 8-hour and 24-hour of individual stacks are lower than Project
Standard from 1.6 to 10 times. CO emission in combined all stacks and HC purge flare are well
within project standards and lower than the project standards from 1.6 to 9 times. The
maximum ground concentration of CO is in the range of 1,102 - 7,264m (Appendix IV, Figure
IV.13 to IV.18).

PM10 emission results in 24-hour and annual of individual stacks in normal operation are lower
than Project Standard from 2.2 to 6.4 times. In combined case for all stacks and HC flare, the
maximum ground concentration of PM10 is lower than the project standards from 1.5 t0 4.6
times. The maximum ground contents are in the range of 1,898 - 2,334m (Appendix IV, Figure
IV.19 to IV.22).

In briefly, the maximum ground concentrations of SO
2
, NOx, CO and PM
10
accounted for
individual stack and 1 flare as well as combined case of all stacks and flare are very low and
well within the applicable of National Technical Regulation QCVN 05:2009 and World Bank/IFC
standards. In normal operation, HC purge flare is working for maintaining purpose. Therefore,
there is no emission of SO
2
and emission results of NOx, CO and PM are negligible.

Generally, the maximum ground concentrations from individual stacks SRU, CDU, ETP,
RHDS1, RHDS2, NACs, KHDS1, KHDS2 and GOHDS are within plant boundary in the range
of 84 - 680 m from the stack basement. The maximum ground concentrations of FGD, RFCC,
GT1, GT2 stacks and HC purge flare stacks are in the range of 900 to 4,088m in the downwind


direction of the stacks site. The sites having maximum ground concentrations are fell mostly
within the confine of the refinery site of Coc Mountain and some mountain nearby as Chuot
Chu, Tran and Xuoc Mountain which are away from the residential areas. Therefore, impact
level from point sources in the normal operation is assessed as minor to air quality.

The emission concentrations results stated above are based on primary stack height, emission
levels estimated and modeled during the FEED stage of the Project. These values shall be
reassessed with the emission information from the Vendor and the revised height shall ensure
the compliance to the Vietnamese and IFC Guideline requirements.

Impacts frompoint source emission in emergency case

Table 3-21 Maximum ground concentrations of air pollutants
from flares in emergency case

Case
1 hour - SOx
Maximum Ground
Level
(ppm)
1 hour - NOx
Maximum Ground
Level
(ppm)
1 hour - CO
Maximum Ground
Level
(ppm)
HC Purge gas flare GPF island 1 14.28 0.035 0.186
HC flare GPF island 1 0 0.074 0.405
HC Purge gas flare GPF island 2 2.91 0.027 0.145
HC Purge gas flare max H
2
S 29.03 0.008 0.042
ERPG (1,2,3)* 0.3 3 15 1 15 30 200 350 500
Note: ERPG (1,2,3)*: ERPG1, ERPG2, ERPG3

The modeling results from Table 3-21 show that:

In emergency cases, the maximum ground concentrations of 1-hour NOx and 1-hour CO are
much lower than the Emergency Response Planning Guideline 1 (ERPG1) value (Appendix IV,
Figure IV-23 & Figure IV-30). It means that no adverse health effects to individuals.

Under emergency conditions, SOx emission is only occurred at HC Flare. The maximum
ground concentrations of SOx from GPF of island 1 is within the Emergency Response
Planning Guideline 3 (ERPG3) values (15ppm) and maximum ground level concentrations of
SOx from GPF of island 2 is within the ERPG2 (3ppm). But emission results of SOx in the Max
H
2
S case are unaccepted with two times higher than ERPG3 (Appendix IV, Figure IV-31 &
Figure IV-32).

In emergency cases, radiation intensity at sterile radius: 6.31 kw/m
2
(API recommendation). A
minimum sterile radius of at least 60 m shall be required to avoid injury to personnel due to the
possible emission of burning liquid droplets. Radiation intensity at property boundary 3.18
kW/m
2
.
In practice, the maximum flaring time in the case of max H
2
S is happened in very short time.
But health effects might occur to project employees and communities nearby.



Impacts of VOC fromtank system

Fugitive emissions of volatile organic compounds (VOC) from the Complex have been estimated from
hydrocarbon loss. The estimated quantities of fugitive emissions are based on storage volumes from
tank system.
VOC emissions from tank farms are controlled due to inherent design features, e.g., installing floating
roof tanks, vapor recovery systems, nitrogen blanketing, etc. Considering all the above measures, the
facility wide VOC emissions are very small. Total VOC loss is approximately 141 tons/year (see Table
3.7), compared with 9,6 million tons of crude oil/year. The ratio of VOC tons and crude oil million tons is
14.69 compared with the Benchmark of IFC Guideline on Petroleum refinery from 120 to 300. The VOC
emission will be well within acceptable limits. And therefore, the impacts level is considered as minor.

Impacts of green house gas (GHG)

The Complex is designed to use energy efficiently by using energy saving technology such as energy
optimum method in CDU, energy recovery in preliminary heaters to reuse heat from emission gas,
saving energy between units and using energy saving devices.

A heat exchange network is designed to optimize recovered heat, reduce operation cost and increase
operational ability of process units. Input temperature of the CDU heater is at maximum value due to
taking advantage of heat from stacks and it achieves target of heat sources efficient using.

The operation of process units will generate a significant amount of CO
2
into the environment that will
contribute green house effects.

Total volume of CO
2
generated from the Complex operation is about 5.9 million tons/year. However, in
comparison with statistical data of green house gas in the United States (1990-2007), total CO
2

generated from burning of fossil fuels in 2007 was about 5.7x10
12
tons, so CO
2
emission level of the
Project is insignificant in comparison of the ones of the global.

2. Noise and vibration

Project activities

Process equipment such as compressors, pumps, heaters, blowers, flare, boilers, turbines, etc. will be
major noise sources during the operation phase. The truck loading will also be a generation of noise at
plant site as well as along their route to the Complex.

Potential impacts

As mentioned in Section 1, project noise level standards are based on the most stringent limits from
local Vietnamese and IFC guidelines. So the noise generated by the equipment shall not exceed the
noise limits for any of the conditions of operation, including turndown, start-up, shut-down and
commissioning of the equipment. The equipment must comply with the most restrictive of the specified
work area or sound power level criteria. Sound pressure level limits apply at 1m from the process
equipment surface and at 3m from vent or on nearest platform (Table 3.22).



Table 3.22 Noise Level in the Operation Phase

Noise Source Work Area Code Noise Limit dB(A)
Centrifugal compressors G1 85
Centrifugal and axial R1 95
Fired heaters and boilers G1 85
Gas turbines G1 85
Air cooled exchangers G1 85
Cooling tower G1 85
Pumps, gears, G2 82
Blowers, agitators/mixers G1 85
Equipment fitted with acoustic enclosure R2 110
Operating vents G1 85
Emergency vents R2 110
Valves and piping components G2 82
Other noise sources located outdoors G2 82
Noise sources located inside process G3 79
Flare G1 85
Source: FWL, October 2009

Based on Table 3.22, the noise generated equipments at the Refinery will be kept at value of 85 dB(A).
Equipment fitted with Acoustic Enclosure and Emergency Vents will be at 110 dB(A). The flare will be at
85 dB(A) during emergency operations, but start up noise will be less than 85 dB(A). Therefore, the
noise generating from machines, equipment and process units will be limited inside the plant boundary
and cause directly to project workers only. The impact level is considered as minor and long term.

NSRP LLC is defined the design Noise level standard for construction to meet relevant standards
during operation. Detail assessment will be carried out during detail design phase. However, during
detail engineering, EPC Contractor will carry out the assessment to make sure that noise levels meet
Project Standard.

3.2.2.1.2 Water Quality

Impact of continuous water intake

Project activities

The Refinery and Petrochemical Complex will require continuous supply of large volume of sea water
(Max 42.8 m
3
/s) for cooling purpose.

Potential impact

The automatic filters between 2 and 3 times per day will generate high suspended materials in the
released water. In the case of discharging water from the backwash cycle into the outfall sump, it will
cause the exceeding (>30mg/l as PS) of suspended solid content at the outfall site.

The maintenance dredging of the intake channel may affect to coastal water quality within the four week
plant maintenance cycle. However, this activity is small in comparison with the dredging activities for
harbor area and the impact level is minor and limited locally in intake channel only.


Optimumeffluent outfall and thermal impacts

Project activities

Project operation will need to discharge a maximum condition at 154,000m
3
/h to Nghi Son coastal
water including cooling water, treated industrial and sanitary effluent, FGD effluent and RO effluent with
and maximum temperature of 40
o
C.

Potential impacts

In order to estimate the thermal impact caused by effluent discharge, NSRP LLC has used the CORMIX
model to predict dilution and thermal dispersion abilities of cooling water [11]. Summary of principle of
the CORMIX model is as follows:

CORMIX is a USEPA-supported mixing zone model and decision support system for
environmental impact assessment of regulatory mixing zones resulting from continuous point
source discharges. The system emphasizes the role of boundary interaction to predict steady-
state mixing behavior and plume geometry.

The CORMIX methodology contains systems to model single-port, multiport diffuser discharges
and surface discharge sources. Effluents considered may be conservative, non-conservative,
heated, brine discharges or contain suspended sediments.

CORMIX can predict mixing behavior from diverse discharge types ranging from power plant
cooling waters, desalinization facility or drilling rig brines, municipal wastewater, or thermal
atmospheric plumes. CORMIX can also be applied across a broad range of ambient conditions
ranging from estuaries, deep oceans, swift shallow rivers, to density stratified reservoirs and
lakes.

Some special hydrodynamic features of CORMIX include:

Makes complete near-field and far-field plume trajectory, shape, concentration, and dilution
predictions and visualizations.
Includes plume boundary interactions, including dynamic near-field attachments.
Models conservative, non-conservative, and heated pollutant types.
Alerts user when plume encounters regulatory mixing zone constraints, including Toxic Dilution
Zone CMC and CCC values.
Application to steady, unsteady ambient currents/tides, or stagnant ambient conditions.

In order to select optimum effluent outfall location and assess thermal effects to Nghi Son Bay
seawater, US Environment Protection Agencys CORMIX model has been used by NSRP LLC to
determine near-field initial dilution and the number and spacing of the discharge ports. It also describes
the modeling of the thermal plume in the far-field zone to determine the outfall length required to meet
the environmental and process criteria. Input data for thermal modeling are given in Table 3.23.



Table 3.23 Input data for thermal modeling

Condition Value
Rate of discharge to receiving waters
154,000 m
3
/h or 42.78 m
3
/s
Distance of riser ports above seabed
1.0 m
Orientation of discharge ports
Horizontal
Temperature of discharge water
40
o
C
Salinity of discharge water
31 ppt
Density of discharge water
1,015.02 kg/m
3

Ambient current velocity
0.02 m/s
Wind speed at sea surface
2.0 m/s
Ambient water temperature
31
o
C
Ambient water salinity
31 ppt
Ambient water density
1,018.39 kg/m
3

Source: FEED Document No. 9T7151/R082 provided by FWL, October 2009

Near-field modeling is used to obtain an estimate of the dilution of the effluent within the near-field
mixing zone. The discharge layout combinations are considered for 9 cases (L1 L9), number of pipes,
number of risers, number of ports, velocity of nozzle at different water depth in the range of 4 - 6m
(Table 3.24). The results of COMIX modeling are given in Table 3.25.

Table 3.24 Discharge layout combinations

Discharge
layout
Number of
pipes
Number of
risers
Number of
port (nozzles)
on each riser
Interval
between
risers
Velocity at
nozzle (m/s)
L1 5 25 2 10 2.42
L2 5 25 2 20 2.42
L3 5 12 4 10 2.52
L4 5 12 4 20 2.52
L5 5 12 4 40 2.52
L6 3 25 2 10 4.04
L7 3 25 2 20 4.04
L8 3 12 4 40 4.20
L9 4 12 4 20 3.15
Source: FEED document No. 9T7151/R082 provided by FWL, October 2009



Table 3.25 Results of CORMIX Model Runs

Test Cases
Initial
local
Dilution
Initial local
temperature
excess (C)
Dilution at
100m
distance
Temperature
excess at
100m distance (C)
Overlapped
temperature
excess at 100m
distance (C)
L 1 + AC 1 6.3 1.43 6.35 1.42 6.10
L 1 + AC 4 9.5 0.95 9.53 0.94 4.72
L 2 + AC 2 13.0 0.69 13.06 0.69 3.44
L 2 + AC 3 14.3 0.63 14.40 0.63 3.15
L 2 + AC 4 15.6 0.58 15.70 0.57 2.85
L 3 + AC 1 3.7 2.46 3.72 2.45 12.25
L 4 + AC 1 5.9 1.52 5.95 1.51 6.55
L 5 + AC 2 12.2 0.74 12.26 0.73 3.65
L 5 + AC 3 13.4 0.67 13.49 0.67 3.35
L 6 + AC 1 4.4 2.04 4.40 2.04 6.12
L 6 + AC 4 6.6 1.36 6.62 1.36 4.07
L 7 + AC 2 9.0 1.00 9.02 1.00 2.99
L 7 + AC 3 9.9 0.91 9.92 0.91 2.73
L 7 + AC 4 10.8 0.84 10.83 0.83 2.50
L 8 + AC 2 8.4 1.07 8.43 1.07 3.20
L 8 + AC 3 9.3 0.97 9.32 0.97 2.90
L 9 + AC 5 15.2 0.59 15.36 0.59 2.35
Source: FEED document provided by FW in October, 2009
Notes: AC1 to AC4: water depth at 4m; 5; 5.5m and 6m
L1 to L9: discharge layout with different pipe number, riser number, port number and different velocity at nozzle

The results show that at water depth of 4m none of the 8 discharge layouts comply with the World Bank
guidelines due to Overlapped temperature excess at 100m distance (C) is higher than 3
o
C. At a
water depth of 5m, only layout 7 complies with the guideline. At water depth of 5.5m, both layouts 7 and
8 comply with the guideline and at a water depth of 6m Layout 9 complies with the guideline.

The initial local dilution of layout 7, 8 and 9 at water depth more than 5m is rather good. Dilution of
these layouts is in the range of 9.92 10.83 times at the distance of 100m. Therefore the following
recommendations may be made:

The outfall should have a minimum of 3 diffuser pipes
Each diffuser section should be 440m long with12 risers or 480m long for 25 risers
The diffuser sections should be located in a minimum water depth of 5.5m

In order to assess the thermal plume caused by effluent discharge, CORMIX model for far-field effect is
undertaken for satisfying two following criteria:
1. The temperature of the water at the edge of a scientifically defined mixing zone shall not
exceed 3
o
C above the temperature of the ambient water; and
2. The temperature of the water at the intake shall be no more than 0.5
o
C above the ambient
water temperature for 100% of the time.



The first criteria is required in order that the benthic flora and fauna are not adversely affected, whilst
the second is a process requirement dictated by NSRP Consultant (Foster Wheeler Energy Ltd.) and
effectively means that there shall be no recirculation of the warmer discharge water into the intake.

The model is run for five outfall length scenarios (Table 3.26).

Table 3.26 Modeling Scenarios

VN-2000 Coordinates
Model
scenario
Outfall length
(km)
Easting Northing
Discharge
flow (m
3
/s)
Temperature
of discharge
(
o
C)
1 2.5 584778.958 2142821.628 42.8 40
2 3 585271.010 2142860.380 42.8 40
3 3 585271.010 2142860.380 42.8 37
4 4.5 586766.958 2143248.525 42.8 40
5 6 588608.056 2143631.635 42.8 40

From the discussion of the plume movement across a spring and neap tide, it is possible to see a
pattern emerging. On spring tides the currents disperse the excess heat more effectively. On neap
tides, due to the limited tidal range and therefore lower current velocities, there is a gradual build-up of
excess heat in the sea water. This is then flushed, to a degree, by the spring tides that follow on.

Figure 3.7 shows a graph of the time series of excess temperature against time. The scenarios
examined are clearly identified. For the 2.5km (pink line) and 3km (green line) outfalls the pattern of
peaks and troughs is similar. The peaks represent the neap tides where the excess temperatures are
highest. The troughs represent the spring tides when the currents are fastest and the advection and
dispersion is at its most effective. By inspection it can be seen that the peaks i.e. the excess
temperatures on neap tides, are increasing over the first three cycles. This process also applies to the
spring tides i.e. the troughs. This suggests that whilst the receiving waters are efficient at dispersing
heat from the discharged cooling water for a short while after discharging starts, there is a gradual
build-up of residual heat in the water.

The same pattern is seen when the time series of the 4.5km (blue line) and 6km (orange line) outfalls
are plotted. For the 6km option the thermal plume model has been run for approximately 2 months
model time. The increase in residual heat in the water is more gradual, but after 2 months the curve is
beginning to move down again. The more gradual shape of the excess temperature time series curve
for the 6km outfall is believed to be as a result its location and distance offshore. Thus, whilst the depth
of water and the distance play a part the degree of flushing inshore induced by a flood spring tide is
much weaker. A similar pattern is shown for the 4.5km outfall option; although it is evident that whilst
the operational criteria is met for much of the time, excess temperature does eventually exceed the
0.5
o
C limit.



Figure 3.7 Time series plot of excess temperature at intake channel

On the basis of the two months simulated data for the 6km outfall (without eddy diffusivity) a continuous
distribution function (cdf) has been plotted. This shows that even against the relaxed process criteria,
the excess temperature is at or below 0.1
o
C for approximately 33% of the time.

Including eddy diffusivity for the 2.5km and 3km outfalls would not induce sufficient mixing to be of
benefit. It is also unlikely that it would lower the residual build-up sufficiently to make a 4.5km outfall
viable in terms of the process criteria. At 6km the model results show that the process criteria can be
met, but that it is possible that a residual build-up of excess heat could occur. The recommendation
therefore is that the discharge outfall should be further optimised to between 4.5km and 6km.

In summary, some conclusions of the modeled results are as follows:

An outfall discharging 2.5km offshore does not meet either the environmental criteria or the
process criteria, as the temperature of the receiving waters at the intake channel is in excess of
the 3
o
C limit imposed by the World Bank IFC guidelines.
An outfall discharging 3km and 4.5km offshore meets the World Bank IFC guidelines, but does
not meet the process requirements.
An outfall discharging 6km offshore meets both World Bank IFC guidelines and operational
criteria. Notwithstanding this an examination of the temperature excess time series at the
intake suggests that there is the potential for a long term build-up of residual heat in the sea
water.
Therefore, on the basis of the model simulations, the 6km outfall is adopted for NSRP.

For the outfall discharging 6km offshore, the thermal dispersion result are summarized in Figure 3.8
and Figure 3.9 including:


At 6 hours before the spring tide high water, the plume traveling north but with the tail of the
plume spread out to encompass the coral beds and sensitive fishing grounds at the Hon Me
Archipelago. The temperature around the archipelago is between 0.2
o
C and 0.4
o
C above the
ambient temperature (E1Figure 3.8).
At 3 hours before high water the plume has moved further north and has almost cleared the
Hon Me Archipelago (E3Figure 3.8). At high water the tide is turning and the plume is shown
moving south again on an ebb tide. The outer edge of the plume is skirting the edges of the
archipelago, but the temperature excess is well within the allowable range of 3
o
C. The
temperature at the intake channel is at or below the operational requirement.
At 3 hours after high water (E4Figure 3.8) the ebb flow is well developed. The western edge of
the plume is shown approaching the main breakwater roundhead but is not affected by it. At 6
hours after high water the plume passes between the Hon Me Archipelago and Nghi Son Island
(E5Figure 3.8). It does not reach the main breakwater.
On the flood cycle of the neap tide, the plume extends north and makes contact with the
coastline and also extends south to surround the Hon Me Archipelago at the coastline. At the
site of the discharge the excess temperatures rise as a result of the much lower tidal currents
and weaker advection and dispersion. Where the plume makes contact with the coastline and
the archipelago the temperature is well within the environmental requirements (E6-Figure 3.9).
As the tide moves towards the neap high water the shape of the plume changes but the excess
temperatures around the islands and at the coastline to the north does not increase (E6 to E10
Figure 3.9). Indeed through out the neap tidal cycle there is little movement at the edges of
the plume; the main activity being near to the discharge where excess temperatures above 8
o
C
are predicted. The different sea water temperature at the area around Hon me island is in the
range of 0.6 0.8
o
C only, within allowable environmental limit of the IFC.

Briefly, the modeling of the thermal plume is undertaken for a worst case condition of 154,000 m
3
/h of
cooling water discharge, 40
o
C of cooling water temperature at the outfall and 31
o
C of receiving
temperature (sea water). The worst case conditions have been considered and conditions on site would
likely be better than predicted. In practice, the discharged cooling water volume is less than the
modeled value (68.3%) and it will be mixed together with 18.7% of other treated effluents before routing
to the outfall.

By above the serious consideration of dynamic current, outfall layout, outfall length scenarios and
thermal plume effect, the thermal impact level of effluent discharge is considered as minor and long
term.



Figure 3.8 Thermal Plume Plots Outfall 6km, Discharge 40C Spring Tide


Figure 3.9 Thermal plume plots outfall 6km, discharge 40C Neap tide



Impacts of continuous effluent discharge

Project activities

When project comes into operation phase, following effluents need to be discharged to the sea:

Treated ETP effluent for industrial and sanitary wastewater
Treated FGD effluent for desulphurisation (De-SOx)
Cooling sea water
RO reject effluent

In the operation phase, drainage systems are built to collect separately different effluents generating
from site-wide and process units including clean process water (CPW), clean storm water (CSW),
accidentally oil contaminated wastewater (AOC), continually oil contaminated wastewater (COC) and
sanitary wastewater. In addition, specific wastewater streams are collected in dedicated systems before
passing to the ETP, including:

Dedicated collection of Benzene Contaminated Water (BCW) in a closed system to prevent
atmospheric emission of benzene.
Dedicated collection of Spent Caustic Effluent for flow balancing and prevention of atmospheric
H
2
S emissions.
Potential impact

All above-mentioned wastewater drainage systems other than the CSW system and PCW system are
routed to appropriate effluent treatment Plant (ETP). Clean storm water (CSW) shall be assumed to
comply with the necessary standard for direct discharge to the sea via the North Trapezoidal Channel.
The reject and regeneration streams from Demineralised water plant, after pH neutralisation, are
considered clean for direct discharge via the seawater return line.

Quality of the treated water will strictly comply with the Project standards presented in Introduction
Section - Item 0.2.2.3. These project standards are considered based on Vietnamese standards and
IFC EHS guideline values for petroleum refining facilities, large scale organic chemical manufacturing
and petroleum based polymer manufacturing. The project standards are more stringent than the
national technical regulation on industrial wastewater (QCVN 24:2009/BTNMT) for discharge of treated
effluents to coastal water.

After treated, effluent is routed to treat waste water storage basin. At here, waste water will be tested
before blended with sea water to discharge. If not meeting the Standards, effluent will be routed back to
storage tank and treated at oily waste water treatment system. The storage tank may contain maximum
volume of fire water during 6 hours or waste water for 24 hours. As estimation, volume of this storage
tank is 17,220m
3
.

In the ETP, industrial and sanitary effluents will be pre-treated separately before routing to integrated
treatment tank for further treatment (detail ETP will be mentioned in mitigation measures).

In order to assess how effluents impact to receiving resource - seawater, the summary of water intake
and outlet are presented in Table 3.27.


Table 3.27 Maximum water intake and outlet of NSRP in the operation phase

Parameters
Peak ETP
outlet
Peak
RO/IX
Reject/
Regent #
FGD
outlet
(max.
assumed)
Cooling
water
Sea
water
intake
Water
outlet
Minimum
dilution at
outfall
zone
(assuming
8 times)
Costal
water
Standard
QCVN10:
2008/BTNMT
Amount (m
3
/h) 600 564 23,000 105,200 128,200 129,364 -
Temp (deg.C) 40
Ambient
<40 40 40 30 40.00 31 30
pH 6 to 9 6 to 9 6 6.74 6.74 6.5 to 8.5
BOD 25 0 1 0.735 0.735 - -
COD 72 0 10 1.917 1.917 3.67 2 4
TSS 30 30 30 30 10.5 30.00 13 50
Cadmium 0.009 0 0.005 0.005 0.005 0.005 0.005 0.005
Hydrocarbon 4.5 0.5 0.0139 0.0139 0.0139 0.04 0.016 0.1
Chromium
(total) 0.5 0.25 0.25 0.02 0.02 0.06 0.0249 -
Chromium (III) - 0 - - - - 0.1
Chromium (VI) 0.05 0 0.05 - - - 0.05
Copper 0.5 0.5 0.005 0.005 0.005 0.01 0.0055 0.5
Zinc 2 2 0.0136 0.0136 0.0136 0.03 0.0156 1
Iron 3 2.5 0.188 0.188 0.188 0.211 0.1906 0.1
Cyanide Total
(Free) 0.1 0.1 - - - - -
Cyanide CN- 0.09 0.09 0.007 0.007 0.007 0.008 0.0071 0.005
Lead 0.1 0.05 0.0043 0.0043 0.0043 0.00 0.0044 0.02
Nickel 0.45 0.45 - - - - -
Mercury 0.009 0.005 0.001 0.001 0.001 0.00 0.0010 0.002
Vanadium 1 1 1 1 1 1.00 1.0000 -
Phenol 0.2 0 0.001 0.001 0.00100 0.002 0.0011 0.001
Benzene 0.05 0 0.001 0.001 0.001 0.00 0.0010 -
Benzopyrene 0.05 0 - - - - -
Vinyl chloride 0.05 0 - - - - -
Di chloroethane 1 0 - - - - -
AOH 0.3 0 - - - - -
Sulphide (S
2-
) 0.45 0.25 - - - - 0.01
T-Nitrogen 10 10 0.62 0.62 0.62 0.704 0.6294 -
NH4 9 9 0.038 0.038 0.038 0.119 0.0470 0.5
T-Phosphorus 2 2 0.0143 0.0143 0.0143 0.032 0.0163 -
Coliform 4,500 4,500 55 55 55 95 59 1000
DO - - 5.84 5.84 5.84 - >=4
F
-
9 9 - - - - 1.5
As 0.09 0.09 - - - - 0.04
Mn 0.9 0.9 - - - - 0.1
AOH: Adsorbable Organic Halogens
calculate "< values" as minimum analysis limit values
Offshore (K number points) DO data is applied for Sea water DO
'# Assuming peak flow - Normal flow shall be 313 m
3
/hr.


The results in Table 3.27 show that each waste water treatment properties (ETP and FGD) are satisfied
with Industrial waste water discharge limit. The combined discharge mode has much advantage for
both economic and environmental point of view. The most contribution is cooling water (81.32%) while
ETP treated effluent is a minor (0.46%) which is diluted about 215 times before discharging at the
outfall. For FGD treated effluent, its contribution is about 16.78% and be diluted about 5.62 times at the
outfall. Consider COD loading from treated effluent (ETP and FGD) of NSRP (Table 3.28), total loading
is rather small of 273.2 kg/h.

Table 3.28 Estimate COD loading from NSRP in operation phase

Effluent stream
Flow rate
m
3
/h
% Flow
COD level
mg/l
COD loading
kg/h
Maximum treated effluent from ETP 600 0.46 72 43.2
Maximum RO effluent 564 0.44 0 0
Maximum treated effluent from FGD 23,000 16.78 10 230
Cooling water 105,200 81.32 1.92 201,6
Total Treated effluent discharge 129,364 100 2
474.8

According to the document of FEED, most effluents of the Complex are treated at ETP and meet
industrial waste water standard of the Project. Effluent from demineralization unit and desulphurization
system are separately treated and meet industrial waste standard of the Project. Cooling water is
considered as clean effluent and without treatment. Domestic wastewater at harbour area is treated to
meet project standards for domestic wastewater. Then, these effluents are blended and discharged into
the sea. This blending action make effluents from the Refinery have the same properties with receiving
water source (the sea water).

As mentioned in the report, effluent is discharged via several smaller diffuser pipes branching off the
main discharge line above 1m on the seabed that point towards the surface. The diffuser pipes
enhance the dispersion plume and outfall location is 6km far from the shoreline. Based on CORMIX
Model Runs [Ref.11] effluent will be diluted at least 8 times at the 100m distance outfall zone. The
calculation shows that almost pollutants (COD, TSS, Cd, Zn, Hg, NH
4
+
, As, Coliform, etc.) from treated
effluent meet coastal water standard QCVN 10:2008/BTNMT. Some pollutants as Oil, Iron, Cyanide
and Phenol are slightly higher than the costal water standards (QCVN10:2008). The main reason is that
their baseline concentrations of Nghi Son bay are really higher than the ones in the allowable limits of
QCVN 10:2008/BTNMT. On the other hand, the above estimation is based on maximum discharging of
ETP while normal operation of ETP is 350m
3
/h only. Therefore, the impact level of effluent discharge
will not cause significant impact to coastal sea water quality.

3.2.2.1.3 Groundwater environment

Project activities

During the operation phase, water supplied for the Complex will routed from Nghi Son water supply
plant, so the groundwater will not be affected.

A significant amount of hazardous waste managed, stored and disposed or leaked will cause a potential
risk of groundwater contamination.



Potential impact

All hazardous materials, chemicals and waste materials will be contained in proper vessels /storage
facilities with adequately designed containments to prevent any impact sources or spills on the land and
subsequently to groundwater. Appropriate methods of handling and transportation will be established
for hazardous materials and wastes. There will be no underground storage tanks at the facility and the
material loading and unloading areas will be designed with proper enclosures on paved surfaces. In
addition, the process effluents and sewage will be treated onsite at adequately designed ETP facilities
to meet the regulatory requirements for recycling and disposal standards. Therefore, the potential for
groundwater contamination is insignificant.

The potential causes for groundwater contamination are the disposal of solid and hazardous wastes on
land and accidental spillages of hazardous materials (oils, chemicals, paints, cleaning solvents, etc.).
All solid and hazardous wastes will be properly collected, segregated and stored in appropriate storage
areas. Recyclable wastes such as metal and wood scrap will be sold to scrap buyers, as feasible. Other
non-hazardous wastes will be disposed off to approve landfill sites. Therefore, potential impacts due to
discharge of handling of solid / hazardous wastes will be minimized by implementation of measures as
above.

3.2.2.1.4 Soil environment

The normal operation of NSRP complex will not cause any additional impact to soil environment due to
modern technology and cemented plant surface. However, potential impacts may be created from
hazardous materials, hazardous wastes storage and handling and accidental releases only.

Effect of leakage fromstorage tanks

Project activities

The handling and storage a significant hazardous wastes inside boundary might be a potential risk of
soil contamination. The estimated type and amount of the waste are show in Table 3.9.

Potential impacts

The potential leakage might occur at pipe joints, valves, loading arms, etc. The leakages are usually
small and only limited at working area. In practice, Crude oil and products are stored and handled in
closed systems and involve the use of insulated storage tanks and lagged and trace-heated transfer
lines. Exposure to fuel oil is therefore limited, except on tank filling and during maintenance operations.
In addition, each tank is surrounded by bund system; any crude/product release will be kept inside the
bunds.

Commercial caustic flakes/ beads are received in 25 kg bags by road trucks in the refinery complex.
The bags are unloaded and stored in the Refinery warehouse or in dry enclosed space. Solid caustic
feeding package is provided for automatic handling, opening and unloading the caustic bags into the
concentrated caustic preparation tank. Caustic flakes are safely unloaded into the tank using a solid
caustic feeding package. Therefore, the potential risk of caustic leakage is small and impact level is
assessed as minor to soil environment.



Effect of hazardous wastes storage and handling

Project activities

The handling and storage a significant hazardous wastes inside plant boundary might be a potential risk
of soil contamination. Based on Table 3.9, regular hazardous wastes are oily wastes (426m
3
/year),
sludge from ETP (5,204 tons/year), ash generated from incinerator (2,100 tons /year), spent
replacement materials (1,760 tons /year), spent catalysts (1,110.8 tons in every 4-5 years), spent
absorbents (17.32 tons in every 4 years), spent desorbent (1,116 tons in every 20 years), catalyst
grading materials (49 tons in every 4 years), spent caustic (1,623 m
3
/year), etc. from different process
units.

Potential Impacts

The release/fall out hazardous wastes may pollute not only soil environment, but also ground water.
However, NSRP LLC will establish waste management plan in which hazardous material/waste
disposal may be introduced for easy identification, ensuring responsibilities, right disposal destination
and tracking. So, the significance of these impacts is considered as moderate during the operation
phase.

3.2.2.1.5 Marine ecosystem

Impact by continuous intake water system

Project activities

The Refinery and Petrochemical Complex will require continuous supply of large volume of sea water
(Max 42.8 m
3
/s) for cooling purpose.

Potential impact

Cooling water intake can impact aquatic organisms basically in two ways including:

The first is entrainment, which is taking of small organisms with the cooling water including
plankton, fish eggs and larvae, etc. In practice, intake water is taken from intake channel (in
between breakwater and low crested breakwater) where sea water is already settled down.
Moreover, the phytoplankton community of Nghi Son bay was not diversity and community indices
was classified as bad level, but The zooplankton community was relatively diverse and diversity
indices was relatively high (Table 3.29). However, the intake volume is small in comparison with
Nghi Son bay capacity and the affected organisms are insignificant with the reproductivity of the
open bay as Nghi Son sea.

Table 3.29 Summary plankton and benthos in Nghi Son bay

Parameters Phytoplankton Zooplankton Benthos
Number of species 43 59 156
Density 8.8 x 10
8
cells/m
3
915 ind./m
3
351.7 ind./m
2

Biomass (g/m
2
) - - 9.45
Diversity indices H(s) Bad levels Relatively high Rather good


The second way is impact to aquatic life such as fish, cuttle-fish, shrimp through entrapment-
impingement. This is the blocking of larger entrained organisms that enter the cooling water intake
by some type of physical barrier. According to distribution ground of the Research Institute of
Marine Products in Hai Phong on fishing, shrimp, cuttle-fish grounds, there is only cuttle-fish ground
at nearshore area where cooling water intake channel situated. However, the intake channel is
installed at the seashore with 350m in length, 70m in width and -7.92 in depth. It is designed with
the purpose of taking water slowly and reducing fine particles to the intake system and screens.
This design also prevents aquatic species entering to the system. Moreover, there are two levels of
screens, screen 25mm and screen smaller than 3mm, to prevent rubbish. These screens also have
functions to avoid small fish entering to the system. Therefore, potential impact to aquatic life is low
and the environmental impacts of intake water are considered as minor.

Impact by effluent discharge
Project activities

The Refinery and Petrochemical Complex is required continuous discharging a large volume of
effluents (Mean of 129,364 m
3
/h and Max of 154,000 m
3
/h) in which 105,200m
3
/h is cooling water;
23,000m
3
/h is from treated FGD effluent, 600m
3
/h is treated effluent from ETP and 564 m
3
/h is from RO
unit.

Potential impacts

The effluent discharge including cooling water will impact in different ways. In some respects, mainly in
improving the growth rate, an increase in temperature may even be advantageous. The discharge has
some unfavourable effects because it attracts fish and thus causes indirectly food shortage,
deterioration of the condition.

The primary effects of thermal pollution are direct thermal shock, changes in dissolved oxygen and the
redistribution of organisms in the outfall. Because water can absorb thermal energy with only small
changes in temperature, most aquatic organisms have developed enzyme systems that operate in only
narrow ranges of temperature. These stenothermic organisms can be killed by sudden temperature
changes that are beyond the tolerance limits of their metabolic systems.

Based on thermal dispersion plume (Figure 3.8 and Figure 3.9) at outfall 6km, at the spring tide, the
plume traveling north about 5-6 km and the tail of the plume spread out to encompass the coral beds
and sensitive fishing grounds at the Hon Me Archipelago. The temperature around the archipelago is
between 0.2
o
C and 0.4
o
C above the ambient temperature. That means thermal plume will not cause
significant effect to aquatic habitat and coral reef around Hon Me island.

On the neap tide, the plume extends north and makes contact with the coastline and also extends south
to surround the Hon Me Archipelago. At the site of the discharge the excess temperatures rise as a
result of the much lower tidal currents and weaker advection and dispersion. That means thermal plume
will cause significant effect to aquatic habitat in the range of 300m surrounding the outfall. But the
thermal plume in the coastline and the archipelago varies in range of 0.6 0.8
o
C and is well within the
environmental requirements (3
o
C). Therefore, the impact level is considered as small at the outfall
and minor to coastal aquatic habitat and coral reef around Me island.



3.2.2.2 OPERATION OF THE OFFSITE FACILITIES (HARBOR, BREAKWATER, CRUDE PIPELINE
AND SPM)


1. Emission gas

Project activities

When the project comes into operation phase, the main sources of air quality impacts caused by
marine facilities are from unloading activity of crude oil at the SPM and loading of petroleum products
at the jetties.

For loading process, petroleum products will be transferred to the product tank farm to export via 7
berths and directly loaded to the vessel. Gasoline and Diesel will be dispatched via the ocean berths,
while Jet fuel, fuel oil, benzene, paraxylene and partly Gasoline and Diesel will be dispatched via the
coastal berths. For safety reason, LPG will be loaded in indicated berth.

Potential impacts

The loading of above liquid products will generate significant quantities of hydrocarbon vapour, these
activities will cause long term and significant effects to the environment. However, volatile products like
Gasoline, Benzene and paraxylene generating volatile organic compound (VOC) will be recovered in
common return vapor recovery system. Displaced vapour from ship will be returned to the shore via a
vapour return piggybacked to a loading arm. The recovered liquid will be re-injected into gasoline
product loading line stream of metering package. After completion of loading, the loading arm/manifold
will be purged with nitrogen into the out board section of the loading arm. Any remaining material in the
loading line and manifold will be drained into slop drums. For the LPG, displaced vapour from ship will
be routed back to the mixed LPG spheres. Non-volatile products like Jet fuel and Fuel oil are loaded to
the ships through respective loading arms. These above activities shall control and reduce VOC
released to the environment. Therefore, impact level to air environment is considered as minor during
operation phase.

Due to the nature and frequency of emissions from the jetty vent it is concluded that releases from this
source are insignificant. As such, these emissions will not be included as part of the air dispersion
modeling for offsite facilities.

Loading solid sulphur product has potential risk of dust exposure. Sulphur forming unit and solid
sulphur bulk storage are located at the jetty, therefore dust formation is significantly minimized while
conveying. Impact level is considered as minor.

Offloading of crude oil at SPM will generate a small amount of hydrocarbon. However, since the SPM is
located 33.5 km offshore, hydrocarbon generated will be well dispersed and only minor environmental
impact is anticipated.



2. Noise

Project activities

During operating phase, main sources of noise are from the operation of equipment, truck movement,
shipping activities (engines and whistling) and maintenance dredging.

Potential Impacts

Noise impact generated from harbor and shipping activities are peak noise coming from metal contact
or foghorn. These noise events will be occasional. Therefore, the significance of the noise impact
during the operation is assessed as minor.

3.2.2.2.2 Water environment

Impact of crude offloading at SPM

Project activities

Crude offloading process will be carried out at SPM from tankers 300,000 DWT to the Refinery crude
tank farm. Floating hoses are used to transfer crude from the ship to the SPM and a pipeline end
manifold (PLEM) is sited on the seabed below the SPM for connecting horses to the SPM. The SPM is
tied to the Refinery crude tank farm by a double 48" submarine unloading pipeline.

Upon an incident to the SPM in which it is not operational the transfer of crude oil to the Refinery will be
carried out by ship-to-ship transfer to 30,000 DWT vessels offshore from the refinery and shuttled into
the harbor for unloading. In order that the Refinery output is not affected two 30,000 DWT vessels are
required.

Potential impacts

According to NSRP marine consultant, the chance that the wind and wave height of a severe typhoon
pass the SPM terminal is small but realistic and conditions differ significantly from the 100-year return
environmental conditions.

Based on feedstock for the Refinery, there are a maximum of 33 parcels of transported crude from the
Kuwait to Nghi Son Bay with an interval between parcels of 10 days. The offloading of large crude
tankers at the SPM will take approximately 24 hours/ship. For the tanker arriving at the SPM, the cut off
time for berthing is 1.5 hours before sunset. Therefore, berthing occupancy of tanker at SPM might be
more than two days. The crude offloading from large ships at Nghi Son Bay will take place for year
round.

Area used for normal offloading operation at SPM and support activities will permanently occupy 31ha,
while normal crude pipeline operation seems not cause significant effect to seawater quality. However,
these above-mentioned activities might cause high potential risk of oil spill at SPM and on crude
pipeline system, especially of ship to ship transfer by 30,000DWT vessel in the case of incident to the
SPM.

In the case of accident of SPM, all crude oil from tanker will be loading by 30,000DWT ships. It is estimated that there
are about 10 times loading crude from 300,000 DWT tanker to 30,000DWT ships. Crude will be transported to the
harbour and then continue loading by pipeline system to plants tankage system.


The above-mentioned activities of crude loading and transportation will cause high potential risk of oil leakage at SPM
area, increase shipping density and increase shipping collision at harbour area. Depending on oil spill tier, affected area
might be a partly or all Nghi Son coastal area. Impact level depends tolally on oil spill level.

The detail of oil spill scenarios will be mentioned in the oil spill response plan report. In the case of oil
spill occurs at SPM or crude oil pipeline, spilled oil will drift to Nghi Son bay and shoreline in the first
day and its impact level will be considered from significant to severe, due to SPM and crude pipeline
system locations are too close to the shoreline. The significance of the impact will depend much on
spilled time and tier scale, spilled oil might affect further to Southern direction (in the Northeast
monsoon) or to Northern direction in the Southwest monsoon.

Impact of product loading at jetties

Project activities

It is planned that 95% of the refinery products will be distributed by ship. The products will be routed by
pipeline from product tank farm and loaded directly into vessels/tankers through loading arms at the
ocean /coastal berths. The berths turnaround times for the ocean berths and the coastal berths are
estimated at 22 and 16 hours respectively.

It is estimated that about 92.71% of refinery products will be exported via the coastal berths and about
6.29% are exported via ocean berths. Total number of tanker/vessels (1,000 10,000 DWT) will be
1,179 ships/year (Table 3.30).

Table 3-30 Berth occupancy in the operation phase

Product Mass exported (T/SD) No. of ships per year
LPG 158 44
RON 92 3,610 142
RON 95 3,610 142
Jet 1,709 168
Kerosene - -
Premium Diesel 6,043 238
Regular Diesel 4,029 158
Fuel Oil - -
P-X 1,849 135
Benzene 693 84
Poly-propylene 1,074 40
Sulphur 740 28
Total (Liquid Product Berth) 21,701 1,111
Total (Solid Loading Berth) 1,814 68
Total 23,515 1,179
Source: NSRP LLC, November 2009

The loading time is in the range of 3-7 hours for vessel 3,000 tons, from 5-11 hours for vessel 5,000
tons, 4-5 hours for vessel 10,000 tons and 12-14 hours for ocean ship 30,000 DWT. It is estimated that
8 vessels may occupy the channel at any one time. All the vessels in the channel must be traveling with
a minimum gap of 15 minutes between vessels. Total berth occupancies are in the range of 33-54% for
the coastal berths, about 10-29% for ocean berths and about 5% for LPG berth. The harbor topsides is


capable to load several tankers with the same product at the same time or one Ocean tanker and two
Coastal tankers can be loaded with one product at the same time.

Potential impact

The product loading activities at the harbor will impact to water quality by tankers/vessels propellers
and mooring. Other potential impacts include the effects of anti-fouling paints, the types used for
vessels to undergo cleaning in the harbor. The estimated area affected by activities at the area of
harbor, access channel, breakwater and cooling sea water intake channel is about 193 ha.

During routine loading operations, small leakages of oil products may occur at the harbor due to human
error, for example. These include the tightening of equipment performance and compliance
requirements for tank structural components, valves, and plugs, supporting and anchoring devices and
other fittings. The impact level is considered as small and be limited in the harbor area.

Since the Project harbor is constructed nearby the specific port of Nghi Son Cement Factory (in the
South) and sea way transport route leading to PTSC Port will cut across the Project area of crude oil
pipeline and access channel, so the vessel density at this area will increase significantly and also
cause high risk of collision between ships. Although NSRP has given effective mitigation and
prevention measures to minimize potential risks, impact level of this activity is assessed as moderate
during operation phase of the Project. Total effects caused by vessels activity will be mentioned in
detail in Item 3.2.3.

It is important to note that the density shipping activities at harbor and access channel might cause
high risk of ship collision and oil spill. The density of petroleum products is generally lower than that of
water, so in the case of product spillage into the sea; the product itself is extremely volatile at ambient
temperature and always floats on the surface. Since it is quickly dispersed into the air, the risk of long-
term environmental impact to sea water quality will be significant. Oil spreading and assessment will be
analyzed in detail in the separately report named Oil Spill Response Plan for NSRP.

Impact of periodical maintenance dredging

Project activities

Maintenance dredging activities will be carried out after 4 years for the harbor and access channel and
last for 06 months. Estimation of maintenance dredged volume is approx. 2.9 million m
3
in which 0.7 M
m
3
in the harbor area and 2.2 million m
3
in the access channel. It is planned that dredged materials will
be disposed at the same dumping location in the construction phase, 6.7 km away from the South of
Hon Me Island). Initial dredging activity for the first stage of the Project will be carried out, assessed and
chosen dumping location by NSPM.

Potential impact

Choose dumping location

As mentioned in Section 2, sea bed sediment at harbor basin is much diversified from very loose to
dense, fine sand to silt sand. At some locations, mud is status of loose / soft clayey sand. At 2 m under
the sea bed, the sediment layer is very hard, including stiff to very stiff clay. Above types of dredged


sludge are not suitable for site leveling of the Project or other onshore projects. Hence, the optimum
option is dumping at location out of the Project area.

Dumping location must meet requirements of environmental protection and safe for vessel activity. The
dumping site in this phase is considered as follows:

- Water depth must be suitable in order not to prevent vessels transportation;
- Appropriate distance between the access channel and SPM so that flow of sediments will not
impact on dredging site;
- Main direction of wastes movement;
- Enough space for receiving dredged sludge;
- The transport distance from the harbor is minimum to reduce emission gas and dredging cost;
- Minimize negative impacts on marine ecosystem, especially the area of coral reef at Me island;
- Avoid or limit to dump at fishing grounds;

According to research/consideration of dredging for marine constructions [12], 04 positions considered
to choose as dumping site are as follows:

- Position I: the South West area of Me island;
- Position II: the North West area of Me island;
- Position III: the area between Nghi Son island and Me island, near small islands;
- Position IV: the area locates near the South West islands of Me island.

Analysis of sea bed features and dredged sludge receiving ability and environmental impacts of 4
positions are presented in Table 3.31 and Figure 3.10.

Table 3.31 Comparison of proposed dumping sites

Proposed dumping sites
Criterion
I II III IV
Water depth -20 m -15 m -11 m to -13 m -15 m
Distance from
dredging site to
the harbor
18.5 km along route A
19.1 km along route B
12,5 km away from the North area
11.2 km away from the South area
9,2km 10,7km
Sea bed
topography
- Rather even and flat
- There are 02 narrow
water areas with -18 m in
depth
- Natural hole with depth of -21m
- The South natural hole with
depth of -27.4 m
- Natural hole with depth
of -19.8 m

- Natural hole with
depth of -21.2 m

Receiving ability - Receiving area of 9km
2

- Maximum receiving
volume of 18 millions m
3

- Receiving area of 1 km
2

- Maximum receiving volume of
3 millions m
3

- Receiving area of 0.65
km
2

- Maximum receiving
volume of 2.3 millions
m
3

- Receiving area of
0.58 km
2

- Maximum receiving
volume of 3.6 millions
m
3

Environmental
sensitivity
- Low
- Not affect on coral
- High
- Affect on coral
- High
- Affect on coral
- High
- Affect on coral



Figure 3.10 Selectable dumping sites


Above comparison results show that position I locating 6.72 km away from the South West of Me island (Figure 3.11) is
the most suitable for the Project. Moreover, in comparison with dumping site proposed by Thanh Hoa Port Authorities in
February 2009, position I is further from the seashore and more suitable or following reasons:

Away 8.7 km from nearest pipeline; 6.72 km from Me island; 6.3 km from Dot island and 8.7 km from Mieng
island;
Direction of sediment dispersion is the South, so the dumping site must locate in the South of the harbor and
corridor of the pipeline;
Do not affect on ecosystem of coral around Me island;

Figure 3.11 Proposed dumping site

According to calculation, volume of dredged sludge at dumping site is not higher than 1/10 of the sea level. Therefore,
maximum allowable height of deposited sludge at dumping site must be 2 m. Due to dispersion of the sediment by time,
an area in size of 3.0km x 3.0km with filling height of 2m may receive 18 millions m
3
. Beside advantage of space for
dumping, this position also has an enough depth to mitigate impact of dredged sludge on current and disperse sludge
by time. Moreover, 02 narrow water areas with -18m in depth will make impact of dumping more sludge insignificant. In
order to keep balance of height between dumping site and surrounding area, dumping site must limit filling height of
-18.0m.

Current depth is about -19m in the West and -20m in the East compared with dumping site, average filling height is only
about 1.5m. Therefore, with dredging frequency of 04 years and dumping sludge volume of 2.9 millions m
3
, it is
necessary to have a dumping site in size of 1.4km x 1.4km.

Effect of dumping activity
Dredging (and dumping) activities at any scale may cause impact on water environment. Movement of the current will
stir the sediment layer and increase turbidity in a large area. This will make the sediment layer be dispersed significantly.

Calculation of 2.9 million m
3
sludge by sludge dispersion model is carried out on the supposition that it must be
discharged 800,000 m
3
/month. Since dredging activities will be done for each 4 year in any month in year, the model is


run for whole 12 months. The results show that maximum thickness at dumping site varies in range of 2.66 4.48m.
Affected area with sludge thickness of 0.1m is about 160,000 220,000m
2
up to time of dumping. Affected area of
sediment layer with thickness of 01m is about 27,000 80,000m
2
(Table 3.32 and Figure 3.12)

Table 3.32 Seabed area affected by dredging sludge

Affected area (m
2
) Month
Material thickness of 0.1m Material thickness of 1m
Maximum thickness at
dumping site
(m)
1 158,438 52,813 4.07
2 158,438 26,406 4.54
3 184,844 26,406 4.48
4 158,438 26,406 4.17
5 158,438 26,406 4.09
6 184,844 26,406 4.48
7 211,250 79,219 2.66
8 184,844 26,406 4.67
9 158,438 52,813 4.12
10 158,438 26,406 3.95
11 158,438 52,813 3.80
12 158,438 52,813 3.54

Dredging activities will strongly disturb the top sediment layer. These activities cause temporary instability for the sludge
deposition process. Due to the strong disturbance, some particulates are suspended and some are re-deposited. These
activities will increase organic content and nutrients (N, P v S
-2
) together with inorganic constituents (Na, Ca, K) in
water. When outside sediment layer is removed, the anaerobic inside will be exposed. In this condition, all benthos are
destroyed or dispersed.

In dredging process, suspended solid content will locally increase. Activities of the dredger ship take place in the sea.
This will increase temporarily suspended solids and affect mainly on the top of water column. Dumping process will
make the turbidity, pollutants and BOD increase, but concurrently decrease dissolved oxygen (DO) in water. This
impact may last for 6 to 12 months.

Impact level is assessed as moderate and short-term during dredging and dumping process.



January
March
May J uly
September November

Figure 3.12 Diagram of dredged sludge dispersion



Impact by harbor effluent discharges

Project activities

Sources of effluent within harbor will consist of the following streams: clean water, oily water and
sanitary effluent.

Potential impact

Typically storm water run-off from non-process or unused areas where there is no potential to pollute
water-run-off is classified as clean effluent. Clean effluents are collected to gravity drainage systems
and in open ditches at the harbor. Clean effluents normally have low or negligible content of pollutants
and meet the discharge limits. Therefore, this effluent can be discharged, untreated, direct to sea. The
discharge of clean effluents directly to the sea at the harbor will not pollute seawater.

Sanitary effluent generated is based on an estimated flow of 300 liters/person/day. It is anticipated that
the number of employees will be 42 persons and an allowance of 12 additional persons. The estimation
sanitary volume is about 16.2 m
3
/day. The maximum daily pollution loads before treatment as a long
term average is given in Table 3.33.

Table 3.33 Maximum daily pollution loads

Case Maximum daily load
Flow 16,200 kg/day
Pollutants kg/day ppmw
BOD
5
3.24 200
TSS 3.78 233
NH
4
+
-N 0.43 27
Total Phosphor 0.16 10
Source: Technical Document No. 3550-8110-PS-190-0180 - REV D1 Provided by FWL, November 2009
Notes:
The pollution loadings are based on typical daily allowances per person: 300l/day of water, 60 g/day of BOD, 70 g/day
of SS, 8 g/day of NH4
+
-N & 3 g/day of Phosphorus.
Normal flows are likely to be lower than the peak identified above but the pollution load is likely to be as identified for
extended periods of time thus the sewage strength is expected to normally be substantially higher than that indicated
above for the peak flow.

This sanitary effluent will be treated by sewage treatment package at the harbor and then routed to
project outfall. The treated wastewater will meet discharge standards of the project (see Item 0.2.2.3).
The sludge will be transferred to the secondary treatment stage (biological) of the refinery effluent
treatment plant (ETP). So sanitary effluent generated from harbors topsides will not cause direct impact
to seawater. Project activities will be updated during EPC phase.



Impacts of wastewater and solid wastes fromvessels

Oily wastewater

In the operation phase, there are about 33 very large tanker (300,000 DWT) transporting crude oil from Kuwait to SPM
every year. These ships are equipped preliminary oily separator. Cleaning and runoff water sweeping oil sticking on the
surface floor around the equipments will be collected and treated by the oil separator to ensure that oil content in treated
wastewater must less than 40 ppm before discharged into the sea (offshore area beyond 12 nautical mile). On the other
hand, the projects crude tanker will only operate offshore at SPM which is 33.5 km far from the shore with frequency
ship to SPM is one per every 10 days. Moreover, volume of oily wastewater from tanker is small and the mixing ability of
the environmental receiver is very well, so discharging treated oily wastewater will cause insignificant impact on marine
environment.

At product export berths, there will be about 1,179 ships of 1,000 30,000 DWT every year going in and out, in which
93% of them are 1,000 10,000 DWT ships. As planned, the NSRP harbor will only receive double hull ships or having
2 containing holds, not for ships having ballast water. Moreover, according to the MARPOL signing progress, all these
ships must have certification of the Vietnam Register of shipping before berthing in the harbor. The operation process of
these tankers at the harbor will generate a small volume of oily runoff water since oil stains are swept away from the floor
of the ship by rain water. This oily wastewater will be preliminarily extracted the lower layer because oil is lighter than
water and will float on the surface. The above oily water layer will be collected and routed to a separate tank and treated
periodically (when the tank is nearly full) by the onboard oil/water separator or a licensed company outside the harbor.
Therefore, the NSRP harbor will not receive oily wastewater from product vessels and impact level on sea water
environment is assessed as insignificant.

Domestic wastewater

Domestic wastewater generated onboard of crude tankers and product ships will be collected and preliminary treated
before discharging into the sea. However, number of screws working on these specific ships is not much. Therefore,
discharging treated domestic wastewater from ships will cause insignificant impact on the marine environment.

Solid waste

Domestic rubbish from canteen area as waste food generated from each ship is not significant. All amount of rubbish
will be crushed into small pieces less than 25 mm in size and discharged directly into the sea without treatment. It is
noted that small pieces of rubbish ( 25mm) should not be discharged nearshore due to effects on ship activities at the
harbor.

Normal operation of crude tankers and product ships will generate frequently amount of solid waste. These solid wastes
are mainly non-hazardous waste as domestic rubbish and a small amount of hazardous waste as oily rag, batteries
As planned, all solid wastes generated onboard will be classified at source into separate bins before transporting to
temporary storage area at NSRP harbor. At the harbor area, hazardous waste will be transported to specific storage
area of the Complex and treated together with hazardous wastes of the Complex. Non-hazardous wastes will be
transported and treated properly by a licensed treater company; and NSRP LLC will be responsible for hiring this
company in accordance with current regulations. Therefore, impact level of solid wastes generated from ships on sea
quality at Nghi Son gulf is assessed as minor.

Amount of solid wastes generated from these tankers will be defined by the EPC Contractor in the detailed design
phase of the Project.



3.2.2.2.3 Soil and groundwater environment

Project activities

Main activities caused potential soil impact are operation of 2km onshore pipeline, pipeline pigging and
maintenance and solid wastes management at the harbor.

Potential impacts

Onshore pipeline system and loading activities

Product loading at harbor will not cause significant impact to soil environment due to loading activities
are operated on the harbor structure.

Normal operation of crude and product pipelines connecting from Refinery and Petrochemical Complex
to harbor will not cause soil pollution. In the case of occurring onshore pipeline failure/rupture, spilled
oil/product will cause soil contamination along the pipeline right of way. In practice, pipeline tracks are
buried at minimum of -1m in depth and isolated with the vicinity by fence and will be supervised by
NSRP LLC. On the other hand, onshore oil spill/leakages are usually minor and easy to handle.
Therefore, the impact level is considered as minor.

During the periodic pipeline pigging, any deposit or fluids inside the pipeline will be discharged to the
tank ahead at the pig receiving station in the plant. Therefore, the level impact of maintenance pigging
on soil contamination is considered as negligible.

Solid wastes

Solid wastes generated from normal operation of jetty area are in small quantity. Most of the non-
hazardous solid wastes are coming from the 42 persons working at Jetty Area Control / Admin Building.
Domestic wastes from Jetty are estimated at 45.9kg/day which will be regularly collected and disposed
by an accredited local Urban and Public Hygiene Company.

3.2.2.2.4 Marine Environment

Project activities

Main activities caused potential impact to marine habitat at this phase are offloading crude oil at SPM
through pipeline system, product loading at jetties and maintenance dredging and material dumping.

Potential impacts

As above mentioned, normal offloading crude oil at SPM through pipeline system and product loading
at jetties will be at high potential risk of oil spill. In the case of oil spill occurs, the main threat posed to
living resources by the persistent residues of spilled oils and water-in-oil emulsions is one of physical
smothering leading, in cases of severe contamination, to death through the prevention of normal
functions such as feeding, respiration and movement. As damage is caused by physical contact, the
animals and plants at most risk are those that could come into contact with contaminated water.



Maintenance dredging and material dumping activities will cause similar impacts as ones in the
construction phase. However, the presence of contaminated sediments may be higher due to effluent
discharges from industrial activities. The potential effects of these changes on marine life are:

Cause the removal of benthic animals at the dredge site.
Temporary increases in the level of suspended sediments in the water column which can give
rise to increased turbidity, and the possible release of oxygen depleting substances (organic or
anaerobic sediments), nutrients and contaminants.
Temporary reduction of algal/plant growth due to increased turbidity.
Disturbance to sensitive benthic animals and fish due suspended sediments, which may cause
temporary disruption of migration of fish.
Temporary disturbance of marine animals from the depletion of oxygen due to release of
organic-rich material.
Nutrient enrichment possibly causing increased food supplies/algal blooms.
Uptake of contaminants by marine life possibly causing direct toxic effects or effects further up
the food chain.
Smothering of benthic animals and plants due to resettlement of suspended sediments.
The overall effect of maintenance dredging on the hydrodynamics and geomorphology of a site has all
the complexity of a capital scheme but the impacts are less magnitude. In many cases the magnitude of
dredging related alterations may fall well within the range of naturally occurring phenomena and
probably impose little or no additional stress to marine features (IADC/CEDA 1998). For maintenance
dredging, the extent of these environmental affects is near-field and temporary generally only lasting as
long as dredging operations are taking place (ABP Research R707 1997; IADC/CEDA 1998).

However, the presence of contaminated sediment may increase the impact of the maintenance
dredging at the disposal site. The impact level is considered as significance.

3.2.3 CUMULATIVE IMPACT DURING OPERATION PHASE OF ONSHORE AND OFFSHORE
CONSTRUCTIONS ON OTHER PROJECTS IN THE LOCAL AREA

Cumulative impact assessment of NSRP is based on overall development background of other projects in the local
area. The Complex is constructed in Nghi Son economic zone (NSEZ), other industrial activities in NSEZ include:

Petroleum Technical Services Corporation (PTSC) and Vinashin shipyard factory are in site leveling phase. PTSC
Port is 7 km away from the South of the Project. Current PTSC port mainly serves for domestic import/export of
construction materials and cargo. The appearance of 5 new harbors will increase risk of ship collision and cause
significant impacts on the environment and society.

Nghi Son Thermo-electric Plant with capacity of 1,800 MW locating in front of the PTSC Ports include Nghi Son 1
Plant (600 MW) and Nghi Son 2 (1,200 MW) and 6km away from the Project. The Plant will use 14 tons of
coal/hour, the feedstock is from coal mine in Hon Gai, Quang Ninh province. Coal will be transported to the Plant by
seaway and kept in the coal storage area. Operation of the Plant is a significant air pollution causing source. New
product export berth of the Plant will increase risk of ship collision.


Nghi Son cement factory is 5 km far from the Project area. The factory locates near Road 513 but its jetty is built at
Nghi Son Gulf. This jetty is near the harbor of NSRP, so ship activities of Nghi Son cement factory and NSRP may
increase risk of ship collision.

In future, there will be a new harbor of NSEZ locating near the harbor of NSRP. This new harbor may prevent the
sea traffic since it is too close to the harbor of NSRP. Due to this high potential risk, the new harbor of NSEZ will
have a complete different access direction.

PTSC Ports and Nghi Son Thermo-electric Centre locate behind Chuot Chu Mountain with its height of 157m and is 6
7 km far from the Project area. On consideration of distance between projects and practical topography condition,
emission gas and waste water dispersion of the Project will not cause cumulative impact on environmental constituents
at Project area.

However, growth of ship activities due to the development of trade ports and fishery activity will increase environmental
risks, especially the oil spills. Therefore, it is necessary to assess cumulative impact between NSRP and other projects.
Most of cumulative impacts will affect on:

Habitat;
Biological diversity.

Although Nghi Son Cement Factory locates in NSEZ, this will not cause cumulative impact on air quality because:

According to EIA report of Nghi Son Cement Factory, SOx is not generated from the Factory since it is
absorbed during cement production process. Average ground concentration of NOx is under allowable limit of
TCVN (0.19 0.22 mg/Nm
3
). Average ground concentration of cement dust is in range of 0.19 0.21 mg/Nm
3

at distance of 600m from the stack base. Therefore, affected area is limited in the area of Nghi Son Cement
Factory.

Nghi Son Cement Factory is 5 km far from NSRP and behind Chuot Chu Mountain.

Operation and appearance of harbor constructions of different projects will generate cumulative impacts due to the
increase of sea traffic and high potential risk of ship collision.

According to Thanh Hoa Port Authorities, Nghi Son integrated port (PTSC Port at present) may receive 10,000 DWT
ships at berth 1 and 30,000 DWT ships at berth 2. The capacity of the port is about 900,000 1,400,000 tons/year with
cargo such as rice, cement, iron, steel, fertilizer and coal. International ships going in and out Nghi Son integrated Port
are mainly from Japan, Thailand, Malaysia and China. More than 80% of ship activities in Thanh Hoa province
concentrate at Nghi Son gulf with density of 830 997 ships/year. Access channel routing to Nghi Son integrated Port,
Vinashin shipyard factory and Nghi Son thermo-electric plant is from the South of Bien Son mountain and 9 km far from
NSRP. Therefore, ship collision incident may occur in area from Buoy 0 to Nghi Son integrated Port, oil slick may affect
directly on Nghi Son gulf and NSRP harbour. Polluted area may spread out if the incident occurs in time of March to
August (Southwest monsoon). In this case, Me island, Nghi Son cement port, NSRP harbor and Thanh Hoa coastal
area will be affected.

Nghi Son cement port is 1 km far from the South of NSRP harbor. 3 specific ships used to transport coal from Quang
Ninh Province to the jetties name Development (12,000 DWT), Helitech (7,000DWT) and San Ho (14,000
16,000DWT); and a large ship (17.000 27.000DWT) used to transport clinker from Japan, plaster from Thailand and
cement to Hiep Phuoc Port (HCMC). The capacity of the Port is about 1,100,000 1,300,000 tons of cement, clinker
and coal per year. At present, density of vessels at Nghi Son Cement Port is low and there is no any ship collision
incident. However, the access channel of this port is used flexibly for ships from the North (China, Quang Ninh)
passing access channel of NSRP harbor and ships from the South will also pass Me island. Hence, there will be


potential risk of ship collision when NSRP Harbor comes into operation phase. In case of incident at Cement Port or
NSRP Harbour, oil will drift to Nghi Son coastal area and Me island in the first day in both monsoons.

In normal operation, frequency of ship going in and out NSRP Harbour is about 1,179 ships/year; and 150 186
ships/year for Nghi Son Cement Port. Risk of collision will be higher when a new trade port of NSEZ is constructed and
operated near NSRP harbor (in the North). Based on consideration and assessment of ship activities at all harbors,
situation and sea traffic at access channel, cumulative impact is assessed as significant.

Tankers at SPM may collide with ships going in and out Nghi Son integrated Port, Nghi Son Cement Harbor, future Port
of the Thermo-electric Plant and Trade Port of NSEZ. Main risk to aquatic environment is oil spill accident from SPM,
crude oil pipeline or ship collision at harbor or access channel of Nghi Son Cement Port. Although the frequency is low,
the result is serious and unchangeable. These cumulative impacts will affect on biological diversity, especially coral,
aquatic environment Cumulative impact level is assessed as major and long-term.

3.2.4 SOCIO-ECONOMIC IMPACT ASSESSMENT

Development of NSRP will affect on many aspects of the local communitys living including change of
landuse, job opportunity and issues caused by the development. The main impacts mentioned in this
item include:
Land acquisition;
Compensation and resettlement;
Training and recruitment plan;
Job change and local supply opportunity.

NSEZ Management Board is responsible for resettlement of affected people in NSEZ. However, NSRP
will carry out a due diligence of resettlement activities in the Project area in accordance with
requirements of IFC.

3.2.4.1 Impacts caused by land acquisition

Total acquired area for the Project is 394 ha in the area of Hai Yen, Mai Lam and Tinh Hai Communes.
Most acquired land (65%) is agricultural.

Around 2,607 HH (9,000 persons) will be affected by the Project. Among these APs, 687 HH will lose
most of their land and their main houses and they have to relocate in another location. Three
resettlement sites have been designed to accommodate these relocated APs.

Table 3.34 Scope of land acquisition
Total
Productive
land Residential land
Project components
HH ha HH ha HH ha
Relocate
d HH
Loss of
graves
Plant Site (B)
1,907 328 1,398 289 509 39 456 2,348
- Mai Lam
525 63 468 52 57 11 53 1,083
- Tinh Hai
600 117 450 105 150 12 101 832
- Hai Yen
782 148 480 132 302 16 302 433
Pipeline and Marine Facility (Areas E & J)
700 66 469 231 231 N/A
Total
2,607 394 1,867 289 740 39 687 2,348
Source: Resettlement Due Diligence report, February 2010



During the first survey, most of the HHs in the plant site were losing a significant part of their land
(86.7% lost more than 30% of their total holdings) and 42% of HH who lost agricultural land declared
that their remaining land was no longer viable.
As already indicated, all the APs already relocated in Mai Lam Commune had lost all their residential
land.

Table 3.35 Affected land in the plant site and in the borrow areas

Affected area/Total area (%)
0-10% 11-30% 31-60% >61%
Location

Number
of
surveyed
HH
HH % HH % HH % HH %
Plant site 105 4 3.8 10 9.5 38 36.2 53 50.5
Already relocated
APs in Mai Lam
25 0 0.0 0 0.0 0 0.0 25 100.0
Source: Resettlement Due Diligence report, February 2010

Table 3.36 Viability of remaining agricultural land

Remaining land viable
Yes No (too small)
Location

Number of
surveyed
HH HH % HH %
Plant site 105 61 58.1 44 41.9
Already relocated APs in Mai Lam 25 0 0.0 25 100.0
Source: Due Diligence Surveys (2008-2009)

3.2.4.2 Impact caused by graves relocation

In the Project area, graves locate mainly under the foot of Chuot Chu (area of borrow pits), Coc mountains and rice
fields (the Plant site). Some graves are buried in the middle of rice fields or near home.

Compensation rate for removing graves: APs had to move graves to new cemeteries. According to
APs, the compensation for graves, between 800,000 VND and 3,600,000 VND, doesnt reflect
replacement cost. Most APs hire workers to move their graves. They said that the cost of workers is
higher than the compensation proposed. The disturbance or loss of graves could potentially result in
social and cultural disruption of traditional burial customs as well as traditional beliefs based on their
relationship of ancestors to living beings. According to consultation with affected communes,
compensation rate for graves relocation is lower than practical cost.

Situation of new cemetery in Mai Lam commune: a new cemetery was built in Mai Lam commune.
However, APs and local authorities are very unsatisfied with the way it was built. Most of the relocated
graves stones have fallen down, and are inclined due to the poor and careless construction of the new
cemetery, which didnt follow the approved design.

The project will affect 1083 graves in Mai Lam commune, 433 graves in Hai Yen commune and 832
graves in Tinh Hai commune. Local authorities have compensated and moved all affected graves to
cemetery of each commune. However, considering the number of affected graves and the belief of the
people the significance of this impact is assessed as major.



3.2.4.3 Impact caused by compensation and resettlement

The responsibility of implementing the resettlement of affected people in NSEZ belongs to Tinh Gia
District and NSEZ Management Board. However, NSRP is doing a follow-up of the current resettlement
activities in the project area.

According to the Due Diligence Resettlement Report prepared in February 2010, around 2,607 HH
(9,000 persons) will be affected by the project. Among these APs, 687 will lose most of their land and
their main houses and will have to relocate in another location. Due to the number of households
affected by the Project, the significance of this impact is serious.

Resettlement activities started in early 2008 for this project and are ongoing. The resettlement activities
focused first on the plant site and utilities where compensation payments were made to households
who had agricultural land and graves affected by the NSRP. APs in the plant site have now been fully
compensated.

Due to change in the design, some new areas (areas E & J) are now under the project. A new
resettlement site in Tinh Hai commune has also been developed.

Due to this situation, the status of resettlement activities for the various components of the project is at
different stages. Below table indicates the status of resettlement activities up to May 2010.

Table 3.37 Status of resettlement activities by commune, up to May 2010

Commune Impacts Status of resettlement activities
Mai Lam 63 ha affected by NSRP;
525 HHs
57 HHs to be relocated
1,083 graves need to be
relocated
Plant Site: all compensation paid
54/57 HHs have already moved and handed over their land; 3
HHs have moved to other locations.
All graves already removed
The plant site (B)
148 ha affected
782 HHs
433 graves need to be
relocated
All compensation paid
104/302 HHs received land and building home in the RS.
Graves: 433/433 graves already removed
Hai Yen
The pipeline and harbour
areas (E & J)
66 ha affected
relocated
Being investigated in detail
Tinh Hai 117 ha affected
600 HHs
relocated
Plant site
- All compensation paid;
- 83/101 HHs received land and building home in the RS.
Graves: 780/832 graves already removed
Source: Investigation result, May 2010

Three resettlement sites are constructed to relocate people affected by the Nghi Son Refinery Project.
They are: Mai Lam, Tinh Hai and Xuan Lam-Nguyen Binh RS. Two RS, Mai Lam and Tinh Hai, are
located within the NSEZ and Xuan Lam-Nguyen Binh RS is located outside the NSEZ. All three RSs
conform to the Master Plan of the NSEZ. In general, affected HHs are satisfied about the RS, except for


Mai Lam RS due to environmental condition and distance from the previous land to the new RS. These
HHs are willing to deliver their land to the project and relocate temporarily or live with their relatives. A
new RS will be built for HHs living in Tinh Hai Commune.

The RS construction process is not the same for all the RS. Tinh Hai RS will be built later since local
people want to move to a new RS. Up till May 2010, there are 104 of 302 HHs in Hai Yen Commune
and 83 of 101 HHs in Tinh Hai Commune received land and constructing home in the new RS.

The process for plot allocation to APs is as follows:

Priority is given to APs who were located in profitable/convenient locations of their former
resident places;
Other APs are chosen randomly for their plots.

The size of plots in each RS varies. Two main types of land plots with the size of: (i) 5 x 20 m; (ii) 10 x
18 m. Priority to allocate to agriculture households who will have to change their occupation from
agriculture production to non-agriculture production. In addition, some plots have a size of 70 m
2
.

Affected HHs will have option to build themselves their houses but following the regulation of house
building under urban area issued by department of construction.

The assistance policy for moving and relocation of APs applied for Nghi Son Economic Zone was
issued by Thanh Hoa PPC by Decision No.2531/2008/QD-UBND dated 18 August 2008. The
assistances are as follows:

Assistance for life stabilization and production stabilization
Assistance for house rental
Education assistance
Training allowance
Progress bonus
Assistance for individual relocation

The residual impact on socio-economic conditions of the affected households related to the loss of
residential land is strong according to the first Public Consultation of November 2008 and Due Diligence
Resettlement Survey.

1. Resettlement

Resettlement site development and suitability constituted one of the most difficult issues in the Project.
The construction of resettlement sites was severely delayed. NSEZMB planned to finalize all the RS by
the end of April 2009. As of the date of the preparation of this report (May 2010), there are many HHs
received land and are building their homes in the RS.

Mai Lam RS

The resettlement site in Mai Lam Commune was not found to be satisfactory for APs in Mai Lam
Commune nor by local authorities due to environmental reasons. Therefore, all APs in Mai Lam
Commune refused to be relocated in the proposed RS and chose to be relocated by themselves.
Currently, 54 HHs among 57 HHs from Mai Lam commune have already relocated; 03 HHs moved
outside the NSEZ.


Tinh Hai RS

APs in Tinh Hai commune refused the proposed location of the RS in 2008. A new RS was again
proposed to them in 2009 by NSEZ and it has been satisfied APs. Two public meetings were
organized in July 2009 by NSEZ. Now, the RS is nearly completed and there are 83 HHs building
their houses in this RS.

Late construction progress of RS

APs worry about the delays in relocation. They will move to the RS only when the infrastructures in
the RS are fully completed. NSEZ promised the completion of the RS for April 2009. However, in
October 2009, no APs had been relocated.

As indicated above, the stabilization allowance, intended to cover expenses and loss of income
during the transition period (currently for 6 months). So APs are asking for the extension of this
allowance if the RS is not completed after 6 months. In practice, in the end of year 2009, Thanh
Hoa PPC has decided to extend period of stabilization allowance up to 60 months with 30kg of
rice/person/month, it is even better than their expectation.

Size of lots of land in RS

APs found the size of land in the RS (200 m
2
) is too small. APs are asking for 500 m
2
plots of land
to be able to have a garden for growing vegetables and fruit trees.

APs want to combine two types of land plots in the RS: one for housing and one for business. In the
design of the RS, the locations of business and residential plots are separated. HH want to get two
plots at the same location to be able to take care of their business during the night.

Plots of land in RS only for residential land with houses

Some APs did not agree with the new Resolution No.128/2009/NQ-HDND of the Thanh Hoa
Peoples Committee on the moving and relocation policy applied for the Nghi Son Economic Zone;
Article 3, Clause 2 of this resolution stated that to obtain a plot of land in an RS, HHs have to meet
the three following conditions:

- HH with residential land (with existing houses on it) to be acquired by the Project;
- HH should have permanent registration;
- HH have to move their place of residence to the RS.

2. Replacement cost survey

A replacement cost survey was conducted in the Project area. Local authorities, affected persons and
non-affected persons were met. To assess if the compensation prices paid to APs (based on Thanh
Hoa PPC prices) meet replacement costs, a replacement cost survey was conducted. This survey
focused mainly on residential land because compensation prices for this type of land are the most
contested by APs.



Residential land

Compensation rates established by Thanh Hoa PPC for residential land are below market rates for
all locations and for all communes. This confirms the opinions of APs. However, APs are offered
land for land compensation (plot in an RS). If they choose land for land compensation, they will not
be affected by the low compensation rates for residential land.

Productive land
Compensation rates for agricultural land, according to PPC rates, are 22,000 VND/m
2
in Thanh
Hoa Province. However, this rate was raised from 22,000 to 55,000 VND/m
2
for the Project area by
Decision No.1151/2008/QD-PPC dated 28/04/2008 amending and adjusting some prices for
agricultural land in Nghi Son Economic Zone. This new rate for agricultural land is satisfactory to
Aps.
In 2010, following Decision No.4366/2009/QD-UBND issued to reflect the new Decree 69/CP
issued by the GoV, the compensation rate for agricultural land has to be multiplied by 1.5.
Therefore, the new compensation rate for agricultural land will be 82,500 VND/m
2
.

House

The investigation showed that the prices of construction materials have increased considerably due
to the 25% inflation rate (it may be lower now). The prices for construction materials are 30 to 45%
more than 6 months ago. Therefore, local authorities as well as affected people require the PPC to
compensate by applying Decision No. 1048/QD-UBND dated 22
nd
April 2008 but following the
inflation rate. The new compensation rates of Thanh Hoa PPC in Decision No.345/Q-UBND dated
25
th
January 2010 have been increased and equal to current market price.

3. Compensation
To assess the process of resettlement and compensation, a due diligence survey was conducted for
the plant site. 105 HHs were surveyed at the plant site to assess the process of resettlement and
compensation.

In 2008, at the time of the survey for APs in the plant site, APs had only been compensated for
productive land and not for structures. Also, at this time no APs had been relocated. This is the reason
why the new due diligence survey among the 25 already-relocated HH was conducted in October 2009.

Satisfaction with compensation

During the first survey in the plant site, APs were generally satisfied with the compensation they
had received for agricultural land (62%) and for trees/crops (51.4%). This showed that
compensation prices for agricultural land generally met market prices.
However, among the already relocated APs in Mai Lam Commune, all the APs complained due to
the low compensation rates for residential land. The amount they received was not sufficient to get
a similar plot of land in the same area.




Table 3.38 Satisfaction with received compensation
Satisfied with compensation

received for land
Satisfied with compensation
received for fruit trees/crops
Yes No (too low) Yes No (too low)
Location
Number of
surveyed
HH
HH % HH % HH % HH %
Plant Site 105 65 61.9 40 38.1 54 51.4 51 48.6
Already relocated
APs in Mai Lam
25 0 0 25 100 25 100 0 0
Source: Resettlement Due Diligence Report, February 2010

In the plant site, some APs (19 %) complained to local authorities with no results. Most of the APs
(75.2%) attended public meetings organized by local authorities. For already relocated APs, all the APs
surveyed complained to local authorities.

It should also be noted that in the plant site, although almost all APs (98.1%) were compensated before
the start of the civil work, 3 APs declared that they were compensated after the start of the civil work.

However, for the already relocated APs, all APs declared that civil works started before the
compensation. The result of the due diligence survey conducted with 25 of 75 relocated APs in Mai
Lam showed that all 25 surveyed APs complained that they did not receive full compensation and
allowances before handing over the site to the Project. Three new allowances: an accommodation
allowance (VND 12.0 Million per HH), support for purchasing construction material (VND 10.0 Million
per HH), and a training allowance have still not been paid to APs. This was confirmed during the public
meeting held in January 2010.

Table 3.39 fully compensated before start of civil works

Fully compensate before civil works?
Yes No Location
Number of
surveyed HH
HH % HH %
Plant Site 105 103 98.1 2 1.9
Already relocated APs in Mai Lam 25 0 0 25 100

4. Change in source of income

Because many HH lost their productive land, which was their main source of income, several HH have
to change occupations. In the plant site, agriculture was the main source of income for 81% of the APs
before clearance; now only 61% have this main source of income. Several APs became workers and
were hired by companies or by individuals. Secondary sources of income became the first source of
income for some APs.

Among the already compensated APs, most of surveyed HH (23/25) are still working on agricultural
land while two are now hired laborers.



Table 3.40 Source of primary income before and after clearance for already relocated APs

Agriculture Trading Services
Hired
labor
Wages Forestry Aquaculture Government
Source of
primary
income
Surveyed
HH
HH % HH % HH % HH % HH % HH % HH % HH %
Before
clearance
25 24 96 1 4
After clearance 25 22 88 2 8 1 4

Table 3.41 Source of secondary income before and after clearance for already relocated APs

Agriculture Trading Services
Hired
labor
Wages Forestry Aquaculture Government Others
Source of
primary
income
Surveyed
HH
HH % HH % HH % HH % HH % HH % HH % HH % HH %
Before
clearance
25 1 4 12 48 4 16 5 20 1 4
After clearance 25 1 4 1 4 13 52 3 12 1 4 1 4 2 8

5. Impacts on living standards

Nearly half of the APs in the plant site declared that they are in a worse situation than before the
clearance. At the time of the survey, APs in the plant site were in a transition period. They had received
cash compensation but they had also lost their source of income. For some HHs, they had never had
so much money and their living standards have risen, at least temporarily. An article published in June
2008 on Vietnam News showed that some APs in the Nghi Son economic zones made extravagant
purchases. However, most of the APs didnt see any change in their living standards while 45%
estimate that their living standards are worse now. APs have been asking for some programs to help
them change occupations.

In 2009, this situation became even worse. 24 among the 25 already-relocated HH in Mai Lam
Commune declared that their living standards were worse now due to the absence of a restoration
program. They no longer have productive land for cultivation and they have also used part of the money
they received from compensation for daily expenses. This situation has lasted for one year and a half
now.
Table 3.42 Impacts on living standards

Living standards
Same than before Better Worse Location
Number of surveyed
HH

HH % HH % HH %
Plant Site 105 51 48.6 7 6.7 47 44.8
Already relocated
APs in Mai Lam
25 1 4.0 0 0 24 96.0



Main concerns of APs already compensated are follows:

Compensation price for residential land too low

As indicated above, APs are not satisfied with the price of compensation for residential land. This
was confirmed by the replacement cost survey. Prices are from 2 to 3 times lower.

Almost all relocated APs in Mai Lam commune also complained about lower compensation prices
for residential land. They were fully compensated in July 2009 with the compensation rate for
2009. All APs have already received compensation but they are still complaining about the lower
rate for residential land. Because they chose to relocate individually, the compensation received
for residential land was not sufficient to buy a piece of land similar to the one they lost outside the
NSEZ.

However, for APs relocated in an RS, the compensation will be land for land, so APs will not be
affected by the low rate of compensation for residential land. In addition, the RS are provided with
services that APs dont benefit from at their current location (piped water, sanitation). The objective
of the DRC is to move all the APs into an RS.

APs in Mai Lam also complained that the compensation rate they received in 2009 for residential
land was much lower (640,000 to 800,000 VND/m
2
) than the one issued in 2010 for Hai Yen
(1,035,000 to 1,418,000 VND/m
2
). APs from Mai Lam were the first ones to be relocated and
compensated.

Compensation price for structures too low
1

Compensation rates for structures were established at the beginning of 2008. In 2008, the rate of
inflation was high and by the end of 2008, compensation rates for structures didnt reflect market
prices. However, the due diligence survey conducted in October 2009 among 25 HHs showed that
most of them (17/25 HHs, about 68%) were satisfied with the compensation rates for structures.

Compensation for remaining land

APs, especially in Hai Yen Commune, will be relocated in Xuan Lam Nguyen Binh RS located 18
km away from their previous land. Some of the APs have remaining agricultural land not affected
by the project. However, this land will not be acquired by the project. For APs who will be relocated
far away, it will be quite impossible to cultivate the land due to the expenses linked to traveling.
They are asking the authorities to acquire the remaining land.

Relocated APs for Mai Lam Commune also required the Project to acquire remaining agricultural
land.

Concern about their future source of income, especially during the transition period

1
We should note that since the survey (August 2008), the rate of inflation has increased from 20 to 35% in
Vietnam due to the financial crisis.


During the first survey in August 2008, it was assessed that some APs who had already been
compensated had lost their productive land for more than 6 months and were waiting for relocation
in the RS. Relocation can take several months during which APs have no income. They have
money due to the compensation they received. However, they cannot start any new activity
because they are waiting to move. In addition, some APs misused the compensation they
received.

It is necessary to provide assistance to APs regarding managing money and ensuring that APs
use the money properly.

APs received an allowance for the transition period for 6 months to provide for loss of income.
However, it is not known how long the transition period will last. If the transition period lasts more
than 6 months, it will be necessary to extend the transition allowance until the RS is ready.

Jobs in the industrial zone

APs want training to be able to be employed in the industrial zone. They want the NSEZ and
NSRP to tell them in which field they should be trained to be able to be employed.

Older APs are very worrying about their future. According to persons met, it will be difficult for
them to find new jobs.

Re-establishment of livelihood

In the plant site, in 2008, most of the HH would have preferred land for land compensation for
residential land (57.3%). Land for land means a plot of land in one of the 3 serviced resettlement
sites. In the pipeline and marine facility areas, most of the HH prefer cash compensation. The RS
situation in 2009 (delays, environmental problems) probably incited APs to make their own
arrangements.
Table 3.43 Preferred Form of Compensation

Preferred Form of Compensation
Replacement land Cash Compensation Other Location
Number of
surveyed
HH
HH % HH % HH %
Plant site 171 98 57.3 73 42.7 0 0
Marine facility 267 72 27.0 99 37.1 96 36.0
Pipeline 14 3 21.4 11 78.6 0 0.0
Total 452 173 38.3 183 40.5 96 21.2

3.2.4.4 Impact on training and recruitment plan of NSEZ

1. Nghi Son economic zone (NSEZ)
Land acquiring for NSEZ development will make thousands of farmers loss agricultural land. In the
NSEZ, there are about 16,780 HHs (65,861 persons) and 44,593 laborers living in 12 communes of
Nghi Son Economic Zone. On this, 11,786 laborers are looking for a job. Among these 11,786 laborers,
2,551 have been trained and 9,235 are unskilled.



NSEZ Management Board conducted a survey on the labor force in the 3 communes affected by the
project (Hai Yen, Tinh Hai and Mai Lam) and 2 communes (Hai Thuong and Hai Ha) in the vicinity in
April 2008. According to this survey, the number of laborers with training interest is 7,682, of which:

791 laborers have aspiration to follow high vocational college;
2,573 laborers have aspiration to follow intermediate vocational college; and
4,318 laborers to follow primary vocational college.

The survey also shown 1,366 trained laborers are looking for a job, of which:

01 person graduated university;
57 persons graduated higher vocational college;
398 persons graduated intermediate vocational college; and
910 persons graduated primary vocational college.

The above laborers are now working in different provinces in the South. However, if the refinery-
petrochemical complex and other industrial factories need laborers then most of them have to be
retrained.

At present, a center of vocational training college is located in Tinh Gia District. This center is
connected with other vocational colleges at different levels from central to provincial.

Other vocational centers such as Truc Lam Higher Vocational College, Vinashin Shipbuilding College,
and Licogi College of high vocational economics have training programs for laborers who are willing to
work in Nghi Son Economic Zone and Refinery and Petrochemical Project.

2. NSRP LLC

NSRP LLC will implement traning courses for its own employees after recruitment. However, NSRP
LLC will also partially sponsor training programs implemented by local authorities for APs via its
proposed Social Support Program (SSP).

Construction Phase

During the construction phase (2010-2013), 10,000 to 15,000 workers will be required. Most of the
jobs will require specific skills (specialists, engineers, etc.). However, the Project will also need
between 2,000 and 3,000 unskilled workers. This will constitue job opportunity for local people and
especially affected persons.

The construction period will also create a great demand for various services (food, accommodation,
entertainment services, etc.) in order to serve the workers. The construction will generate a 2-3
billion VND turnover/day. Local people and APs could also benefit from this demand by providing
these types of services.

Operation Phase

During the operation phase (from 2014), about 1,000 skilled and unskilled employees will be
employed.

In the middle of 2010, the company will start to recruit and train its staff in Vietnam and overseas.


Priority will be given to local people if the recruitment requirements are met.

The different types of workers needed are presented in Table 3.44. Workers will be hired only if
they meet the company requirements, such as work experience, English ability, academic
background, etc. The recruitment will be spread over the construction period from 2010 to 2013.

Table 3.44 Tentative recruitment plan for Operation phase

Qualification
No Occupation
Number
(person) Graduated
English
(IELTS)
Background
1 Engineer 450 University 4 - 5
Chemical Engineering, Chemical,
Mechanical, Electrical, Civil, etc
2 Operator 180 College 2
Chemical Engineering, Chemical,
Mechanical, Electrical, etc
3 Technician 40 College 2 Chemical, Mechanical
4 Helper 100
High
School
1 -
5 Non-Technical Staff 80 University 5
Economics & Management, Applied
Mathematics, etc
Source: NSRP-LLC, May 2010
Note 1: Evaluation: Entrance Examination & Interview
Note 2: More than 5 years work experience will be required for Occupations 1, 2, 3 and 5

Table 3.45 Period of recruitment during operation phase

2010 2011 2012 2013
1-3 4-6 7-9 10-12 1-3 4-6 7-9 10-12 1-3 4-6 7-9 10-12 1-3 4-6 7-9 10-12 No Occupation
Operation
1
Engineer (450)
10 40 80 70 70 90 90
2
Operator (180)
90 90
3
Technician (40)
40
4
Helper (100)
100
5
Non-technical
staff (80)
20 20 20 20

NSRP will subcontract some services (outsourcing). This will also constitute a source of jobs for local and
affected people. Both skilled and unskilled workers will be required as presented in the following tables.

Table 3.46 Need for skilled workers of contractors

No Occupation Number (person) Recruitment plan
1 Maintenance work 500
2 Fire Fighting 30
From March 2011
3 Marine works 20 From March 2012
4 Clinic 15 From September 2012
- Basic Qualifications will be decided by the contractors
- The number hired will be decided by the contractors.


Table 3.47 Need for unskilled workers of contractors

No Occupation Rough Number Recruitment plan
1 Security 30
2 Canteen 30
3 House keeping 20
From September 2012
Note:
- No special qualifications will be required basically
- The number hired will be decided by contractors.

NSRP Project has the potential to create a major significant positive economic impacts on workers
employed during construction as well as their families. This impact will benefit to the local communities
nearby the NSRP Project but will also be extended to other communities in Tinh Gia District, Thanh
Hoa and Nghe An Provinces as well as other regions in Vietnam.

During the construction phase, the Project will create about 20,000 skilled workers and 3,000 unskilled
workers. The construction period will also create a great demand for various services (food,
accommodation, entertainment services, etc.) in order to serve the workers. Local people and APs
could also benefit from this demand by providing these types of services.

In operation phase, NSRP will create 1,000 direct jobs for skilled and unskilled workers. Besides, there
will be 650 indirect jobs through contracts between NSRP and service suppliers.

When the Project comes into operation phase, it will meet more than 40% of total fuel demand of the
country contributing to ensure national energy security and make a foundation for development of
petrochemical industry and other services The Project will contribute to national budget hundreds of
million US dollars every year through taxes.

Support other training programs

NSRP LLC will have partial financial support for some training courses organized by local
authorities through community support activities. The main purpose of the program is to improve
living standard of local community through social projects. The support will be carried out based on
the consultation of local authorities and people. Community support plan may be training, social
activities and contributing to communitys fund.

However, NSRP LLC will not organize training courses for those applying for jobs before
recruitment. NSRP LLC will train only for recruited employees.

3.2.4.5 Land and natural resources

NSEZ has been established in 2006 by a Government Decree to develop the economic potential of
Thanh Hoa Province. NSEZ covers 18,612 ha on 12 communes. The purpose of this economic zone is
to attract more investment projects to the province. Thanh Hoa Province has invested significantly in
NSEZ to develop infrastructures since 2006. The infrastructures comprise traffic-road works, wave
control dykes, deep-water ports, seaport, raw water supply system, resettlement areas, access roads


etc. Following this Decree, the NSEZ has prepared a Master Plan for the development of the economic
zone including the construction of a Refinery and Petrochemical Complex and port facilities.

NSRP Project will have permanent impacts on the land use, property, and plantations in the Project
Area. Land and natural resource impacts will arise mainly from land take for construction of the refinery
and petrochemical complex (328 ha), the pipeline and road infrastructure (30 ha), and the port facilities
(36 ha), but also from the quarry, borrow pits and disposal area. A total of 394 ha of land will be
required for the Project. Three communes, Hai Yen, Mai Lam and Tinh Hai will be affected by land take.

Agricultural land constitutes the most important land use for these three communes followed by
Forestry land. Land use impacts will affect mostly agriculture, forest planted and residential lands. Key
impacts addressed in this section are therefore:

Loss of agricultural land;
Lost of residential land.

The loss of agricultural and residential lands represents the strongest impacts fell by the affected
population based on the first and the second Stakeholder Meeting and Public Consultation event hold
respectively on 4
th
and 5
th
November 2008 and 27
th
and 28
th
January 2010 for the NSRP Project. Most
of the mitigation and compensation measures are already implemented by the Government of Vietnam
through Thanh Hoa Province People Committee, Tinh Gia District People Committee and Nghi Son
Economic Zone. Recommendations to reduce the impacts associated with land take have been
proposed in the Due Diligence Resettlement Report (February 2010) and will be summarized in this
section of the EIA Report. Only the remaining significant impacts will be presented in that section since
some of the issues (for example: loss of plantation) have been solved by Tinh Gia District Authorities
and agreed with the affected peoples.

3.2.4.6 Loss of agricultural lands to other uses

Project activities

During the pre-construction phase some agricultural lands have been permanently appropriated for the
Project. This area will be used for permanent infrastructure as plant site, pipeline, accommodation for
workers, storage area.

Permanent agricultural lands (including agriculture, forest, marshes) affected by the Project account for
394 ha which represent 75% of the total affected land by the Project. Farmers will see their annual
income significantly reduced by this land take.

Potential impacts

According to the Due Diligence Resettlement Survey, carried out in August-September 2008 amongst
105 households surveyed and affected by land take for the Plant site; 50% of the households surveyed
have lost more than 60% of their agricultural land, and 36% between 31 and 60%. For 58% of the
Households, the remaining land is too small to be viable. Impacts from loss of agricultural land may
include:



Loss of annual and perennial crops;
Decrease agricultural production due to decrease of agricultural land.

No other land agricultural lands are available in the same commune or the same district to replace all
the affected farmers. More than 73% (Plant Site) of the affected people have agricultural activities as
their main source on income so the impact on the APs will be very strong. Considering the number of
households affected from the loss of agricultural land by the Project and the importance of this
economic activity on their income, the significance of this impact is significant for the affected farmers.

3.2.4.7 Loss of forestry land

Project activities

During the pre-construction phase, some forestry lands are going to be permanently appropriated for
the Project. Forestry lands affected by the Project are located in three communes Hai Yen, Mai Lam
and Tinh Hai, on Chuot Chu mountains. Forestry lands will serve as borrow pits for the current Project
as well as other industrial projects in NSEZ.

Permanent forestry lands affected by the Project account for 199 ha which represent 20.6% of the total
affected land by the Project. The three affected communes have a total of 800 ha of forest planted
lands. Most of the planted forests belong to public owners as Tinh Gia District Forest Company.

Potential impacts

According to the Due Diligence Resettlement Survey carried out in February 2009 amongst 105
households affected by land take for the Plant site and other infrastructure, only one percent of the
Affected Households have Forestry as their primary source of income and two percent as their
secondary source of income. On the other hand, the three affected communes will lose 25% of their
forestry lands.

Since very few households having forestry land as their primary or secondary incomes have been
affected by the Project, this adverse impact is assessed as significantly minor.

3.2.4.8 Loss of residential land

Project activities

During the pre-construction phase some residential lands are going to be permanently appropriated for
the Project purposes. Residential lands affected by the Project are located mainly in three communes
Hai Yen, Mai Lam and Tinh Hai. Residential lands will mainly be used for the plant site, the marine
facilities and the pipeline.

The three affected communes have a total of 146.6 ha of residential lands. Residential lands affected
by the Project account for 39 ha which represent 8% of the total affected land by the Project.

About 90% of APs in the project area have a LURC (Land Use Right Certificate). Some are still waiting
for the issuance of the LURC. No APs without any rights on their land have been found.



Potential impacts

According to the Due Diligence Resettlement Report prepared in December 2009, around 2,695 HH
(9,000 persons) will be affected by the project. Among these APs, 687 will lose most of their land and
their main houses and will have to relocate in another location. At the time of the report, clearance
already took place in the plant site and APs have been compensated for their productive land.
Structures were not yet compensated.

Due to the number of households affected by the Project, the significance of this adverse impact is
major.

3.2.4.9 Livelihood activities

Project activities

Project development implies the loss of agricultural, forest planted and residential lands. Construction of
the refinery and petrochemical complex and associated facilities will interrupt the economic activities of
households that reside in the Project area and will be displaced but also for families who utilize land
and resources that will be acquired for NSRP LLC.

Potential impacts

Land clearance for the construction of the refinery and petrochemical complex and associated facilities
will affect 2,695 households (9,000 persons) including the relocation of 687 households that will be
directly affected by economic displacement within the Project area. Most of these households will be
permanently impacted by the Project.

In the project area, the average HH monthly income is around 4,200,000 VND. It is higher than the
average income in the North Central Coast (2,100,000 VND) and for all of Vietnam (3,200,000 VND).
However, from an area to another the household income varies from 2,900,000 to 5,700,000 VND. The
secondary source of income contributes to around one third of the total average HH income.

According to the Department of Labor, Invalids and Social Affairs of Thanh Hoa Province, (DOLISA),
those living in urban areas who earn VND 450,000 per capita per month (around 2,500,000
VND/HH/month) or less are considered poor. In rural areas, the threshold is 350,000 VND per capita
per month (around 1,800,000 VND/HH/month). Average income in all project areas is higher than the
poverty line.

One of the main concerned related to resettlement is the ability of the affected households to re-
establish household incomes and livelihoods following economic displacement. Most of the project
affected people are involved in farming (61%) and aquaculture (13%) which represents their main
source of income.

3.2.4.10 Education

Each affected commune has its own primary school. Secondary schools can be found in the district
town (Tinh Gia).



Within 3 years from the date of handling over the site to the project, all pupils from primary school to
high school who have to move and relocate in the resettlement sites will receive 100% of educational
fees and other contributions. So, impacts on education is considered as minor.

Children whose families resettled have to change their school. This move is affected to their study.
However, from now on, they have more time for study (instead of helping their parents in agricultural
works). Adults will recognize that increasing your knowledge is the best way to find out a job so that
more and more people will take part in vocational courses. NSRP Project is a lever to develop NSEZ
economic therefore NSEZ industrialization develops step by step. Job opportunities are increased
gradually for them to do. Kid gardens, schools and vocational centre will be opened to satisfy their
studying demand.

3.2.4.11 Disruption/Damage to Infrastructure and Services

Project activities

NSRP and its contractors will utilize the existing infrastructure and services present in NSEZ. There will
be heavy vehicles on national, provincial and district roads coming to the Project Site. Most of the
earthworks for site leveling carry out by the NSEZ are on going and will be partly completed when the
NSRP will take over the site.

Potential impacts

Prior to the establishment of the Refinery and Petrochemical Complex, NSRP LLC and its contractors
will need to use local infrastructure and services, especially roads and power lines. Since the Project is
located within NSEZ most of the infrastructure and services are adequate and can be used for such
project.

Disruption of existing infrastructures by the Project will adversely cause short term moderate impact to
the local population as well as industrial activities (Nghi Son Cement Factory) and Nghi Son Port
activities.

3.2.4.12 Gender

In accordance with Vietnams Law on Gender Equality, effective July 2007, and the recent decree for
the implementation of law on gender equality (N70/2008/ND, 4 June 2008), the Project interventions
should contribute to promoting gender equity and opportunities for women.

Constitution and law of the Socialist Republic of Vietnam has defined gender equity is an important part
of social equity. Constitution 1992 has affirmed All male and female citizens have equalitarian right on
every field of politics, economy, society, culture and in the family. All actions of differentiation and
abusiveness dignity to the women are strictly forbidden.

Project activities

In Viet Nam, females are generally responsible for a variety of tasks related to household as children
education, family health, water supply, agricultural activities and income generation.



According to Due Diligence Resettlement Surveys 2008-2009, no significant differences for the level of
education, between men and women head of households, have been noticed. Most of men and women
have a relatively fair level of education (mainly lower secondary). Few women have been identified as
head of households in the Project area.

At the local level, the focal role of gender is undertaken by the Womens Union (WU), there is
organizational structure operated widely from central to provincial, district, commune and village levels.
The WUs of different levels are authorized to officially represent women's interests and voice in national
and local decision-making processes; it receives regular financial support from the state. Women
among affected HH are strongly involved in the WU: more than 90% of women surveyed are involved in
the WU.

Women in the Project area join in all economic activities (agriculture, aquaculture, salty production and
forestry). Moreover, they are also responsible for housework and breed cattle for home economics.

Potential impacts

There are many job opportunities for local women in the construction phase which contributes to
improve and keep stable income source.

Refinery and Petrochemical Development including associated facilities will result in the residential
relocation (or physical displacement) of 687 households (2,800 people). Most of the relocated
households are located in Mai Lam, Hai Yen and Tinh Hai Communes.

Given their large responsibilities in regard to the family, women will be greatly affected specifically by
the relocation of households.

3.2.4.13 Indirect employment and local procurement opportunities

Project activities

NSRP LLC and its contractors will rely on numerous vendors and service providers to meet the daily
operating needs of the Project and also the domestic needs of its employees. In addition, the Project
will induce secondary/tertiary economic activity due the immigration of people from outside the Project
area who will require housing, food, and other supplies.

Potential impacts

Construction of the NSRP Project will create a range of sustained indirect economic opportunities at
local, provincial and national levels. Local sourcing of goods and services will result in revenues for
local businesses and entrepreneurs, provided they can offer sufficient quality and reliability and can
meet Project standards, particularly on health, safety and environment.

There is a risk that local people could be excluded from direct employment benefits because of low
education and technical skill levels. The recent experience from Nghi Son Cement Factory shows that
very few local workers have been employed permanently at the site. The Socio-economic survey
carried during the Due Diligence Resettlement Survey indicates that more than 70% of the surveyed


households are interested to find a job in Nghi Son economic zone. In the same time, more than 77% of
the surveyed households want to be trained to get a new job.

The period corresponding to the end of the construction phase and the start of the operation could be
difficult for the local communities since the workforce will be reduced by more than 70%.

3.2.4.14 Fisheries

In coastal communes and Nghi Son peninsula, most of residents are living by fishery (80-90%). The
remaining is salt-making, aquaculture, trading and agriculture. According to the statistical data from
local authorities, total fishing boats along coastal areas is given in 3.48.

Table 3.48 Number of fishing boats of coastal communities

No Coastal commune Number of boat/ship Capacity (HP/unit)
1 Hai Thuong 52 6 12
2 Hai Yen 6 6
3 Hai Ha 189 40-90
4 Tinh Hai 44 12
5 Nghi Son 217 40-90
Source: Commune People Committee, 2009

In Nghi Son commune, there are 479 floating fish-cages (4,780m
2
) to feed typical fish such as
Lutjanus.sp (Ca Hong), Cephalopholis nigripinnis (ca Mu) and Lutjanidae erythropterus (ca Hanh) are in
Nghi Son sea area.

Potential impact

In the construction phase, the marine construction activities of SPM, crude pipeline, harbor, breakwater,
intake water, outfall system as well dredging activities will significantly reduce fishing areas and disturb
local fishing. The total surface area prohibited for fishing activities is 298 ha at Nghi Son bay. It is noted
that the harbor construction will occupy nearshore fishing ground of local fishermen (see figure below).
In addition, the project shipping activities for the transportation of construction materials, construction
barges at the harbor will increase the shipping density at Nghi Son bay and might interrupt fishing boat
access of local fishermen living in Nghi Son commune. The impact level is assessed as medium.

In operation phase, crude oil offloading at SPM and product exporting at jetties will cause long-term
impact on local fisheries. Crude oil offloading by offshore pipeline takes at least 24 hours and there are


33 large ships mooring at SPM per year. In case SPM is out of work, crude oil from 300,000 DWT ship
will be transferred to 30,000 DWT ship, then led to the harbor. This activity makes number of vessels in
this area (from SPM to the harbor) more increase.

Appearance of sub-marine constructions such as PLEM and 33.5 km paralleled pipelines may be
affected by anchoring of fishing boats or using illegally mines which usually occur in Nghi Son gulf.

As designed, intake channel with 350m in width and 70m in length is constructed between two
breakwaters. Therefore operation of intake system of the project will not cause any effect to shipping
activities in the area.

The presence of effluent discharge system on the sea bottom at the distance of 6km far from the shore
will not cause effect to shipping activities in the area due to all discharge system is buried under the sea
bottom at suitable depth and only discharge outlets are installed at distance of 1m above sea bottom.
However, the presence of discharge outlets on the sea bed and marine facilities will decrease 193ha
surface water of coastal fishing area.

There is no aquacultural activity at project area and location of fishing cages of Nghi Son commune is
toward to the south about 5-6km far from project area. Therefore, normal operation of marine facilities,
intake and discharge system do not cause effect to aquacultural area.

In the case of oil spill occur, it is potential severe impact to shallow water and fishing activities of Nghi
Son gulf and the vicinity. The unloading crude at SPM and regular product loading at harbour will cause
long tern impact to fishing activity in the area.

At Nghi Son gulf, high density of crude and product tankers going in and out of harbour will disturb local
fishing boats and cause high potential risk of shipping collision between tanker and fishing boats. The
impact level is considered as major and long term.

3.2.4.15 Access restrictions and diversions

Project activities

The Project will require acquisition of land and access roads used by local communities for daily
activities and access to services. Directly affected people will be compensated for the loss of lands,
assets and income related to land acquired for the Project; however there will be restrictions to access
within the project area during the construction activities.

Project construction activities will loss access route connecting from Hai Binh and Tinh Hai to road 513,
causing difficulties for local economic development and job opportunities of Hai Binh and Tinh Hai
people. These areas of the EZ will not be connected to the center of EZ until new road is built to
replace.

Potential impacts

The Project construction activities will result in changes in access routes in Tinh Hai, Hai Yen and Mai
Lam Communes. At least, one of these routes is important for the local population and deserves the
centre of Hai Yen, Tinh Hai and Hai Binh Communes, given also access to the south to Hai Thuong,


Hai Ha and Nghi Son Communes. This road is also a short cut to reach Tinh Gia Town, the centre of
the district, by reducing the distance by 4 km.

Two earth roads given access to agricultural lands for the local population will also be located within the
Refinery site.

The significance of this adverse impact is major for the local population since they will loss direct
access to the centre of their communes and services (school, health centre), affect economic activities
along the road (businesses) and increase travel distance to get access to their current economic and
social activities. Moreover, it may be quite difficult for the population living north of the Project to get
access rapidly to employment for NSRP Project during the construction.

There is a positive impact to this situation. The traffic in Hai Binh village should be reduced and
especially for heavy vehicle. Road safety should then be indirectly improved in this village.

3.2.4.16 Impact on health

Health Impact Assessment is considered for the workers and community as follows:
Workers who work in projects onshore and offshore
Community living nearby the Project.

Mai Lam, Hai Yen and Tinh Hai communes with around 1,582 households will be affected by the
project. Among these affected persons, about 1,004 households will lose most of their land and their
main houses and will have to relocate in resettlement location. The rest will be impacted by the project
activities during the construction phase,

Project activities

The immigration of thousand of workers for the construction period and construction activities is the
main source of health impacts

Potential impacts

The displacement of those currently living on the site could lead to health impacts associated with
disruption to their communities and the loss of agricultural land and the loss of income. The inward
migration of large numbers of workers and their family into the area are likely to increase the risks of
infectious disease, gastro-intestinal illnesses, injuries, traffic accidents and psychological disorders
including stress. There will also be health impacts associated with the greater demands on the areas
infrastructure and the general increase in affluence. The physical processes of construction and
operation of the Complex will create impacts on traffic, air quality, waste management and water quality
that will in turn result in potential human health impacts.

In the absence of appropriate mitigation, the overall risks to health from infectious diseases are likely to
be significant for both workers and the local community. The proposed mitigation measures to limit the
spread of infection among workers, control vector populations, provide clean water, implement high
standards of food hygiene and address the risks associated with STDs will substantially reduce the
risks to health. The impact of infectious illnesses on the health of some workers and some members of
the local population would still be significant but risks of contracting a serious infectious illness will be
low for most individuals.


The non-infectious illnesses arising from the Project are likely to include stress, substance abuse,
violence and possible occupational illness. These effects will arise during the construction phase and
continue into the operational phase of the Project, at lesser extend, although the exact effects will
evolve as the workforce and nature of operations change.

Stress, substance abuse and violence are likely to be of greatest importance during the construction
phase. These effects will be largely controlled by planned mitigation measures. Some individuals are
particularly prone to these types of ill health and although the risks of significant effects are minor for
most of the population, they will be moderate for a small proportion of both workers and local residents.

3.2.4.17 Impact on poverty

Project activities

Poverty levels in the Project area are relatively high. According to The Department of Labor, Invalids
and Social Affairs of Thanh Hoa Province, (DOLISA), in 2007, among the 7,704 households in the 5
communes in which there are three effected communes by project, 2,299 (29.3%) are poor households.
The poverty incidence has however decreased from 33% to 29.3% between 2006 and 2007. In the
whole district the poverty incidence was 26% in 2007.

The project is expected to create an average of 22,000 jobs during the construction period and around
33,000 for the peak of the construction period. In addition, the Project will contribute indirectly to create
100,000 jobs in the Project area through business development. These activities will require many un-
skill workers

Potential impacts

The creation of a large number of jobs during construction activities of the Project should contribute
greatly to the reduction of poverty not only in the affected communes but also in NSEZ (12 communes)
and Tinh Gia District.

3.2.4.18 Economic activities

Project Activities

The Complex will enhance the development of a series other industries such as production of
construction materials, light industry, production of home appliances, transportation, tourism, services,
etc., and will create many kind of jobs for 150,000 to 200,000 jobs during the operation period.

NSRP will rely on numerous vendors and service providers to meet the daily operating needs of the
Project and also the domestic needs of its employees. Project employees will likely enjoy a high income
level which will contribute to the demand for local products and services.

Potential Impacts

The implementation of Refinery and Petrochemical Complex will create a range of sustained indirect
economic opportunities at local, provincial and national levels. Local sourcing of goods and services will
result in revenues for local businesses and entrepreneurs, provided they can offer sufficient quality and
reliability and can meet Project standards, particularly on health, safety and environment.



In construction phase, the Project will create about 20,000 jobs for skilled workers and 3,000 jobs for
unskilled worker. Local services such as food, entertainment, accommodation will also develop to
supply for demand of these work force. This is an opportunity for local people to change job from
agriculture to industry and other services.

In operation phase, NSRP will create 1,000 direct jobs for skilled and unskilled workers. Besides, there
will be 650 indirect jobs through contracts between NSRP and service suppliers.

In construction and operation phase, NSRP will recruit a number of skilled workers and foreign
engineers for operating the plant. However, the quantity of these employees are limitted to ensure
creating job opportunities for national and local employees. NSRP LLC commits to strictly obey the
Vietnamese labor Law in recruiting project employees and will not recruit non-skilled foreign people for
NSRP.

When the Project comes into operation phase, it will meet more than 40% of total fuel demand of the
country contributing to ensure national energy security and make a foundation for development of
petrochemical industry and other services The Project will contribute to national budget hundreds of
million US dollars every year through taxes.

3.2.4.19 Infrastructure and Service

Project activities

NSRP will utilize the existing infrastructure and services present in NSEZ during the operation.
However, most of the import/export activities will be done through the new harbor facilities. There will
also be additional heavy vehicles on national, provincial and district roads coming to the Project Site
and going to the consumers.

Potential impacts

The Project will aim to result in no reduction in the quality, quantity or availability of existing local
infrastructure. The Refinery and Petrochemical Complex will operate its own power plant as well as
water supply and water treatment system. Moreover, NSRP will operate its own port for product export.
Importation of oil from Kuwait will come directly from the sea through a Single Point Mooring Station
and a pipeline system.

Minor adverse impact is anticipated for the operation period due to the increase of traffic on local roads,
Provincial Road 513 and National Highway 1A.

Improvements to roads and provision of new community infrastructure such as school are expected to
offset any long-term impacts associated with infrastructure and services that may arise from the Project.


3.2.5 POTENTIAL ENVIRONMENTAL ACCIDENTS CAUSED BY PROJECT IMPLEMENTATION

3.2.5.1 Fire and Explosion

Potential source

Fire & explosion risks including the accidental release of syngas (containing carbon monoxide and
hydrogen), oxygen, methanol, and refinery gases from process operation will cause serious accident,
even catastrophic accidents. Potential sources of fire and explosion of NSRP are identified from as
follows:

Process units: CDU, LPG Recovery and Treatment Unit; KHDS, GOHDS, RHDS, RFCC, PPU,
SHU and Ind Alk, HMU, HCDS, NAC;
Storage Tanks and pumping system;
Fuel gas system;
Berth Area;
Spheres;
Propane loading;
Fuel Gas system.

Potential impacts

Based on the Coarse Quantitative Risk Assessment (QRA) report for NSRP Refinery and
Petrochemical Complex Project - August 2009 [13] undertaken by ABS Consulting Limited, the
explosion risk to the workers is dependent on the protection afforded by various building as is thus
dependent on building types. All the occupied buildings at this site have very low explosion risk. The
over-pressure results are all lower than the anticipated damage from a 10
-4
per year explosion
scenario. Operator Shelter in the Jetty Area falls within the ALARP range for which mitigation should be
considered to reduce the risks to as low as reasonably practicable. All the other occupied buildings are
considered to be exposed to negligible risk from fire and explosion events.

For the buildings at the site, there are a number of buildings at the site that require risk reduction
measures. This includes 13 buildings where risk mitigation must be undertaken and 19 buildings where
risk mitigation should be considered, and implemented as necessary, in order to demonstrate that the
buildings risk status is ALARP. Even though the explosion risk at NSRP is low, it is recommended that
best industrial practice should be used and building classification not be downgraded based on the
results of this risk assessment

For the societal risks, the village is considered to have approximately 320 dwellings with 5 people each
on average. The construction of the dwellings is assumed to be basic, affording little protection from
fire or toxic gas ingress. The F-N curve shows that the societal risks to the village population from the
NSRP are unacceptable (Figure 3.13).



Figure 3.13 F-N Curve (Road users and villagers)
Notes:
The risk levels in the F-N curve are represented as follows:
- Red Region: Unacceptable;
- Yellow & Green Region: Acceptable according to UK HSE document R2P2 definition;
- Green Region: A conservative acceptability criteria used by some companies.

For the local commune to the East of the site (Area C)

The risk to the village population, both in terms of individual and societal is unacceptable. Assuming
that the site location has been decided, the risk from the NSRP site to the village population are
such that reasonable measures of reducing risks to an acceptable level could be impractical. The
Societal risks can be reduced by reducing the population and reducing the frequency and
magnitude of hazards from the site. However, the risk assessment here does not take account of
the fact that the village is in the middle of wooded area which is susceptible to fire escalation. In
light of this relocation of the village to a safer place should be given a serious consideration.

For the Road to the South of the plant (Area B)

The societal risks, excluding the village to the east (Area C) are shown to within the acceptable
band of values. This implies that the numbers of fatalities at the road from hazards from NSRP site
are not likely to be excessive. However the Individual Risk is greater than the acceptance criteria
for the general population and therefore risk reduction measures should be considered where cost
effective.

The Location Specific Individual Risk (LSIR) shows that the maximum LSIR at the 513 road area is
5x10
-3
/year. The occupancy ratio considered for the 513 road is 0.006 based on the traffic moving
at 60 km/hour and any one individual traveling twice a day, six days per week across the site on
this road. Therefore, the maximum individual risk at the road is 3x10
-5
/year which corresponds to
the ALARP region based on the risk tolerability criteria.


In order to mitigate these risks, NSRP will establish an Emergency Response Plan for different
scenarios and mobilize human resource as well as response equipment to avoid/prevent environmental
risk and societal risks.

When spheres containing LPG and Propylene are in danger, all gases in the spheres will be released
and routed to HC Flare system to burn for safe of the Plant.

3.2.5.2 Toxic gas leakage

Potential source

Potential sources for toxic gas release are from following process units: CDU, SWS, ARU, SRU, RFCC,
GOHDS, KHDS and RHDS unit.

Potential impact

During the operation phase, workers may be exposed to chemical hazards (through inhalation, or
contact with chemical or catalysts). The risk of caustic and chloroethane in process may result in
occupational health for workers such as personnel injury, cancer, odor nuisance, etc. The chemical
hazards during process activities cause Workers occupational health.

Based on Toxic Gas (H
2
S) Dispersion modeling results for the 150mm hole size run by ABS Consulting
Limited [Ref.13], the ERPG-2 and 3 contours to the Amine Acid gas on the SRU unit considering a
150mm hole size release is presented in Figure 3.14.

Figure 3.14 ERPG-2 and ERPG-3 Contours to the Amine Acid Gas on the SRU Unit

In the case of H
2
S release at the ERPG-3 on the SRU unit, the health risk distance to project workers is
in the range of plant boundary and Coc Mountain. While at the ERPG-2, health risk distance is over
plant boundary in the range of 1,702m.



3.2.5.3 Hydrocarbon Spills

Potential source

When project comes into operation phase, offloading crude at SPM, presence of crude pipeline under
sea water, loading refinery products at harbor and shipping activities are the main sources of oil/refined
product spills. Following oil spill scenarios are chosen for oil drift modeling:

1. Oil spill at SPM
2. Crude pipeline interruptive
3. Shipping collision at access channel or at harbor area

During the loading/unloading period the tanker will be connected to only one line, meaning that the bow
of the vessel will normally always point towards the current. This again means that any oil spilled will go
along the hull of the vessel, so any boom formation should be positioned at the stern of the vessel. Also
it is essential to have an assisting vessel stand-by with environmental equipment during
loading/unloading procedure. The stand-by vessel can, by the use of an anchor or similar, deploy some
booms behind the tanker to prevent spreading of the leaked oil. However, a second vessel will normally
be required for emergency oil spill response operation.

Potential impacts

Owing to location of scenario 2 and 3 are very closely to shore and only location of scenario 1 is 33.5
km offshore. So in the case of oil spill occurred, spilled oil will be easy to drift to shore. The detail oil
drift modeling result will be mentioned and discussed in separately OSCP report.

If oil spill occurred at SPM with Tier II, spilled oil might drift as follows:

In Northeast monsoon (October to March), spilled oil will drift to the shoreline of Nghi Son bay
in the first day toward to the south direction (Figure 3.15). All Nghi Son bay will be affected by
spilled oil in the first and second day. Spilled oil might drift to Nghe An shoreline at the forth or
fifth day depending on wind and wave states.

In the Southwest monsoon (May to July), spilled oil will drift toward the vulnerable resources in
Me island and shoreline of Nghi Son bay in the day 1 and then toward to the North (Figure
3.15). Spilled oil may reach shoreline of Ninh Binh after 4-5 days and Thai Binh shoreline after
8-9days with about 60% of remained oil.



Figure 3.15 Oil drifting in the case of oil spill at SPM in October and July

Figure 3.15 shows that in the case of oil spill occurred at SPM all Nghi Son bay will be affected by oil.
The impact level much depends on oil spill tier and response measures. Generally, the main threat
posed to living resources by the persistent residues of spilled oils is one of physical smothering leading,
in cases of severe contamination, to death through the prevention of normal functions such as feeding,
respiration and movement. Some species affected by contacting with polluted marine water surface, are
organism living at coastal area, coral reef around Me archipelagoes and floating fish cages aquaculture
located in Nghi Son bay.


The amount of recoverable plants and animals after oil spill incident as well as time for environmental
balancing depend on the point of time that the incident occurring and its recovery level, as well as the
restoring capability of each species. Species has a capability of rapidly reproducing and growing can
repopulate an area rapidly when pre-spill conditions are restored, in contrast with slowly growing
species which can just recover the quantity after many years. Summary of spilled oil to sensitive marine
resource is as follows:

Plankton

When oil spill incident happened, polluted oil can directly impact on planktons due to the different
oil sensitivity of specific species or indirectly affect on a special species. The coastal area is easier
to affect by drifting oil than other areas, in particularly the area where sand and mud are affected by
low tide. While plankton (phytoplankton and zooplankton) living in submerged tidal areas are
capable to suffer unfavourable conditions in a short time. They can die if affecting by toxic oil
compounds or suffocating by oil and emulsions.

This problem will lead to the risk of shortage of natural nutrient resources for aquatic organisms as
well as lacking of important food source for aquacultural area by extensive and improvement
extensive aquacultures. In addition, many algae and zooplanktons, which are very abundant in this
rainy season and used as food for young fishes and shrimps in breeding season, were died or
disappeared.

Larvae, Fish Eggs and Young Fish

Contrary to adult fish, larvae, fish eggs and young fish are very sensitive and vulnerable to oil spill.
An important caution should be taken into account is that if the incident happened in spawning
season of many aquatic species from April to June (Pham Thuoc). At this time, prawn and fish
parents usually come to coastal area, in particularly estuaries for breeding. Thus, polluting oil
causes serious and permanent damages to prawn and fish ecosystem in the region makes
exhaustion the natural post larva and fingerling source in the future.

Benthic

High quantity of suspended solid in water will increase the speed of the oil coagulation and
settlement process. Light refined products containing high quantity of toxic substances can affect to
mussel, sea urchins and sea worms. The penetration of oil into sediments can cause long-term
effects in several years, and is capable to create death and infectious diseases to high economic
value species. Oil settlement process can make benthic suffocating.

When being affected by oil, benthic can loose consciousness so that they are removed out of rock
surface or drift out their caves. At that time, they are easy to become food for predators, or to drift
to unfavourable living conditions areas. The complete recovery of the regular balance can take
many years.

Coral reef

Oil spills from harbour and access channel will cause major impact to coral reefs, since spilled oil
can spread quickly to tidal beaches, floating fish cages and water area surrounding islands. The
magnitude of the damage depends on volume of spilled oil. As result, such accident could kill


shrimp and fish. Fishing grounds will be lost or fish will migrate to other area due to oil pollution.
Coral reefs and organisms will be serious affected.

In the case of oil spills occurs at pipeline route and SPM in the northeast monsoon, spilled oil will
cause strongly impact to coral reef at Hon Me islands.

Sea-birds

Sea birds living in this area can be affected at locations where oil drifted in large quantity, but
effects will not be serious because almost of sea birds are sea sparrows, a bird species rarely
contact with oil spill on the sea surface.

However, polluting oil can affect to some kinds of bird living at bayside and estuaries such as
storks, herons, etc. because food and the surface are polluted. They would have to eat oil
contaminated food or staving to death when staying at this tainted ecosystem.

3.2.5.4 Ship Collision

It is important to note that the shipping activities at harbor and access channel in construction and
operation phases might cause high risk of ship collision and oil spill. The density of petroleum products
is generally lower than that of water, so in the case of product spillage into the sea; the product itself is
extremely volatile at ambient temperature and always floats on the surface. Since it is quickly dispersed
into the air, the risk of long-term environmental impact to sea water quality will be significant. The detail
oil spreading and assessment will be mentioned in detail in Oil spill Response plan.

3.2.5.5 Pipeline Rupture or Leakage

The main causes of pipeline rupture and leak are corrosion (internal and external), construction
damage, weld failure, incorrect operation, and third damage party like ship anchors and bottom trawls.

Although partly pipelines are generally buried and incidents are relatively rare, they cannot be
considered as fit and forget. Unless inspected and maintained, all pipelines may eventually suffer from
leaks or ruptures. Engineering studies have identified 22 types of threat to the integrity of a pipeline,
which are recognised in the American engineering code. Grouped into nine threat classes, these are:

External Corrosion;
Internal Corrosion;
Third Party Damage;
Stress Corrosion Cracking;
Manufacturing Defects;
Construction Defects;
Equipment Failure;
Incorrect Operation;
Weather Related / Ground Movement.

Some of these threats are considered to be time dependent (for instance, corrosion; a small area of
corrosion could grow over time to cause a failure) while some are time independent (for example, Third
Party Damage; a pipeline being struck by equipment during building construction near an established


pipeline would be characterized as a random event not dependent of the build-up of a condition over
time).

In the worst case, crude pipeline is broken during unloading crude at SPM. Affected area and impact level are
mentioned in item 3.2.5.3. Response scenarios will be presented in separately report of oil spill response plan.

3.2.5.6 Radioactivity

There are some activities related to radioactivity such as carrying out NDT (Non-destructive Testing) for
tank, bullet, etc. Radioisotopes used by specialist EPC Contractor or Sub-contractors and these
activities may cause hazard to employee and public due to exposure to high level of radiation. Activities
radioactivity detected flaws of materials are RT (Radiographic Testing), PT (Liquid Penetrant Testing),
MT (Magnetic Particle Testing) and UT (Ultrasonic Testing).

Radiation exposure may arise to injury or serious illness to workers during the Construction phase.
Since it is always carried out by trained and skilled employees, the significance of the impact is
considered as moderate.

The recommendations made by NSRP are given to EPC Contractor for Handling and usage in
accordance with Vietnamese Decree No. 50/1998/ND-CP dated July 16, 1998, Vietnamese Standards
(TCVN 6866:2002): Radiation protection Dose limits for radiation workers and public and Circular No.
04/2008/TT-BLDTBXH dated February 27, 2008 guiding procedures for registration and verification of
machines, equipment and supplies subject to strict labour safety requirements.

With handling and usage of radioactivity in accordance with Vietnamese regulatory requirements, the
residual impact of radioactivity during construction phase is assessed as minor.

3.3 EVALUATION OF DETAILED AND CONFIDENCE LEVEL OF THE ASSESSMENT

3.3.1 Determination of impact significance

The assessment considers project-related impacts that are positive, negative, direct, indirect,
cumulative, synergistic, reversible, and irreversible. The significance of an impact depends on the
intrinsic value of the affected ecosystem component(s) (i.e., sensitivity, uniqueness, rareness, and
reversibility) and also on the social, cultural, economic, and aesthetic values attributed to the
component(s) by the population. The significance of impact also depends on whether the affected
environmental components have already undergone modifications. Impact significance has been
established by using the following criteria:

The component is recognised by a law, policy, regulation, or official decision (e.g. a park,
ecological reserve, rare or endangered species, habitat for fauna or flora, archaeological site, or
historical site);
The risks to the health, security, and well-being of the population;
Magnitude of the impact (i.e., spatial dimension such length or area);
Duration of the impact (i.e., temporal aspect and reversibility);
Frequency of the impact (e.g., intermittent occurrence);


Probability of the impact;
Indirect effect on other components (i.e., link between the affected component and other
components);
Sensitivity or vulnerability of the component;
Uniqueness or rareness of the component;
Durability of the component and the ecosystems;
Value of the component to the community

This methodology considers the intensity of the impact which integrates the degree of perturbation and
environmental value criteria used for determining the intensity and significance of impacts are the
following: The degree of perturbation assesses the magnitude of the modifications brought to the
structural and functional characteristics of the affected component. The environmental value indicates
the relative importance of the project-affected component and reflects both intrinsic and social values.

The significance of impacts considers also the extent of an impact that indicates the distance or relative
area over which an impact will apply and the proportion of the component that will be affected, and the
duration which specifies the temporal dimension of the impact

3.3.2 Assessment Method

Following methods are used for assessment for NSRP project:
1. Statistical method: is used to treat the environmental analytical data, and the meteo-hydrological
and socio-economic data;
2. Model method: is used to calculate and stimulate the air emission processes, the wastewater and
the thermal dispersion caused by project activities. Some mathematic models are used for
preparing this report including:
To assess air quality, the Atmospheric Dispersion Modeling System (ADMS) from CERC
(Cambridge Environmental Research Consultants) with the UK Meteorological Office,
National Power plc and University of Surrey is used by FWL. The first version of ADMS was
released in 1993 and the current model is ADMS version 4.
To assess thermal effects to Nghi Son Bay seawater, US Environment Protection Agencys
CORMIX model has been used by FWL.
To assess explosion risk to the workers and community, Fire risk (BLEVE) model is used to
predict to affect the neighboring village. Coarse Quantitative Risk Assessment (QRA) has
been undertaken by ABS Consulting Limited for NSRP Refinery and Petrochemical Complex
Project.
To assess oil spill effect in the Nghi Son bay, an oil drifting model is undertaken by CPSE to
calculate different oil spill scenarios from project marine facilities.
To assess dredged material dumping by used mud and fluid dispersion model of Kverner
Engineering A.S, Environmental Sandefjord, Norway. This model is carried out by CPSE for
maintenance dredged material dumping every 4 years.
3. Field survey and measurement method: is used to take samples, measure on site and analyze at
the laboratories (air, water, soil, sediment and biology samples) at the project area. Moreover,


this method is used to survey vegetation cover, take the photographs and interview in the field
trips for colleting the existing environmental and socio-economic situation;
4. Social investigation method: is used to interview the authorities, departments and local residents
at the project area;
5. Comparative method: is used to evaluate environmental quality of air, soil, water, sediment, and
biology on the basis of comparison with current Vietnamese and International environmental
standards.
Above methods are used in order to quantify environmental characteristics of the project area as well
as forecast impacts of air emission, wastewater and cooling water discharged to receiving environment.
Confident level of these methods can quantitative evaluate during project implementation.

Almost Environmental impacts and risk assessments for NSRP are quantified by calculating and
modeling based technical data and surveyed studies.

Approved EIA Sec 3 EG Trans 28-9-2010 Sec.3-Final

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ENVIRONMENTAL IMPACT ASSESSMENT Page 3-1

NGHI SON REFINERY AND PETROCHEMICAL COMPLEX Final Report

ENVIRONMENTAL IMPACT ASSESSMENT Page 3-84

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