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Environmental Management Plan
August 2021
Viet Nam: Lotus Wind Power Project
Lien Lap, Phong Huy, and Phong Nguyen Wind
Power Projects – Waste Management Plan –
Operation Phase
Prepared by ERM Vietnam for the Asian Development Bank.
This environmental management plan is a document of the borrower. The views expressed herein
do not necessarily represent those of ADB's Board of Directors, Management, or staff, and may
be preliminary in nature. Your attention is directed to the “terms of use” section on ADB’s website.
In preparing any country program or strategy, financing any project, or by making any designation
of or reference to a particular territory or geographic area in this document, the Asian
Development Bank does not intend to make any judgments as to the legal or other status of any
territory or area.
PUBLIC. This information is being disclosed to the public in accordance with ADB’s Access to Information Policy.
Waste Management Plan –
Operation Phase
Lien Lap, Phong Huy, Phong Nguyen Wind
Power Projects
29 July 2021
Project No.: 0552758
The business of sustainability
Document details
Document title Waste Management Plan – Operation Phase
Document subtitle Lien Lap, Phong Huy, Phong Nguyen Wind Power Projects
Project No. 0552758
Date 29 July 2021
Version 4.0
Author ERM Vietnam
Client Name PCC1 and Renova
Document history
Version Revision Author Reviewed by ERM approval to issue Comments
Name Date
Draft 0.0 Thuy Bui Phu Hoang, Hai Pham 05.05.2021 Draft for Client’s
J.P. Gonzales review
Draft 1.0 Thuy Bui Phu Hoang, Hai Pham 14.05.2021 Draft for ADB’s
J.P. Gonzales review
Draft 2.0 Thuy Bui Phu Hoang, Hai Pham 06.07.2021 Updated version
J.P. Gonzales based on ADB’s
comments
Draft 3.0 Thuy Bui Phu Hoang, Hai Pham 23.07.2021 Updated version
J.P. Gonzales based on ADB’s
comments
Draft 4.0 Thuy Bui Phu Hoang, Hai Pham 29.07.2021 Final submission
J.P. Gonzales
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Signature Page 29 July 2021 Waste Management Plan – Operation Phase Lien Lap, Phong Huy, Phong Nguyen Wind Power Projects Hai Pham Partner in Charge ERM Vietnam 3rd Floor, Saigon Finance Centre 09 Dinh Tien Hoang, Dakao Ward District 1, Ho Chi Minh City Vietnam © Copyright 2021 by ERM Worldwide Group Ltd and/or its affiliates (“ERM”). All rights reserved. No part of this work may be reproduced or transmitted in any form, or by any means, without the prior written permission of ERM www.erm.com Version: 4.0 29 July 2021 Project No.: 0552758 Client: PCC1 and Renova
Waste Management Plan – Operation Phase
Lien Lap, Phong Huy, Phong Nguyen Wind Power Projects
Document No.: [Document Code]
Revision No.: 1.0
Effective Date: 00/00/0000
Waste Management Plan – Operation Phase
Lien Lap, Phong Huy, Phong Nguyen Wind Power Projects
Document history
Rev. Date of Author PCC1 and Renova approval to issue Reason for change
change
Reviewed by Approved by Issue Date
1.0 00.00.0000 ERM - - 00.00.0000 Fist Issuance
www.erm.com Version: 4.0 29 July 2021
Project No.: 0552758 Client: PCC1 and RenovaWASTE MANAGEMENT PLAN – OPERATION PHASE CONTENTS
Lien Lap, Phong Huy, Phong Nguyen Wind Power Projects
CONTENTS
1 OBJECTIVES AND SCOPE ......................................................................................................... 4
1.1 Introduction .................................................................................................................................... 4
1.2 Purpose ......................................................................................................................................... 6
1.3 Scope............................................................................................................................................. 6
2. REFERENCES ............................................................................................................................. 7
3. APPLICABLE REQUIREMENTS AND STANDARDS ................................................................ 8
3.1 National Legislation ....................................................................................................................... 8
3.2 International Standards .................................................................................................................. 8
4. DEFINITIONS ............................................................................................................................... 9
5. ROLES AND RESPONSIBILITIES ............................................................................................ 10
6. WASTE MANAGEMENT ............................................................................................................ 13
6.1 Waste Streams of the Projects .................................................................................................... 13
6.2 Waste Management Requirements ............................................................................................. 13
6.2.1 Waste Management Strategy ..................................................................................... 13
6.2.2 Waste Classification.................................................................................................... 14
6.2.3 Waste Collection and Storage .................................................................................... 16
6.2.4 Waste Transportation and Disposal/Treatment ........................................................... 18
6.2.5 Management of Specific Waste Streams .................................................................... 20
6.2.6 Safety Management Related to Waste ....................................................................... 21
6.3 Waste Vendor Selection and Audit .............................................................................................. 21
6.3.1 Waste Vendor Selection ............................................................................................. 21
6.3.2 Waste Vendor Audit .................................................................................................... 24
6.3.3 Hazardous Waste Generator Registration .................................................................. 24
7. MONITORING AND REPORTING ............................................................................................. 25
7.1 Monitoring .................................................................................................................................... 25
7.2 Audit ............................................................................................................................................ 28
7.2.1 Internal Audit ............................................................................................................... 28
7.2.2 External Audit ............................................................................................................. 28
7.3 Reporting ..................................................................................................................................... 28
7.3.1 Internal Reporting ....................................................................................................... 28
7.3.2 External Reporting ...................................................................................................... 29
8. TRAINING AND DISCLOSURE ................................................................................................. 30
8.1 Training and Communication ....................................................................................................... 30
8.1.1 Training ....................................................................................................................... 30
8.1.2 Communication ........................................................................................................... 32
8.2 Community Disclosure ................................................................................................................. 32
9. MANAGEMENT REVIEW .......................................................................................................... 33
10. RECORDS AND DOCUMENTATION ........................................................................................ 34
APPENDIX A THE PROJECTS’ MAP
APPENDIX B TEMPLATE OF HAZARDOUS WASTE LABEL
APPENDIX C DOMESTIC AND NON-HAZARDOUS INDUSTRIAL WASTES TRANSFER
RECORD
APPENDIX D HAZARDOUS WASTE MANIFEST
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Project No.: 0552758 Client: PCC1 and RenovaWASTE MANAGEMENT PLAN – OPERATION PHASE CONTENTS Lien Lap, Phong Huy, Phong Nguyen Wind Power Projects APPENDIX E EXAMPLE OF WASTE VENDOR AUDIT CHECKLIST APPENDIX F ENVIRONMENTAL PROTECTION REPORT List of Tables Table 1.1 Overview of the Projects ................................................................................................................ 4 Table 1.2 Update on Land Area for Operation Phase .................................................................................... 5 Table 3.1 List of National Legislation ............................................................................................................. 8 Table 5.1 Roles and Responsibilities ........................................................................................................... 11 Table 6.1 Waste Streams of the Projects .................................................................................................... 13 Table 6.2 Waste Classification Guidance .................................................................................................... 15 Table 6.3 Location and Number of Waste Container Requirements ............................................................ 16 Table 6.4 Criteria of Waste Vendor Selection .............................................................................................. 22 Table 7.1 Compliance Rating ...................................................................................................................... 25 Table 7.2 Monitoring Program ..................................................................................................................... 26 Table 7.3 Internal Auditing Program ............................................................................................................ 28 Table 8.1 Waste Management Training Matrix ............................................................................................ 31 List of Figures Figure 5.1 Operation Organisation Chart of the Projects .............................................................................. 10 www.erm.com Version: 4.0 29 July 2021 Project No.: 0552758 Client: PCC1 and Renova
WASTE MANAGEMENT PLAN – OPERATION PHASE CONTENTS Lien Lap, Phong Huy, Phong Nguyen Wind Power Projects Acronyms and Abbreviations CSR Corporate Social Responsibility E&S Environmental, health and safety, and social EHSS Environment, Health, Safety and Social EHS Environment, Health and Safety EIA Environmental Impact Assessment EPP Environmental Protection Plan GIIP Good international industry practice IESE Initial Environmental and Social Examination JSC Joint Stock Company OHS MP Occupational Health and Safety Management Plan O&M Operation and Maintenance MP Management Plan PCC1 Power Construction JSC No.1 PPE Personal Protective Equipment PS Performance Standard www.erm.com Version: 4.0 29 July 2021 Project No.: 0552758 Client: PCC1 and Renova
WASTE MANAGEMENT PLAN – OPERATION PHASE OBJECTIVES AND SCOPE
Lien Lap, Phong Huy, Phong Nguyen Wind Power Projects
1 OBJECTIVES AND SCOPE
1.1 Introduction
The Power Construction JSC No. 1 (PCC1) and Renova Renewables Vietnam 1 Pte. Ltd. (Renova)
(collectively referred to as the “Sponsor”) are developing three wind power projects located in the
mountainous area of Huong Hoa District, Quang Tri Province with a total installed capacity of 144MW
(collectively referred to as the “Projects”). To manage and operate the Projects, the Sponsor has
established three project subsidiary companies (individually referred to as the “Project Owner” or
collectively as the “Project Owners”). In addition, the Project Owners have contracted with two
companies i.e. Bao Lam Hydropower JSC (Bao Lam or BOP) and Vestas Wind Technology Vietnam
(Vestas) for operation and maintenance (O&M) of three Projects. Details are described as below.
No. Project Project Owner O&M Contractor
1 Lien Lap Wind Power Project Lien Lap Wind Farm Joint Stock Vestas Wind Technology
(“Lien Lap”) Company (JSC) (“Lien Lap Vietnam (Vestas): be
JSC”) responsible for O&M of
turbines; and
2 Phong Huy Wind Power Phong Huy Wind Farm JSC
Project (“Phong Huy”) (“Phong Huy JSC”) Bao Lam Hydropower JSC (Bao
Lam or BOP): be responsible
3 Phong Nguyen Wind Power Phong Nguyen Wind Farm JSC for O&M of other facilities (e.g.
Project (“Phong Nguyen”) (”Phong Nguyen JSC”) the T/L, and Operation House)
The Project Owner established a Wind Farm Level Team for managing all activities associated with the
operation of all three Projects. The operation of the Projects will be mainly taken place at:
Three wind farm areas, where wind turbines located.
An Operation House located in Cua village, Huong Tan Commune, Huong Hoa District, Quang Tri
Province. This is a shared facility of all three Projects but registered under Phong Nguyen Project.
Transmission Lines (the T/L) connecting the Projects with substations. These substations are
invested and managed by other wind farms projects in the local area and will not be included in the
scope of this document.
See descriptions of these facilities in Table 1.1 and Table 1.2 .
Detail site map and facility for operation of each Project are provided in Appendix A.
Table 1.1 Overview of the Projects
Project Lien Lap Wind Farm Phong Huy Wind Farm Phong Nguyen Wind
Project Project Farm Project
Project Owner Lien Lap Wind Farm JSC Phong Huy Wind Farm Phong Nguyen Wind
JSC Farm JSC
Operation House ■ Located in Cua village, Huong Tan Commune, Huong Hoa District
■ Total footprint: 9,407 m2
Wind farm Location Tan Lap, Tan Lien, Huong Huong Tan and Tan Huong Phung and Tan
Tan Communes and Khe Thanh Communes. All Thanh Communes. All
Sanh Town. All areas are areas are located in areas are located in
located in Huong Hoa Huong Hoa District. Huong Hoa District.
District.
Approval of Decision No. 254/UBND- Decision No. 252/UBND- Decision No. 253/UBND-
Intention of CN dated on 02 Feb 2021 CN dated on 02 Feb 2021 CN dated on 02 Feb 2021
Investment by Quang Tri Province
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Project Lien Lap Wind Farm Phong Huy Wind Farm Phong Nguyen Wind
Project Project Farm Project
People’s Committee by Quang Tri PPC by by Quang Tri PPC by
(PPC) Quang Tri PPC Quang Tri PPC
Approval of EIA/ (EPP) Decision No. (EIA) Decision No. (EIA) Decision No.
EPP 2690/GXN-STNMT dated 1017/QD-UBND dated 17 1016/QD-UBND dated 17
23 August 2019 by April 2020 by Quang Tri April 2020 by Quang Tri
Department of Natural PPC PPC
Resources and
Environment of Quang Tri
Province.
Project Operation ■ 12 wind turbines with ■ 12 wind turbines with ■ 12 wind turbines with
Facilities1 total installed capacity of total installed capacity total installed capacity
48 MW. of 48MW. of 48 MW.
■ Internal road connecting ■ Internal road ■ Internal road connecting
turbines of 7,284 m. connecting turbines of turbines of 10,892 m.
7,659 m.
■ Transformers 0.72/35 ■ Transformers 0.72/35
kV. ■ Transformers 0.72/35 kV.
kV.
■ Transmission line (T/L) ■ T/L 35kV: 1,174 m
35 kV: 10,330 m (i.e. ■ T/L 35 kV: 1,963 m underground cables
1,200 m 35 kV underground cables connecting transformers
underground cable connecting 0.72/35 kV at each
connecting turbines to transformers 0.72/35 kV turbines to the overhead
overhead T/L, and 9,130 at each turbine to T/L 35 kV and 9,750 m
m 35 kV overhead T/L overhead T/L 35 kV and overhead T/L
connecting to Huong 5,510 m overhead T/L connecting to Huong
Tan Substation 35/110 connecting to Huong Tan Substation 35/220
kV). Tan Substation kV.
35/220kV.
Land Agreement ■ Contract No. 20/HDTD ■ Contract No. 02/HDTD ■ Contract No.
Contract dated 3 Mar 2021 dated 18 Jan 2021 03/HDTD dated 18
Jan 2021
Total area of land for the operation phase will be presented in Table 1.2.
Table 1.2 Update on Land Area for Operation Phase
Component Land area (m2)
Lien Lap Phong Huy Phong Nguyen
Turbine foundation 123,038.60 37,035.00 72,824.00
Internal road 186,382.70 125,958.00 91,201.00
35kV TL and pylons 700 228.00 128.00
Subtotal within Project 310,121.30 163,221.00 164,153.00
Boundary (1)
Other pylons and TL ROW 12,681.30 - -
(2)
1 The access roads being used for Lien Lap, Phong Huy, and Phong Nguyen WPPs will be handed over and fully managed by
local authorities once completed.
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Component Land area (m2)
Lien Lap Phong Huy Phong Nguyen
Total 322,802.60 163,221.00 164,153.00
Note:
(1): These data were covered in Land Agreement Contracts mentioned in Table 1.2.
(2): These data refer to 15 pylons and RoW located outside of the Project’s boundary for Lien Lap project
only. Refer to Addendum of LREMDP Lien Lap for further details. These data will be updated once CSR
documents are available.
1.2 Purpose
This Waste Management Plan (the “Plan” or Waste MP) is intended to set out responsibilities and the
management practices associated with the management of waste during operation and maintenance
(O&M) of the Projects. This Plan is developed to:
Ensure that the Projects comply with applicable environmental, health and safety, and social (E&S)
requirements defined in Section 1;
Ensure that all personnel involved in the operation of the Projects, including Wind Farm Level Team
and any contractors and subcontractors working for or on behalf of the Projects will fully understand
Project Owner’s expectations on waste management; and
Implement applicable Good International Industry Practices (GIIPs) to manage waste related
issues in an appropriate manner.
1.3 Scope
This Plan applies to activities that are relevant to waste management during O&M of Lien Lap, Phong
Huy and Phong Nguyen Wind Power Projects (hereafter refers to “the Sites”) as the following:
Commissioning and operational activities at Operational House;
Commissioning and O&M activities at the Projects’ sites (e.g. O&M of the Wind Turbine Generators
(WTGs) area, the access roads and the T/L);
O&M activities of ancillary facilities such as yards, stores, Central Monitoring System (CMS)
building facilities;
Rather than the facilities and areas of the Projects listed in Section 1.1 and activities listed in this
section, this Plan DOES NOT COVER: (i) the substations; and (ii) the T/L connecting from the
substations to National Grid (220 kV Lao Bao Substation of EVN) as these facilities are invested
and managed by other windfarm companies in the local area.
This Plan applies to all parties working for or on behalf of the Projects have activities relating to the
generation of waste during commissioning and operation of the Projects.
This Plan does not apply to wastewater which is covered under Water and Wastewater Management
Plan.
Failure to comply with the requirements of this Plan may lead to disciplinary action:
for an individual, following National Labor Code 2019 (e.g. reprimand, deferment of pay rise for up
to 6 months, demotion, dismissal); and
for the Sites including Contractor and Subcontractors following contractual penalty as guided in
Law on Construction 2014 and Civil Code 2015 (e.g. withholding the payments, fines,
compensation for damages).
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Lien Lap, Phong Huy, Phong Nguyen Wind Power Projects
2. REFERENCES
The Plan will be applied systematically in conjunction with the following related management plans and
programs.
The Projects’ Environmental Impact Assessment (EIA) or Environmental Protection Plan (EPP)
Reports;
The Projects’ Initial Environmental and Social Examination (IESE) Reports;
The Projects’ Environmental and Social Compliance Audit Reports;
The Project Owner’s Environmental & Social Management Plans, including:
- Air Quality and Noise Management Plan;
- Water and Wastewater Management Plan;
- Occupational Health and Safety Management Plan;
- Community Health and Safety Plan;
- Stakeholder Engagement Plan;
- Grievance Mechanism Procedure; and
- Emergency Preparedness and Response Plan.
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Lien Lap, Phong Huy, Phong Nguyen Wind Power Projects
3. APPLICABLE REQUIREMENTS AND STANDARDS
All employees, the Wind Farm Level Team, contractors and subcontractors to be engaged during O&M
are required to comply with applicable E&S requirements and standards that are defined in this section
for waste management during O&M of the Projects. These requirements will also be incorporated into
commercial contracts with the Wind Farm Level Team. In addition, where standards referred to below
are inconsistent or contradictory, the approach is to apply the most stringent standard unless otherwise
agreed by the Project Owner.
3.1 National Legislation
Table 3.1 List of National Legislation
Classification Titles
Law ■ The Law No. 72/2020 QH14 on Environmental Protection.
Decree ■ Decree No. 38/2015/ND-CP dated 24 April 2015 on Management of Waste
and Scraps; and
■ Decree No. 40/2019/ND-CP dated 13 May 2019 amending and
supplementing a number of articles of Decrees Detailing and Guiding the
Implementation of the Law on Environmental Protection.
Circular ■ Circular No. 36/2015/TT-BTNMT dated 30 June 2015 on Management of
Hazardous Wastes;
■ Circular No. 35/2015/TT-BCT dated 27 October 2015 on Environmental
Protection in the industry and trade sector.
Decision ■ Decision No. 155/1999/QD-TTg dated 16 July 1999 promulgating the
Regulation on Management of Hazardous Wastes; and
■ Decision No. 09/2020/QD-TTg dated 18 March 2020 promulgation of
Regulation on Waste-related Emergency Response
National Technical Regulation ■ QCVN 07:2009/BTNMT on Hazardous Waste Thresholds
and / or National Standards
3.2 International Standards
Asian Development Bank’s Safeguard Policy Statement
Equator Principles III
Japan International Cooperation Agency’s Guidelines for Environmental and Social Considerations
International Finance Corporation’s Performance Standard (PS):
- PS1: Assessment and Management of Environmental and Social Risks and Impacts
- PS3: Resource Efficiency and Pollution Prevention
World Bank Group General Environmental, Health, and Safety Guidelines;
Basel Convention 1989.
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Lien Lap, Phong Huy, Phong Nguyen Wind Power Projects
4. DEFINITIONS
Term Definition
Project Owner Lien Lap JSC, Phong Huy JSC and Phong Nguyen JSC
Project Sponsor Power Construction JSC No.1 and Renova Renewables Vietnam 1 Pte. Ltd.
Wind Farm Level Team The Management Team established by the Project Owners, directly managing
the Lien Lap, Phong Huy, Phong Nguyen Sites during the operation phase.
The Wind Farm Level Team has an office in the Operation House located in Cua
village, Huong Tan Commune, Huong Hoa District, Quang Tri Province.
O&M contractor An individual or company that enters into a contract (directly or indirectly) with
the Wind Farm Level Team to perform a specific task or provide operational and
maintenance services for the Projects.
Subcontractor An individual or company that enters into a subcontract (directly or indirectly)
with the contractor of the Projects to perform a specific task or provide services
for the Projects during operation
Employees Refer to all employees who participate in the Project including employees of
Project Owners, the Sites, O&M contractor and subcontractors
Domestic solid waste or Solid waste generated from daily-life activities of humans (e.g. food waste,
municipal solid waste plastic waste, yard waste etc.)
Industrial non-hazardous solid Solid waste generated from operation, maintenance and/or service activities
waste containing non-hazardous substances or components (e.g. discarded metals,
plastics bags or boxes, etc.)
Hazardous waste Wastes containing elements that are toxic, radioactive, contagious, flammable,
explosive, abrasive, poisonous or otherwise harmful
Non-hazardous waste Wastes that is not classified as hazardous waste such as domestic trash and
garbage, and metal scraps
Waste Any hazardous and non-hazardous solid, liquid, or contained gaseous materials,
generated from operation, maintenance works and domestic activities, which
can no longer be used for intended purposes and need to be handled (e.g.
reused, treated, disposed) to protect the environment
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WASTE MANAGEMENT PLAN – OPERATION PHASE ROLES AND RESPONSIBILITIES
Lien Lap, Phong Huy, Phong Nguyen Wind Power Projects
Within this Plan, roles and responsibilities in relation to waste management are provided in Table 5.1.
Table 5.1 Roles and Responsibilities
Roles Responsibilities
Company Level
Environmental, health, ■ Oversee performance and compliance of the Projects with requirements of
safety and social (EHSS) this Plan through regular meetings with the Project Owner and The Wind
Manager Farm Level Teams and review of reports; He/she is also responsible for and
has to ensure that compliance is achieved.
■ Ensure that technical support is provided to The Wind Farm Level Team for
implementation of this Plan;
■ Approve remedy for grievances;
■ Lead the consultations between the Projects and stakeholders;
■ Advise the General Director when it comes to review and possible revision of
this Plan to ensure its effectiveness, if necessary;
■ Approve Waste Vendors selection and ensure appropriate hazardous waste
management contracts are established;
■ Ensure Waste Vendors’ full compliance with applicable standards and
regulations;
■ Ensure legal waste management documentation (such as Hazardous Waste
Generator Registration Book, annual Environmantal Protection Report
including waste management) are obtained, submitted as appropriate; and
■ Other duties assigned by the General Director.
EHSS Deputy Manager ■ Inform EHSS Manager of any waste issues.
■ Assist EHSS Manager with the implementation of this Plan.
■ Monitor and report to the EHSS Manager on the status of the Projects’
performance;
■ Ensure that corrective actions are implemented in a timely manner;
■ Assist EHSS Manager in reviewing reports and preparing EHSS documents;
■ Participate in the review and possible revision of this Plan, if necessary; and
■ Other duties assigned by EHSS Manager
EHSS Staff ■ Coordinate EHSS activities throughout the Projects;
■ Collect The Wind Farm Level Team’s periodic reports and data on waste
management practices;
■ Assist management on waste related matters;
■ Maintain relevant records and reports;
■ Collaborate with EHS Manager to conduct audit at Waste Vendor’s facilities,
and submit the result to EHSS Manager; and
■ Other duties assigned by EHSS Deputy Manager and EHSS Manager
Wind Farm Level Team – Wind Farm Level
Wind Farm Director ■ Allow adequate resources for the implementation of this Plan;
■ Sign waste collection and disposal contracts with certified Waste Vendors;
■ Liaise with the Project Owner for implementation of this Plan;
■ Monitor the agreed resolution and ensure all physical works, if applicable, are
completed to an acceptable standard or other resolutions proposed are closed
out;
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Roles Responsibilities
■ Ensure that waste management issues are included in weekly reports to be
prepared by the Wind Farm Level Team for the Project Owner; and
■ Submit monthly reports to the Project Owner.
EHS Manager ■ Carry out all duties assigned by Wind Farm Director to ensure that the
implementation of this Plan is in line with the Projects’ standards;
■ Plan and provide related trainings to workers;
■ Conduct periodic site inspections and audits to identify and correct potential
non-compliance issues;
■ Coordinate and communicate all waste -related matters with O&M Manager,
and the Project Owner;
■ Collaborate with Corporate Social Responsibility (CSR) Manager and the
Project Owner in case grievances are raised;
■ Submit monthly waste management report (incorporated into Monthly EHS
Monitoring Report) to EHSS Manager and EHSS Deputy Manager;
■ Work with the Waste Vendor to arrange collection, transportation and
disposal/treatment of wastes;
■ Other duties assigned by Wind Farm Director.
Environmental Supervisor ■ Support EHS Manager by maintaining a visible presence to the field
performing site visits to the Projects;
■ Assist EHS Manager in the coaching, mentoring and implementation of this
Plan in the field;
■ Ensure that all incidents and issues are reported immediately;
■ Participate in the investigation of incidents to determine root cause and
corrective actions, where necessary;
■ Collaborate with EHS Manager and Wind Farm Director in periodic inspection
and audit;
■ Prepare weekly and monthly waste management report (incorporated into
Monthly EHS Monitoring Report) and submit to EHS Manager;
■ Prepare and sign the hazardous waste manifest;
■ Other duties assigned by EHS Manager and Wind Farm Director.
H&S Supervisor (including ■ Support Environmental Supervisor, EHS Manager and Wind farm Director in
BOP and Vestas) periodic inspection and audit;
■ Participate in the investigation of incidents to determine root cause and
corrective actions, where necessary;
■ Other duties assigned by EHS Manager and Wind Farm Director.
All employees (including ■ Participate in induction training and all related trainings as required;
employees of ■ Understand their responsibilities and comply with requirements of this Plan;
Contractors/Subcontractors) ■ Cooperate with their employer, fellow workers and other duty holders;
■ Report any incidents or issues to their supervisors.
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6. WASTE MANAGEMENT
6.1 Waste Streams of the Projects
There are three kinds of waste anticipated to be generated from O&M of these Projects and classified
as per legal requirements as below.
Table 6.1 Waste Streams of the Projects
Type of waste Anticipated waste Potential generation areas/activities
Domestic solid waste food, packaging, paper, stationery employees’ activities at Operation House,
Security Station
Non-hazardous industrial paper, packaging, metal, plastic, maintenance activities at Projects’ sites,
waste electrical wiring Operational House, Security Station,
ancillary facilities
Hazardous waste ■ discarded/spilled oil and grease, maintenance activities at Projects’ sites,
chemicals; Operational House, Security Station,
■ waste fuel; ancillary facilities, waste/chemical storage
areas
■ contaminated rags;
■ discarded hazardous material
containers;
■ fluorescent lamp;
■ battery;
■ medical waste such as mask,
bandage, needle, gloves from
medical room
6.2 Waste Management Requirements
6.2.1 Waste Management Strategy
The EHS Manager shall ensure that waste management during operation is aligned with Project
Owner’s E&S Policies including strategy to prevent and minimize waste generation.
The EHS Manager shall control wastes generated from operation activities of the Projects by applying
the following Hierarchy:
Eliminate: avoid generation of waste in the first place and consider substituting raw materials used.
“Eliminate” can be promoted by:
- Projects are not allowed to purchase equipment or materials containing restricted hazardous
materials as specified in the OHS MP - Section 6.2.3 – Purchasing;
- Avoiding the creation of waste by carrying out works in the correct order to minimise the need
for remedial actions;
- Ordering materials in bulk to reduce packaging waste and the frequency of possible;
- Seeking “buy-back” arrangements with chemical suppliers for return of surplus chemicals,
when possible;
- Using refillable container for collection of waste fluids such as waste oil, hydraulic oil, used
grease and etc.
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Reduce: minimise the amount of waste generated. “Reduce” can be promoted by:
- Substituting raw materials or inputs with less hazardous or toxic materials, or with those where
processing generates lower waste volumes;
- Instituting good housekeeping and work practices, including inventory control to reduce the
amount of waste resulting from materials that are out-of-date, off-specification, contaminated,
damaged, or excess to operation activities needs;
- Instituting procurement measures that recognize opportunities to return usable materials such
as containers and which prevents the over ordering of materials;
- Minimizing hazardous waste generation by implementing stringent waste segregation to
prevent the commingling of non-hazardous and hazardous waste to be managed;
Reuse: use the material as many times as possible or reuse waste as material where feasible.
“Reuse” can be promoted by:
- Checking, cleaning, repairing, refurbishing, whole items or spare parts;
- Reusing domestic organic food waste as fertilizer;
- Reusing single sided paper with no confidential information by printing rough draft on blank
side and use them as note pad.
Recycle: recycle what you can only after we have re-used it such as material and plastic bags,
metals. “Recycle” can be promoted by:
- Evaluation of waste production processes and identification of potentially recyclable materials;
- Establishing recycling objectives and formal tracking of waste generation and recycling rates;
and
Dispose/ treatment: only consider disposal if the above options are not feasible.
The EHS Manager shall also ensure that:
All generated wastes shall be collected, stored, recycled/reused (where possible), transported, and
treated/ disposed in compliance with applicable standards;
All personnel engaged in waste management activities are provided with relevant awareness and
management training;
This waste management strategy shall be included in engagement/ induction and refresh training
to employees of the projects;
All wastes management will not cause any nuisance and/or adverse impact to communities and
surrounding environments;
Monitoring of waste generation and reduction shall be included in the Projects’ E&S performances
as required in Section 7;
Projects shall consider potential of waste elimination/reduction/reuse/recycle parameters based on
its performance of previous year(s) to set a relevant target(s) in annual E&S targets; and
All departments, contractors and employees shall conduct good house keeping at their workplaces
and good operational/maintenance practices where applicable to reduce the amount of wastes
resulting from expired materials, spills and contaminations.
Details of minimum management requirements are presented from Section 6 to Section 10.
6.2.2 Waste Classification
The EHS Manager shall classify all the waste generated from operation of the Projects into Domestic
Wastes, Non-hazardous Industrial Wastes and Hazardous Wastes.
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This shall be accomplished by having separate waste bins (containers) for the different waste types,
using a color coding system to facilitate better waste segregation, where possible. Color codes and
relevant classification requirement and guidance are provided in Table 6.2.
Table 6.2 Waste Classification Guidance
Waste and Classification requirement and guidance
Color Code
Domestic The Wind Farm Level Team shall collect domestic waste generated from employee’s day-life
Waste or activities at their workplaces. Domestic wastes are recommended to be segregated into three
Municipal Solid subgroups if practicable as below:
Waste
■ Recyclables e.g. glass, plastic bottle, metal cans, paper boxes, etc.;
■ Organics e.g. food waste, dead animal, etc.; and
■ Others .i.e. plastic bags, food wrappers, etc.
Non- The Wind Farm Level Team shall collect separately the non-hazardous industrial waste
Hazardous generated from operation activities. Non-hazardous industrial waste is unwanted materials
Industrial generated directly or incidentally from operation and maintenance activities such as glass,
Waste plastic, carton paper, steel and metallic waste, packaging, electrical wiring, etc. Non-hazardous
industrial waste is recommended to be segregated into two sub-groups as below:
■ Recyclables .i.e. glass, plastic, carton paper, steel and metallic waste, etc.; and
■ Non-recyclables .i.e. electrical wiring, etc.
Hazardous Examples of hazardous waste in operation such as discarded oil, grease, fuel, contaminated
Waste containers and medical wastes. The Wind Farm Level Team shall comply with following
requirements regarding classification and storage of hazardous waste:
■ The EHS Manager shall identify all kinds of hazardous waste generated at the Projects
during operation associated with hazardous waste codes/ identifications (IDs) required in
Appendix 01 of Circular 36/2015/TT-BTNMT;
■ The EHS Manager shall maintain a list of all hazardous waste and their hazardous IDs for
each Project;
■ The Wind Farm Level Team shall collect separately the hazardous waste whenever
generated from operation activities as per each type of hazardous waste identified above
and transfer to hazardous waste storage area. Refer to Sections 6.2.3 and 6.2.4 for
detailed requirements of collection, storage and transportation to final disposal/ treatment;
■ The EHS Manager shall ensure that each kind of hazardous waste shall be identified and
separated from others at source and separately stored associated with their responsible
working areas;
■ Medical waste shall be separated from other wastes and stored in seprate waste bin
containers;
■ Mixed hazardous and ordinary solid waste shall be managed as hazardous waste; and
■ In the event that the Wind Farm Level Team is unsure about classification, it shall be
considered as hazardous waste to avoid misleading disposal. In case the Wind Farm Level
Team want to confirm and to manage the cost for final treatment or disposal, the Wind
Farm Level Team shall test the waste to confirm whether the waste contains any
hazardous compositions or has any hazardous characteristics/ parameters exceeding the
hazardous thresholds as per QCVN 07:2009/BTNMT. Potential hazardous waste that
contains hazardous compositions or has hazardous characteristic/ parameters that exceed
the hazardous thresholds shall be classified as hazardous waste.
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6.2.3 Waste Collection and Storage
The Wind Farm Level Team shall collect and store waste streams separately as per requirements
in Section 6.2.2.
The EHS Manager shall provide waste storage facilities at their workplaces, being aligned with
classification practices and below requirements:
Waste containers
- Provide three types of waste containers/bins at each security station, public areas and, working
places of Operational House, in accordance with following requirements:
Three containers/bins at each station shall be in for domestic waste (green), non-
hazardous industrial waste (yellow), and hazardous waste (red) in accordance with color
codes in Section 6.2.2;
The sizes of containers shall be based on employee’s activities at each station, but at
least 30 liters per containers;
The number of containers is specified in Table 6.3.
Table 6.3 Location and Number of Waste Container Requirements
No. Location Type of containers No. of containers
and color code
1 Each domestic waste at least two (the actual total number of containers shall support
security keeping waste onsite at least seven days)
station
non-hazardous at least one
industrial waste
hazardous waste at least one (if wastes are incompatible, more hazardous waste
containers shall be provided to ensure those wastes are stored
separately)
2 Public area domestic waste at least two (the actual total number of containers shall support
keeping waste onsite at least seven days)
non-hazardous at least two
industrial waste
hazardous waste at least one (if wastes are incompatible, more hazardous waste
containers shall be provided to ensure those wastes are stored
separately)
3 Working domestic waste at least four (the actual total number of containers shall support
places of keeping waste onsite at least seven days)
Operational
House non-hazardous at least one to keep reused, recycled waste
industrial waste
hazardous waste at least one (if wastes are incompatible, more hazardous waste
containers shall be provided to ensure those wastes are stored
separately)
4 Waste domestic waste at least three (the actual total number of containers shall support
storage keeping waste onsite at least seven days)
area
non-hazardous at least four
industrial waste
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No. Location Type of containers No. of containers
and color code
hazardous waste at least four (if wastes are incompatible, more hazardous waste
containers shall be provided to ensure those wastes are stored
separately) including at least one for medical waste.
Medical waste bin(s) shall be clearly marked on its label as
“Medical Waste” and have Biological Hazards Warning Signs.
5 Medical hazardous waste at least one for medical waste. Medical waste bin(s) shall be
room clearly marked on its label as “Medical Waste” and have Biological
Hazards Warning Signs.
Waste storage areas
- Provide a non-hazardous industrial waste storage area at Operational House. The size of the
area shall be based on the quantity of non-hazardous industrial waste to be generated from
operation and maintenance activities, but shall be at least 10m2. The non-hazardous industrial
waste storage area shall ensure the following:
be located away from water resources, and in an area that is not at risk of flooding or
inundation;
avoid impacts from rain or have proper cover and roof to avoid rain water and wind to
minimise nuisance and control vector and odour;
For temporary storage in the form of warehouse, it must meet the prescribed
construction technical standards and regulations;
In case storage area is outdoor, following requirements shall be met:
○ There is a system to collect and treat storm water runoff and wastewater generated
in the storage of non-hazardous industrial waste to ensure compliance with
environmental technical regulations;
○ There is a foundation level to ensure no flooding; ensure the floor is tight, not
cracked, non-permeable, and durable enough to withstand the load of the transport
vehicle and the stored waste.
- Provide a designated hazardous waste storage area at Operational House. The size of the
area shall be based on the quantity of hazardous waste to be generated from operation and
maintenance activities. The hazardous waste storage area shall ensure the following:
Be located away from water resources, and in an area that is not at risk of flooding or
inundation
avoid impacts from rain or have proper cover and roof to avoid rain water and wind to
minimise nuisance and control vector and odour;
Hazardous waste storage area shall have proper floor to prevent penetration and
contamination of soil and groundwater;
Hazardous waste storage area shall be provided with firefighting facilities, sand and/or
absorbent materials and drains to mitigate fire and spill incidents;
Alarms, notifications, instructions signboard will be properly installed in compliance with
applicable standards;
Hazardous waste such as discard greases, lubricants, or chemicals shall be provided
with Safety Data Sheet (SDS) as applicable. The available volume of secondary
containment shall be at least 110 percent of the largest storage container, or 25 percent
of the total storage capacity (whichever is greater), in that specific location.
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Provide adequate ventilation where volatile wastes are stored.
Hazardous waste shall be stored in closed containers.
Waste is stored in a manner that allows for inspection between containers to monitor
leaks or spills.
Preparing and implementing spill response and emergency plans to address their
accidental release (Refer to the Emergency Preparedness and Response Plan)
Incompatible hazardous wastes shall be strictly separated during the collection and
storage process;
Hazardous waste storage area shall be protected from unauthorised access. Limiting
access to hazardous waste storage areas to employees who have received proper
training;
Hazardous waste storage activities shall be subject to special management actions,
conducted by employees who have received specific training in handling and storage of
hazardous wastes.
Provision of readily available information on chemical compatibility to employees,
including labelling each container to identify its contents
The EHS Manager shall provide notification (labels, hazards warning signs and
hazardous waste codes) for their hazardous waste storage areas in accordance with
Circular 36/2015/TT-BTNMT. Sample of waste labels are provided in Appendix B;
- The EHS Manager shall ensure that the waste storage applies Waste Color Codes in Section
6.2.2 for storage equipment and labels; and
- Waste classified as recyclable or reusable shall be stored in separate containers or separate
areas;
The EHS Manager shall monitor waste storage areas of the Projects in weekly EHS Tour/
Inspections. Weekly inspection records shall be maintained and included in Weekly EHS Report of
the Projects.
The EHS Manager shall maintain a waste storage layout for each Project and update if necessary
during operation. The waste layout shall identify the location of waste storage containers at security
stations, public areas and Operational House, and waste storage areas at Operational House.
6.2.4 Waste Transportation and Disposal/Treatment
Internal transportation (from wind farms to Operational House):
Waste generated from operation and maintenance activities at wind turbines or from security staff’s
activities shall be classified and transported to the waste storage area at Operation House for
storage.
Before the maintenance activity, the O&M Manager shall ensure to anticipate the type of wastes
that can be generated during maintenance, and therefore relevant waste containers are brought
by maintenance team. If liquid waste is anticipated, enclosed containers and spill kits for managing
materials (e.g. greases and lubricants) and discarded hazardous liquid waste (e.g. discarded
grease and lubricants) shall be provided.
The EHS Manager shall ensure the internal transportation of waste from generated location to the
storage area shall:
- not drop, cause dust/odour or leaking, especially for liquid waste shall be kept in sealed/
enclosed boxes;
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- ensure compliance of workers with safety precautions while handling hazardous waste,
including:
wearing proper PPE before working;
no horseplaying while working; no eating or smoking while handling wastes;
driving vehicles backward only when there is instructor spotter;
vehicle cleaning task will be prohibited when vehicle is in operation;
comply with requirements in Section 6.2.6 on safety management related to waste;
- ensure vehicle(s) used for internal hazardous waste transport (if any) shall be provided with
spill kits, firefighting facilities, warning signs and comply with other technical requirements of
Circular 36/2015/TT-BTNMT where applicable; and
- ensure vehicle used for internal hazardous waste transport (if any) shall be in good conditions
to minimize air and noise pollution during waste loading and unloading;
- ensure employee who will carry out hazardous waste collection and transportation shall be
provided with proper personal protective equipment (PPE) and chemical safety trainings;
- for maintenance of the transmission line in the forest where vehicle cannot access, the O&M
Manager shall ensure waste containers are carried by trained employees and above safety
precautions shall be ensured where applicable.
External transportation and disposal/treatment (from Operation House/Security Stations to
Waste Vendor):
The Wind Farm Director shall ensure wastes that cannot be reused and recycled have to be treated or
disposed in an environmentally acceptable manner in accordance with international good practice and
relevant national regulations. The following requirements shall be implemented to manage
transportation and disposal of wastes:
The Wind Farm Director shall be responsible for signing waste collection and disposal contracts
with certified Waste Vendors as specified in Section 6.3;
The EHS Manager shall work with the Waste Vendor to arrange collection, transportation and
disposal/treatment of wastes;
Frequency of waste collection (from storage areas at Operation House and Security Stations
transferring to waste vendors) shall be suitable to the characteristics of the type of waste, the size
of the storage area or the capacity of the containers and depends on the actual amount of waste.
The minimum requirements include:
- Domestic solid waste: shall be collected at least twice per week and disposal at the agreed
sanitary landfill (Dakrong Town landfill);
- Hazardous waste: shall be collected every 3 months after waste generation or when the
storage area is full, whichever is sooner. Special requirements for storing hazardous waste
onsite longer than 3 months period are as follows:
Hazardous waste is only allowed to be kept in storage warehouse at Operational House
from 3 – 6 months after generation, if the total amount of hazardous waste is very small
i.e. less than 50kg within previous 3 months. Environmental Supervisor shall prepare
hazardous waste inventory for seeking approval from the EHS Manager for this
requirement.
Hazardous waste IS NOT ALLOWED to be kept for more than 6 months after generation
without official notification to Quang Tri Provincial Department of Natural Resources and
Environment. In case the Wind Farm Level Team cannot transfer hazardous waste for
treatment within 6 months (due to unavailability of feasible transferring/treating plan or
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having not found a competent hazardous waste treatment vendor), the EHS Manager
shall report to Quang Tri Provincial Department of Natural Resources and Environment
(in periodic waste management report or in a separate document) about hazardous
waste storage at Projects’ site as legally required.
- Medical waste shall be collected weekly by local Medical Service.
The Waste Vendor is responsible for waste transporting, treating or disposing according to the
requirement of Decree 38/2015/ND-CP and Circular 36/2015/TT-BTNMT, including but not limited
to the following general requirements:
- Segregation of hazardous and non-hazardous wastes must be ensured during the whole
collection and transport processes;
- Transportation of waste shall be conducted in the manner that prevent or minimize spills,
releases, and exposure to employees and the public;
- If drums or other containers are used to transport waste, containers shall be in good condition
and compatible with the waste and are adequately secured in the transport vehicle;
- Adequately label all transport tanks and containers to identify the contents, hazards, and
actions required in various emergency situations;
- All waste containers designated for off-site shipment shall be secured and labeled with the
contents and associated hazards, be properly loaded on the transport vehicles before leaving
the site; and
- In case of waste incident (such as fire, spills or contamination) during transportation, the
driver/witness person shall report immediately to telephone number 112 or People’s
Committees at all levels where the incident occurs. The Waste Vendor is responsible to report
immediately to People’s Committees at all levels where the incident occurs and District-level
Command Center for Natural Disaster Management Board. In addition, the Waste Vendor shall
comply with other waste incident response regulations as specified by Decision 09/2020/QD-
TTg
For each shipment of domestic and non-hazardous industrial wastes, the Environmental Supervisor
shall prepare and sign the waste transfer record with Waste Vendor (refer to Appendix C) to record
the waste transported, treated or disposed; and
For each shipment of hazardous waste, the Environmental Supervisor shall prepare and sign the
hazardous waste manifest with Waste Vendor/Medical Service (refer to Appendix D), to record the
waste transported, treated or disposed.
6.2.5 Management of Specific Waste Streams
Contaminated soil arising from hydrocarbon spills (e.g. vehicle fuel, grease and lubricants from
maintenance): the EHS Manager shall ensure that oil spilled/ contaminated areas shall be cleaned
up; contaminated soil to be treated as hazardous waste. Investigation minutes of the event shall
be an attached as records;
Sewage Sludge: Sewage Sludge from septic tank of toilets shall be regularly collected and
disposed by a certified company, as per Water and Wastewater Management Plan; and
Hazardous liquid wastes: the EHS Manager shall ensure that chemicals, oil or solvent, and
wastes being used onsite are in designated areas with hazardous warning signs and secondary
containers or anti-spillageequipment.
Medical waste: medical waste shall be separated from other wastes and managed as hazardous
waste.
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