20201228-Final Masterplan en
20201228-Final Masterplan en
20201228-Final Masterplan en
PREPARED BY
TRIGON ASSOCIATES, LLC
1515 POYDRAS ST. SUITE 2200
NEW ORLEANS, LA 70112
USA
DISCLAIMER
THE VIEWS EXPRESSED IN THIS PUBLICATION DO NOT NECESSARILY REFLECT THE VIEWS OF THE UNITED STATES AGENCY FOR
INTERNATIONAL DEVELOPMENT OR THE UNITED STATES GOVERNMENT.
ACKNOWLEDGEMENT
This document was developed in collaboration between the United States Agency for International
Development (USAID), Ministry of National Defence (MND), Air Defence-Airforce Command
(ADAFC) and as well as several Vietnamese Government entities (local governments and other
ministries).
The active participation during the Roadmap meetings for the Masterplan development is highly valued.
We appreciate the time, contribution and substantial input of all Project stakeholders. This
collaboration provides a solid foundation for a successful implementation.
• MND
• ADAFC
• Office 701
• Ministry of Natural Resources and Environment (MONRE)
• Ministry of Science and Technology (MOST)
• Dong Nai Department of Natural Resources and Environment (DONRE)
• Military Science Department (MSD)
• Security Protection Department
• MND Department of Foreign Affairs
• Chemical Command (CC)
• Center for Technology and Environmental Treatment (CTET)
• National Action Center on Toxic Chemicals and Environmental Treatment (NACCET)
• Vietnam - Russia Tropical Centre (VRTC)
• Academy Military Science and Technology (AMST)
• New Technology Institute (NTI)
• Dong Nai People’s Committee (Dong Nai PC)
• Bien Hoa City People’s Committee (BH PC)
• Other Ministry of National Defence (MND) Agencies
ANNEXES
ANNEX 1 – RISK IDENTIFICATION AND MANAGEMENT PLAN
ANNEX 2 – SITE-WIDE SAMPLING AND ANALYSIS PLAN (SAP) / QUALITY
ASSURANCE PROJECT PLAN (QAPP)
ANNEX 3 – SITE-WIDE HEALTH AND SAFETY PLAN (HASP)
ANNEX 4 – SITE-WIDE ENVIRONMENTAL MITIGATION AND MONITORING
PLAN (SWEMMP) INCLUDING THE SITE-WIDE STORMWATER
POLLUTION PREVENTION PLAN (SWPPP)
FIGURES
Figure 1-1 Bien Hoa Airbase Overview ....................................................................................................... 2
Figure 1-2 Project Roadmap Meetings.......................................................................................................... 7
Figure 2-1 Surface Dioxin Concentration................................................................................................. 12
Figure 2-2 Proposed Land Use based on EA/EIA .................................................................................... 15
Figure 2-3 Proposed Project Action Levels for Masterplan Development ....................................... 16
Figure 2-4 Surface Dioxin Concentration Post-Phase 1........................................................................ 18
Figure 2-5 Post-Remediation Surface Dioxin Concentration .............................................................. 19
Figure 3-1 Masterplan Project Stakeholders ............................................................................................ 20
Figure 3-2 Roadmap to Masterplan Development.................................................................................. 21
Figure 4-1 Project Site Conceptual Model ............................................................................................... 34
001 July 20, 2020 All Final Masterplan MND and USAID
COR
002 August 10, 2020 All Revised to incorporate ADAFC & MND and USAID
USAID comments COR
Added Executive Summary and
003 August 31, 2020 Selected incorporated Roadmap Meeting 4/5 MND and USAID
consensus COR
Subsequently, on May 11, 2018, USAID and Vietnam’s Air Defense – Air Force Command (ADAFC)
signed a Limited Scope Grant Agreement (LSGA) to carry out the Dioxin Remediation at Bien Hoa
Airbase Area Project (the “Project”) “…in order to remediate dioxin contamination at the Bien Hoa
Airbase area, thereby reducing human exposure to dioxin and possible harm to human health, subject
to availability of resources.” The LSGA documented an initial USAID total estimated contribution of
$183 million to be provided in increments over five years.
This Masterplan presents a comprehensive roughly 10-year plan to remediate dioxin at the Bien Hoa
Airbase area that generally follows the remediation Alternative 4 described in the 2016 USAID
Environment Assessment of Dioxin Contamination at Bien Hoa Airbase. Masterplan activities are
divided into two five-year phases. Phase 1 activities over the next five years will largely be implemented
under the existing USAID-ADAFC LSGA.
MASTERPLAN
USAID and ADAFC coordinated several “Roadmap to Masterplan Development” meetings over the
course of ten (10) months from September 2019 to June 2020 to engage GVN stakeholders and
benefit Project design and implementation. Further details are provided in Section 3. The participants
represent a wide range of mostly technical agencies. Those with a role in implementing the Project
are described further in Section 1.2. During the Masterplan Roadmap meetings, consensus was
reached with GVN stakeholders on key Project issues including the Applicable or Relevant and
Appropriate Requirements (ARARs) (Section 2.2), the means of isolating low concentration dioxin-
contaminated material (Section 4.4.1) and the decision to use thermal conductive heating (TCH)
technology to treat high concentration material (Section 4.4.2).
The Project background in Section 2 includes a high-level summary of what needs to be done and what
will be accomplished. Figures in Section 2.3 through Section 2.5 track the existing surface dioxin
concentrations, the proposed land use, the remedial actions to be taken (treat or long-term storage),
and the surface dioxin concentrations after Phase 1 and Phase 2 (post-remediation).
REMEDIAL ACTIONS
The objective of the remedial actions is to reduce risk to humans and the environment by halting off-
Airbase migration of contaminated media, preventing recontamination of remediated areas, treating
highly contaminated soil and sediment, and minimizing land use controls. The selected remedial actions
are described in Section 5, including the process to achieve remediation, and the packaging into
remedial activities. The remedial actions include the following:
• LAND USE CONTROLS – controls will be implemented based on any remaining dioxin levels
after remediation to prevent future exposure. All formerly contaminated sites will be restored
with treated material, at a maximum dioxin concentration of 100 ppt TEQ, or backfilled at a
maximum dioxin concentration of 21.5 ppt TEQ. For further detail see Section 5.6.
Phase 1 Remediation
185.1 0.4 8.6 22.2 31.2 36.0 44.8 42.0
Activities
EXCAVATION QUANTITIES Phase 1 Remediation
CONCENTRATION (m3) 47.0 7.4 10.8 10.4 8.5 3.3 3.3 3.3
Support Activities
PHASE TOTAL (m3)
LOW HIGH Phase 2 Remediation
198.8 0.2 2.1 1.1 49.5 45.3 46.3 43.2 11.1
Activities
Phase 1 144,757 99,390 244,147
Phase 2 Remediation
19.3 0.4 0.4 0.5 3.6 3.6 3.6 3.6 3.6
Phase 2 56,995 185,846 242,841 Support Activities
TOTAL 201,752 285,236 486,988 TOTAL 450.3 7.8 19.4 32.5 39.6 39.9 50.6 46.9 53.2 48.9 49.9 46.8 14.7
1) Remediation activities with the highest potential for reducing health and environmental risk
are prioritized in the first five years of implementation;
2) High contamination soil and sediment that are currently safely stored in the Z1 area landfills
are planned for treatment at the end of the Project; and
3) Detailed treatment and excavation designs finalized during Masterplan implementation will
propose approaches that minimize capital costs while meeting Project objectives. One
example of such design efforts, already accepted in principle by participants in Masterplan
meeting 4/5, is a modification of stormwater flows in Pacer Ivy as described in Section 4.7.
POST-PROJECT
After Project completion, MND will be responsible for maintenance of the Long-Term Storage Area
and other on-base land use controls to ensure that the Project benefits are sustained. During Project
implementation, USAID will support GVN stakeholder capacity building to help ensure that
Vietnamese land use controls are effectively resourced. Additional details are provided in Section 5.6.
Subsequently, on May 11, 2018, USAID and Vietnam’s Air Defense – Air Force Command (ADAFC)
signed a Limited Scope Grant Agreement (LSGA) to carry out the Dioxin Remediation at Bien Hoa
Airbase Area Project (the “Project”) “…in order to remediate dioxin contamination at the Bien Hoa
Airbase area, thereby reducing human exposure to dioxin and possible harm to human health, subject
to availability of resources.” The LSGA documented an initial USAID total estimated contribution of
$183 million to be provided in increments over five years.
This Masterplan presents a comprehensive roughly 10-year plan to remediate dioxin at the Bien Hoa
Airbase area that generally follows the remediation Alternative 4 described in the 2016 USAID
Environment Assessment of Dioxin Contamination at Bien Hoa Airbase. Masterplan activities are
divided into two five-year phases. Phase 1 activities over the next five years are largely to be
implemented under the existing USAID-ADAFC LSGA. A map providing an overview of the Airbase
Area and identifying the eight (8) main contaminated areas on the airbase is shown in Figure 1-1.
• GVN National Steering Committee 701: oversees and coordinates all dioxin-related matters
within GVN;
• MND: includes the Project Owner (ADAFC) and other agencies tasked with planning and
implementing roles;
• MONRE: GVN environmental authority; and
• Provincial Government: provides local insight for the Dong Nai Province and plays a key role in
implementing off-site Project activities and conducting outreach to the local community.
USAID is the U.S. Government agency responsible for procuring and managing the contractors
responsible for Project execution. The A&E Bien Hoa Contractor is responsible for development of
the Masterplan, providing oversight of Implementing Contractors, and interacting with stakeholders.
DEVELOPMENT
TECHNICAL
OVERSIGHT
FUNDING
SUPPORT
PROJECT
OWNER
STAKEHOLDER
The following subsections provide detailed descriptions of the GVN and USAID implementing parties.
• Ministry of Finance (MOF) ensures the Project funds are disbursed by the Project Owner, ADAFC,
in accordance with applicable GVN and MND laws and regulations; and
• Ministry of Planning and Investment (MOPI) is tasked with providing oversight of administrative
Project activities to ensure compliance with applicable GVN and MND laws and regulations.
• DIVISION 370 – fits administratively between the national ADAFC and the local Regiment 935
at the Airbase. Some activities need formal or informal concurrence from Division 370;
• REGIMENT 935 AT BIEN HOA AIRBASE – stationed at the Bien Hoa Airbase and provides
coordination of on-Airbase activities and logistical requirements for site access, security, and UXO
clearance; and
• ADAFC TECHNICAL CONSULTANTS – come from other agencies within MND but outside
of ADAFC, described below:
– ACADEMY OF MILITARY SCIENCE AND TECHNOLOGY (AMST) – provides Project
technical oversight and guidance and will be engaged throughout the design process for each
portion of the Project. AMST will collaborate in development of designs for non-remedial and
remedial Project activities and provide approval for Masterplan technical approaches. The
relationship with AMST is critical to achieving Project objectives requiring strategic planning
and careful preparedness. The agency will engage in technical status and strategy meetings and
develop productive partnership for engineering design and construction phases;
– CHEMICAL COMMAND (CC) – was responsible for the XD2 project to excavate and
isolate some contaminated soils from Southwest and Z1 areas. They are among the MND
agencies to review design submittals. Under CC there is a branch called the Center for
Technology and Environmental Treatment (CTET) which has been involved in assessing
remediation technologies; and
1.2.1.4.1 DONG NAI PROVINCIAL AND BIEN HOA CITY PEOPLE’S COMMITTEES
The Dong Nai Provincial and Bien Hoa City People’s Committees lead the relocation efforts of people
living in the Project sites off the Airbase.
1.2.1.4.2 DONG NAI PROVINCE DEPARTMENT OF NATURAL RESOURCES AND THE ENVIRONMENT (DONRE)
DONRE is responsible for providing review and oversight for planning and execution of off-Airbase
remediation activities, capacity building efforts and strategy to sustain land use controls. DONRE leads
the local environmental efforts on off-Airbase contamination and helped characterize the off-Airbase
areas by collecting environmental samples.
The Chief of Party (COP) interfaces regularly with USAID and is responsible for establishing and
maintaining clear communications with both USAID and GVN stakeholders. The COP effectively
communicates USAID’s objectives and supports the continuation of the strategic relationship between
the U.S. Government and GVN. Designated staff participate in regular meetings and Project events
with USAID and GVN, developing productive relationships with the appropriate GVN technical
experts.
The Masterplan is organized into two volumes. Volume 1 (Sections 1 through 7) provides the detailed
information regarding the Project, remedial alternatives, implementation approach, schedule and
estimated costs. Section 1 introduces the Project objectives, roles and responsibilities of the Project
implementers, scope of Project activities and how they were developed. Section 2 provides the
Project background, key planning documents, applicable requirements, and the current state of dioxin
contamination. Section 3 describes stakeholder engagement, primarily through roadmap meetings, to
develop and, in the future, to implement the Masterplan. Section 4 provides a summary of the
Masterplan including remedial actions, site maps, design parameters, applicable standards, and risks to
be managed. Section 5 presents an overview of the selected remedial actions, the process to achieve
remediation, and the packaging into remedial activities. Section 6 provides an introduction to the
Project Work Breakdown Structure (WBS), description of cost elements as they relate to the
remediation activities, implementation schedule, and costs. Masterplan maps are provided throughout
the document as well as in Section 7 for quick reference.
Volume 2 (Sections 8 through 10) provides further detail on the information collected and decisions
made to develop the Masterplan. It includes summaries of key environmental and planning
documentation, previous and ongoing remediation efforts, data gaps analysis and a baseline risk
assessment.
The Masterplan outlines the proposed remediation project approach and incorporates, as appropriate
by reference and/or annex, the maps, plans, and work products completed under CLIN 1 as part of
the ultimate goal of developing the Masterplan. The Masterplan serves as the basis for planning and
future implementation of the overall Project by USAID and MND. MND’s Air Defence–Air Force
Command (ADAFC) has been assigned as the GVN Project Owner.
The Masterplan, particularly Volume 1, is a focused and concise document presenting the Project
work activities, shown in a WBS format, with schedules and estimated costs, to implement the
remedial approach for the duration of the entire Project. The complete Masterplan includes the
following:
• Project description;
• Remediation objectives;
• Implementation activities, schedule, and estimated cost, including interim and long-term remedial
measures; and
• Accomplish Project goals and objectives while striving for “Zero Injuries;”
The objective of the Project is to remediate dioxin contamination. As discussed in Section 4.1, a
second objective is to not adversely affect risks from arsenic, whether naturally occurring or from use
of Agent Blue during the American-Vietnam War which contained two organic arsenic compounds as
active ingredients.
In Vietnam, dioxin is addressed in laws, regulations, and standards aimed at specific processes (site
remediation, hazardous waste management and treatment) and environmental media (air, water, soil,
sediment), as summarized in the following paragraphs. National Technical Regulations (QCVNs) are
legally binding. National Standards (TCVN) are advisory unless incorporated by reference into a
National Technical Regulation (QCVN). The key ARARs for dioxin include:
• National Technical Regulation QCVN 45:2012/BTNMT, Allowed Limits of Dioxin in Soils, which
identifies limits based on land use. Table 2-1 summarizes the four (4) land use types designated by
MND and Dong Nai Province for the Bien Hoa Airbase Area and provides a limit on dioxin
allowable for each land use;
• National Standard TCVN 8183:2009, Dioxin Threshold in Soil and Sediment, provides the
allowable limit of 150 ppt TEQ for sediment in waterbodies not designated for aquaculture,
including stormwater management features;
• National Standard TCVN 9737:2013, Dioxin Discharge Standards in Wastewater and Waste Gas
from Residual Dioxin Treatment Activities, will be utilized in the design of the treatment process
to select the treatment technology to apply in the event that remedial activities (including leachate,
decontamination, and stormwater collection and management) result in the generation of dioxin-
impacted water requiring discharge;
• Dioxin-contaminated soil can become airborne in the form of respirable dust. The National
Technical Regulation QCVN 19:2009/BTNMT, Industrial Emission of Inorganic Substances and
Dusts, stipulates maximum allowable concentration of dioxin in emissions. This regulation will be
applicable to excavation, isolation, and treatment activities; and
• National Technical Regulation QCVN 07: 2009/BTNMT, Hazardous Waste Thresholds, will be
utilized to guide sampling and analysis to determine if levels of dioxin or arsenic exceed hazardous
waste thresholds. Based on the waste classification, the appropriate disposal options will be
determined for the specific wastes, (e.g., soils, sediments, vegetation, construction waster,
demolition debris, and investigation-derived wastes). Restricted re-use will consider additional
requirements beyond QCVN 07:2009 as appropriate.
The estimated area of dioxin contamination (in the EA) encompasses approximately 537,100 square
meters (m2), or 53.7 hectares, of which approximately 396,100 m2 (39.6 hectares) are in soil areas
and approximately 141,000 m2 (14.1 hectares) are in sediment areas. Additional information on the
EA is provided in Volume 2, Section 8.1.
Separate from the EA efforts, DONRE has conducted dioxin monitoring for soil and sediments at
several locations around the Airbase and shared these results since the EA was completed. DONRE
identified three additional off-Airbase areas with elevated dioxin concentrations in soils and sediment,
including one residential area (DONRE-A1, DONRE-A2, MND-A42).
A summary of these additional off-Airbase areas plus changes to the off-Airbase lake outside of Gate
2 identified during the EA as contaminated (Gate 2 Lake, G2L) is as follows:
• Since the EA, USAID has chosen to reclassify PI-08 and PI-10 to sediment since stormwater flows
through these decision units (DUs) before leaving the Airbase. This results in additional volume
to be remediated under this Project as compared to the EA;
• MND’s Chemical Command (CC) excavated high contamination soils from the Southwest area
and predominantly low concentration soils from Z-1 area in 2015 and 2016 after EA sampling was
completed. The volume excavated under this XD2 project was 51,520 m3, which exceeds the
volumes estimated in the EA for these areas; and
• The drainage channel outside of the Airbase which flows from Pacer Ivy to the Dong Nai River
was impacted by the toll booth and widening of the road Huỳnh Văn Nghệ in 2016. The installation
of a concrete box culvert capped any contaminated sediments under it; thus, blocking any
exposure to the western end of PI-15 and truncated the remaining portion of PI-15 still needing
remediation. Separately, Dong Nai Province is assessing how to address the contamination in
PI-16 identified by the EA. Since PI-16 is not part of the ongoing relocation efforts by the Province,
it is inaccessible and thus not included in the Project at this time.
The updated total estimated volume that this Project will remediate is approximately 486,990 m³ with
contingency (457,100 m3 without). This amount is summarized by areas and sediment/soil in
Table 2-2. The outcome of all the changes discussed above is that the volume with contingency is
8,310 m3 lower than in the EA (48,600 m3 higher without). All further discussions in the Masterplan
of estimated volume to be remediated use the updated volumes with contingency.
• CLEANUP ACTION LEVELS – for soils/sediments are the applicable QCVN 45:2012/BTNMT
or TCVN 8183:2009 standard ranging from 150 ppt to 1,200 ppt TEQ based on land-use. No
Project sediment areas have been identified with aquaculture (QCVN 43:2017/BTNMT). Figure
2-2 displays the proposed land-use;
• STORAGE ACTION LEVEL – for long-term storage of soils/sediments are those soils/sediments
with dioxin concentrations < 1,200 ppt TEQ but exceeding the Project cleanup action levels. The
DUs and Sub-DUs that need storage as the remediation action are shown in Figure 2-3 with dark
orange/red and dark blue colors;
• TREATMENT ACTION LEVEL – for the treatment of soils/sediments are for those with
concentrations of dioxin ≥ 1,200 ppt TEQ. This threshold equates to lowest allowable
concentrations of dioxin in soils for anticipated land uses on the Airbase. This threshold maximizes
the ability to use treated material as fill or other material on the Airbase in formerly contaminated
areas. Achieving lower residual dioxin concentrations in treated material could allow even greater
reuse on the Airbase. The DUs and sub-DUs that need treatment as the remediation action are
shown in Figure 2-3 with orange and light blue colors;
• ACTION LIMIT FOR BLOOD SERUM DIOXIN – is 30 picograms/gram (pg/g) of lipid or parts
per trillion TEQ; and
Based on these Project Action Levels, the amount of remediation work to be completed each year is
provided in Table 2-3 by task, volume of low and high dioxin concentration material, and decision
units. This information is broken down further by phase and activity in Section 5.8.
The Roadmap meeting process and main topics discussed are shown in Figure 3-2 and described
below. Additional events such as workshops and meetings will be planned as part of Masterplan
implementation.
During Roadmap Meeting 1, stakeholder consensus was reached on the Masterplan development
process, the identification of Project stakeholders, the structure and content of Roadmap Meetings,
and an initial outline for Masterplan document.
During Roadmap Meeting 2, stakeholder consensus was reached on the SCM; the ARARs process and
an initial tabulation of Project ARARs (with comments); the identified data gaps and their
determination of criticality in the Data Gaps Analysis; the Project remedial standards (to include
cleanup action levels, storage action level, treatment action level, and treatment threshold); and the
selection criteria for evaluating remedial treatment technologies.
During Roadmap Meeting 3, stakeholder consensus was reached on the siting and general conceptual
design (Alternative 2) for the LTSA, the medical monitoring program contained in the Site-Wide HASP
for Project activities (with comments), the evaluation of remedial treatment technologies using the
established selection criteria, and determination of TCH as the selected treatment technology for this
Project.
During Roadmap Meeting 4/5, stakeholder consensus was reached on remediation activities and
remediation support activities for Phase 1 and 2, additional site characterization to address undefined
bottoms and boundaries in several decision units (Figure 7-26), establishing new decision units in the
Northeast area to be characterized (Section 4.6), and the material disposition approach
(Section 5.7.3). In addition, there was consensus with ADAFC/Regiment 935’s requirement that walls
and roads at the boundaries of decision units would be hard limits to excavation.
Community outreach as well as press releases and events are being considered to mark the following
Project milestones:
Activities will occur in two phases both on and off the Airbase. The Airbase and adjacent off-Airbase
lands can be divided into eight (8) main areas which are further divided into smaller, numbered DUs
to characterize the extent of any dioxin contamination (e.g., SW-03 in Southwest [SW]). The schedule
of activities is summarized in Table 4-1 and described below.
Interim Measures 2
(IM2)
Remediation Support
4.1.1 PHASE 1
Phase 1 (2019 through 2025) includes the following projects:
– Design and construction of temporary high and low concentration storage areas (HCSA and
LCSA) in PI area to receive excavated soil and sediment;
– Excavation of soil and sediment exceeding dioxin cleanup action levels (threshold to
determine if excavation is necessary, based on land use) in three Pacer Ivy DUs that total of
34,805 m³. Haul, sort, and place material in appropriate temporary storage areas. Site
restoration after excavation of each area has been completed; and
– USAID proactively reclassified the cleanup action level (threshold to determine whether the
soil or sediment in a DU need to be excavated and remediated) for the PI DUs to the sediment
standard of 150 parts per trillion (ppt) TEQ 1 for PI-08 and PI-10 since surface water and
stormwater flows off of the Airbase through these DUs. This reclassification results in an
additional 19,200 m3 to be remediated under this Project as compared to the EA estimation.
• SECOND INTERIM MEASURES (IM2) – Detail design is complete, and the construction package
is in procurement, with a draft invitation for bid publicly available. Details regarding the activities
to be performed under the IM2 contract include the following:
– Construction of a permanent LTSA for isolation of all Project excavated low concentration
soil and sediment;
– Renovation of the road leading to Airbase Gate 3 and upgrade Airbase hauling roads as needed
to facilitate two-way traffic;
– Excavation of soil and sediment exceeding dioxin cleanup action levels in the Southwest area,
and two (2) off-Airbase areas. Low concentration excavated material meeting the Project
storage action level (threshold to determine whether excavated soil or sediment can be
isolated rather than treated) will be hauled and placed in the LTSA. High concentration
excavated material meeting the Project treatment action level will be hauled and placed in the
HCTS area. Site restoration after excavation of each area has been completed; and
– Upon land handover from Dong Nai Province through MND, construct fencing around two
(2) additional off-Airbase areas adjacent to Pacer Ivy as identified by Dong Nai Department of
Natural Resources and Environment (DONRE).
• CIVIL WORKS PHASE 1 – is the non-treatment procurement package that will address the
remaining Phase 1 construction activities not included in IM1 or IM2. It is planned to be
implemented in five (5) annual work orders. Details regarding the activities to be performed under
this contract include the following:
– Excavation of soil and sediment exceeding dioxin cleanup action levels in the Northeast,
Northern Forest, Northwest, Pacer Ivy, ZT (taxiway), and off-Airbase areas identified by
1
TEQ = Toxicity Equivalents which standardizes toxicity of dioxins/furans and dioxin-like substances to
2,3,7,8-tetrachlorodibenzodioxin (2,3,7,8-TCDD).
– Transfer of IM1 low concentration material to the LTSA. Transfer of IM1 and IM2 high
concentration material to the TCH Treatment Plant; and
– Design and construction of sediment and erosion control measures, temporary staging areas,
and haul road improvements.
• TCH TREATMENT PLANT (DESIGN, BUILD & OPERATION) – is the procurement package
to address treatment of soils or sediment excavated in Phase 1. It will be a design/build then
operate procurement. Details regarding the activities to be performed under the TCH contract
include the following:
– Design and construction of the TCH treatment structure(s), liquid-vapor treatment plant, and
associated infrastructure in the Z1 area with the capacity to treat annually up to approximately
55,000 m³ of excavated soil and sediment above the Project treatment action level. In Phase 1,
the minimum cumulative design capacity is 150,000 m3; and
– Operate and treat material from the IM1 HCSA, the IM2 HCTS, as well as other excavated
material that meets the Project treatment action level.
REMEDIATION SUPPORT ACTIVITIES – include the following and will be performed by the A&E
Bien Hoa Contractor and Civil Works Phase 1 Contractor:
• Project management;
• Topographic surveying;
• Site-wide hydrology study, upgrades, and monitoring (includes assessment of Pacer Ivy area
preventive measures previously constructed by Office 33 and ADAFC);
• Additional soil/sediment site characterization which will modify the planned remediation volumes
(for example, determining if contamination exists in SW-08 that is the source of the off-Airbase
contamination in DONRE-A2);
• Environmental Mitigation and Monitoring Plan (EMMP) baseline sampling and monitoring;
2 Utility Supply
3 Design Approval
– Treatment Plant
– Ambient Air & Water (Baseline & Monitoring) Aug 2020 – Dec 2030
4.1.2 PHASE 2
Phase 2 projects are planned to be implemented starting in 2024 and extending through 2030. The
Phase 2 projects include:
• CIVIL WORKS PHASE 2 – is the non-treatment procurement package that will address Phase 2
construction activities. It is planned to be implemented in three (3) annual work orders. Details
regarding the activities to be performed under this contract include the following:
– Excavation of soil and sediment exceeding dioxin cleanup action levels in the remaining Pacer
Ivy and Z1 areas. Low concentration excavated material meeting the Project storage action
level will be hauled and placed in the LTSA. High concentration excavated material meeting
the Project treatment action level will be hauled and placed at the TCH Treatment Plant. Site
restoration after excavation of each area has been completes; and
– Design and construction of sediment and erosion control measures, temporary staging areas,
and haul road improvements.
REMEDIATION SUPPORT ACTIVITIES – will continue. They will include the following and will be
performed by the A&E Bien Hoa Contractor and the Civil Works Phase 2 Contractor:
• Project management;
• Surveying;
• Site-wide hydrology study update and monitoring;
• EMMP sampling and monitoring; and
• Roads (hauling roads review and recommendations).
All remedial activities and remediation support activities are described in more detail in Section 5.
The baseline risk assessment discussed in Volume 2, Section 9.2 includes a review of available data for
constituents of concern beyond dioxin and arsenic, including: metals, volatile organic compounds
(VOCs), semi-volatile organic compounds (SVOCs), herbicides, and polychlorinated biphenyls (PCBs).
There were no other substantial constituents of concern identified.
Size 300,000 cubic meters (m3) per MND Decision No. 3869 /QD-BQP
Maximum 1,200 ppt TEQ in soils and sediments
Incrementally filled based on the excavation schedule
Operational Affordability Minimize the need for operations and maintenance (O&M)
Identify O&M plan
As detailed in the LTSA Risk Assessment technical memorandum (TM) provided in Volume 2,
Annex 8, the proposed LTSA design provides necessary protection to human health from the low
dioxin-contaminated soil proposed to be stored in the LSTA (below Vietnamese industrial land use
standard). Three (3) health endpoints were assessed for dioxin and arsenic including threshold effects
for noncancer and cancer, and an additional non-threshold effect for cancer. The assessment
determined that dioxin and arsenic in the LTSA would have to be 140 times more mobile before the
noncancer hazard would be unacceptable, 1,700 times more mobile before the cancer hazard would
be unacceptable, and 30 times more mobile before the increased lifetime cancer risk is above the
acceptable residential risk level. Further information on the design, construction, and operation of the
LTSA is provided in Section 5.3.
The GVN mandated goal of remedial treatment at the Bien Hoa Airbase area and the Project action
levels are consistent – to effectively reduce dioxin in the soils with concentrations equal to or greater
than 1,200 ppt TEQ to a concentration below 100 ppt TEQ. This threshold also maximizes the ability
to use treated material as fill or other material on the Airbase in formerly contaminated areas.
The selection process was built on the technology evaluation conducted as part of the joint USAID–
MND EA that evaluated 22 remedial technologies for treating contaminated soils from the Bien Hoa
Airbase (Airbase) area, screening them against three identified criteria addressing effectiveness, costs,
and acceptability.
Since publication of the EA in 2016, MND has conducted pilot tests at Bien Hoa Airbase evaluating
several treatment technologies, namely soil washing, a TCH-Matrix Constituent Separator technique,
and a TCH technique involving hot air circulating steel tubes. The technology selection process
described utilized available results from these pilot tests as well information on advancements in
remedial treatment technologies since completion of the EA. Stakeholders agreed that developments
since completion of the EA provided no justification for adding new remedial treatment technologies
to the original list of 22 potential remedial technologies.
To re-evaluate the potential remedial technologies, USAID and GVN stakeholders agreed on criteria
in seven categories for assessing the technologies (general, effectiveness, implementability,
sustainability, cost, residual risks, and acceptance), as well as a two-stage process to apply the criteria.
The first stage involved screening the technologies against nine (9) criteria defined by the stakeholders
as “critical” to meeting Project objectives. It was agreed that only technologies meeting all nine (9) of
these critical criteria would be considered further at a second evaluation stage. The second stage
involves assessing technologies that passed the first screening stage against the remaining additional
evaluation criteria using agreed upon weight factors.
GENERAL
• Overall protection of human health and environment (1A); and
IMPLEMENTABILITY – Technology should be easy to operate and maintain and been proven to work
on dioxins. The technology must also be able to efficiently treat material in the dry and rainy season,
• Meets timeline for treating estimated volumes of soil and sediment (3B).
The assessment of remedial technologies resulted in only one (1) technology meeting all nine (9)
screening criteria: TCH. Additional detail is provided in the Technology Evaluation and Recommended
Treatment Methods TM provided in Volume 2, Annex 8.
Although three (3) technologies were identified as viable in the EA assessment, only TCH was
determined to be viable as a result of the revised evaluation process since TCH was the only
technology that met all nine (9) critical criteria. The mechano-chemical destruction technology was
eliminated from further consideration, primarily due to a lack of proven treatment effectiveness over
the range of dioxin concentrations present at Bien Hoa and lack of GVN stakeholder acceptance.
Although incineration is a proven and mature technology, the high costs associated with the energy
input requirements and the lack of GVN stakeholder acceptance eliminated incineration from further
consideration.
One example of successful use of TCH technology for dioxin remediation is the ex situ In Pile Thermal
Desorption (IPTD) system used at the Environmental Remediation at Danang Airport project (USAID
2015a, 2015b, 2015c), where soils were placed in an insulated and capped pile, and heated.
While TCH is the selected remedial treatment technology, there are a number of ways this technology
can be configured including:
EFFECTIVENESS
IMPLEMENTABILITY
• Ability to efficiently treat material in dry and rainy seasons and tropical storms (3C);
• Technology commercialized for persistent organic pollutants or have been tested on site (3F);
and
COST
ACCEPTANCE
Further information is provided on the design, construction, and operation of the TCH Treatment
Plant in Section 5.4.
Pacer Ivy and Z1 areas are significant Stormwater Runoff Dietary Exposure / Off-Airbase Adults and
secondary sources Ingestion Children (particularly
near Pacer Ivy)
• Sources
– Dioxin-contaminated soil and sediment exist as a result of past handling, storage, and disposal
of Agent Orange and, to a much lesser extent, other herbicides at the Bien Hoa Airbase;
– Contaminated surface soils and sediments have spread from their original sites of storage,
handling, and spills through several primary transport and release mechanisms: runoff during
rainfall events; excavation and movement of contaminated material during the course of
Airbase activities, construction, and agriculture; and through wind erosion;
– Secondary sources of contamination remain at the Bien Hoa Airbase Area in the form of
dioxin-contaminated soils and sediments, with a significant fraction of these dioxin-
contaminated soils and sediments being located in the Pacer Ivy and Z1 areas; and
– Off-Airbase dioxin contamination is mostly within soils and sediments located in land areas
adjacent to the Pacer Ivy Area.
– Dioxin-contaminated soils and sediment can continue to migrate from their original source
sites through physical transport mechanisms, including stormwater runoff, surface water flow,
wind erosion and deposition, and excavation and movement of contaminated materials;
– Groundwater flow is not a significant dioxin migration pathway as dioxin is not very soluble
and is prone to portioning to suspended organic solids; and
– Some contaminated soil has been disturbed since the performance of an EA (e.g., XD2
project).
• Exposure Pathways
• Receptors
– Off-Airbase adults/children who reside in proximity to the Pacer Ivy Area are particularly at
risk for exposure.
The A&E Bien Hoa Contractor has evaluated and prioritized the current list of thirty-six (36) Project
risks using the risk rating and prioritization process contained in the Project Risk Register included in
the Risk Identification and Management Plan. The Risk Identification and Management Plan provides
processes to identify risks, assign Risk Owners to monitor and manage the identified risks, and review
and action mitigation on a quarterly basis throughout the life cycle of the Project.
Appendix C provides an overview of the 19 risks determined to have a high inherent risk level, which
is a qualitative measurement based on the likelihood and impact of the identified risk. The table also
presents risk controls and mitigation for each identified risk. The remaining 17 risks consisting of four
risks determined to have a low inherent risk level and 13 risks determined to have a moderate
inherent risk level are discussed in the Risk Identification and Management Plan (Annex 1).
1) Remediation activities with the highest potential for reducing health and environmental risk
are prioritized in the first five years of implementation;
2) High contamination soil and sediment that are currently safely stored in the Z1 area landfills
are planned for treatment at the end of the Project.
3) Detailed treatment and excavation designs finalized during Masterplan implementation will
propose approaches that minimize capital costs while meeting Project objectives. With regards to the
third strategy, USAID has already identified an opportunity to reduce some of the costs and schedule
uncertainty in the Pacer Ivy area. As was discussed at Roadmap Meeting 4/5, the depth of
contamination in PI-20 is not yet defined, and the excavation needed to meet the sediment cleanup
action level could be very extensive because of the additional costs and scheduling challenges with
dewatering in a shallow groundwater level area. The consensus resolution is to reclassify PI-20 from
sediment to soil and expand the pond in PI-17 to account for the loss of the pond in PI-20. This is
shown in Figure 4-4.
Examples of other alternative solutions that have has cost and schedule implications are provided in
Section 5.9
• LAND USE CONTROLS – controls will be implemented based on any remaining dioxin levels
after remediation to prevent future exposure. All formerly contaminated sites will be restored
with treated material, at a maximum dioxin concentration of 100 ppt TEQ, or backfill at a
maximum dioxin concentration of 21.5 ppt TEQ.
Each activity is described in the Project Summary Charts including excavation volumes, dependencies,
constraints, and estimated cost/schedule in Appendix A.
• Project XD1, implemented by the CC from 2005 to 2010, included excavation and isolation in
the XD1 Landfill, in the Z1-01 DU, of approximately 62,510 m3 of dioxin-contaminated soils across
4.3 hectares (ha) in the Z1 Area. This material will be treated during Phase 2. Additional
information on the landfills is provided in Section 5.9.1;
XD2 Volume
51,520 m3
242,840 m3
Phase 2
Remaining Volume
To Excavate
244,150 m3
Phase 1
• MND/ADAFC aquaculture ban in the Bien Hoa Airbase Area since 2010 intended to reduce
and/or eliminate the dietary exposure/ingestion route;
• Office 33 and UNDP Global Environmental Finance project in 2013 included the construction of
a series of drainage ditches and diversion/retention structures around the perimeter of the Pacer
Ivy Area designed to eliminate the migration pathway and the associated dioxin exposure routes;
• MND/ADAFC construction of fencing in 2019 around select Pacer Ivy Area DUs to limit access
and prevent direct exposure risks and the posting of signs to warn of dioxin hazards and further
deter fishing in lakes and ponds on the Airbase;
• DONRE and City of Bien Hoa resettlement efforts in 2019 and 2020 to relocate approximately
75 households from the Bửu Long Ward adjacent to the Pacer Ivy Area and demolish residences
in anticipation of remediation activities to be conducted by this Project.
IM1 is a design/build construction package that differs somewhat in the excavation design since
additional site characterization data was not available at the time of award. Thus, the IM1 excavation
process includes confirmation of meeting the cleanup action level post-excavation.
The total estimated volume of dioxin-contaminated soils and sediments to be remediated by this
Project is 486,990 m3. The volumes of contaminated soil and sediment by area are provided in
Table 2-2 in Section 2.3.
The excavation process will commence after the following site preparation activities are completed:
• UXO Clearance: Through coordination with ADAFC and Regiment 935, a UXO Clearance
Contractor will conduct clearance surveys, then collect and dispose of UXOs found in accordance
with GVN regulations;
• Above ground vegetation in areas to be remediated will be removed, chipped, and applied to land
as topical application, or composted for mulch to be used in accordance with the following
guidelines:
– In Airbase areas where current soil dioxin concentrations exceed 150 ppt TEQ and the
designated land use allowable dioxin level is above 150 ppt TEQ (i.e., not rural residential,
forested land or annual cropland); and
– In a manner such that disposed vegetation will readily degrade into topsoil and not erode into
water bodies used for aquaculture, nor create a potential fire hazard or in applications of
chipped material greater than ten centimeters to prevent detrimental soil moisture retention.
As an additional measure, a buffer of ten meters could be applied at the boundaries between
suitable and unsuitable areas.
• All roots and subsurface vegetative material will be handled the same as contaminated soil;
• Erosion prevention and sediment control measures will be constructed to prevent sediment from
moving out of the excavation area and prevent rainwater from flowing out of the excavated area;
• Measures to clean and disinfect vehicles at the exit points of each excavation area will be
constructed to detoxify and avoid spilling contaminated soil on the roads;
• All sediment DUs and other DUs with standing water will be dewatered before the excavation.
Pumped water will be treated and tested before discharging into surface water bodies; and
• A temporary water collection area will be arranged in sediment DUs in which the excavated
sediment will be drained before being loaded into the vehicle.
After site preparation, excavation will commence. The following bullets detail the specific excavation
activities:
• The excavated material will be transported via dump trucks. It is anticipated that this activity will
require several dump trucks operating during the dry season to move the contaminated volumes;
• The excavation will primarily occur during the dry seasons using equipment and vehicles such as
bulldozers, crawler excavators, and conveyor belts;
• During excavation, some locations will need to be dewatered due to groundwater levels higher
than excavation depths. This process will be performed by pumping water from low spots and
arranging temporary wells near the excavated areas; and
• The removal of sediment in the Pacer Ivy Area, Northwest Area, Northeast Area, and areas
outside the Airbase will occur during dry seasons. Dewatering at lakes and submerged areas will
occur, as needed, to best facilitate the use of construction equipment normally used to excavate
in dry conditions.
After excavating the contaminated sites, transportation of contaminated soils and sediments will occur
as follows:
• Depending on the concentration level (i.e., low or high concentration), excavated soil and
sediments material will be transported to either the TCH Treatment Plant, the LTSA or a
temporary location along the service roads at the Airbase; and
• The A&E Bien Hoa Contractor will coordinate with the truck routes used by Regiment 935 and
Implementing Contractors to ensure that the routes do not interfere with the activities at the
Airbase. Sequencing of activities and tasks is further discussed in Section 6.
5.3.1 DESIGN
The characteristics for the selected LTSA location are as follows:
• Generally level and dry location with an existing north-south drainage channel;
• Reinforce drainage channel where required, and reroute channel to the west of the LTSA site;
• Land use determination is industrial (maximum dioxin of 1,200 ppt TEQ); and
• The LTSA will have the capacity to isolate approximately 300,000 m³ of material.
5.3.2 OPERATIONS
Excavation, hauling, and loading of the LTSA is anticipated to occur over an eight to ten-year period.
Details on the schedule of such work are provided in Section 6. During the operational phase of the
LTSA, the following activities will be performed:
• Confirm stability of the isolation area: Perform quarterly survey and maintenance plan to ensure
LTSA stability. Survey for caves dug by animals on the covering, development of plants, eroded
drains, signs of depression, and determine status of the system of containment dikes, fences, and
signs around the LTSA;
• Conduct repairs to remedy identified problems and conduct surveys, if necessary, after heavy rains
along with following repairs such as replanting grass or adding more soil;
Post-Project, MND will be responsible for ongoing operation and maintenance of the LTSA and needs
to commit dedicated funding to accomplish this.
• Flexible design to allow for a change of ± 10% of the actual soil/sediment volume;
• Prevent water absorption and ensure rainwater cannot absorb into the soil and treatment can
occur during the rainy season;
• Building materials that can withstand high temperatures and the acidic conditions that may occur
during treatment;
• A bottom, which is both airtight and watertight, that reduces heat loss during processing;
Siting for the TCH Treatment Plant is based on the following criteria:
• At a site elevation that is higher compared to surrounding areas to avoid flooding during the rainy
season. This will also reduce the volume of fill materials for establishing ground which is higher in
elevation than the flood level;
• At a distance and elevation that does not adversely affect Airbase flight operations; and
• Proximity to contaminated DUs in order to reduce the transport distance from dioxin
contaminated areas
Site Readiness
Excavation
Treatment
Material Reuse
Demobilization
• STAGE 1: ENGINEERING AND DETAIL DESIGN – The engineering and detail design will
provide clarity on the type of TCH treatment system, its capacity, safety, constructability,
recontamination controls, material reuse and demobilization. Several joint review meetings will be
held with GVN stockholders according to their area of expertise and responsibility. Design
submittals during the design development will be shared with MND to obtain their input and
approval;
• STAGE 2: SITE READINESS – Preparation of the treatment site will include development of
areas to store the stockpiles of contaminated soil, treatment structure/containers, secondary
treatment of liquids and vapors, support facilities, and stockpiles of treated material. Prior to
commencing construction, the areas will be cleared of UXO and vegetation, raised and graded as
needed, required utility connections will be installed, and haul roads will be improved;
• STAGE 3: EXCAVATION – As much as possible, high concentration soils will not be excavated
until the TCH Treatment Plant is available for operation. These soils will be stockpiled at the
treatment area until they are transferred to the treatment process location. Treated material
and/or uncontaminated fill will be used to backfill the excavation areas. Excavation will occur under
the Civil Works activities;
• STAGE 6: MATERIAL REUSE – After each batch of material is treated, it will be stockpiled in
areas designated for treated material. The treated soil is intended for reuse within the Airbase
property. A detailed material reuse plan will be developed for the Project to facilitate the effective
utilization of the treated soil and sediment on the Airbase; and
• ACTIVATION – The vacuum system is activated to provide a negative pressure to draw vapors
into the liquid–vapor treatment;
• HEATING – Once the contaminated material in the structure is heated, it starts to dry, and the
contained water evaporates. There will be a plateau in temperature at 100°C (212°F) until all the
water is converted to steam. The contaminated steam is extracted under vacuum for further
treatment;
• POST STEAM HEATING AND TREATMENT – After the water content evaporate, then the
dry material can be heated to the designated treatment temperature of 335°C (635°F) for the
designated duration (typically days to weeks). Confirmation sampling will be used to ensure that
the treatment process has achieved the Project treatment threshold of ≤100 ppt TEQ;
• QUENCHING – After decontamination has been confirmed, cool air and water will be brought
into the heated material to support the cooling process; and
• END OF OPERATION – After quenching, the treated material will be removed, the structure
will be inspected, and the TCH Treatment Plant will be prepared for the next batch.
Following completion of the operational phase, the TCH Treatment Plant will be dismantled and
demobilized.
• As fill for other projects (e.g., roadway construction) in support of the Civil Works packages.
Geotechnical and chemical analyses of the treated soil/sediment will be conducted to determine what
amendments are necessary to make the material suitable for use as backfill as well as to determine
whether if this option (use as backfill) is cost-effective.
After completing the thermal desorption operation, the thermal desorption pile structure, along with
equipment and thermal desorption system, will be removed, decontaminated, and returned to the
suppliers. Porous and semi-porous materials, such as concrete and building materials, will be
characterized as hazardous or non-hazardous waste. Material and equipment will be decontaminated
and characterized, via composite and/or wipe samples, before disposal or returning the supplier.
Activated carbon that may be used in the secondary treatment process will be disposed in secured
and licensed landfill facilities in Vietnam or transferred to a third country for treatment by the
contractor. The TCH demobilization process is shown in Figure 5-10.
As previously noted, GVN/USAID prepared an EA in 2016 and MND/ADAFC prepared an EIA for
this Project in 2019. The EIA outlines four Project activities and discusses the environmental aspects
and impacts (i.e., Preparation, Construction, Remediation Operations, and Environmental
Restoration). Negative environmental impacts identified relate to air quality (dust, vehicle/equipment
emissions, thermal treatment plant emissions), water quality (erosion, stormwater drainage to surface
waters, process water discharges), ambient noise and vibration (vehicle/equipment noise and
vibration), greenhouse gases (GHGs) (vehicle/equipment emissions, GHG effect) and weather.
• Monitoring to establish baseline surface water quality, air quality, groundwater quality, and ambient
noise/vibration conditions;
• Minimum process water discharge (dewatering, vehicle/equipment rinsing, leachate) and point-
source air emission limits (TCH Treatment Plant stack);
• Parameters, limits, and monitoring frequencies for surface water quality, groundwater quality, air
quality, and ambient noise/vibration monitoring;
• A Weather Station at the Project Office on Bien Hoa Airbase for monitoring temperature, relative
humidity, wind speed and direction, precipitation, solar radiation, and barometric pressure for the
duration of the Project; and
• A system for notifying Implementing Contractors of current or pending weather events (e.g.,
increasing wind speeds, changing wind directions) affecting Project activities.
EMMPs are living documents and the Project-level SWEMMP and any activity-level EMMPs will be
reviewed annually by the A&E Bien Hoa Contractor and amended with USAID concurrence as
warranted.
• Minimize disturbed areas and protect natural features and native soils to the greatest extent
practical;
• Provide and maintain natural buffers and/or equivalent erosion and sediment controls when
disturbance is within 15 meters of surface waters;
• Direct stormwater runoff whenever feasible to vegetated areas, and maximize stormwater
infiltration and filtering to reduce pollutant discharges;
• Install perimeter controls (e.g., filter berms, silt fences, vegetative strips, and temporary
diversionary dikes) at the Project site in areas to receive stormwater pollutant discharges;
• Minimize potential for vehicles and construction equipment to carry sediment beyond exit points;
• Minimize dust by applying water or other dust suppression techniques to exposed soils;
• Minimize soil compaction in areas where final vegetative stabilization is to occur, or infiltration
practices are to be installed;
• Protect storm drain inlets that remove sediment from stormwater discharges (e.g., install silt
fencing, rock-filled bags, or block and gravel);
• Install velocity dissipation devices as needed (e.g., check dams, sediment traps) to minimize
drainage channel and streambank erosion and scour in vicinity of discharges;
• Install sediment basins or impoundments as needed to reduce discharge volume and velocity and
minimize drainage channel and streambank erosion and scour;
• Stabilize exposed soils (e.g., seeding, sodding, mulching, erosion control blankets, hydro mulch,
gravel) when clearing, grading, excavating, or other land disturbing activities have permanently
ceased, or temporarily ceased on any portion of the site and will not resume for a period exceeding
14 days; and
• Provide final stabilization for any areas not covered by improved surfaces or permanent structures.
In addition to allowable dioxin levels, stakeholders will base future land use decisions on the following:
• Airbase site constraints, such as flight line clearances, explosive ordnance, and explosive safe
standoff requirements; and
As was highlighted for the LTSA, this includes operations and maintenance responsibility after Project
completion. In addition, GVN stakeholders will need to ensure that land remediated to levels of
contamination acceptable for industrial zones not be converted to urban residential land where the
allowable contamination levels are lower. During Project implementation there will be technical tasks
to build GVN stakeholder capacity to effectively maintain the LTSA and risks from residual
contamination in the Airbase Area over time. These efforts to ensure sustainable isolation at the LTSA
and established Vietnamese institutionalized controls on residual contamination are referred to as land
use controls and require GVN to commit resources in order to track, monitor, and maintain.
5.7.1 PLANNING
Project planning occurs from both a site-wide and project perspective. Planning at the project level
establishes the preliminary design, schedule, and siting for the project. Based on the preliminary design,
cost estimates are developed, which are later refined during advanced design stages.
ADAFC constructed fencing and three vehicle gates. USAID has engaged Regiment 935 to provide
personnel to manage the security gates and provide for security patrols. The Project access Gate 3 is
shown in Figure 5-15. The Project site office, Gate 3 and security posts are shown in Figure 5-16.
Prior to excavation and project activities, the Southwest, Northeast, Northwest (LTSA Site), ZT and
Z1 Areas must be secured. Off-Airbase project areas will also need to be secured.
5.7.2 CONSTRUCTION
Some activities will have a construction phase in addition to having a planning phase. There are critical
dependencies of activities in order to progress to the construction phase, which will be often
constrained to the annual dry season (November to April). The construction phase includes site
preparation, construction, oversight, and engineering services during construction.
• Vegetation Clearance and Disposal – vegetation clearance and disposal will occur in order to
prepare sites for remedial activities. Vegetation from above ground in uncontaminated areas will
be chipped and spread as mulch. However, vegetation from contaminated DUs will be excavated
for remedial treatment or long-term storage. All roots and subsurface material will be left in place
during vegetation clearance and treated the same as contaminated soil during excavation; and
• Erosion Controls and Recontamination Prevention Measures – as indicated in Section 5.5.2, each
activity will include measures to prevent the potential spread of contamination and materials
during construction.
Many different materials and equipment will be used throughout the Project. Some materials are on
the Airbase already while others will need to be brought onto the Airbase. All need to be managed
safely at the end of the Project with respect to residual levels of the Project constituents of concern
(i.e., dioxin and arsenic). Each of the Implementing Contractors will be required to follow the Project
Material Disposition Approach TM, which is provided in Volume 2, Annex 8. This approach sets
several objectives that include preventing or minimizing waste, considering material source to prevent
or minimize waste disposed on the airbase, and maximizing safe reuse.
• UNRESTRICTED REUSE – the item has a “low” level of residual dioxin or arsenic. No
limitations are placed on how an item in this category may be reused in the future;
• RESTRICTED REUSE – the item has a “medium” level of residual dioxin or arsenic.
Limitations are placed on how an item in this category may be reused in the future. For
example, the material might be limited for use in an industrial setting; and
• HAZARDOUS WASTE – the item has a “high” level of residual dioxin or arsenic. Items in this
category will be managed and treated/disposed as a hazardous waste.
Equipment
Beneficial Reuse
Waste
DISPOSITION CATEGORIES:
Unrestricted Restricted Hazardou
Reuse Reuse s Waste
Three material types are established that take into consideration the material’s condition and
potential disposition. The material types are:
• EQUIPMENT: The item can be used for its original purpose. In general, the item will be returned
to the vendor/owner, sold, or donated;
• BENEFICIAL REUSE: The item can be reused for a purpose that is different from its original
intent. For example, treated soil is the most significant item and will be used for backfill and
stockpiled for other uses; and
• WASTE: The item can no longer be used for its original purpose and has no beneficial reuse in
its current condition. The item will be sold as scrap or disposed/treated as waste.
USAID will require all Implementing Contractors to develop, and update, a material disposition plan
with a master list summarizing the materials planned to be used on site and the plans for their
disposition. For each master list item, the plan will identify the material’s name, description, estimated
quantity, potential for direct or indirect contact with dioxin and arsenic, and location of purchase
(e.g., in-country or imported to Vietnam), residual contamination testing approach, and disposition
methods and destinations for contamination at different action levels/disposition categories.
A map highlighting the on-Airbase and off-Airbase areas in which various activities of Phase 1 and Phase
2 will be implemented is shown in Figure 5-17.
Table 5-4 provides the Phase 1 excavation and hauling activities by decision unit, including Civil Works
Phase 1.
Figure 5-18 shows the areas in which remediation activities will be implemented under Phase 1 of the
Project.
IM1 will include excavation of soil/sediment containing dioxin concentrations exceeding excavation
standards in the Pacer Ivy Area, PI-8, PI-10, and PI-13A’ (a total of 32,948 m³), to a depth of 90 cm.
Table 5-5 provides a summary of the contaminated volumes to be excavated.
IM1 will include clean up to the sediment standard in areas where surface water/stormwater exits the
Airbase. IM1 will include design and construction of a high concentration storage area (HCSA) to
receive excavated soils with dioxin concentrations equal to or greater than 1,000 ppt TEQ within
Pacer Ivy Area DU PI-2. Finally, the project will include design and construction of a low concentration
storage area (LCSA) to receive excavated soils with dioxin concentrations less than 1,000 ppt TEQ.
Table 5-6 provides the Phase 1 excavation and hauling work by decision unit under IM1.
TABLE 5-6 PHASE 1 EXCAVATION & HAULING WORK BY DECISION UNIT – IM1
ACTIVITY OR CONCENTRATION (m3) TOTAL
ANNUAL DU NOTES
LOW HIGH (m3)
WORK ORDER
PI-08 13,190 3,100 16,290 Dig and haul to LCSA, HCSA, or HCTS
IM1
based on material concentration Reload
PI-10 10,910 4,710 15,620 high concentration material to TCH
Treatment Plant in Civil Works Annual 3
PI-13A' 1,040 - 1,040
Notes:
Volume figures (amounts) are rounded to the nearest ten
• Excavation, hauling, and storage of contaminated materials located in the Southwest DUs SW-01,
SW-02, SW-03, SW-07, and in off-Airbase areas G2L-01 and MND-A42;
• LTSA for Airbase-wide low concentration storage. With design and construction of the LTSA
concurrent to excavation, low concentration materials will be hauled directly to the LTSA;
• Temporary high concentration soil storage area in PI-13;
• Rehabilitation of the access road leading to Gate 3 as well as the construction of a new access
road to the Uncontaminated Construction Debris Disposal Area (UCDDA) north of the LTSA;
and
• Security fence for off-Airbase areas DONRE A1 & A2.
Table 5-7 provides a summary of the contaminated volumes to be excavated.
Table 5-8 provides the Phase 1 excavation and hauling work by decision unit under IM2.
TABLE 5-8 PHASE 1 EXCAVATION & HAULING WORK BY DECISION UNIT – IM2
ACTIVITY OR CONCENTRATION (m3) TOTAL
ANNUAL DU NOTES
LOW HIGH (m3)
WORK ORDER
Total
41,380 14,100 55,480
Remediation work areas under IM2 including the location of the LTSA is shown in Figure 5-20.
The project will include the stages discussed in Section 5.2, such as the design and construction of
erosion control measures, temporary staging areas, and haul road improvements to the TCH
Treatment Plant and the LTSA. Site restoration will occur, per Section 5.6, upon the completion of
excavation. Fill for the restoration will initially be brought from off-site. After Civil Works Annual 3,
treated materials may be considered for use as site restoration fill.
A key aspect of this activity is the phasing of excavation. The criteria below provide a basis for the
priority of phasing for the excavation of contaminated DUs:
• Cleanup to sediment standards areas where storm/surface water leaves the Airbase;
This activity is projected to occur over a four-year period. Site security, UXO clearance and site
investigations will occur for all areas in the first year of the implementation.
Figure 5-21 shows the remediation work areas which will be performed as part of the Civil Works
activities in Phase 1 of the Project.
• Annual 1
– Low-concentration materials in temporary storage at the LCSA, excavated during IM1 and the
off-Airbase area G2L-01 (part of IM2) will be transferred to the LTSA. The remaining low-
concentration materials excavated in IM2 Areas will be hauled directly to the LTSA; and
– Contaminated materials will be excavated from NF-04 and hauled to the LTSA.
Table 5-9 provides the Phase 1 excavation and hauling work by decision unit in Annual 1.
TABLE 5-9 PHASE 1 EXCAVATION & HAULING WORK BY DECISION UNIT – ANNUAL 1
ACTIVITY OR CONCENTRATION (m3) TOTAL
ANNUAL DU NOTES
LOW HIGH (m3)
WORK ORDER
Annual 1: Reload Total 35,270 82,160
LCSA and G2L
LCSA - - 25,140
in SW-02 to Reload to LTSA
LTSA, Dig and G2L in SW-02 - - 1,370
haul NF-04 35,270 - 35,270 Dig and haul to LTSA directly
Figure 5-22 shows the work that will be performed under Civil Works – Annual 1 in Phase 1 of
the Project.
– Contaminated materials will be excavated from Northeast (NE-07, NE-08, NE-09, NE-11, NE-
12, NE-15) and Northwest (NW-03, NW-04). These materials will be hauled to either the
LTSA or the HCTS area.
Table 5-10 provides the Phase 1 excavation and hauling work by decision unit during Annual 2.
TABLE 5-10 PHASE 1 EXCAVATION & HAULING WORK BY DECISION UNIT – ANNUAL 2
CONCENTRATION
ACTIVITY OR ANNUAL (m3)
DU TOTAL (m3) NOTES
WORK ORDER
LOW HIGH
Figure 5-23 shows the work that will be performed under Civil Works – Annual 2 in Phase 1 of
the Project.
– High concentration materials in temporary storage at the HCSA and HCTS, excavated from
IM1, IM2 and Annual 1 Civil Work, will be reloaded to the TCH Treatment Plant; and
– Contaminated materials will be excavated from off-Airbase (DONRE-A1 and A2), Pacer Ivy
Area (PI-12, PI-15) and Taxiway (ZT-02). These materials will be hauled to either the LTSA
or the TCH Treatment Plant.
Table 5-11 provides the Phase 1 excavation and hauling work by decision unit during Annual 3.
TABLE 5-11 PHASE 1 EXCAVATION & HAULING WORK BY DECISION UNIT – ANNUAL 3
ACTIVITY OR CONCENTRATION (m3) TOTAL
ANNUAL DU NOTES
LOW HIGH (m3)
WORK ORDER
Figure 5-24 shows the work that will be performed under Civil Works – Annual 3 in Phase 1 of
the Project.
– The project will include the excavation and hauling of high concentration materials from PI-
02C and a portion of PI-02B to the TCH Treatment Plant;
– The remaining low concentration materials from PI-13A’’ (previously underneath the HCTS)
will be excavated and hauled to the LTSA.
Table 5-12 provides the Phase 1 excavation and hauling work by decision unit during Annual 4.
TABLE 5-12 PHASE 1 EXCAVATION & HAULING WORK BY DECISION UNIT – ANNUAL 4
CONCENTRATION
ACTIVITY OR ANNUAL (m3)
DU TOTAL (m3) NOTES
WORK ORDER
LOW HIGH
Figure 5-25 shows the work that will be performed under Civil Works – Annual 4 in Phase 1 of
the Project.
As detailed in Section 5.4, the TCH Treatment Plant will be constructed and filled during the dry
season and the soils will be treated during the rainy season. Unloading to a post-treatment storage
area will occur during the beginning of the next dry season. Material will then be reused for either
excavation fill or for construction fill. Table 5-13 provides a summary of the TCH Treatment Plant
estimated footprints.
A map showing the main components of the TCH Treatment Plant is presented in Figure 5-26.
Table 5-14 identifies and provides the timeline for the remediation support activities.
5.8.2 PHASE 2
Phase 2 activities address contaminated DUs within the PI and Z1 areas of the Airbase and are listed
along with the timeline in Table 5-15.
Table 5-16 provides the Phase 2 excavation and hauling work by decision unit, including Civil Works
Phase 2.
Annual 1: Dig and haul PI-02 A 5,030 40,980 46,010 Dig and haul to LTSA or TCH
Treatment Plant based on
material concentration
PI-02 B - 25% - 11,240 11,240
Figure 5-27 shows the areas in which remediation activities will be implemented under Phase 2 of the
Project.
The project will include the elements discussed in Section 5.2, such as the design and construction of
erosion control measures and haul road improvements to the Z1 and the LTSA. Site restoration will
occur, per Section 5.6, upon the completion of excavation. Fill for the restoration will initially be
brought from off-site. In Annual 1 of the project, treated materials may be considered for use for site
restoration fill.
This activity is projected to occur over a four-year period under annual work orders. Since the UXO
clearance was completed in Phase 1, any site investigations can occur for all areas in the first year of
Phase 2.
Figure 5-28 shows the remediation work areas which will be performed as part of the Civil Works
activities in Phase 2 of the Project.
• Annual 1
– The project will include excavation and hauling of high concentration materials from the
remaining part of the PI-02 (PI-02A & PI-02B 25%) area to the TCH Treatment Plant; and
– Low-concentration materials will be excavated and hauled from the remaining part of the PI-
02 (PI-02A) area to the LTSA.
Table 5-17 provides the Phase 2 excavation and hauling work by decision unit during Annual 1.
TABLE 5-17 PHASE 2 EXCAVATION & HAULING WORK BY DECISION UNIT – ANNUAL 1
CONCENTRATION
ANNUAL - ACTION DU (m3) TOTAL (m3) NOTES
LOW HIGH
Figure 5-29 shows the work that will be performed under Civil Works – Annual 1 in Phase 2 of
the Project.
– The project will include excavation and hauling of high concentration materials from PI-17, PI-
18, PI-20, and portion of Z1-01 50% areas to the TCH Treatment Plant; and
– Low-concentration materials will be excavated and hauled from the PI-17 and PI-18 areas to
the LTSA.
Table 5-18 provides the Phase 2 excavation and hauling work by decision unit during Annual 2.
TABLE 5-18 PHASE 2 EXCAVATION & HAULING WORK BY DECISION UNIT – ANNUAL 2
CONCENTRATION
ANNUAL - ACTION DU (m3) TOTAL (m3) NOTES
LOW HIGH
Figure 5-30 shows the work that will be performed under Civil Works – Annual 2 in Phase 2 of
the Project.
– The project will include excavation and hauling of high concentration materials from remaining
Z1-01 50% and Z1-XD2 35% areas to the TCH Treatment Plant; and
– Low-concentration materials will be excavated and hauled from the Z1-02, Z1-03, and Z1-06
areas to the LTSA.
Table 5-19 provides the Phase 2 excavation and hauling work by decision unit during Annual 3.
TABLE 5-19 PHASE 2 EXCAVATION & HAULING WORK BY DECISION UNIT – ANNUAL 3
CONCENTRATION
ANNUAL - ACTION DU (m3) TOTAL (m3) NOTES
LOW HIGH
Figure 5-31 shows the work that will be performed under Civil Works – Annual 3 in Phase 2 of
the Project.
– The project will include excavation and hauling of high concentration materials the Z1-10 and
Z1-XD2 65% areas to the TCH Treatment Plant; and
– Low-concentration materials will be excavated and hauled from the Z1-07, Z1-09, Z1-10 and
Z1-16 areas to the LTSA.
Table 5-20 provides the Phase 2 excavation and hauling work by decision unit during Annual 4.
TABLE 5-20 PHASE 2 EXCAVATION & HAULING WORK BY DECISION UNIT – ANNUAL 4
CONCENTRATION
ANNUAL - ACTION DU (m3) TOTAL (m3) NOTES
LOW HIGH
Figure 5-32 shows the work that will be performed under Civil Works – Annual 4 in Phase 2 of
the Project.
TCH treatment of dioxin-contaminated soil and sediment is necessarily complex, requiring a level of
experience and technology that makes this the most expensive type of remedial activity per cubic
meter of material handled. For safety and cost reasons, it is most efficient to continually ask whether
a task must occur or would substantially benefit from being performed by the TCH Treatment
Contractor. Opportunities to shift work and better match contractors’ specialties include removing
construction of the pre-treatment and post-treatment material stockpiles from the TCH Treatment
Contractor’s statement of work (SOW) and into the Civil Works Phase 1 SOW as depicted in
Figure 5-34 using red color for the TCH Treatment Contractor and green for the Civil Works Phase 1
Contractor.
Level 3:
Remediation
Activity Activities
Remediation Support Activities
Type
Level 4: IMs
Civil Utilities (Power & Treatment
Activity Works Water) Infrastructure Plant
Level 5: Roads
Drainage
LTSA Cover etc.
Sub-Activity Improvements
Roads Fencing
5 Sub-Activity Drainage Improvements Temporary structures
LTSA Cover Sampling
Planning Operations
Engineering and Design Post-construction
6
Work Stage Procurement/ Bid and Award Oversight/CM/EMMP
Engineering Services During Procurement
Construction
and Construction
Design Submission Treatment
GVN Approval Restoration
Design Review Final Documentation
7 Task
Site Mobilization Material Reuse and Waste Disposal
Traffic Control Demobilization
Excavation Final Inspection
Notes:
CM – Construction Management
EMMP – Environmental Mitigation and Monitoring Plan
TCH – Thermal Conductive Heating
UXO – Unexploded Ordnance
IM1 – Interim Measures 1
IM2 – Interim Measure 2
• Phase 1 – Phase 1 is comprised of the activities and tasks that will be used to execute remediation
through 2025. Phase 1 activities are listed in Figure 6-1 and are described in Section 5.8. These
activities and tasks address contaminated materials posing the greatest risk to off-Airbase base
areas. Phase 1 activities and tasks seek to halt contamination migration to off-Airbase areas; and
• Phase 2 – Phase 2 is comprised of the activities and tasks that will be used to execute remediation
and demobilization through 2030. Phase 2 activities are listed in Figure 6-1 and are described in
Section 5.8. Currently, highly contaminated materials in Phase 2 areas are currently contained and
do not pose as high of a risk to off-Airbase and migration of contaminants.
• Remediation activities are works for dig and haul, civil works, LTSA, treatment plant, utilities
(power and water) infrastructure and related activities. Most of these works are on the critical
path driving the Project schedule completion; and
• Remediation support activities which progress though out the project life cycle for facilitating,
managing and controlling the remediation activities until completion. MND’s contributions which
includes UXO clearance, power infrastructure, water infrastructure, project coordination,
oversite and design approvals are also vital parts of the continuous flow of the remediation
activities.
In Phase 1 five remediation activities are identified (i.e. IM1, IM2, Civil Works Phase 1, Utilities [Power
and Water] Supply infrastructure and TCH Treatment Plant). The TCH Treatment Plant activity
includes design, construction and operation stages. In addition, remediation support activities are
identified for implementation in Phase 1. All of Phase 1 activities are described in Section 5.8 and are
summarized in overview charts found in Appendix A.
Two remediation activities are identified to be implemented in Phase 2. The TCH Treatment Plant
Operation and Demobilization and Civil Works Phase 2. Phase 2 Activities are also described in
Section 5.8 and are summarized in overview charts found in Appendix A.
The schedule in Section 6.2 shows the sequencing of the remediation efforts. In terms of sequencing,
the LTSA and TCH Treatment Plant must be ready to accept excavated soils and sediments in the
early phase of the Project. During the first-year of the Masterplan implementation construction of the
LTSA along with a main segment of the road leading to Gate 3 of the Airbase will occur to facilitate
the excavation, hauling, storing and site restoration of contaminated soil and sediment as part of
The Project schedule was developed with several constraints, dependencies and assumptions.
Examples of the constraints include available funding, off-Airbase relocation schedule, weather, work
hours schedule, market, available equipment, traffic management. Dependencies include UXO
clearance, design approvals, utilities, LTSA construction and Treatment Plant construction. Capital
cost estimates include contingency volumes, unit rates, activity/sub-activity durations.
The Project schedule for Phase 1 and Phase 2 activities shown in Figure 6-2 and Figure 6-3. A more
detailed schedule that presents all Masterplan activities is provided in Appendix B.
Unit rates for the various activities and tasks were derived from the current Project planning and
design activities, the EA, EIA, the Environmental Remediation at Danang Airport, and recent cost data
from IM1 and IM2.
A contingency rate of 10% was added on the construction cost to improve the estimate accuracy to
accommodate implementation maturation.
The distribution of expenditure for the remediation activities and the remediation support activities
over the span of the masterplan implementation is shown in Table 6-3, while an overall estimated
Project cumulative capital cost (S-curve) and annual distribution (cash flow) is shown in Figure 6-5.
60.0 500.0
450.0
50.0
400.0
40.0
300.0
30.0 250.0
200.0
20.0
150.0
100.0
10.0
50.0
0.0 0.0
2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030
• Figure 7-1 Historical (1968) Overlay Bien Hoa Airbase Area (Larger/Detailed Image);
• Figure 7-4 Proposed Project Action Levels for Masterplan Development (Larger/Detailed Image);
• Figure 7-27 Northeast Area Showing Topography, Post-Project Dioxin Concentrations, and Land
Use (Larger/Detailed Image);
• Figure 7-32 Groundwater Table Contours - Dekonta Report, 2014 (Larger/Detailed Image);
Masterplan approval is required for > As an approval risk this is a single point of failure.
implementation; therefore, delay in approval will > Follow the Implementation Masterplan Workplan.
3 delay (or stop) procurement and High > Update the Implementation Masterplan Workplan.
implementation. > Assure concurrence is gained at key milestones during Roadmap Meetings.
Design Review Cycle can be lengthy; therefore, > As an approval risk this is a single point of failure.
4 approvals of the treatment and other designs High > Map the Design Review Cycle and Approval Process to identify key dates and
may be delayed. potential bottle necks, key hand offs and other potential single points of failure.
Internal and external "Approvals" of various > Specifically identify Approvals as Single Points of Failure.
deliverables across the project life cycle are > Map Approvals tasks and dates.
5 critical to project progress; therefore, delayed High > Have Approvals as specific agenda items in Project Risk Owner Calls.
Approvals will disrupt or halt project progress in > Assure Approvals are monitored and tracked on a weekly basis so that proactive
multiple project phases. management and corrective actions can be taken immediately.
Land use determines the allowable limits for > Review this risk with stakeholders and applicable GVN agencies to assure
dioxin in soils (21.5 ppt to 1,200 ppt TEQ), but requirements are identified early in the process.
6 some areas (on and off-Airbase) do not have land High > Reach consensus by Roadmap Meeting 3
use determined; therefore, there is uncertainty > Identify when design requirements need to account for the various standards.
in volumes and remedial measure design for > Assure all design reviews account for the various standards.
these areas.
Unlicensed dioxin hazardous waste disposal > Closely monitor progress on GVN activities in this area by engaging with DONRE
facility may not be operated on an on-going basis and MONRE.
7 therefore it is possible GVN regulations relevant High > Participate in discussions with Stakeholders regarding such facilities.
to these facilities could affect management of low > Reach consensus by Roadmap Meeting 3
levels of dioxin at Bien Hoa Airbase. > Assure designs at Bien Hoa Airbase account for any related regulations.
ARARs will become more stringent during the > Identify ramifications of ARARs to activities
8 life of the Project; therefore, changes in activities High > Plan activities for most stringent ARAR scenario
will increase schedule and/or costs. > Identify cost and schedule impacts of ARARs
The application of QCVN 43:2012 and 2017 to > Review standards for applicability to the Bien Hoa Area
different areas on and off-Airbase is unclear; > Monitor the regulations for changes to applicability
9 therefore, there is uncertainty in volumes and High > Seek stakeholder input for clarity of applicability
remedial measure design for sediment. > Assess impacts to project phases based on concentrations and potential changes
in expected sediment treatment volumes
PREPARED BY
TRIGON ASSOCIATES, LLC
1515 POYDRAS ST. SUITE 2200
NEW ORLEANS, LA 70112
USA
TABLES
TABLE 1: GENERAL ROLES AND RESPONSIBILITIES FOR PROJECT RISK IDENTIFICATION
AND MANAGEMENT ACTIVITIES .......................................................................................................... 2
TABLE 2: GENERAL ROLES AND RESPONSIBILITIES FOR PROJECT RISK IDENTIFICATION
AND MANAGEMENT ACTIVITIES .......................................................................................................... 6
TABLE 3: QUARTERLY AND SEMI-ANNUAL REVIEWS OF THE PROJECT RISK PLAN AND
RISK REGISTER ............................................................................................................................................... 7
TABLE 4: THREE OF THE HIGH-LEVEL RISKS FROM THE RISK BRAINSTORMING SESSION ............. 10
TABLE 5: RISK ASSESSMENT ...................................................................................................................................... 11
TABLE 6: RISK RATING AND PRIORITIZATION METHOD............................................................................ 11
TABLE 7: HIGH-LEVEL RISK CONTROL AND MITIGATION ACTIONS..................................................... 12
TABLE 8: 14-STEP PROJECT RISK MATRIX DATA POPULATION PROCESS ............................................ 13
TABLE 9: RISK ELEVATION TEMPLATE .................................................................................................................. 13
TABLE 10: POTENTIAL OPPORTUNITIES ............................................................................................................. 14
TABLE 11: PROJECT KEY RISK METRIX ................................................................................................................. 14
This plan has been established in part as a result of findings and recommendations in the Office of the
Inspector General Report, Audit of USAID/Vietnam’s Environmental Assessments and Remediation
Project, Audit Report No. 5-440-15-001-P and specifically Recommendation 1: “We recommend that
USAID/Vietnam implement a formal risk management plan with updated potential risks and documented
responses to address the identified risks.”
An initial list of thirty-six (36) project risks were identified, and more risks will be added when identified
as the project progresses. Individual segments and components of The Project Risk Register are described
in detail in Section 3 of this plan and the entire Project Risk Register is in Appendix A. Most risks were
identified by representatives from the USAID and the Architect–Engineer (A&E) Bien Hoa Contractor at
a Project Risk Brainstorming Session in Bien Hoa on October 10, 2019. Attendees were presented with,
and discussed, a Project Risk Identification and Management Plan Framework which included the five (5)
principles (listed in Section 1) used to develop this Project Risk Identification and Management Plan and
the risk management process described in Section 2.
A summary of the approach and objective to determine Project risks was subsequently presented and
discussed during the Project Masterplan Roadmap Meeting #2 on November 19, 2019 with Government
of Vietnam (GVN) stakeholders who collaboratively identified another six (6) key preliminary Project
risks. As the Project progresses other risks will emerge, be identified, assessed, and prioritized for risk
management using similar consultation processes.
USAID and the A&E Contractor have evaluated and prioritized the current list of thirty-six (36) Project
risks using the risk rating and prioritization process contained in the Project Risk Register included in
Appendix A:
• 19 risks are rated High Risks (to be reduced to Moderate by controls and mitigation)
• 13 risks are rated at Moderate Risks
• 4 risks are rated as Low Risks
USAID has assigned preliminary high-level Risk Control and Mitigation Actions to the nineteen (19) High-
level Risks and these are listed in the Project Risk Register. The Project Risk Register is a simple,
straightforward MSExcel® workbook with multiple tabs holding supporting information including:
definitions of terms, a simple prioritization calculation to rate and rank risks, the Risk Register population
process, Risk Elevation form, and tabs for organizing opportunities and metrics. The Project Risk Register
is a tool to organize, describe, prioritize, manage and track project risks across all phases of the project.
The process is designed to provide guidance to decision-makers, not make decisions for them.
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FINAL PROJECT RISK IDENTIFICATION AND MANAGEMENT PLAN
PLAN IMPLEMENTATION
Implementing this Project Risk Plan and achieving its objectives (Section I) will involve all project
participants and will be managed throughout the project life cycle. Project Risk Plan implementation, (see
Section 2), will be executed by the A&E Contractor. The A&E Contractor will intermittently review
project activities during all phases of the project to identify risks that emerge or change throughout the
project life cycle. Project Risk Plan implementation will include the following key steps and timeframe:
• Review Project Risk Plan content with A&E Contractor and USAID in March or April 2020
• Address A&E Contractor and USAID comments and finalize the Project Risk Plan by Meeting #4
• Assign Risk Owners responsible for implementing risk control and mitigation actions in April 2020
• Develop a Project Risk Plan training session to train Risk Owners and others on content and
requirements of the Project Risk Plan, and the Project Risk Management process for Meeting #4
• Provide training for Risk Owners and other personnel responsible for work activities (Date to be
determined [TBD])
• Identify additional project risks and during training add to the Project Risk Register (Date TBD)
• Hold Risk Owner calls to review progress on project high risks (Bi-weekly)
• Make adjustments to Project Risk Management practices as necessary (After Quarterly Reviews)
• Monitor Risk Owner progress on Project Risk controls and mitigation actions (Monthly)
• Update the Project Risk Register as necessary (After Quarterly and Semi-Annual Reviews)
• Prepare and conduct Quarterly Internal and Semi-Annual GVN Stakeholder Project Risk Reviews
• Communicate project risks to inform USAID and GVN Stakeholders (In Semi-Annual Reviews)
TABLE 1: GENERAL ROLES AND RESPONSIBILITIES FOR PROJECT RISK IDENTIFICATION AND MANAGEMENT ACTIVITIES
Organization Role Project Activity Frequency
Interaction on Project Risks with GVN Stakeholders As Needed and during
Contracting Officer’s
USAID and direction to A&E Contractor on Risk Quarterly and Semi-
Representative (COR)
Management Practices and Progress Annual Reviews
Supports USAID with updates on Project Risk As Needed and during
Management Progress Quarterly and Semi-
A&E Contractor Chief of Party (COP) Assigns responsibility for maintaining the Project Risk Annual Reviews
Register and monitoring progress on Project Risk As Needed in all
Controls and Mitigation Actions Project Phases
USAID, A&E Assure Risk Control and Mitigation Actions As needed by the A&E
Contractor, established in the Project Risk Register are executed to assure Project Risk
Remediation in a timely manner and progress requirements are Control and Mitigation
Risk Owners
Technical Support met
and Project Review Moderate and Low rated risks and upgrade Quarterly for review
Contractors or demote as necessary at Internal Reviews
A&E Contractor Remediation Technical Identify and manage Project Risks in project work Daily and as needed
Remediation Leads and Project activities and provide to the Project Risk Lead to for Quarterly and
Technical Support Managers populate the Project Risk Register Semi-Annual Reviews
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FINAL PROJECT RISK IDENTIFICATION AND MANAGEMENT PLAN
QUARTERLY AND SEMI-ANNUAL PROJECT RISK REVIEWS BY USAID AND GVN
STAKEHOLDERS
The A&E Contractor will review the status of the risks with USAID during Quarterly Internal Review
meetings and with USAID and GVN Stakeholders during Semi-Annual Reviews. The A&E Contractor will
update the Risk Register prior to each review, as needed when new risks are identified during project
activities, and for A&E internal meetings in preparation for the USAID and GVN Stakeholder Quarterly
and Semi-Annual Project Risk Review meetings. Reviews will be conducted according to the partial
schedule as shown below in Table 2 (see additional detail in Table 3, Section 2.2 and the complete schedule
in Appendix B). Each review will take place during a Project Risk Workshop designed to inform attendees
about progress on controlling and mitigating Project Risk. The Workshop will identify new Project Risks
and establish control and mitigation actions.
The Quarterly and Semi-Annual Reviews will be facilitated by the A&E Contractor to gather input on and
feedback on the Project Risk Identification and Management Plan, Control and Mitigation Actions, and the
associated Risk Management process. Workshop activities will review how Project Risks are identified,
prioritized and managed. GVN Stakeholder attendees at the Workshops will be encouraged to participate
in a training exercise to identify risks and describe them using the “Risk Statement” method and prioritize
them using the method embedded in the Project Risk Register. In this manner Quarterly and Semi-Annual
Project Risk Review Workshop attendees will gain a “hands-on” understanding of the Project Risk
Management process. This activity will contribute to Risk Management Capacity Building as described
below. Results of the Review Workshops will improve the Plan and overall management of project risks.
This process for managing Project Risk established in this plan is designed to be easily accessed and
understood by users and communicated to stakeholders. When used in a systematic manner as described
in this Project Risk Plan and executed through the Project Risk Register. The Project Risk Plan contains
simple but effective means to identify, organize, prioritize, control and manage Project Risks.
However, it should be recognized that this Plan is only a tool to help Risk Owners and the Project team
manage and communicate project risks to USAID and GVN Stakeholders. This Plan and the Project Risk
Register will not take the place of disciplined, diligent and dedicated risk management actions by all Bien
Hoa Airbase Area Dioxin Remediation A&E Contractor Project Team members and Contractor and
Subcontractor Leads. Ultimately, the success of this Project Risk Plan depends on the positive and
constructive efforts of all team members to identify, understand, manage and communicate risks.
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FINAL PROJECT RISK IDENTIFICATION AND MANAGEMENT PLAN
1 PURPOSE AND INTRODUCTION
The purpose of the Project Risk Identification and Management Plan is to identify, evaluate, prioritize, and
manage the risks associated with the planning, design, procurement, construction and post-construction
project life cycle phases of the Project.
The Project Risk Plan was developed according to the following five (5) principles to make the Plan as
useful and easy as possible to understand and communicate:
This Project Risk Plan is designed to help the A&E Contractor accomplish these five (5) objectives:
• Identify, assess, prioritize and manage project risks throughout all project life cycle phases.
• Define, establish and update risk control and mitigation measures.
• Identify Risk Owners responsible for implementing risk control and mitigation measures.
• Support review of project risks by the A&E, USAID and GVN Stakeholders.
• Contribute to USAID efforts to build GVN Capacity for Dioxin Project Risk Management.
The success of the Plan in meeting these objectives will be monitored and evaluated during A&E
Contractor internal reviews and during Quarterly and Semi-Annual Reviews with USAID and GVN
Stakeholders. Change to the Project Risk Plan and the Project Risk Register will be made based on the
results and recommendations of the reviews.
Risk is an intrinsic part of life as every activity has some risk involved. Risk also involves some uncertainty
and hazard or danger to people. Risk is also about uncertainties that can affect how an organization or a
project achieves objectives. Risk management is about controlling and reducing risk to people, programs
and projects to prevent and reduce the impact of problems. The purpose of managing risk is to take action
on problems before they get out of control and cause a program, project, or organization to fail. There
are certain widely considered effective means to address risk, although these vary from reference to
reference, among them are the following:
• Avoid the risk • Control the risk
• Eliminate the risk • Mitigate to reduce the risk
• Transfer the risk • Accept the risk (and Monitor)
• Share the risk
Risks can be accepted without extensive controls, as is the case with this plan for Project risks rated
moderate and low, but they should always be monitored on a routine basis. This Project Risk Plan includes
provisions for monitoring risks that are accepted but also for elevating them if they change. Risks
identified and prioritized as not having an effect on early project phases will be reevaluated as the project
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FINAL PROJECT RISK IDENTIFICATION AND MANAGEMENT PLAN
transitions from one phase to the next. Reevaluating risks when the project moves into a new phase
assures that risks are reprioritized during all the project phases. This will likely result in risks rated
moderate or low in early project phases being rated high in the later project phases.
Reducing risk requires systematic identification, assessment, and management actions. To reduce project
risk, it is necessary to systematically evaluate and prioritize and focus on what is most important. Focusing
on what is important, not just what is urgent, is key to achieving project objectives and assuring project
and organization success. Reducing the greatest amount of risk in the shortest amount of time at the
lowest cost helps assure project success. Reducing risk also involves making decisions about where to
allocate resources. Defending resource allocation decisions to top leadership about why the decisions are
made is necessary to meet the expectations for resources to be applied most effectively.
As Project Risks are identified the A&E Contractor will describe them in the Risk Statement section of
the Risk Register Matrix. A Risk Register process description is included in Appendix A of this Plan. After
the risks are adequately defined the A&E Contractor will prioritize them using the risk rating and ranking
scoring method embedded in the Risk Register. If the risk rates “High”, the A&E Contractor will establish
risk control and mitigation actions and assign a Risk Owner who will be responsible for actions to control
and mitigate the project risk. Project Risk Plan implementation will include the following key steps:
• Review Project Risk Plan content with A&E Contractor and USAID in March or April 2020
• Address A&E Contractor and USAID comments and finalize the Project Risk Plan by Meeting #4
• Assign Risk Owners responsible for implementing risk control and mitigation actions in April 2020
• Develop a Project Risk Plan training session to train Risk Owners and others on content and
requirements of the Project Risk Plan, and the Project Risk Management process for Meeting #4
• Provide training for Risk Owners and other personnel responsible for work activities (Date TBD)
• Identify additional project risks and during training add to the Project Risk Register (Date TBD)
• Hold calls with Risk Owners to review progress on project high risks (Bi-weekly)
• Make adjustments to Project Risk Management practices as necessary (After Quarterly Reviews)
• Monitor Risk Owner progress on Project Risk controls and mitigation actions (Monthly)
• Update the Project Risk Register as necessary (After Quarterly and Semi-Annual Reviews)
• Prepare for Quarterly Internal and Semi-Annual GVN Stakeholder Project Risk Reviews (Bi-Monthly)
• Communicate Project Risks to USAID and GVN Stakeholders (Quarterly and Semi-Annual Reviews)
Additional detail on Project Risk Plan implementation is included in Table 2 in Section 2.1 and Table 3 in
Section 2.2 below, the Project Risk Register in Appendix A, and the Quarterly and Semi-Annual Review
Schedule in Appendix B.
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FINAL PROJECT RISK IDENTIFICATION AND MANAGEMENT PLAN
2.1 PROJECT RISK MANAGEMENT GENERAL ROLES AND RESPONSIBILITIES
In order to effectively manage Project Risks it is necessary to assign responsibilities the Bien Hoa Area
Dioxin Remediation Project management, technical and construction project roles and tasks. Table 2
below describes the general responsibilities related to the Project Risk Plan, key project activities and the
frequency of execution.
TABLE 2: GENERAL ROLES AND RESPONSIBILITIES FOR PROJECT RISK IDENTIFICATION AND MANAGEMENT ACTIVITIES
Organization Role Project Activity Frequency
Interaction on Project Risks with GVN Stakeholders As Needed and during
Contracting Officer’s
USAID and direction to A&E Contractor on Risk Quarterly and Semi-
Representative (COR)
Management Practices and Progress Annual Reviews
Supports USAID with updates on Project Risk As Needed and during
Management Progress Quarterly and Semi-
A&E Contractor Chief of Party (COP) Assigns responsibility for maintaining Project Risk Annual Reviews
Register and monitoring progress on Project Risk As Needed in all
Controls and Mitigation Actions Project Phases
USAID, A&E Assure Risk Control and Mitigation Actions As needed by the A&E
Contractor, established in the Project Risk Register are executed to assure Project Risk
Remediation in a timely manner and progress requirements are Control and Mitigation
Risk Owners
Technical Support met
and Project Review moderate and low rated risks and upgrade or Quarterly for review
Contractors demote as necessary at Internal Reviews
As needed for Internal
Maintains, updates and makes adjustments in the
A&E Contractor meetings and in
Project Risk Project Risk Register as new risks are identified and
Remediation preparation for and
Management Specialist based on results of A&E Internal and Quarterly and
Technical Support during Quarterly and
Semi-Annual USAID and GVN Stakeholder Reviews
Semi-Annual Reviews
A&E Contractor Remediation Technical Daily and as needed
Remediation Leads and Project Identify and manage Project Risks for Quarterly and
Technical Support Managers Semi-Annual Reviews
Daily and as needed
Project
Contractor Leads Identify and manage project work activity risks for Quarterly and
Contractors
Semi-Annual Reviews
Project
Construction Manager Monitors and manages project construction risks Daily
Contractors
Vietnamese Local
Local Lead Engineers Conduct Site Work and manage work activity risks Daily
Contractors
Lead Safety and Maintains Applicable or Relevant and Appropriate
Environmental Requirements (ARARs) List and monitors and
A&E Contractor Daily
Compliance Specialist manages environmental and safety legal and
(LSECS) regulatory compliance
Development
Outreach Assures consistent messaging on Dioxin Remediation
USAID As Needed
Communication Project activity
Specialist (DOCS)
Treatment
Contractor Lead Manages treatment process Daily
Contractor
The A&E Contractor will communicate the status of the risks and progress on risk management to USAID
and GVN stakeholders during the Quarterly and Semi-Annual Reviews. The A&E Contractor will update
the Risk Register prior to the reviews or as needed when new risks are identified during project activities
or A&E internal meetings in preparation for the USAID and GVN Stakeholder Quarterly and Semi-Annual
Project Risk Review meetings. The A&E Contractor will develop Agendas for the Reviews (see example
Agendas in Section 2.4.1).
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2.2 PROJECT RISK IDENTIFICATION AND MANAGEMENT PLAN REVIEWS
This Plan will be reviewed by USAID and GVN Stakeholders during Quarterly and Semi-Annual Reviews
conducted according to the schedule as shown here in Table 3. Each review will take place during a
Project Risk Workshop designed to inform attendees about progress on controlling and mitigating Project
Risk. Workshop attendees will be asked to identify new Project Risks and establish control and mitigation
actions. The Quarterly and Semi-Annual Reviews will be facilitated by the A&E Contractor to gather
input on and feedback on the Project Risk Plan, Control and Mitigation Actions, and the established Risk
Management process. Workshop activities will include reviewing how Project Risks are identified,
prioritized and managed. Workshop attendees will be encouraged to participate in a team effort to define
the risks using the “Risk Statement” method and rate them using the very simple prioritization method in
the Project Risk Register. Thus, Quarterly and Semi-Annual Project Risk Review Workshop attendees
will gain a “hands-on” understanding of the Project Risk Management process. The Workshops will
improve the overall Project Risk Management process and contribute to USAID GVN Capacity Building.
TABLE 3: QUARTERLY AND SEMI-ANNUAL REVIEWS OF THE PROJECT RISK PLAN AND RISK REGISTER
Month Review Actions Outputs
January Meeting with USAID, A&E and Contractor Leads
1st Quarterly Internal Meeting to Microsoft PowerPoint® (PPT) review of the Plan
and Meeting Minutes
Review the Project Risk Plan and Risk Content
Revised Risk Register
February Register Review of Risk Register and Progress on Risk
Mitigation Actions and Elevate Risks if necessary
Preparation includes calls with A&E Contractor
Preparation for 2nd Quarter Internal Quarterly and Semi-
and Contractor Leads to set agenda for the
March Review and Semi-Annual GVN Annual Meeting
review meeting, identify and rate new risks,
Stakeholder Project Risk Plan Review Agendas
remove extraneous risks, adjust risk mitigation
Meetings Revised Risk Register
actions, change risk owners.
2nd Quarter Project Risk Plan and
Meeting with USAID, A&E and Contractor Leads
Risk Register Review and Semi-Annual
April PPT review of Project Risk Plan Content Meeting Minutes
Stakeholder Review of Risks,
Review of Risk Register and Progress on Risk Revised Risk Register
Mitigation Actions and Progress-to-
Mitigation Actions
Date Meetings
Preparation includes calls with A&E Contractor
May and and Contractor Leads to set agenda for the Quarterly Meeting
Preparation for 3rd Quarter Project
June review meeting, identify and rate new risks, Agenda
Risk Plan and Risk Register Review
remove extraneous risks, adjust risk mitigation Revised Risk Register
actions, change risk owners.
Meeting with USAID, A&E and Contractor Leads
July 3rd Quarter Project Risk Plan and Risk Review of Risk Register and Progress on Risk Meeting Minutes
Register Review Meeting Mitigation Actions Revised Risk Register
Risks Needing Elevation
August Preparation includes calls with A&E Contractor
Quarterly and Semi-
Preparation for 4th Quarter and Semi- and Contractor Leads to set agenda for the
and Annual Meeting
Annual Stakeholder Project Risk Plan review meeting, identify and rate new risks,
Agendas
September and Risk Register Review remove extraneous risks, adjust risk mitigation
Revised Risk Register
actions, change risk owners.
4th Quarter Project Risk Plan and Risk
Meeting with USAID, A&E and Contractor Leads
Register Review and Semi-Annual
October PPT review of Project Risk Plan Content Meeting Minutes
GVN and Stakeholder Review of Risks,
Review of Risk Register and Progress on Risk Revised Risk Register
Mitigation Actions and Progress-to-
Mitigation Actions
Date Meetings
November Preparation includes calls with A&E Contractor
and Contractor Leads to set agenda for the Quarterly Meeting
and Preparation for 1st Quarter Project
review meeting, identify and rate new risks, Agenda
Risk Plan and Risk Register Review
December remove extraneous risks, adjust risk mitigation Revised Risk Register
actions, change risk owners.
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2.3 CAPACITY BUILDING IN PROJECT RISK IDENTIFICATION AND MANAGEMENT
FOR GVN STAKEHOLDERS
Importantly, when the Quarterly and Semi-Annual Reviews are conducted as described above in Section
2.2 and Table 3, they will become Risk Management Capacity Building Workshops helping to build GVN
attendee Project Risk Identification and Management capacity and capability. Workshop results recorded
in the minutes of the meetings can provide direct and measurable evidence of USAID support of Capacity
Building for Vietnam in Risk Management.
2.4.1 EXAMPLE QUARTERLY AND SEMI-ANNUAL PROJECT RISK IDENTIFICATION AND MANAGEMENT
PLAN REVIEW AGENDAS
Example Agenda: Quarterly Review of the Risk Identification and Management Plan
• Review of Plan Content and Progress (PPT slide file)
• Review of Risk Register
o Review of High Risks
o Progress on Control and Mitigation Actions
o Risk Owner Effectiveness
o Summary of Moderate and Low Risks
o Transfer of Risks to Other Risk Owners
o Assignment of Risk Owners to New Risks
• Risks Added, Removed or Demoted to Lower Status, e.g. Moderate or Low
• Risks Elevated within A&E Contractor, Other Contractors, USAID or GVN Stakeholders
• Proposed Opportunities Recommended to Improve Project Risk Management for A&E Analysis
Example Agenda: Semi-Annual Review by USAID and GVN Stakeholders (and other
invitees)
It is important to note that this Plan is only a tool to help Risk Owners and the Project Team identify and
manage Project risks. The Plan and Project Risk Register are designed to augment, not take the place of
disciplined, diligent and dedicated risk management by all A&E Contractor Team members.
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3 THE PROJECT RISK REGISTER
The Project Risk Register is the primary Project Risk Identification and Management Plan implementation
tool, designed as a dynamic document to be frequently monitored and routinely reviewed and updated.
It is designed to easily modify existing risks and add new risks when they emerge as the Project goes
through each project life cycle phase. It is a very simple, straightforward MSExcel® workbook with four
(4) main sections of the Project Risk Management process in the Project Risk Register Matrix. These
main segments of the Project Risk Register are designed in a logical sequence with subcomponents that
make up the Project Risk Management Process. The main segments are:
• Definitions of Terms used in the Project Risk Plan and Project Risk Register;
• Project Risk Prioritization Method for rating and ranking projects risks;
• Risk Register Data Population Process;
• Risk Elevation form;
• Potential Opportunities Assessment form; and
• Metrics Development form.
Definitions are provided so the A&E Contractor can develop a shared understanding with all project
participants and stakeholders of how the words are used in the Risk Register and Project Risk Plan
documents. The Risk Register qualitative prioritization method is based on very simple addition and
multiplication, without complex number schemes, formulas or wording. Simple Likelihood and Severity
indicators are used to rate and rank the risks with the scores combined to establish the relative level of
the risk. The process to populate the Project Risk Register is listed out in 14 very simple steps. The Risk
Elevation form is for moving risks upward in the chain of command to other decision-makers. The
Potential Opportunities Assessment form will support determining which Opportunities are beneficial
and worthy of investment. The Metrics Development form will be used to identify and select key project
performance indicators and measures. The entire process is designed to provide guidance to decision-
makers on managing Project Risks, not make decisions for them.
Since some conditions, circumstances and consequences may be complex or especially technical in nature,
they may require somewhat more detailed wording than others. The risk statement is flexible enough to
have more or less detail depending on what is needed to clearly communicate the condition or
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circumstance and the consequences. It is the risk statement that is evaluated for the specific likelihood
and severity ratings to establish the risk score and identify the risk as High, Moderate or Low.
As examples, Table 4 below lists three (3) of the 18 risks identified during the Risk Brainstorming Session
attended by representatives from USAID and the A&E Contractor in Bien Hoa on October 10, 2019. The
Risk Statements in Table 4 describe three (3) of the 11 risks identified that day as High Risks.
TABLE 4: THREE OF THE HIGH-LEVEL RISKS FROM THE RISK BRAINSTORMING SESSION
(1)
Risk Identification and Description
Category Area of Risk Risk Statement
Risk
Emphasis (Internal or Source
ID
External) (Causes) (Description)
Some soil and sediment decision units do not have a defined bottom to
1 Internal Technical contamination; therefore the scope of remedial measures may be
underestimated.
As stated in the introduction, risks that are not eliminated in an early project phase, (for example, the
Planning Phase), should be reevaluated routinely but particularly when the project moves from one phase
to the next. In this manner the risks that have consequences in later phases may be re-elevated as the
project progresses.
This approach allows risks identified in the early project phases to be reprioritized as they begin to have
increasing effect in the later project phases. It also promotes identification of new risks that emerge later
in the project life cycle.
The qualitative risk assessment, scoring and prioritization method is based on determining the degree to
which the consequences in the Risk Descriptions can disrupt or otherwise negatively affect activities in
any or all of the project life cycle phases. The scores are obtained by adding the “Yes” answers from the
“Pick Lists” in the Severity determination columns for each Project Life Cycle Phase (a-e) in Table 5.
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The sum of the Severity “Yes” determinations is multiplied by either 3, 2 or 1 from the selected Likelihood
Rating indicators: “Likely to Occur” (3); “Just as Likely Not to Occur as to Occur” (2); “Not Likely to
Occur” (1). Thus the “Risk Rating Score” is the combination of the Likelihood and Severity scores.
The “Inherent Risk Level” in Table 5 is the level of the Risk before Risk Control and Mitigation Actions
are implemented.
Table 6 shows the Likelihood and Severity Indicators and how the scores are calculated based on the
selections from the pick lists embedded in the Project Risk Register Matrix (Appendix A).
The Risk Assessment includes rating the Likelihood of the occurrence and the Severity of the
consequences, before Control and Mitigation actions are implemented, and combines these two indicators
to identify the relative level of the risk.
The three (3) risk levels are High, Moderate and Low. As Table 6 indicates, the Project Risk Register
shows these levels in colors as Red for High, Amber for Moderate and Green for Low.
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TABLE 7: HIGH-LEVEL RISK CONTROL AND MITIGATION ACTIONS
(3)
High Risk Control and Mitigation Action Plans
(Contingency Plan with mitigation and project control measures and references to the Environmental Mitigation and
Monitoring Plan (EMMP) when applicable.)
Risk Controls and Mitigation Action Tasks Residual Risk Level
(In Project Management Software) With Actions
> Conduct additional data collection to develop excavation design and
determine soil and sediment quantities.
> Closely monitor IM1 confirmation sampling of excavated sediment quantities 20
during the construction Phase.
> As an Approval Risk this is a Single Point of Failure.
> Map the Treatment Technology Approval tasks and dates.
> Identify key Treatment Technology Approval steps in the process. 16
> Monitor monthly then weekly after submittal for indications of GVN delay or
variation from expectations for approval timeliness.
> As an Approval Risk this is a Single Point of Failure.
> Follow the Implementation Masterplan Workplan.
> Update the Implementation Masterplan Workplan.
> Assure concurrence is gained at key milestones during Roadmap 20
Stops/Meetings.
> Monitor monthly then weekly after submittal for indications of GVN delay or
variation from expectations for approval timeliness.
To assure that Control and Mitigation Actions are implemented effectively and in a timely manner a Risk
Owner is assigned to each High-level Risk. The Risk Owner is responsible for tracking and taking action
to reduce the likelihood or the severity of the risk. Risk Owners are also responsible for reporting on
their progress at managing their risks during bi-weekly Risk Owner calls, during meetings and calls in
preparation for Quarterly Internal USAID Project Risk Plan Reviews and, as necessary during Semi-Annual
Reviews with GVN Stakeholders.
In order for Project Risks to be managed systematically, it will be helpful if Control and Mitigation Action
tasks are integrated into the overall A&E Contractor project management software. Risk Owners should
have at least “Read-Only” access to their particular risk management tasks. This will assure that they can
stay familiar with the tasks on a daily basis and monitor and report on their progress to complete the
tasks according to the schedule.
Risk Owner bi-weekly calls will review the overall risk portfolio but focus on the High-level risks to assure
Control and Mitigation Actions are working. Moderate- and Low-level Risks can be routinely monitored
(monthly or quarterly) to determine if the Risk Levels are increasing and to assure these risks are not lost
in the distractions of everyday work activities.
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TABLE 8: 14-STEP PROJECT RISK MATRIX DATA POPULATION PROCESS
Project Risk Matrix Data Population Process and Roles and Responsibilities
As risks emerge or change intermittently throughout the project, the A&E Contractor will identify, evaluate, document and
communicate risks and update the Risk Register as needed.
Step Project Risk Matrix Population Process Steps Responsible Party
1 Evaluate project management and work activities to identify risks and single A&E Technical Staff and Project
points of failure and coordinate with the Project Risk Lead to insert risks in the Leads and Risk Management
Project Risk Register Matrix. Lead (if delegated by Chief of
Party)
2 Identify Risk Category and Source. A&E Technical Staff and Project
4 Describe the risk in the Risk Statement format. Leads and Project Risk
5 Rate the Severity of the Risk across each Project Life Cycle phase. Management Lead
6 For Project Risks rated as High Risk, establish Risk Control and Mitigation
Actions.
Chief of Party
7 Identify the Risk Owner organization and the Risk Owner Title.
8 Determine Risk Owner risk management and reporting schedule
9 Validate the Project Risk and High Risk Controls and Mitigation Actions and Project Risk Management Lead
Schedule with the A&E Contractor and adjust specific Project Risk as necessary.
10 Manage the Project Risk consistent with established Risk Control and Mitigation
Chief of Party
Actions.
11 Report on Risk Management Progress during Risk Owner calls. Project Risk Management Lead
12 Make adjustments in Risk Controls and Mitigation Actions as Needed.
13 Communication of Progress on and Status of Risk Management to A&E
Chief of Party
Contractor during preparatory calls and meetings for Quarterly USAID Internal
Reviews and during Semi-Annual Reviews by USAID and GVN Stakeholders.
14 Inform A&E of need to Elevate Project Risks if necessary due to changes in the Project Risk Management Lead
nature of the risk or other circumstance requiring attention by others in the
A&E Contractor organization hierarchy, e.g. additional resources or conflicting
work activities.
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3.6 POTENTIAL OPPORTUNITIES
Potential Opportunities for Project improvement will be identified as the project progresses through each
phase of its life cycle. Opportunities are conditions, circumstances or events that might be leveraged for
beneficial effect on the Bien Hoa Area Dioxin Remediation Project. Potential Opportunities will be
identified and evaluated for benefit, cost and ease of capture and for their potential to help the Project
reduce risk, lower costs, improve schedules, and increase Project performance in achieving the Plan
objectives. This Project Risk Register has a template, shown here in Table 10, for identifying, assessing
and rating Opportunities.
When used in a systematic manner the Project Risk Register and its subcomponent parts provides a simple
but effective means to identify, organize, prioritize, control, manage and communicate Project Risks. The
Project Risk Register is designed to be easily understood, used and communicated to stakeholders. The
Project Risk Plan and the Project Risk Register are part of a systematic, comprehensive and holistic
process designed to provide guidance and support to the A&E Contractor, USAID and GVN Stakeholder
decision-makers for effective management of Project Risks, not make decisions for them.
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APPENDIX A: PROJECT RISK IDENTIFICATION AND MANAGEMENT PLAN RISK REGISTER MATRIX
APPENDIX A
Project Risk Identification and Management Plan Risk Register Matrix
(3)
High-Risk Control and Mitigation
(2) Action Plans
(4)
(1) Risk Assessment (Contingency Plan with mitigation
Responsibility for Controls and Mitigation Actions and Monitoring and
Risk Identification and Description Rating, Ranking and Risk Level and project control measures and
Reporting on Schedule.
Likelihood X Severity = Risk Level references to the Environmental
Mitigation and Monitoring Plan
(EMMP) when applicable)
(When)
Risk Owner
Monitoring
Residual and
Severity
Risk Inherent (What) Risk Level (Who) Reporting on
of
Rating Risk Level With
Category Area of Emphasis Risk Statement Likelihood Impact Risk Controls and Risk Owner Progress
Risk ID Risk Source (Causes) Score (High, Controls Risk Owner Organization
(Internal or External) (Description) Rating Score Mitigation Action Title during
(Max Moderate, Tasks and
(Max Bi-weekly
30) or Low) Mitigation
10) Risk Owner
Actions
Calls and
Other
Reviews.
> Conduct additional
Some soil and
data collection to
sediment decision
develop excavation Monitor
units do not have
design and determine soil Daily and
a defined bottom
Likely to and sediment quantities. Local Lead Review
1 Internal Technical to contamination; 10 30 High 20 A&E Contractor
Occur > Closely monitor IM1 Engineer during Risk
therefore the
confirmation sampling of Owner Bi-
scope of remedial
excavated sediment weekly calls.
measures may be
quantities during the
underestimated.
construction Phase.
Monitor
Treatment
> As an Approval Risk monthly then
Technology Contracting
this is a Single Point of weekly after
approval by GVN Officer's
Failure. submittal for
may be difficult to Representative
> Map the Treatment indications of
obtain in a timely Likely to (COR)
2 External Approvals 8 24 High Technology Approval 16 USAID GVN delay
manner, therefore Occur
tasks and dates. or variation
completion of A&E
> Identify key Treatment from
Masterplan and its Contractor
Technology Approval expectations
implementation Chief of Party
steps in the process. for approval
could be delayed.
timeliness.
> As an Approval Risk
this is a Single Point of Monitor
Masterplan Failure. monthly then
approval is > Follow the weekly after
required for Implementation COR submittal for
implementation; Masterplan Workplan. indications of
Likely to
3 External Approvals therefore delay in 10 30 High > Update the 20 USAID and A&E Contractor A&E GVN delay
Occur
approval will delay Implementation Contractor or variation
(or stop) Masterplan Workplan. Chief of Party from
procurement and > Assure concurrence is expectations
implementation. gained at key milestones for approval
during Roadmap timeliness.
Stops/Meetings.
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APPENDIX A
Project Risk Identification and Management Plan Risk Register Matrix
(3)
High-Risk Control and Mitigation
(2) Action Plans
(4)
(1) Risk Assessment (Contingency Plan with mitigation
Responsibility for Controls and Mitigation Actions and Monitoring and
Risk Identification and Description Rating, Ranking and Risk Level and project control measures and
Reporting on Schedule.
Likelihood X Severity = Risk Level references to the Environmental
Mitigation and Monitoring Plan
(EMMP) when applicable)
(When)
Risk Owner
Monitoring
Residual and
Severity
Risk Inherent (What) Risk Level (Who) Reporting on
of
Rating Risk Level With
Category Area of Emphasis Risk Statement Likelihood Impact Risk Controls and Risk Owner Progress
Risk ID Risk Source (Causes) Score (High, Controls Risk Owner Organization
(Internal or External) (Description) Rating Score Mitigation Action Title during
(Max Moderate, Tasks and
(Max Bi-weekly
30) or Low) Mitigation
10) Risk Owner
Actions
Calls and
Other
Reviews.
> As an Approval Risk
this is a Single Point of
Design Review Failure.
Review
Cycle can be > Map the Design
progress
lengthy, therefore Review Cycle and
Likely to weekly and
4 External Approvals approvals of the 8 24 High Approval Process to 16 USAID COR
Occur during Bi-
treatment and identify key dates and
weekly Risk
other designs may potential bottle necks,
Owner Calls.
be delayed. key hand offs and other
potential single points of
failure.
> Specifically identify
Internal and
Approvals as Single
external
Points of Failure.
"Approvals" of Monitor
> Map Approvals tasks
various monthly then
and dates.
deliverables weekly after
> Have Approvals as
across the project submittal for
specific agenda items in COR
life-cycle are indications of
Likely to Project Risk Owner
5 Internal Approvals critical to project 10 30 High 20 USAID and Project Contractors GVN delay
Occur Calls. Contractor
progress; or variation
> Assure Approvals are Leads
therefore delayed from
monitored and tracked
Approvals will expectations
on a weekly basis so that
disrupt or halt for approval
proactive management
project progress timeliness.
and corrective actions
in multiple project
can be taken
phases.
immediately.
Land use > Review this risk with
determines the stakeholders and
allowable limits applicable GVN agencies
Monitor
for dioxin in soils to assure requirements COR
Daily and
(21.5 ppt to 1,200 are identified early in the
Likely to Review
6 External Laws and Regulations ppt), but some 8 24 High process. 16 USAID and A&E Contractor A&E
Occur during Risk
areas (on and off > Reach consensus by Contractor
Owner Bi-
base) do not have Meeting #3 Chief of Party
weekly calls.
land use > Identify when design
determined; requirements need to
therefore there is account for the various
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APPENDIX A
Project Risk Identification and Management Plan Risk Register Matrix
(3)
High-Risk Control and Mitigation
(2) Action Plans
(4)
(1) Risk Assessment (Contingency Plan with mitigation
Responsibility for Controls and Mitigation Actions and Monitoring and
Risk Identification and Description Rating, Ranking and Risk Level and project control measures and
Reporting on Schedule.
Likelihood X Severity = Risk Level references to the Environmental
Mitigation and Monitoring Plan
(EMMP) when applicable)
(When)
Risk Owner
Monitoring
Residual and
Severity
Risk Inherent (What) Risk Level (Who) Reporting on
of
Rating Risk Level With
Category Area of Emphasis Risk Statement Likelihood Impact Risk Controls and Risk Owner Progress
Risk ID Risk Source (Causes) Score (High, Controls Risk Owner Organization
(Internal or External) (Description) Rating Score Mitigation Action Title during
(Max Moderate, Tasks and
(Max Bi-weekly
30) or Low) Mitigation
10) Risk Owner
Actions
Calls and
Other
Reviews.
uncertainty in standards.
volumes and > Assure all design
remedial measure reviews account for the
design for these various standards.
areas.
Unlicensed dioxin
> Closely monitor
hazardous waste
progress on GVN
disposal facility
activities in this area by
may not be
engaging with DONRE Monitor
managed on an
and MONRE. monthly and
on-going basis
> Participate in review
therefore it is
Likely to discussions with during Simi-
7 External Laws and Regulations possible GVN 10 30 High 20 USAID COR
Occur Stakeholders regarding Annual
regulations
such facilities. Reviews with
relevant to these
> Reach consensus by GVN
facilities could
Meeting #3 Stakeholders
affect management
> Assure designs at Bien
of low levels of
Hoa Airbase account for
dioxin at Bien Hoa
any related regulations.
Airbase.
Monitor
ARARs will
monthly and
become more > Identify ramifications of
review
stringent during ARARs to activities Lead Safety and
during
the life of the > Plan activities for most Environmental
Likely to Quarterly
8 Internal Laws and Regulations Project; therefore 10 30 High stringent ARAR scenario A&E Contractor Compliance
Occur Internal and
changes in > Identify cost and Specialist
Simi-Annual
activities will schedule impacts of (LSECS)
Reviews with
increase schedule ARARs
GVN
and/or costs.
Stakeholders
The application of > Review standards for Monitor
QCVN 43:2012 applicability to the Bien monthly and
and 2017 to Likely to Hoa Area review
9 External Laws and Regulations 10 30 High 20 A&E Contractor Chief of Party
different areas on Occur > Monitor the during
and off base is regulations for changes Quarterly
unclear; therefore to applicability Internal and
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APPENDIX A
Project Risk Identification and Management Plan Risk Register Matrix
(3)
High-Risk Control and Mitigation
(2) Action Plans
(4)
(1) Risk Assessment (Contingency Plan with mitigation
Responsibility for Controls and Mitigation Actions and Monitoring and
Risk Identification and Description Rating, Ranking and Risk Level and project control measures and
Reporting on Schedule.
Likelihood X Severity = Risk Level references to the Environmental
Mitigation and Monitoring Plan
(EMMP) when applicable)
(When)
Risk Owner
Monitoring
Residual and
Severity
Risk Inherent (What) Risk Level (Who) Reporting on
of
Rating Risk Level With
Category Area of Emphasis Risk Statement Likelihood Impact Risk Controls and Risk Owner Progress
Risk ID Risk Source (Causes) Score (High, Controls Risk Owner Organization
(Internal or External) (Description) Rating Score Mitigation Action Title during
(Max Moderate, Tasks and
(Max Bi-weekly
30) or Low) Mitigation
10) Risk Owner
Actions
Calls and
Other
Reviews.
there is > Seek stakeholder input Simi-Annual
uncertainty in for clarity of applicability Reviews with
volumes and > Assess impacts to GVN
remedial measure project phases based on Stakeholders
design for concentrations and
sediment. potential changes in
expected sediment
treatment volumes
Certain highly
complex US
regulatory
requirements may > Consider practicability
Review
not be practicable when determining
during
in Vietnam (e.g., applicability of
Quarterly
unavailability of regulations/requirements. Chief of Party
Likely to Internal and
10 Internal Laws and Regulations hazardous waste 8 24 High > Determine the 16 A&E Contractor
Occur Simi-Annual
disposal services, activities likely to be LSECS
Reviews with
lacking regulatory affected and identify
GVN
authority to communication and
Stakeholders
authorize actions) training needs.
and therefore
delay (stop) some
Project progress.
> A consistent and
Consistent and
aligned project message
aligned Project
should be designed and
messaging is
implemented through all Monitory
critical for
contacts with monthly and
external COR
stakeholders. Review
communication
> Address monthly with during
with stakeholder Development
Likely to USAID. Quarterly
11 Internal Management and without it 10 30 High 20 USAID Outreach
Occur > Explore how social Internal and
confusion and Communication
media could be used as a Simi-Annual
miscommunication Specialist
means to help deliver a Reviews with
can occur; (DOCS)
consistent message that GVN
therefore resulting
is aligned with USAID Stakeholders
in disruption of
objectives.
project activities
> Meetings with
and loss of project
stakeholders should be
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APPENDIX A
Project Risk Identification and Management Plan Risk Register Matrix
(3)
High-Risk Control and Mitigation
(2) Action Plans
(4)
(1) Risk Assessment (Contingency Plan with mitigation
Responsibility for Controls and Mitigation Actions and Monitoring and
Risk Identification and Description Rating, Ranking and Risk Level and project control measures and
Reporting on Schedule.
Likelihood X Severity = Risk Level references to the Environmental
Mitigation and Monitoring Plan
(EMMP) when applicable)
(When)
Risk Owner
Monitoring
Residual and
Severity
Risk Inherent (What) Risk Level (Who) Reporting on
of
Rating Risk Level With
Category Area of Emphasis Risk Statement Likelihood Impact Risk Controls and Risk Owner Progress
Risk ID Risk Source (Causes) Score (High, Controls Risk Owner Organization
(Internal or External) (Description) Rating Score Mitigation Action Title during
(Max Moderate, Tasks and
(Max Bi-weekly
30) or Low) Mitigation
10) Risk Owner
Actions
Calls and
Other
Reviews.
participant organized and executed
reputations. to assure the aligned
message is delivered
consistently.
A–E SERVICES FOR DIOXIN REMEDIATION AT BIEN HOA AIRBASE AREA PROJECT | 19
FINAL PROJECT RISK IDENTIFICATION AND MANAGEMENT PLAN
APPENDIX A
Project Risk Identification and Management Plan Risk Register Matrix
(3)
High-Risk Control and Mitigation
(2) Action Plans
(4)
(1) Risk Assessment (Contingency Plan with mitigation
Responsibility for Controls and Mitigation Actions and Monitoring and
Risk Identification and Description Rating, Ranking and Risk Level and project control measures and
Reporting on Schedule.
Likelihood X Severity = Risk Level references to the Environmental
Mitigation and Monitoring Plan
(EMMP) when applicable)
(When)
Risk Owner
Monitoring
Residual and
Severity
Risk Inherent (What) Risk Level (Who) Reporting on
of
Rating Risk Level With
Category Area of Emphasis Risk Statement Likelihood Impact Risk Controls and Risk Owner Progress
Risk ID Risk Source (Causes) Score (High, Controls Risk Owner Organization
(Internal or External) (Description) Rating Score Mitigation Action Title during
(Max Moderate, Tasks and
(Max Bi-weekly
30) or Low) Mitigation
10) Risk Owner
Actions
Calls and
Other
Reviews.
phasing activities
(loss of efficiency).
Documented risk
> Insert risk control and
control and
mitigation action tasks
mitigation tasks
into the project
will benefit Risk
management software. Review as
Owners;
> Allow risk owners necessary
therefore without COR
Likely to access on at least a read- with A&E
16 Internal Management documented tasks 10 30 High 20 USAID and A&E Contractor Chief of Party
Occur only basis so that tasks Contractor
risks would not be Risk Owners
can be properly Chief of
properly
monitored and executed Party
controlled and
as scheduled.
cause negative
> Discuss during Risk
effects on project
Owner Calls.
activities.
> Reference to the
There are multiple EMMP
discharge points > Communication -
from the Airbase internal/external
for surface > Fugitive emissions:
Review
water/storm stormwater LSECS
weekly and
water (particularly Likely to > Document identifiable
18 Internal Technical 8 24 High 16 A&E Contractor during Bi-
from Pacer Ivy); Occur discharge points Local Lead
weekly Risk
therefore > Develop Stormwater Engineers
Owner Calls.
discharges may Management Plan
result in public > Monitor stormwater
concerns and discharge
questions. > Implement corrective
actions as needed
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FINAL PROJECT RISK IDENTIFICATION AND MANAGEMENT PLAN
APPENDIX A
Project Risk Identification and Management Plan Risk Register Matrix
(3)
High-Risk Control and Mitigation
(2) Action Plans
(4)
(1) Risk Assessment (Contingency Plan with mitigation
Responsibility for Controls and Mitigation Actions and Monitoring and
Risk Identification and Description Rating, Ranking and Risk Level and project control measures and
Reporting on Schedule.
Likelihood X Severity = Risk Level references to the Environmental
Mitigation and Monitoring Plan
(EMMP) when applicable)
(When)
Risk Owner
Monitoring
Residual and
Severity
Risk Inherent (What) Risk Level (Who) Reporting on
of
Rating Risk Level With
Category Area of Emphasis Risk Statement Likelihood Impact Risk Controls and Risk Owner Progress
Risk ID Risk Source (Causes) Score (High, Controls Risk Owner Organization
(Internal or External) (Description) Rating Score Mitigation Action Title during
(Max Moderate, Tasks and
(Max Bi-weekly
30) or Low) Mitigation
10) Risk Owner
Actions
Calls and
Other
Reviews.
> Review EA costs for
completeness and
current values
> Use normally
established and routinely
Design, exercised budget
construction and management practices to
post-construction monitor and track
costs uncertainties control of this risk.
exist; therefore > Include high-level
budgets may be control practices in
exceeded. Activity schedules
Example: IM1 Example:
Share results
Contract > Determine reality of
of analysis
(design/build) has cost differential through
with USAID
a cost estimate for clear understanding of Chief of Party
Likely to A&E Contractor review
19 Internal Technical excavation 36% 10 30 High project construction and 20 Contractor
Occur Project Contractors weekly and
higher than the post-construction cost Leads
during Bi-
estimate in the EA drivers
weekly Risk
due to additional > Closely monitor
Owner Calls.
excavation and project cost
moving of soils > Identify where double
beyond the handling can be
amount that was minimized
cost-estimated in > Identify means to save
the EA. Project money on fixed price
may exceed contracts through clearly
anticipated funding defined and detailed
scopes
> Identify local
contractors with
potentially lower cost
profiles
A–E SERVICES FOR DIOXIN REMEDIATION AT BIEN HOA AIRBASE AREA PROJECT | 21
FINAL PROJECT RISK IDENTIFICATION AND MANAGEMENT PLAN
APPENDIX A
Project Risk Identification and Management Plan Risk Register Matrix
(3)
High-Risk Control and Mitigation
(2) Action Plans
(4)
(1) Risk Assessment (Contingency Plan with mitigation
Responsibility for Controls and Mitigation Actions and Monitoring and
Risk Identification and Description Rating, Ranking and Risk Level and project control measures and
Reporting on Schedule.
Likelihood X Severity = Risk Level references to the Environmental
Mitigation and Monitoring Plan
(EMMP) when applicable)
(When)
Risk Owner
Monitoring
Residual and
Severity
Risk Inherent (What) Risk Level (Who) Reporting on
of
Rating Risk Level With
Category Area of Emphasis Risk Statement Likelihood Impact Risk Controls and Risk Owner Progress
Risk ID Risk Source (Causes) Score (High, Controls Risk Owner Organization
(Internal or External) (Description) Rating Score Mitigation Action Title during
(Max Moderate, Tasks and
(Max Bi-weekly
30) or Low) Mitigation
10) Risk Owner
Actions
Calls and
Other
Reviews.
> Seek additional
information from
DONRE.
> Determine what and
when additional data is
DONRE has not
needed.
granted access to
> Identify who should
verify/characterize Monitory
obtain the needed data,
offbase monthly and
including whether it can
contamination. Review
be done before land
There is during
handover. COR
uncertainty in the Likely to Quarterly
20 External Technical 10 30 High > Determine how and 20 USAID and A&E Contractor
volumes and if Occur Internal and
when procurement of Chief of Party
greater than Simi-Annual
the needed data
anticipated this Reviews with
collection services are to
could delay GVN
be obtained on a timely
remedial activities Stakeholders
basis.
and increase
> Gain early access to
costs.
sample.
> Incorporate data
gathered into activities of
all applicable project life-
cycle phases.
> Regular
Unexploded
communication with Review
Ordnance (UXO)
ADAFC is needed on the weekly and
clearance is a
importance and status of during Bi-
critical path item
UXO clearance weekly Risk
with many
> Identify UXO Subject Owner
dependent
Matter Experts to assist MND Review Calls
activities that are
Likely to in implementing the and during
21 External Technical affected by delays 10 30 High 20 Project Contractors
Occur UXO clearance oversight Contractor Quarterly
(site
plan. Leads Internal
investigations,
> Arrange for Reviews and
design work, etc.).
Competent Persons to Semi-Annual
Additionally, UXO
monitor UXO search Reviews with
found after initial
and identification work GVN
screening will
to assure compliance Stakeholders
delay project
with requirements.
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FINAL PROJECT RISK IDENTIFICATION AND MANAGEMENT PLAN
APPENDIX A
Project Risk Identification and Management Plan Risk Register Matrix
(3)
High-Risk Control and Mitigation
(2) Action Plans
(4)
(1) Risk Assessment (Contingency Plan with mitigation
Responsibility for Controls and Mitigation Actions and Monitoring and
Risk Identification and Description Rating, Ranking and Risk Level and project control measures and
Reporting on Schedule.
Likelihood X Severity = Risk Level references to the Environmental
Mitigation and Monitoring Plan
(EMMP) when applicable)
(When)
Risk Owner
Monitoring
Residual and
Severity
Risk Inherent (What) Risk Level (Who) Reporting on
of
Rating Risk Level With
Category Area of Emphasis Risk Statement Likelihood Impact Risk Controls and Risk Owner Progress
Risk ID Risk Source (Causes) Score (High, Controls Risk Owner Organization
(Internal or External) (Description) Rating Score Mitigation Action Title during
(Max Moderate, Tasks and
(Max Bi-weekly
30) or Low) Mitigation
10) Risk Owner
Actions
Calls and
Other
Reviews.
activities until > Establish agreement
removed. with ADAFC on
procedure to request
and complete UXO
clearance during
construction.
Most Project
activities can only
be safely
accomplished
during dry season.
Schedule delays
have the potential
to become delays > Identify likely rainy Share results
to next dry season scenarios in of analysis
season (~ 7 applicable planning with
months later). documents Construction
Excavation and > Include rainy season Lead
treatment present aspect in planning in Monitory
much higher risks construction plans and monthly and
Likely to
22 External Weather when they occur 8 24 High activity designs 16 A&E Contractor Chief of Party Review
Occur
in the rainy > Identify single points of during
season; therefore failure in the Quarterly
the lack of construction schedule Internal and
timeliness for > Monitor SPOFs in Simi-Annual
procurement, schedule and proactively Reviews with
approvals, mitigate whenever GVN
excavations, and possible Stakeholders
other activities
can have
significant negative
implications when
they shift
excavation and/or
treatment into the
A–E SERVICES FOR DIOXIN REMEDIATION AT BIEN HOA AIRBASE AREA PROJECT | 23
FINAL PROJECT RISK IDENTIFICATION AND MANAGEMENT PLAN
APPENDIX A
Project Risk Identification and Management Plan Risk Register Matrix
(3)
High-Risk Control and Mitigation
(2) Action Plans
(4)
(1) Risk Assessment (Contingency Plan with mitigation
Responsibility for Controls and Mitigation Actions and Monitoring and
Risk Identification and Description Rating, Ranking and Risk Level and project control measures and
Reporting on Schedule.
Likelihood X Severity = Risk Level references to the Environmental
Mitigation and Monitoring Plan
(EMMP) when applicable)
(When)
Risk Owner
Monitoring
Residual and
Severity
Risk Inherent (What) Risk Level (Who) Reporting on
of
Rating Risk Level With
Category Area of Emphasis Risk Statement Likelihood Impact Risk Controls and Risk Owner Progress
Risk ID Risk Source (Causes) Score (High, Controls Risk Owner Organization
(Internal or External) (Description) Rating Score Mitigation Action Title during
(Max Moderate, Tasks and
(Max Bi-weekly
30) or Low) Mitigation
10) Risk Owner
Actions
Calls and
Other
Reviews.
rainy season.
there are ripple
effects of things
not getting done
in the rainy.
There is a lack of
full understanding
of local market
capacity to supply
local construction Review
companies during Bi-
qualified for and COR Weekly Risk
> Perform market
capable of Likely to Owner Calls
25 External Management 6 18 Moderate reasearch USAID and Project Contractors
obtaining MND Occur Contractor and
> Monitor over time
authorization may Leads Quarterly
be limited; Internal
therefore Reviews
construction
activities may be
delayed and/or
costs increased.
Incremental
Review
funding for the
during Bi-
Project may not
Just as COR Weekly Risk
meet the planned
Likely Not Owner Calls
26 External Management budget; therefore 10 20 Moderate Accept and Monitor USAID and Project Contractors
to Occur as Contractor and
result in Project
to Occur Leads Quarterly
delays or
Internal
shutdown before
Reviews
completion.
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FINAL PROJECT RISK IDENTIFICATION AND MANAGEMENT PLAN
APPENDIX A
Project Risk Identification and Management Plan Risk Register Matrix
(3)
High-Risk Control and Mitigation
(2) Action Plans
(4)
(1) Risk Assessment (Contingency Plan with mitigation
Responsibility for Controls and Mitigation Actions and Monitoring and
Risk Identification and Description Rating, Ranking and Risk Level and project control measures and
Reporting on Schedule.
Likelihood X Severity = Risk Level references to the Environmental
Mitigation and Monitoring Plan
(EMMP) when applicable)
(When)
Risk Owner
Monitoring
Residual and
Severity
Risk Inherent (What) Risk Level (Who) Reporting on
of
Rating Risk Level With
Category Area of Emphasis Risk Statement Likelihood Impact Risk Controls and Risk Owner Progress
Risk ID Risk Source (Causes) Score (High, Controls Risk Owner Organization
(Internal or External) (Description) Rating Score Mitigation Action Title during
(Max Moderate, Tasks and
(Max Bi-weekly
30) or Low) Mitigation
10) Risk Owner
Actions
Calls and
Other
Reviews.
There are three
major project
management units
that direct Project
activities (e.g.,
ADAFC, USAID > Monitoring should
Environmental include diligent liaison Review
Remediation Unit, with the PMUs to assure during Bi-
and Dong Na Just as that if a conflicting Weekly Risk
DONRE) with Likely Not decision is made or Owner Calls
27 External Management 10 20 Moderate USAID COR
separate fund to Occur as requirement established, and
management to Occur this risk is raised to High, Quarterly
responsibilities; a Risk Owner is assigned, Internal
therefore and additional liaison Reviews
conflicting controls are established.
decisions and
requirements can
cause disruptions
in Project
activities.
There are
numerous
stakeholders
involved in Project
Review
and thus many
during Bi-
opportunities for
Just as Weekly Risk
third parties to
Likely Not Owner Calls
28 External Management interfere with the 8 16 Moderate Accept and Monitor USAID COR
to Occur as and
Project at crucial
to Occur Quarterly
points in the
Internal
project life-cycle;
Reviews
therefore resulting
in delays, work
stoppages, and/or
increased costs.
A–E SERVICES FOR DIOXIN REMEDIATION AT BIEN HOA AIRBASE AREA PROJECT | 25
FINAL PROJECT RISK IDENTIFICATION AND MANAGEMENT PLAN
APPENDIX A
Project Risk Identification and Management Plan Risk Register Matrix
(3)
High-Risk Control and Mitigation
(2) Action Plans
(4)
(1) Risk Assessment (Contingency Plan with mitigation
Responsibility for Controls and Mitigation Actions and Monitoring and
Risk Identification and Description Rating, Ranking and Risk Level and project control measures and
Reporting on Schedule.
Likelihood X Severity = Risk Level references to the Environmental
Mitigation and Monitoring Plan
(EMMP) when applicable)
(When)
Risk Owner
Monitoring
Residual and
Severity
Risk Inherent (What) Risk Level (Who) Reporting on
of
Rating Risk Level With
Category Area of Emphasis Risk Statement Likelihood Impact Risk Controls and Risk Owner Progress
Risk ID Risk Source (Causes) Score (High, Controls Risk Owner Organization
(Internal or External) (Description) Rating Score Mitigation Action Title during
(Max Moderate, Tasks and
(Max Bi-weekly
30) or Low) Mitigation
10) Risk Owner
Actions
Calls and
Other
Reviews.
Frequent changes
in project activity
and deliverable
priorities (already
experienced)
result in "crisis of Review
the day" and "fire during Bi-
fighting;" therefore Just as COR Weekly Risk
this could become Likely Not Owner Calls
29 Internal Management 10 20 Moderate Accept and Monitor USAID and Project Contractors
the standard to Occur as Contractor and
mode of to Occur Leads Quarterly
prioritization Internal
instead of Reviews
proactive,
systematic and
considered
determination of
priorities.
Failure of control
measures during
treatment in the
rainy season
present higher
risk than in the
Review
dry season (e.g.,
during Bi-
harder to repair,
LSECS Weekly Risk
increased
Likely to Owner Calls
30 Internal Management mobilization, loss 6 18 Moderate Accept and Monitor A&E and Project Contractors
Occur Contractor and
of temperature);
Leads Quarterly
therefore
Internal
increased
Reviews
exposure risks,
treatment
duration, and/or
decreased
effectiveness are
likely.
A–E SERVICES FOR DIOXIN REMEDIATION AT BIEN HOA AIRBASE AREA PROJECT | 26
FINAL PROJECT RISK IDENTIFICATION AND MANAGEMENT PLAN
APPENDIX A
Project Risk Identification and Management Plan Risk Register Matrix
(3)
High-Risk Control and Mitigation
(2) Action Plans
(4)
(1) Risk Assessment (Contingency Plan with mitigation
Responsibility for Controls and Mitigation Actions and Monitoring and
Risk Identification and Description Rating, Ranking and Risk Level and project control measures and
Reporting on Schedule.
Likelihood X Severity = Risk Level references to the Environmental
Mitigation and Monitoring Plan
(EMMP) when applicable)
(When)
Risk Owner
Monitoring
Residual and
Severity
Risk Inherent (What) Risk Level (Who) Reporting on
of
Rating Risk Level With
Category Area of Emphasis Risk Statement Likelihood Impact Risk Controls and Risk Owner Progress
Risk ID Risk Source (Causes) Score (High, Controls Risk Owner Organization
(Internal or External) (Description) Rating Score Mitigation Action Title during
(Max Moderate, Tasks and
(Max Bi-weekly
30) or Low) Mitigation
10) Risk Owner
Actions
Calls and
Other
Reviews.
Thermal
conductive heating
is being used as
the basis for
treatment of
material from the
Pacer Ivy area
while a treatment
technology Review
selection process during Bi-
is conducted for Just as Weekly Risk
COR
the rest of the Likely Not Owner Calls
31 Internal Technical 8 16 Moderate Accept and Monitor USAID and A&E Contractor
Project; therefore to Occur as and
Chief of Party
another type of to Occur Quarterly
treatment Internal
technology could Reviews
be identified as
more effective
which will
negatively impact
planned Project
design and
construction
schedules.
Inadequate
consideration for
the GVN's ability
Review
to manage
during Bi-
residual dioxin
Weekly Risk
contaminated COR
Likely to Owner Calls
32 External Technical material at the 6 18 Moderate Accept and Monitor USAID and A&E Contractor
Occur and
Airbase; therefore Chief of Party
Quarterly
potential
Internal
exposure risks
Reviews
and negative
perceptions on
Project success.
A–E SERVICES FOR DIOXIN REMEDIATION AT BIEN HOA AIRBASE AREA PROJECT | 27
FINAL PROJECT RISK IDENTIFICATION AND MANAGEMENT PLAN
APPENDIX A
Project Risk Identification and Management Plan Risk Register Matrix
(3)
High-Risk Control and Mitigation
(2) Action Plans
(4)
(1) Risk Assessment (Contingency Plan with mitigation
Responsibility for Controls and Mitigation Actions and Monitoring and
Risk Identification and Description Rating, Ranking and Risk Level and project control measures and
Reporting on Schedule.
Likelihood X Severity = Risk Level references to the Environmental
Mitigation and Monitoring Plan
(EMMP) when applicable)
(When)
Risk Owner
Monitoring
Residual and
Severity
Risk Inherent (What) Risk Level (Who) Reporting on
of
Rating Risk Level With
Category Area of Emphasis Risk Statement Likelihood Impact Risk Controls and Risk Owner Progress
Risk ID Risk Source (Causes) Score (High, Controls Risk Owner Organization
(Internal or External) (Description) Rating Score Mitigation Action Title during
(Max Moderate, Tasks and
(Max Bi-weekly
30) or Low) Mitigation
10) Risk Owner
Actions
Calls and
Other
Reviews.
Loss of power Review
during treatment; during Bi-
therefore the Just as Weekly Risk
COR
treatment system Likely Not Accept and Monitor Owner Calls
33 External Technical 6 12 Moderate USAID and A&E Contractor
may become to Occur as Reference EMMP and
Chief of Party
ineffective and to Occur Quarterly
result in fugitive Internal
emissions. Reviews
Exposure
thresholds for
dioxin are very
low and having Review
project staff on- during Bi-
site whose jobs Just as Weekly Risk
are not directly Likely Not Accept and Monitor Owner Calls
34 Internal Technical 8 16 Moderate Project Contractors LSECS
related to to Occur as Reference EMMP and
remedial measures to Occur Quarterly
may result in Internal
unnecessary Reviews
exposures and
medical
monitoring.
Difficulty obtaining
Review
staff with the
during Bi-
necessary
Just as Weekly Risk
experience and
Likely Not Contractor Owner Calls
35 External Technical skill-sets for the 6 12 Moderate Accept and Monitor Project Contractors
to Occur as Leads and
Project; therefore
to Occur Quarterly
resulting in
Internal
disruption of
Reviews
Project activities.
Discovery of
Review
contaminated soil
during Bi-
and sediment
Likely to Accept and Monitor Construction Weekly Risk
36 External Technical beyond design 6 18 Moderate A&E Contractor
Occur Reference EMMP Manager Owner Calls
volumes can
and
occur. The
Quarterly
amounts and
A–E SERVICES FOR DIOXIN REMEDIATION AT BIEN HOA AIRBASE AREA PROJECT | 28
FINAL PROJECT RISK IDENTIFICATION AND MANAGEMENT PLAN
APPENDIX A
Project Risk Identification and Management Plan Risk Register Matrix
(3)
High-Risk Control and Mitigation
(2) Action Plans
(4)
(1) Risk Assessment (Contingency Plan with mitigation
Responsibility for Controls and Mitigation Actions and Monitoring and
Risk Identification and Description Rating, Ranking and Risk Level and project control measures and
Reporting on Schedule.
Likelihood X Severity = Risk Level references to the Environmental
Mitigation and Monitoring Plan
(EMMP) when applicable)
(When)
Risk Owner
Monitoring
Residual and
Severity
Risk Inherent (What) Risk Level (Who) Reporting on
of
Rating Risk Level With
Category Area of Emphasis Risk Statement Likelihood Impact Risk Controls and Risk Owner Progress
Risk ID Risk Source (Causes) Score (High, Controls Risk Owner Organization
(Internal or External) (Description) Rating Score Mitigation Action Title during
(Max Moderate, Tasks and
(Max Bi-weekly
30) or Low) Mitigation
10) Risk Owner
Actions
Calls and
Other
Reviews.
timing of Internal
discoveries can Reviews
prevent
completion of
planned
excavations in a
given dry season;
therefore
dependent Project
activities can be
delayed six
months or more.
Review
There is high local
during Bi-
humidity during
Weekly Risk
dry season;
Likely to Accept and Monitor Owner Calls
37 External Weather therefore use of 4 12 Moderate A&E Contractor LSECS
Occur Reference EMMP and
PPE may
Quarterly
negatively effect
Internal
workers.
Reviews
There is offbase
contamination and
proximity of
residents and
workers to Review
treatment in Pacer during
Likely to Accept and Monitor
38 External Access Ivy; therefore the 2 6 Low A&E Contractor LSECS Quarterly
Occur Reference EMMP
lack of access Internal
control and Reviews
compliance
monitoring can
result in
exposures.
Delays in Review
Just as
registration affects during
Likely Not Contractor
39 External Management Project 4 8 Low Accept and Monitor Project Contractors Quarterly
to Occur as Leads
Contractors Internal
to Occur
ability to hire staff Reviews
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FINAL PROJECT RISK IDENTIFICATION AND MANAGEMENT PLAN
APPENDIX A
Project Risk Identification and Management Plan Risk Register Matrix
(3)
High-Risk Control and Mitigation
(2) Action Plans
(4)
(1) Risk Assessment (Contingency Plan with mitigation
Responsibility for Controls and Mitigation Actions and Monitoring and
Risk Identification and Description Rating, Ranking and Risk Level and project control measures and
Reporting on Schedule.
Likelihood X Severity = Risk Level references to the Environmental
Mitigation and Monitoring Plan
(EMMP) when applicable)
(When)
Risk Owner
Monitoring
Residual and
Severity
Risk Inherent (What) Risk Level (Who) Reporting on
of
Rating Risk Level With
Category Area of Emphasis Risk Statement Likelihood Impact Risk Controls and Risk Owner Progress
Risk ID Risk Source (Causes) Score (High, Controls Risk Owner Organization
(Internal or External) (Description) Rating Score Mitigation Action Title during
(Max Moderate, Tasks and
(Max Bi-weekly
30) or Low) Mitigation
10) Risk Owner
Actions
Calls and
Other
Reviews.
and may affect
their ability to
complete work;
therefore there
could be delays or
inadequate quality
in products.
Failure to
properly arrange
transportation of
dioxin materials
from off-Base
locations to on- Review
Just as LSECS
Base and mitigate during
Likely Not
40 Internal Management for handling, traffic 4 8 Low Accept and Monitor A&E Contractor and Project Contractors Quarterly
to Occur as Construction
and weather- Internal
to Occur Manager
related incidents; Reviews
therefore
increased dioxin
exposure and/or
disrupt or delay
project activities.
Uncertainties
exist about the
quantity of
contaminated
materials
Review
generated during
during
the (to be chosen) Likely to Contractor
41 External Technical 2 6 Low Accept and Monitor Treatment Contractor Quarterly
treatment Occur Leads
Internal
process, therefore
Reviews
long-term
maintenance of a
long-term storage
facility may be
needed.
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FINAL PROJECT RISK IDENTIFICATION AND MANAGEMENT PLAN
APPENDIX B: SCHEDULE FOR THE QUARTERLY AND SEMI-ANNUAL REVIEWS OF THE PROJECT RISK IDENTIFICATION AND
MANAGEMENT PLAN AND RISK REGISTER
APPENDIX B
Schedule for the Quarterly and Semi-Annual Reviews of the Project Risk Identification and Management Plan and Risk Register
Month Review Actions Location Call or Meeting Time Outputs
Meeting with USAID, A&E and Contractor Leads
1st Quarter Project Risk Plan and Risk Register PPT review of Project Risk Plan Content 1 Day with A&E Contractor and Contractor Leads Meeting Minutes
January Bien Hoa
Review Meeting Review of Risk Register and Progress on Risk Mitigation Actions 1 Day with A&E, Contractor Leads and USAID Revised Risk Register
Elevate Risks
February
Preparation includes calls with A&E Contractor and Contractor Leads to set
Preparation for 2nd Quarter and Simi-Annual Agenda
March agenda for the review meeting, identify and rate new risks, remove extraneous 4-6 Calls 1 Hour Each
Stakeholder Project Risk Plan Review Meetings Revised Risk Register
risks, adjust risk mitigation actions, change risk owners.
2nd Quarter Project Risk Plan and Risk Register 1/2 Day with A&E Contractor
Meeting with USAID, A&E and Contractor Leads
Review and Semi-Annual Stakeholder Review of 1 Day with A&E Contractor and Contractor Leads Meeting Minutes
April PPT review of Project Risk Plan Content Bien Hoa
Risks, Mitigation Actions and Progress-to-Date 1 Day with A&E, Contractor Leads and USAID Revised Risk Register
Review of Risk Register and Progress on Risk Mitigation Actions
Meetings 1/2 Day with A&E Contractor, USAID and Stakeholders
May
Preparation includes calls with A&E Contractor and Contractor Leads to set
Preparation for 3rd Quarter Project Risk Plan Quarterly Meeting Agenda
June agenda for the review meeting, identify and rate new risks, remove extraneous 4-6 Calls 1/2-1 Hour Each
and Risk Register Review Revised Risk Register
risks, adjust risk mitigation actions, change risk owners.
Meeting with USAID, A&E and Contractor Leads
3rd Quarter Project Risk Plan and Risk Register 1 Day with A&E Contractor and Contractor Leads Meeting Minutes
July Review of Risk Register and Progress on Risk Mitigation Actions Bien Hoa
Review Meeting 1 Day with A&E, Contractor Leads and USAID Revised Risk Register
Risks Needing Elevation
August
Preparation for 4th Quarter and Semi-Annual Preparation includes calls with A&E Contractor and Contractor Leads to set
Quarterly Meeting Agenda
September Stakeholder Project Risk Plan and Risk Register agenda for the review meeting, identify and rate new risks, remove extraneous 4-6 Calls 1/2-1 Hour Each
Revised Risk Register
Review risks, adjust risk mitigation actions, change risk owners.
4th Quarter Project Risk Plan and Risk Register 1/2 Day with A&E Contractor
Meeting with USAID, A&E and Contractor Leads
Review and Semi-Annual GVN and Stakeholder 1 Day with A&E Contractor and Contractor Leads Meeting Minutes
October PPT review of Project Risk Plan Content Bien Hoa
Review of Risks, Mitigation Actions and 1 Day with A&E, Contractor Leads and USAID Revised Risk Register
Review of Risk Register and Progress on Risk Mitigation Actions
Progress-to-Date Meetings 1/2 Day with A&E Contractor, USAID, GVN and Stakeholders
November
Preparation includes calls with A&E Contractor and Contractor Leads to set
Preparation for 1st Quarter Project Risk Plan Quarterly Meeting Agenda
December agenda for the review meeting, identify and rate new risks, remove extraneous 4-6 Calls 1/2-1 Hour Each
and Risk Register Review Revised Risk Register
risks, adjust risk mitigation actions, change risk owners.
A–E SERVICES FOR DIOXIN REMEDIATION AT BIEN HOA AIRBASE AREA PROJECT | 31
FINAL PROJECT RISK IDENTIFICATION AND MANAGEMENT PLAN
ANNEX 2 – SITE-WIDE SAMPLING AND ANALYSIS PLAN (SAP) /
QUALITY ASSURANCE PROJECT PLAN (QAPP)
PREPARED BY
TRIGON ASSOCIATES, LLC
1515 POYDRAS ST. SUITE 2200
NEW ORLEANS, LA 70112
USA
DISCLAIMER
THE VIEWS EXPRESSED IN THIS PUBLICATION DO NOT NECESSARILY REFLECT THE VIEWS OF THE UNITED STATES AGENCY FOR
INTERNATIONAL DEVELOPMENT OR THE UNITED STATES GOVERNMENT.
CONTENTS
WORKSHEETS #1 AND #2 TITLE AND APPROVAL PAGE 1
1.0 INTRODUCTION 2
1.0.1 SITE EVALUATION/DESIGN 2
1.0.2 SITE REMEDIATION/IMPLEMENTATION 2
1.0.3 ANNEXES 3
1.0.4 HISTORICAL OPERATIONS 3
1.0.5 HISTORICAL INVESTIGATIONS 4
1.0.6 DONRE OFF AIRBASE SAMPLING 4
WORKSHEETS #3 AND #5 PROJECT ORGANIZATION AND SITE-WIDE SAP-QAPP
DISTRIBUTION 9
WORKSHEETS #4, #7, AND #8 PERSONNEL QUALIFICATIONS AND SIGN-OFF
SHEET 13
WORKSHEET #6 COMMUNICATION PATHWAYS 16
WORKSHEET #9 PROJECT PLANNING SESSION SUMMARY 19
WORKSHEET #10 SITE CONCEPTUAL MODEL 21
WORKSHEET #11 PROJECT/DATA QUALITY OBJECTIVES 22
11.1 DQO PROCESS OR FORMAT 22
11.2 DQO GOALS 22
11.2.1 SITE-EVALUATION/DESIGN GOALS 23
11.2.2 SITE REMEDIATION/IMPLEMENTATION GOALS 23
11.3 GENERAL DQO PRINCIPLES 24
11.3.1 LAND USE DECISIONS 24
11.3.2 SOIL/SEDIMENT SAMPLING DECISIONS 24
11.3.3 WATER SAMPLING DECISIONS 25
11.3.4 AIR SAMPLING DECISIONS 25
11.4 ANALYTIC APPROACH 26
WORKSHEET #12 MEASUREMENT PERFORMANCE CRITERIA 27
12.1 PRECISION 27
12.2 ACCURACY/BIAS CONTAMINATION 27
12.3 REPRESENTATIVENESS 28
12.4 COMPARABILITY 28
12.5 COMPLETENESS 28
12.6 SENSTIVITY 28
WORKSHEET #13 SECONDARY DATA USES AND LIMITATIONS 56
WORKSHEET #14 AND #16 PROJECT TASKS AND SCHEDULE 57
14.1 MOBILIZATION TASKS 57
14.1.1 INSTALLATION ACCESS AND DIGGING PERMITS 57
14.1.2 UTILITY CLEARANCE 57
14.1.3 UNEXPLODED ORDNANCE CLEARANCE 57
TABLES
Table 3-1. Distribution List ............................................................................................................................................. 9
Table 4-1. Project Personnel Sign-Off Sheet ............................................................................................................. 13
Table 7-1. Personnel Responsibilities and Qualifications ....................................................................................... 14
Table 8-1. Special Personnel Training Requirements .............................................................................................. 15
Table 6-1. Project Communication Pathways ........................................................................................................... 16
Table 9-1. Project Scoping Session Participants ....................................................................................................... 19
Table 12-1. Measurement Performance Criteria Table For VOC, Soil .............................................................. 30
Table 12-2. Measurement Performance Criteria Table for VOCs, Water ....................................................... 31
Table 12-3. Measurement Performance Critiera Table for SVOCs, Soil ........................................................... 32
Table 12-4. Measurement Perforamce Critiera Table For SVOCs, Water....................................................... 33
Table 12-5. Measurement Performance Criteria Table for PCBs, Soil............................................................... 34
Table 12-6. Measurement Performance Critiera Table for PCBs, Water ......................................................... 35
Table 12-7. Measurement Performance Critiera Table For Herbicides, Soil.................................................... 36
Table 12-8. Measurement Performance Critiera Table for Herbicides, Water ............................................... 37
Table 12-9. Measurement Performance Critiera Table for Arsenic Speciation, Water................................. 38
Table 12-10. Measurement Performance Crtieria Table for Arsenic Speciation, Solid .................................. 39
Table 12-11. Measurement Performance Criteria Table for Anions, Water .................................................... 40
Table 12-12. Measurement Performance Critiera Table for Anions, Soil ......................................................... 41
Table 12-13. Measurement Performance Critiera Table for Dioxins, Water .................................................. 42
Table 12-14 Measurement Performance Criteria Table for Dioxins, Soil ......................................................... 43
Table 12-15. Measurement Performance Critiera Table For Dioxins, Air ........................................................ 44
Table 12-16. Measurement Performance Criteria Table for Ferrous Iron, Waters ....................................... 45
Table 12-17. Measurement Performance Criteria Table for Wet Chemistry Parameters ............................ 46
Table 12-18. Measurement Performance Criteria Table for Metals, Water..................................................... 47
Table 12-19. Measurement Performance Criteria Table for Metals, Water..................................................... 48
Table 12-20. Measurement Performance Critiera Table for Metals, Soil .......................................................... 49
Table 12-21. Measurement Performance Critiera Table for Metals, Water..................................................... 50
Table 12-22. Measurement Performance Criteria Table for Metals, Soild ........................................................ 51
Table 12-23. Measurement Performance Critiera Table for Dissolved Gases, Water .................................. 52
Table 12-24. Measurement Performance Criteria Table for Total Organic Carbon, Soil ............................. 53
Table 12-25. Measurement Performance Critiera Table for Total Organic Carbon, Water ....................... 54
Table 12-26. Measurement Performance Criteria Table for PH, Solid .............................................................. 55
Table 13-1. Secondary Data Criteria and Limitations............................................................................................. 56
Table 15-1. Reference Limits and Evaluation Table For Dioxin and Furans, Soil ............................................. 78
Table 15-2. REference Limits and Evaluation Table For Arsenic, Soil................................................................. 79
Table 19-1 & 30-1 Analytical Requirements Table – Water ................................................................................. 82
Table 20-1. Field Quality Control Sample Summary for OW004 ....................................................................... 85
Table 21-1. Project Sampling SOP References ......................................................................................................... 86
FIGURES
Figure 5-1 Project Organization Chart ....................................................................................................................... 11
1.0.3 ANNEXES
The Site-Wide SAP–QAPP does not cover each detailed activity that will be conducted. It is designed such
that changes can easily be made by revising this document and/or by use of annexes to address new
activities and any changes to the DQOs. A task-specific Annex will be developed and be used with the
Site-Wide SAP–QAPP to provide the details of each new activity or revision to include but not be limited
to:
• Specific chemical and physical analyses required;
• Locations of samples to be collected;
• Monitoring points for background, perimeter (Airbase and work area exclusion zones), and
construction activities; and
• Confirmation sample specifics to include but not be limited to:
− Required analyses,
− Required frequency and type of samples, and
− Reporting requirements.
Worksheets provided in this Site-Wide SAP–QAPP that will not change based on task-specific
requirements will not be replicated in the Annexes. The Site-Wide SAP–QAPP will be an iterative
document with revisions incorporated to address all site-wide changes throughout the ‘Project’.
Decision Units DUs of the Dioxin Remediation of the Bien Hoa Airbase Area C
1. This Site Wide Uniform Federal Uniform Federal Policy for Quality Assurance Project
Policy-Quality Assurance Project Plans Optimized UFP–QAPP Worksheets (USEPA
Plan (SAP–QAPP) was prepared in 2012); UFP-QAPP guidance (USEPA 2005a, 2005b,
accordance with the requirements 2005c); and USEPA Guidance for Quality Assurance
of: Project Plans, USEPA QA/G-5 (USEPA 2002a).
2. Identify regulatory program(s): Multiple and various United States and Vietnamese
regulatory programs are applicable to a given task.
The regulatory program will be identified in Annexes
for each task, as determined by stakeholder
participation in the evaluation of Applicable or
Relevant and Appropriate Requirements (ARARs).
3. Identify regulatory Agency(ies): Multiple and various United States and Vietnamese
regulatory requirements and guidance may be
applicable to a given task. The regulatory agencies will
be identified in Annexes for each task.
5. List dates of scoping sessions that April 22, 2019 and additional as applicable (specific
were or will be held: dates to be developed) throughout the Project.
8. If any required SAP–QAPP All required elements are included in this Site-Wide
elements or required information SAP–QAPP.
are not applicable to the project or
are provided elsewhere, then note
the omitted SAP–QAPP elements
and provide an explanation for their
exclusion:
12.1 PRECISION
For each field duplicate and laboratory duplicate pair (including laboratory control sample
[LCS]/laboratory control sample duplicate [LCSD] and matrix spike [MS]/matrix spike duplicate [MSD]),
the relative percent difference (RPD) will be calculated for each analyte whose original and duplicate values
are both greater than, or equal to, the limit of quantitation (LOQ). The RPDs will be checked against the
measurement performance criteria presented on Tables 12-1 through 12-3 of Worksheet #12. The RPDs
exceeding criteria will be identified in the report. Conclusions about the precision of the analyses and
limitations on the use of the data will be described in the report. Precision is most often expressed in
terms of RPD:
𝐶𝐶𝑅𝑅 −𝐶𝐶𝐷𝐷
𝑅𝑅𝑅𝑅𝑅𝑅 = 100 × �[𝐶𝐶 �;
𝑅𝑅 +𝐶𝐶𝐷𝐷 ]�
2
Where:
RPD = Relative percent difference
CR = Measured concentration of the original sample result
CD = Measured concentration of the duplicate result
12.3 REPRESENTATIVENESS
As described by the Intergovernmental Data Quality Task Force (IDQTF) SAP–QAPP Manual (USEPA
2005a), representativeness is a qualitative term that describes the extent to which a sampling design
adequately reflects the environmental condition of the site, and takes into consideration the magnitude of
the site area represented by one sample and indicates the feasibility and reasonableness of that design
rationale. Representativeness also reflects the ability of the sampling team to collect samples and the ability
of the laboratory to analyze those samples so that the generated data accurately and precisely reflect site
conditions.
Field and laboratory sampling and subsampling techniques will follow sampling and laboratory SOPs that
specify premixing/homogenization procedures to ensure that all sub-samples taken from a given sample
or sampling point are representative of the sample as a whole. Soil samples requiring volatile analysis
(volatile organic compounds [VOCs]) will not undergo any premixing or homogenization.
Representativeness will be assessed by a review of the precision obtained by analysis of field and laboratory
duplicate samples. Representativeness will also be assessed through documentation of proper sample
handling techniques and the use of field blanks (e.g., trip blanks) and laboratory method blanks. Previous
project data may be employed to assess the representativeness of a population by defining the continuity
of data from point to point.
12.4 COMPARABILITY
Sample data will be comparable for similar samples and sample conditions. This goal will be achieved using
standard techniques to collect representative samples, consistent application of analytical method
protocols, and reporting analytical results with appropriate units.
12.5 COMPLETENESS
A completeness check will be done on all of the data generated by the laboratory. Completeness criteria
are presented on Tables 12-1 through 12-3 of Worksheet #12. As described by the IDQTF SAP–QAPP
Manual (USEPA 2005a), completeness is a measure of the amount of valid data collected using a
measurement system and is expressed as a percentage of the number of measurements that are specified
in the SAP–QAPP.
The percentage of valid data points will be calculated by dividing the number of valid (i.e., non-rejected)
data points by the total number of data points expected. Analytical results qualified as rejected during data
validation are not considered “valid.” A discussion summarizing data completeness will be included in the
report. Conclusions about the completeness of the data and limitations on the use of the data will be
described in the report.
12.6 SENSTIVITY
As defined by the IDQTF UFP–QAPP Manual (USEPA 2005a), sensitivity is the ability of the method or
instrument to detect target analytes at the level of interest. As defined by DoD QSM v5.0, the LOQ is
the smallest concentration that produces a quantitative result with known and recorded precision and
bias. The LOQ is set at or above the concentration of the lowest initial calibration standard and is within
the calibration range. The DoD QSM v5.0 defines the method detection limit (MDL) as the smallest
Notes:
CAS Number – Chemical Abstract Service Registration Number
LCS/LCSD – Laboratory Control Sample/Laboratory Control Sample Duplicate
LOQ – Limit of Quantitation
MDL – Method Detection Limit
MS/MSD – Matrix Spike/Matrix Spike Duplicate
RPD – Relative Percent Difference
Notes:
1
If non-dedicated sampling equipment is used, an equipment blank will be collected at a frequency of one per event per site and analyzed for the same analytes as the samples.
2
The MS/MSD is not considered a field QC sample; increased sample volume is required.
3
One trip blank required based on assumption that there will be one cooler containing VOCs per sampling event. One additional trip blank per cooler as needed.
% - Percent
MS/MSD – Matrix Spike/Matrix Spike Duplicate
No. – Number
• “BH-“
Installation Acronym (e.g., BH = Bien Hoa Airbase)
• “S##-”
Site Number
• “MW001-“
Location type; MW = monitoring well, SB = soil boring, GP =
groundwater profile, AI = indoor air, AS = sub slab air
• BH-XX004-MW001 and
Are examples of database location IDs
BH-ZZ014-SB002
• “S-“
Sample media; S = soil, G = groundwater, A = air, EB = equipment
blank
• “##”
Designates the sampling event (for groundwater), the beginning and
ending depth of the soil sample, or the sample number of equipment
blanks
For example, BH-SS014-MW001-G-1 represents a groundwater sample collected during the first sampling
event from MW001 at site SS014 at Bien Hoa Airbase. Sample ID BH-SS014-MW001-S-10-15 is a
subsurface soil sample collected at 10 to 15 ft below ground surface (BGS) from MW001 at site SS014 at
Bien Hoa Airbase. Sample ID BH-SS014-GP001-G-10-20 is a vertical groundwater profile collected at 10
to 20 ft BGS from GP001 at site SS014 at Bien Hoa Airbase.
Field duplicates will be designated by adding “D” to the end of the sample ID (e.g., BH-SS014-MW001-G-
1-D). Trip blanks will be associated with a specific cooler on a specific date; therefore, trip blanks will be
assigned a sequential number identical to the cooler number (e.g., BH-SS014-TB040120-01 for cooler #1
on April 1, 2020, BR-SS014-TB040120-02 for cooler #2 on April 1, 2020, etc.). To ensure correct
association and electronic documentation, the sample manager will write the cooler number in the notes
section of the COC.
One field blank will be collected per event for each analytical method. Field blanks will be designated by
“FB” followed by a date identifier (e.g., BH-SS014-FB040220 for the field blank collected on April 2, 2020).
Data Deliverables and Site-Wide SAP–QAPP Sampling Methods and Procedures Standards
Step IIb Validation activities ensure compliance with Measurement Performance Criteria in the Site-Wide SAP–QAPP for both sampling and
analytical data. Some of the elements have both Step IIa and Step IIb validation activities. Examples of Step IIb validation activities are listed as
follows:
Data Deliverables and Site-Wide SAP–QAPP Co-located Field Duplicates Performance Criteria (Initial Calibration
Verification [ICV], Continuing Calibration
Deviations Project LOQs Verification [CCV], Method specific
instrument performance checks (tunes,
Sampling Plan Confirmatory Analyses breakdown checks, instrument checks,
interference checks)
Sampling Procedures Validation Flags
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Presentation made at the Development of Dioxin Remediation Master Plan for Bien Hoa
Airbase Workshop in Do Son, Vietnam, April 12-13, 2012.
CDM International Inc. (CDM Smith). 2018. Environmental Remediation at Da Nang Airport,
Construction Management and Oversight, Assessment of Dong Nai Department of Natural
Resources and Environment (DONRE) Sampling Program. May 18, 2018.
Cecil PF. 1986. Herbicidal Warfare: the RANCH HAND Project in Vietnam 1986:290.
Dekonta. 2014. Report on the construction of the groundwater monitoring system at Bien Hoa Airbase.
Report prepared for the Support to Overcoming of Consequences of Herbicides/Dioxins in
Vietnam Project. Report prepared by Dekonta for the Czech Development Agency, Volutova
2523, 158 00 Prague 5, Czech Republic. 2014.
Department of Defense (DoD). 2007. Presentation made at the Second Agent Orange and Dioxin
Remediation Workshop, Hanoi, Vietnam, June 18-19, 2007. Co-sponsored by U.S. Department
of Defense and Vietnam Ministry of National Defense.
Department of Natural Resources and Environment (DONRE). 2019. Off-Airbase sampling data for
monitoring off-base migration of dioxin in select drainage areas. Unpublished; however, shared
in USAID/DONRE meeting minutes.
Dong Nai Statistical Office. 2013. Statistical Yearbook Dong Nai Province 2013. Government of
Vietnam.
Durant, J.T., T.G. Boivin, H.R. Pohl, and T.H. Sinks. 2014. Public health assessment of dioxin
contaminated fish at former US airbase, Bien Hoa, Vietnam. International Journal of
Environmental Health Research. http://dx.doi.org/10.1080/09603123.2014.938026.
Dwernychuk LW. 2005. Dioxin hot spots in Vietnam. Chemosphere 60: 998 999.
Dwernychuk, L.W., Boivin, T.G., Hung, T.M., Dung, P.T., and Thai, N.D. 2002. Dioxin reservoirs in
southern Vietnam – A legacy of Agent Orange. Chemosphere 47: 117-137.
Hatfield. 2013. Master Plan for Remediation of Bien Hoa Airbase, Vietnam. Report prepared for UNDP,
Hanoi, Vietnam. Hatfield Consultants Ltd., North Vancouver, BC, Canada.
Hatfield and Office 33. 2009. Comprehensive Assessment of Dioxin Contamination in Danang Airport,
Vietnam: Environmental Levels, Human Exposure and Options for Mitigating Impacts. Report
_____. 2011. Environmental and Human Health Assessment of Dioxin Contamination at Bien Hoa
Airbase, Vietnam. Report funded by the Ford Foundation Special Initiative on Agent
Orange/Dioxin, New York, USA. Hatfield Consultants Ltd., North Vancouver, BC, Canada;
Office 33, Hanoi, Vietnam.
Hatfield and Vietnam – Russia Tropical Centre. 2009. Evaluation of Contamination at the Agent Orange
Dioxin Hot Spots in Bien Hoa, Phu Cat and Vicinity, Vietnam. Report funded by the UNDP
Vietnam and Office of the National Committee 33, Ministry of Natural Resources and
Environment (Office 33), Hanoi, Vietnam. Hatfield Consultants Ltd., West Vancouver, BC,
Canada; Vietnam – Russia Tropical Centre, Hanoi, Vietnam.
Lien, Nguyen Manh. 1998. Compilation of Anatomical, Physiological and Metabolic Characteristics for a
Reference Vietnamese Man. February 1.
Ministry of National Defense, Air Defense – Air Force Command, 2019. Report of Environmental
Impact Assessment for The Dioxin Remediation at Bien Hoa Airbase Area Project, February 27,
2019.
National Academy of Sciences. 1983. Risk Assessment in the Federal Government: Managing the
Process. Washington, DC: National Academy of Sciences.
Nevada Division of Environmental Protection. 2015. Technical Guidance for the Calculation of Asbestos
Related Risk in Soils for the Basic Management Incorporated (BMI) Complex and Common
Areas. February 2015.
Nguyen MH, Boivin TG, Son LK, Bruce GS, McNamee PJ, Thang VC, and W Dwernychuk. 2011. Dioxin
Concentrations in Human Blood and Breast Milk near key hotspots in Vietnam: Danang and Bien
Hoa. Paper presented at Dioxin 2011 Conference, San Antonio, Texas.
Nguyen XQ, Ngo XN, Hoang QK, Nguyen QH, Nguyen TB, and Nguyen TD. 2005. Assessment of
Biodiversity and Water Quality of the Bien Hung Lake, Dong Nai Province.
QCVN. 2012. QCVN 45:2012, National technical regulation on allowed limits of dioxin in soils.
Thien-Le Quan. 2015. Vietnamese ignore health risks, catch fish from dioxin-polluted lakes for sale,
Thanh Nien News, December 3, 2015.
Trigon. 2019. Architect–Engineer Services for Dioxin Remediation at Bien Hoa Airbase Area Project:
Draft Technical Memorandum Site Conceptual Model and Data Gaps Analysis. October 4, 2019.
United States Agency for International Development (USAID). 2013. Vietnam Tropical Forest and
Biodiversity Assessment. 67 pp.
_____. 2016. Environmental Assessment of Dioxin Contamination at Bien Hoa Airbase, Final
Environmental Assessment in Compliance with 22 CFR 216. May 2016.
United States Environmental Protection Agency (USEPA). 1989. USEPA Risk Assessment Guidance for
Superfund (RAGS): Vol. 1, Human Health Evaluation Manual, Part A. Office of Emergency and
Remedial Response, Washington, DC. EPA/5401-89/002. December 1989.
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Response. Washington, DC. OSWER No. 9355.4-23. June 1996.
_____. 2002. Guidance for Quality Assurance Project Plans, EPA QA/G-5. December 2002.
_____. 2004. RAGS: Volume 1 - Human Health Evaluation Manual (Part E – Supplemental Guidance for
Dermal Risk Assessment). August 2004.
_____. 2005a. Supplemental Guidance for Assessing Cancer Susceptibility from Early-Life Exposure to
Carcinogens. Washington, DC: Risk Assessment Forum; U.S. Environmental Protection Agency,
2005.
_____. 2006. Guidance on Systematic Planning Using the Data Quality Objectives Process, EPA QA/G-
4, February 2006.
_____. 2009. RAGS: Volume 1 - Human Health Evaluation Manual (Part F – Supplemental Guidance for
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Vu-Anh, L., Tuyet-Hanh, T., Ngoc-Bich, N., Duc-Minh, N., and Thanh-Ha, N. 2010. Public Health
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MAY 6, 2020
This publication was produced for review by the United States Agency for International Development.
DIOXIN REMEDIATION AT BIEN HOA
AIRBASE AREA PROJECT
DISCLAIMER
THE VIEWS EXPRESSED IN THIS PUBLICATION DO NOT NECESSARILY REFLECT THE VIEWS OF THE UNITED STATES AGENCY FOR
INTERNATIONAL DEVELOPMENT OR THE UNITED STATES GOVERNMENT.
Contents
A.1 INTRODUCTION A-7
A.1.1 GEOLOGIC STANDARDS SOP (FO-01) A-7
A.1.2 SITE RECONNAISSANCE, PREPARATION AND RESTORATION SOP (FO-02) A-8
A.1.3 UTILITIES LOCATION SOP (FO-03) A-9
A.1.4 GEOPHYSICAL SURVEY SOP (FO-04) A-10
A.1.4.1 General Requirements for Geophysical Surveys A-10
A.1.4.2 Surface Geophyiscal Surveys A-10
A.1.4.3 Borehole Geophysical Surveys A-11
A.1.5 DRILLING PREPARATION SOP (FO-06) A-11
A.1.6 LITHOLOGIC LOGGING SOP (FO-07) A-12
A.1.7 BOREHEAD ABANDONMENT SOP (FO-08) A-12
A.1.8 HOLLOW-STEM AUGER DRILLING AND SAMPLING SOP (FO-09) A-13
A.1.8.1 Drilling Procedure A-13
A.1.9 DIRECT PUSH DRILLING AND SAMPLING SOP (FO-10) A-15
A.1.9.1 Preparation A-15
A.1.9.2 Setup of Direct Push Rig A-15
A.1.9.3 Sample Collection A-15
A.1.9.4 Prepack Screen Monitoring Well Installation A-16
A.1.10 MONITORING WELL CONSTRUCTION SOP (FO-11) A-19
A.1.10.1 Well Standards Requirement A-19
A.1.10.2 Borehole Requirements A-20
A.1.10.3 Casing Requirements A-21
A.1.10.4 Well Screen Requirements A-21
A.1.10.5 Annular Space Requirements A-22
A.1.10.6 Filter Pack Requirements A-22
A.1.10.7 Bentonite Seal Requirements A-22
A.1.10.8 Casing Grount Requirements A-23
A.1.10.9 Surface Completion Requirements A-23
A.1.10.10 Piezometer Requirements A-24
A.1.10.11 Well/Piezometer Completion Diagram Requirements A-24
A.1.10.12 Temporary Well Installation and Abandoment A-24
The lithologic descriptions for consolidated materials (igneous, metamorphic, and sedimentary rocks) shall
follow the standard professional nomenclature (Tennissen 1983), with special attention given to describing
fractures, vugs, solution cavities and their fillings or coatings, and any other characteristics affecting
permeability. Colors shall be designated by the Munsell Color System.
The lithologic descriptions for unconsolidated materials (soils [engineering usage] or deposits) shall use
the name of the predominant particle size (e.g., silt, fine sand, etc.). The dimensions of the predominant
and secondary sizes shall be recorded using the metric system. The grain size and name of the deposit
shall be accompanied by the predominant mineral content, accessory minerals, color, particle angularity,
and any other characteristics. The clastic deposit descriptions shall include, as a supplement, symbols of
the Unified Soil Classification System (USCS). The color descriptions shall be designated by the Munsell
Color System.
The scales for maps, cross sections, or 3-D diagrams shall be selected in accordance with the geologic and
hydrologic complexity of the area and the purposes of the illustrations. Geophysical logs shall be run at
a constant vertical scale of 1-inch equals 20 feet (ft). When geophysical logs are superimposed on geologic
logs, cross sections, or 3-D diagrams, the scales shall be the same. If defining geological conditions requires
other scales, additional logs at those scales shall be provided.
For orientation, the cross sections shall show the Northern end on the viewer's right. If the line of cross
section is predominantly east-west, the eastern end is on the right. Maps shall be oriented with north
toward the top, unless the shape of the area dictates otherwise. Orientation shall be indicated with a
north arrow.
USCS is a soil classification system used in engineering and geology to describe the texture and grain size
of a soil. The classification system can be applied to most unconsolidated materials and is represented by
a two-letter symbol. Each letter is described below in Table A-1.
If the soil has 5-12 percent by weight of fines passing a #200 sieve (5 percent < P#200 < 12 percent), both
grain size distribution and plasticity have a significant effect on the engineering properties of the soil, and
dual notation may be used for the group symbol. For example, GW GM corresponds to "well-graded
gravel with silt."
If the soil has more than 15 percent by weight retained on a #4 sieve (R#4 > 15 percent), there is a
significant amount of gravel, and the suffix "with gravel" may be added to the group name, but the group
symbol does not change. For example, SP-SM could refer to "poorly graded SAND with silt" or "poorly
graded SAND with silt and gravel."
The A&E Bien Hoa Contractor shall conduct a site reconnaissance prior to the start of the field
investigations. The primary objectives of conducting a site reconnaissance are to recommend possible
changes in the technical approach, and to allow for adequate review of any such changes. During the site
reconnaissance, the A&E Bien Hoa Contractor shall perform the following tasks:
• Review pertinent documents;
• Interview personnel who may be knowledgeable about environmental conditions in the project area;
• Conduct multiple site walks to evaluate monitoring and sampling locations;
• Verify and mark proposed sampling locations;
• Evaluate site accessibility and security;
• Designate field office sites;
• Identify potentially contaminated areas (i.e., discolored soils, stressed vegetation), particularly those
that may require emergency response; and
• Document and evaluate site reconnaissance observations and update site maps.
A geophysical survey shall be conducted for the presence of underground utilities using electromagnetic
methods in areas designated for intrusive sampling. Utility locations are determined using existing utility
maps and are verified using a hand-held magnetometer or utility probe in the field. Vehicle access routes
to sampling locations shall be determined prior to any field activity. Prior to any intrusive fieldwork, the
A&E Bien Hoa Contractor Chief of Party (COP) shall coordinate with the United States (U.S.) Agency for
International Development (USAID) Contracting Officer’s Representative (COR) to ensure that the most
Prior to any intrusive work, the A&E Bien Hoa Contractor shall work with the COR to follow project-
specific requirements and current Airbase requirements for dig permits. Careful planning plays an
important role and is the first step in utility damage prevention efforts. Health and Safety Plans (HASPs)
for projects that include subsurface drilling or excavation shall include a Site-Specific Hazard Analysis for,
but not limited to, safety and provisions for utility line damage prevention. The A&E Bien Hoa Contractor
shall subcontract a third-party utility location subcontractor as necessary to determine the actual location
of all known and unknown utilities through:
• Careful review of the civil/utility drawings;
• Careful evaluation of aboveground features including, but not limited to, manhole investigation (lifting
manhole covers), valve boxes and pipe and cable risers, which indicate the location of underground
utilities; and
• Use of geophysical techniques to identify subsurface utilities and manmade underground features.
The subcontractor shall mark all utilities in a work area and provide utility maps of their utilities location
determinations to the A&E Bien Hoa Contractor prior to subsurface work. Surface marking shall use
stakes, flags, paint, or other clearly identifiable materials to show the field location of underground utilities
in accordance with current color code standards.
The subcontractor shall mark all utilities in a work area and provide utility maps of their utilities location
determinations to the A&E Bien Hoa Contractor prior to subsurface work. Surface marking shall use
stakes, flags, paint, or other clearly identifiable materials to show the field location of underground utilities
in accordance with current color code standards.
If there is any uncertainty that underground utilities have not been fully delineated by the subcontractor,
initial hand digging shall be conducted using a method accepted by the COR (shovel, hand auger, or water
knife, for example) at a careful rate with observers evaluating the first 4-ft of excavation depth closely for
General requirements for all geophysical surveys are: (1) the A&E Bien Hoa Contractor shall have a
qualified geologist or engineer to supervise geophysical survey work, (2) the locations of boreholes logged
with geophysical instruments shall be shown on a site map, (3) the locations of surface geophysical grid
system layouts shall be shown on a site map, (4) the location of areas analyzed with subsurface geophysical
techniques shall be shown on a site map, (5) final results shall be presented in plain views and cross
sections; contours shall be used where appropriate, (6) the interpretation of results shall discuss positive
and negative results as well as limitations of the method and data, and (7) the interpretation of the data
shall be incorporated into the conceptual site model.
Surface geophysical techniques include, but are not limited to, ground penetrating radar (GPR),
magnetometry, and electromagnetic techniques. Use of any of these techniques is dictated by the project
data quality objectives (DQOs), and the objectives of these techniques is to locate the boundaries of
suspected or known underground metallic objects, or volumes of disturbed soil, or other subsurface
features. The areas to be surveyed are described and shown on-site maps presented in the appropriate
sections of the UFP–QAPP.
Surface geophysical surveys are conducted within predetermined grids defined by transect lines crossing
each site or area of interest. The spacing of the grids is determined from the approximate dimensions of
the features to be located. Qualified individuals shall conduct the surveys and shall be supervised by a
qualified geologist or engineer.
Location and elevation information sufficient to map and assess the survey results shall be recorded.
Depending on the level of accuracy and detail required, northing and easting from a surveyed reference
point, measurements in a third order survey, depth BGS, and/or professionally surveyed points and
transects may be included. Location data, instrument numbers, calibration information, geophysical
interpretation, and maps for all geophysical surveys shall be stored in project files.
General requirements for surface geophysical surveys are: (1) the prime A&E Bien Hoa Contractor shall
correlate surface survey data (profiles and soundings) with at least one soil boring, well bore, or outcrop
Borehole geophysical techniques include resistivity, spontaneous potential (SP), gamma ray, sonic,
induction, neutron, downhole camera, cross-hole GPR, tomography, and caliper logging. Some of the
theory and general procedures for borehole geophysical techniques are described in Groundwater and
Wells (Driscoll 1986); others can be found in any borehole geophysical text.
Geophysical logging may be performed in boreholes to identify soil types before monitoring well (MW)
screen intervals are selected. Resistivity, SP, and caliper logging are conducted in pilot boreholes drilled
with mud, air, or water. Gross-count natural gamma ray logging may also be conducted with resistivity
and SP methods to augment identification and correlation of strata or soil types between boreholes.
Borehole geophysical logging shall be conducted by a qualified individual, and a qualified geologist,
geophysicist, or engineer shall supervise all logging activities. Downhole geophysical tools, cables, probes,
and other equipment are decontaminated before and after being lowered into a borehole. For each
geophysical tool, calibration data and scale parameters are verified before logging begins and are
documented for each borehole. Geophysical data are stored in hard-copy and electronic formats. After
logging, a reproducible copy of the field strip-chart log with a heading specifying project, borehole number,
location and depth, geophysical equipment types, and equipment settings shall be maintained in the project
file.
General requirements for borehole geophysical surveys are: (1) all downhole equipment shall be
decontaminated; (2) borehole measurements shall be recorded both going into the hole and coming out
of the hole; (3) paper copies of curves generated from each logging run shall show all the curves at the
scale of 1 inch equals 20 ft, and each paper log shall indicate the location of the well, date of log acquisition,
type of survey instrument, and a list of other instruments used in that borehole; and interpretations shall
be annotated on the margins of paper log records; (4) all logs shall be referenced to a measuring point
notched in the surface casing or to ground level if the well is not cased; and (5) adverse borehole
conditions shall be reported in the field log. Specifics of the geophysical survey shall be presented in the
UFP–QAPP.
This SOP is an overview of drilling preparation requirements. More detailed drilling SOPs follow that
describe specific activities associated with drilling for environmental investigations. Prior to drilling, drill
holes will be numbered and the site cleared for utilities. Boring locations may be adjusted in the field due
to the presence of underground utilities, overhead power lines, or other structures, or if access problems
are encountered. Drilling locations will be approved by the COP and COR prior to initiating drilling
activities. Health and safety equipment specified in the HASP will be calibrated and charged before
proceeding with subsurface drilling activities.
The type of equipment used depends upon the site geology, hydrology, equipment available, and
monitoring design. Control of cuttings and other potentially contaminated materials at the drill site may
influence drilling method selection. Depending upon equipment availability and site geology, more than
one method may be combined to complete a particular MW installation.
The lithology in all boreholes shall be logged. The Drill Log form shall be used for recording the lithologic
logging information. Information on the boring log sheet includes the borehole location; drilling
information; sampling information such as sample intervals, recovery, and blow counts; and sample
description information.
Unconsolidated samples for lithologic description shall be obtained at each change in lithology or every 5
ft interval, whichever is less or as specified in the project requirements. Lithologic descriptions of
unconsolidated materials encountered in the boreholes shall generally be described in accordance with
American Society for Testing and Materials (ASTM) D-2488-90 Standard Practice for Description and
Identification of Soils (Visual-Manual Procedure) (ASTM 1990). Descriptive information to be recorded
in the field shall include: (1) identification of the predominant particles size and range of particle sizes; (2)
percent of gravel, sand, fines, or all three; (3) description of grading and sorting of coarse particles; (4)
particle angularity and shape; and (5) maximum particle size or dimension.
Fines description include: (1) color using Munsell Color System, (2) moisture (dry, wet, or moist),
(3) consistency of fine grained soils, (4) structure of consolidated materials, and (4) cementation (weak,
moderate, or strong).
The USCS group symbol for each unique subsurface layer shall be recorded. Additional information to
be recorded includes the depth to the water table, caving or sloughing of the borehole, changes in drilling
rate, depths of laboratory samples, presence of organic materials, presence of fractures or voids in
consolidated materials, and other noteworthy observations or conditions, such as the locations of geologic
boundaries.
Lithologic descriptions of consolidated materials encountered in the boreholes shall generally be described
in accordance with Section 1.1. Consolidated samples for lithologic description shall be obtained at each
change in lithology or at 5-ft intervals, whichever is less, or as specified in the project requirements. All
samples shall be monitored with an organic vapor monitor (e.g., photoionization detector [PID], organic
vapor analyzer) at sites where volatile organic compounds (VOCs) are possibly present based on
operational history or observed field indicators such as odor. The samples shall be handled in such a way
as to minimize the loss of volatiles, as described in Section 2.4. Cuttings shall be examined for potential
contamination. Materials suspected to be contaminated because of abnormal color, odor, or organic
vapor monitor readings shall be containerized in conformance with the Resource Conservation and
Recovery Act (RCRA) and Government of Vietnam requirements. Rock cores shall be stored in standard
core boxes, and missing sections of core shall be replaced with spacers.
Lithologic descriptions of consolidated materials shall follow the specifications in Section 1.1.
Boreholes that are not converted to MWs shall be abandoned with neat cement grout. The boring shall
be abandoned within 5 days of borehole completion. Borings 5 ft in depth or shallower may be abandoned
Hollow-stem auger (HSA) drilling techniques use large diameter (up to 14-inch outside diameter [OD])
continuous-flight augers, which mechanically excavate drilled materials from the hole. These augers are
built with a large (up to 10.25-inch inside diameter [ID]) axial opening to allow access to the bottom of
the hole without withdrawing the auger string. The augers act as temporary casing during, and at the
completion of, drilling to facilitate the sampling of soil and water and the installation of MWs.
The equipment used for HSA drilling includes either a mechanically or hydraulically powered drill rig,
which simultaneously rotates and axially advances a HSA column. Auger drills are typically mounted on a
self-contained vehicle that permits rapid mobilization of the auger drill from borehole to borehole. Trucks
are frequently used as the transport vehicle; however, auger drills may also be mounted on all-terrain
vehicles, crawler tractors, or tracked carriers. These drilling rigs often have multipurpose auger-core-
rotary drills that have been designed for geotechnical work. Multipurpose rigs may have: (1) adequate
power to rotate, advance, and retract HSAs; (2) adequate drilling fluid pumping and tool-hoisting capability
for rotary drilling; and (3) adequate rotary velocity, spindle stability, and spindle feed control for core
drilling. The continuously open axial stem of the HSA column enables the borehole to be drilled while
the auger column simultaneously serves as a temporary casing to prevent possible collapse of the borehole
wall.
A Direct Push sampling device is used to collect soil, soil gas, and groundwater samples at specific depths
BGS. Direct push systems are hydraulically powered and mounted in a customized four-wheel or track
driven vehicle. The base of the sampling device is positioned on the ground over the sampling location
and the vehicle is hydraulically raised on the base. As the weight of the vehicle is transferred to the probe,
the probe is pushed into the ground. A built-in hammer mechanism allows the probe to be driven through
dense materials. Maximum depth penetration under favorable circumstances is about 50 ft.
Soil samples are collected with a specially-designed sample tube, typically lined with acetate, stainless steel,
or other types of liners. The sample tube is pushed and/or vibrated to a specified depth (approximately
1 ft above the intended sample interval). The interior plug of the sample tube is removed by inserting
small diameter threaded rods. The sample tube is then driven an additional foot to collect the samples.
The probe sections and sample tube are then withdrawn and the sample is extruded from the tube.
Soil gas can be collected in two ways. One method involves withdrawing a sample directly from the probe
rods, after evacuating a sufficient volume of air from the probe rods. The other method involves collecting
a sample through tubing attached by an adaptor to the bottom probe section. Correctly used, the latter
method provides more reliable results.
Slotted lengths of probe can be used to collect groundwater samples if the probe rods can be driven to
the water table. Groundwater samples are collected using either a peristaltic pump or a minibailer.
A.1.9.1 PREPARATION
Determine extent of the sampling effort, sample matrices to be collected, and types and amounts of
equipment and supplies required to complete the sampling effort. Obtain and organize necessary sampling
and monitoring equipment. Decontaminate or pre-clean equipment and ensure that it is in working order.
Perform a general site survey prior to site entry in accordance with the HASP. Use stakes or flagging to
identify and mark all sampling locations. All sample locations should be cleared for utilities prior to
commencing intrusive activities.
Back carrier vehicle to probing location, set vehicle to park, shut off ignition, set parking brake, and block
rear tires. Attach exhaust hoses so exhaust blows downwind of the sampling location (this is particularly
important during soil gas sampling). Start engine using the remote ignition at the Geoprobe operator
position. When positioning the probe, always use the SLOW speed. Check for clearance on vehicle roof
before folding hydraulics out of the carrier vehicle. Extend the hydraulics and lower the derrick to the
ground surface. When the probe axis is vertical and the weight of the vehicle is on the probe unit, probing
is ready to begin. If ground-cover is concrete or asphalt, a Carbide drill tip shall be inserted into hammer
and ground-cover shall be cored via rotation.
Soil samples can be collected continuously via 4-ft-long acetate sleeves, or at specific intervals by driving
the sampler to the correct depth with a drive point in place, then removing the drive point through the
The objective of this procedure is to install a permanent groundwater MW using Direct Push drilling
techniques for applications such as collecting water quality samples and conducting hydrologic and
pressure measurements. These methods meet or exceed the specifications discussed for installation of
permanent MWs with prepacked screens in the United States Environmental Protection Agency’s
(USEPA’s) guidance document, "Expedited Site Assessment Tools for Underground Storage Tank Sites,"
(USEPA 1997) and ASTM Standards D6724 and D6725.
This procedure describes construction of a 2-inch permanent groundwater MW using 2-inch x 3.4-inch
OD prepacked screens installed through 4.5-inch OD probe rods. Two-inch prepacks have a running
length of 5 ft and are completed with 2-inch schedule 40 polyvinyl chloride (PVC) riser pipe. A 2-inch x
3.4-inch OD prepacked well screen (2-inch prepack) consists of a slotted PVC pipe surrounded by
environmental grade sand contained within a stainless steel wire mesh cylinder. The inner component of
the prepacked screen is a flush-threaded, 2-inch schedule 40 PVC pipe with 0.01-inch slots. Stainless steel
wire mesh with a pore size of 0.011 inch (0.28 mm) makes up the outer component of the prepack. The
space between the inner slotted pipe and outer wire mesh is filled with 20/40 mesh silica sand. Two-inch
prepacks are available in nominal 5-ft sections and have an OD of 3.4 inches (86 mm) and a nominal ID of
2 inches.
Installation of a prepack MW begins by advancing 4.5-inch probe rods to depth with a Direct Push rig with
a 4.5-inch expendable drive point as the lead point. Prepacked screen(s) are then assembled and installed
through the 3.75-inch ID of the probe rods using corresponding 2-inch schedule 40 PVC riser pipe (Figure
A-1). Once the prepacks are lowered to depth, the rod string is slowly retracted until the leading end of
the rod is approximately 3 ft above the top prepack.
In certain formation conditions, the prepacked screens may bind inside the probe rods as the rods are
retracted. This is most common in sandy formations sometimes called flowing or heaving sands. This
binding can generally be overcome by lowering extension rods down the inside of the well riser and gently,
but firmly, tapping the extension rods against the base of the well as the rods are slowly retracted. If the
binding persists, clean tap water or distilled water may be poured down the annulus of the rods to increase
the hydraulic head inside the well. This, combined with the use of the extension rods, will free up the
prepacked screen and allow for proper emplacement.
A qualified geologist, hydrogeologist, or engineer shall supervise all MW installation projects and shall have
direct contact with the A&E COP for operations requiring drilling, soil boring, geophysical surveys,
lithologic sampling, and MW construction. The supervising professional shall affix his/her signature to all
drilling logs, as-built well construction diagrams, lithologic logs, sampling records, and similar documents.
When there is a possibility that floating petroleum products (i.e., light non-aqueous phase liquids [LNAPL])
may be encountered, shallow MWs shall be screened across the water table. The length of the screen
shall be such that tidal and seasonal water table fluctuations shall not cause water levels to rise above or
fall below the screened interval. If dense petroleum products (i.e., dense non-aqueous phase liquids
[DNAPLs]) may be encountered, MWs shall be screened at the bottom of the aquifer to capture the
DNAPL. In general, MWs will be constructed with 2-inch ID PVC casing and screen material, unless
otherwise specified.
Borehole diameters shall be at least 4-inches larger than the OD of the casing and well screen. In the case
of a HSA, the ID of the auger shall be at least 4-inches larger than the OD of the casing and well screen.
A completed MW shall be straight and plumb. The MW shall be sufficiently straight to allow passage of
pumps or sampling devices and to adequately determine depth to water.
Formation samples for lithologic description shall be obtained at each change in lithology or at 5-ft
intervals, whichever is less, or as specified in the project requirements. All samples shall be monitored
with an organic vapor monitor (e.g., PID, organic vapor analyzer) if VOCs are potential contaminants of
concern. The samples shall be handled in such a way as to minimize the loss of volatiles as described in
Section 2.4. Cuttings shall be examined for their hazardous characteristics. Materials that are suspected
MWs shall be installed using 2-inch ID PVC schedule 40 casing unless otherwise specified. The casing
requirements that shall be followed are: (1) all casing shall be new, unused, and decontaminated according
to the specifications of Section 1.16 or be brought on-site in manufacturer sealed packaging; (2) glue shall
not be used to join casing, and casings shall be joined only with compatible welds or couplings that shall
not interfere with the planned use of the well; (3) all PVC shall conform to the ASTM Standard F-480-88A
or the National Sanitation Foundation Standard 14 (Plastic Pipe System); (4) all metal casing shall be
seamless stainless steel casing, and the casing “mill” papers shall be included in the appendix of the technical
report; (5) the casing shall be straight and plumb within the tolerance stated for the borehole; and (6) the
driller shall cut a notch in the top of the casing to be used as a measuring point for water levels.
Well screen shall be 2-inch ID PVC schedule 40, 0.010 inch slot size, compatible with the # 3 filter pack
unless otherwise specified. Well screen requirements are: (1) all requirements that apply to casing shall
also apply to well screen, except for strength requirements; (2) MWs shall not be screened across more
than one water-bearing unit; (3) screens shall be factory slotted or wrapped; (4) screen slots shall be sized
to prevent 90 percent of the filter pack from entering the well, and for wells where no filter pack is used,
the screen slot size shall be selected to retain 60 to 70 percent of the formation materials opposite the
screen; and (5) the bottom of the screen is to be capped, and the cap shall be joined to the screen by
threads.
For LNAPL-contamination, well screens shall intersect the water table with a minimum of 1 ft of screen
above the highest anticipated water level. In general, for these wells, 10 ft of screen shall be used, unless
the anticipated range in water level fluctuation is greater than 7 ft. If the fluctuation is greater than 7 ft,
15 ft of screen shall be used.
The annular space requirements are the following: (1) the annular space shall be filled with a filter pack, a
bentonite seal, and casing grout between the well string and the borehole wall; (2) any drilling fluids shall
be thinned with potable water of known acceptable quality to a density less than 1.2 grams per cubic
centimeter (g/cm3) (10 pounds per gal [lbs/gal]) before the annular space is filled; and (3) as the annular
space is being filled, the well string shall be centered and suspended such that it does not rest on the
bottom of the hole, and for wells greater than 50-ft deep, at least two centralizers shall be used (if allowed
by the end user), one at the bottom and one at the top of the screen. Additional centralizers shall be
used as needed.
The filter pack shall consist of silica sand or gravel and shall extend from the bottom of the hole to at least
2 ft above the top of the well screen. After the filter pack is emplaced, the well shall be surged with a
surge block for 10 minutes. The top of the sand pack shall be sounded to verify its depth during placement.
An additional filter pack shall be placed as required to return the level of the pack to 2 ft above the screen.
Surge the well for 5 minutes. Again, place an additional filter pack as required to bring its level to 2 ft
above the screen. If gravel is used, 6-in of coarse sand shall be placed on top of the gravel.
The filter pack material shall be clean, inert, and well-rounded and shall contain less than 2 percent flat
particles. The sand or gravel shall be certified free of contaminants by vendor or the drilling contractor.
The filter pack shall have a grain size distribution and uniformity coefficient compatible with the formation
materials and the screen. The filter pack shall not extend across more than one water-bearing unit. In all
wells greater than 20 ft in depth, the filter pack shall be emplaced with a bottom-discharge tremie pipe of
at least 1-1/2-inch diameter. If the inside of the HSAs are used as the tremie pipe, the top of the filter
pack shall be measured continuously to ensure that no more than 6 inches and no less than 2 inches of
filter pack is in the bottom of the auger between lifts and auger raising. The estimated volume of the filter
pack shall be calculated per foot of borehole annulus; and the volume of filter pack per foot of filter pack
installed should be recorded to provide a quantitative understanding of the filter pack integrity, identify
potential bridging, or void spaces in the pack. The tremie pipe shall be lifted from the bottom of the hole
at the same rate the filter pack is set. The filter pack shall be installed to approximately 3 ft (not less than
2 ft) above the top of the screen.
The A&E Bien Hoa Contractor shall record the volume of the filter pack emplaced in the well. Potable
water may be used, with the approval of the regulatory agency providing oversight, to emplace the filter
pack so long as no contaminants are introduced.
The bentonite seal requirements that shall be followed are the following: (1) place a cap over the well
casing to ensure bentonite does not enter the well casing; (2) the bentonite seal shall consist of at least 2
ft of bentonite between the filter pack and the casing grout; (3) if the top of the filter pack is under water,
coated bentonite pellets should be slowly emplaced through the tremie pipe to allow enough time for the
pellets to sink to the filter pack without bridging; (4) if the top of the filter pack is above the water table,
the bentonite shall be hydrated before placement and shall be installed as a slurry by pump tremie methods
The casing grout requirements are the following: the casing grout shall extend from the top of the
bentonite seal to land surface or to specifications required for well completion. Due to the potential for
frost heave, a bentonite grout, shall be used to minimize the potential for damage to the surrounded casing
during the freeze-thaw action. In accordance with:
1. Bentonite Grout Slurry which must consist of an inorganic mixture of:
a. Soda ash for pretreatment of makeup water, and
b. Minimum of 20 percent solids by weight bentonite that forms a low permeability seal not
greater than 1x10-7 centimeters per second (cm/sec) which resists flow of fluid through
the seal, is pumpable, and is mixed to the manufacturer’s specifications, and, if needed
c. Additives designed for yield/rate control for bentonite products that form a low
permeability seal not greater than 1x10-7 cm/sec which resists flow of fluid through the
seal, is pumpable, and is mixed to the manufacturer’s specifications.
All grout shall be tremied using a side discharge tremie pipe, and pumping shall continue from the bottom
of the annulus until undiluted grout flows from the annulus at the ground surface. The protective casing
shall be set following completion of the grout to land surface.
For flush-mounted completions, cut the casing about 3 inches BGS and provide a water-tight casing cap
to prevent surface water from entering the well. A freely draining valve box with a locking cover shall be
placed over the casing. The top of the casing shall be at least 1 ft above the bottom of the box. The valve
box lid shall be centered in a 3-ft diameter, 24-inch thick concrete pad that slopes away from the box at
1/4-inch per ft. Concrete pad shall be no less than 4 inches thick on the outer edge and no less than 24
inches thick at the borehole annulus. For surface mounts that are in areas of snow removal, tops shall be
1/4-inch below grade to avoid destruction by snow plows. The identity of the well shall be permanently
marked on the valve box lid and the casing cap. Where heavy traffic may pass over the well or for other
reasons, the concrete pad and valve box/lid assembly shall be constructed to meet the strength
requirements of surrounding surfaces.
When aboveground surface completion is used, extend the well casing 2 or 3 ft above the ground surface.
Provide a casing cap for each well, and shield the extended casing with a metal sleeve that is placed over
the casing and cap and seated in a minimum 2-ft by 2-ft square or 2.5-ft diameter by 4 inch concrete
surface pad. To allow for escape of gas, a small diameter (e.g., 1/4-inch) vent hole shall be placed in the
well casing, or a ventilated well cap shall be used. The ground surface shall be freed of grass and scoured
to a depth of 2 inches before setting the concrete pad. The diameter of the sleeve shall be at least 4
inches greater than the diameter of the casing. The pad shall slope away from the well sleeve. Install a
lockable cap or lid on the guard pipe.
The well construction and identifying information shall be engraved or stamped on a rustproof metal label
permanently secured to the well casing with the following information:
A piezometer is a small diameter cased borehole primarily used for water level measurements. The
piezometers’ requirements are the following: (1) piezometers shall be constructed using methods or
materials that do not contaminate groundwater or allow hydraulic communication between water-bearing
units or between the ground surface and water-bearing units, (2) piezometers that penetrate more than
one water-bearing unit shall be constructed in a manner that allows fluid from only one unit to enter
them, and (3) the straightness and plumbness of piezometers shall be the same as for boreholes and MWs,
Sections 1.11.2 and 1.11.3.
A completion diagram shall be submitted for each MW or piezometer installed. It shall include the
following information: (1) well identification (this shall be identical to the boring identification described);
(2) drilling method; (3) installation date(s); (4) elevations of ground surface and the measuring point notch;
(5) total boring depth; (6) lengths and descriptions of the screen and casing; (7) lengths and descriptions
of the filter pack, bentonite seal, casing grout, and any back filled material; (8) elevation of water surface
before and immediately after development; and (9) summary of the material penetrated by the boring.
Temporary MWs may be required when groundwater grab samples are required and the borehole will
not stay open for sampling, or water point samplers will not provide adequate intervals to be sampled.
Installation of temporary wells will be used as necessary to collect single interval grab samples to provide
preliminary/screening delineation of both lateral and vertical contamination. For vertical profiling, a single
The MW development requirements are: (1) all newly installed MWs shall be developed no sooner than
24 hours after installation to allow for grout curing; (2) all drilling fluids used during well construction shall
be removed during development; (3) wells shall be developed using surge blocks and pumps (prior
approval for any alternate method shall be obtained, in writing, from the appropriate stakeholders before
well development begins), and wells shall be developed until: the turbidity/clarity of the water has stabilized
for at least 15 minutes, and if clarity does not stabilize, the stabilization criteria in Bullet 7 of the procedure
below shall be met; (4) discharge water color and volume shall be documented; (5) no sediment shall
remain in the bottom of the well; (6) no detergents, soaps, acids, bleaches, or other additives shall be used
to develop a well; and (7) all development equipment shall be decontaminated according to the
specifications of Section 1.16.
Equipment needed:
• Development rig for surging and pumping;
• Surge block and pump;
• Open-top 55-gal drums;
• Water level indicator;
• Water quality meter including temperature, pH, electrical conductivity (EC), redox potential, and
turbidity; and
• Well construction diagram; and well development form.
Procedure:
All abandonment of MWs shall be performed in accordance with state and local laws and regulations.
Well pads and traffic boxes will be removed and casing will be cut 2-ft BGS unless overdrilling is required
by regulation. Concrete and traffic boxes will be disposed of as construction debris. Remaining well
casing and screen shall be abandoned by forced injection of grout or pouring through a tremie pipe starting
at the bottom of the well and proceeding to the surface in one continuous operation. The well shall be
Water level measurements shall be performed to estimate principal groundwater flow direction(s) and
hydraulic gradient. Water levels shall be measured from the notch located at the top of the well casing.
If well casings are not notched, measurements shall be taken from the north edge of the top of the well
casing, and a notch shall be made using a decontaminated metal file. The following procedures shall be
used to measure water levels.
• PID shall be calibrated to ambient air conditions and a standard traceable calibration gas (e.g.,
isobutylene in air). After uncapping the well, background and casing headspace organic vapor
measurements shall be recorded for any MW that may have VOC contamination.
• An interface probe shall be used for water and product gauging if a nonconductive floating product
layer is suspected.
• Date, well number, field instrument identification number, casing diameter, and other pertinent
observations (e.g., availability of sounder port, well condition) shall be recorded.
• Depth-to-groundwater from the top of casing shall be measured to the nearest 0.01 ft and recorded.
Water level results shall be compared with previous measurements to check for discrepancies.
• The water level sounder tape and probe shall be thoroughly rinsed before being lowered into each
groundwater MW.
• An inspection of the surrounding area shall be made to assure that all equipment and materials have
been retrieved and that the appropriate well cap has been replaced and secured.
• A general well inspection will be completed to include well condition/integrity, well pad condition, and
well security, and documented in appropriate field logs.
Following water level measurement, the total depth of the well from the top of the casing shall be
determined using a weighted tape or electronic sounder and shall be recorded. The water level depth
shall then be subtracted from the total depth of the MW to determine the height of the water column
present in the well casing.
A test pit is an opening in soil, unconsolidated deposit, or bedrock having at least one lateral dimension
greater than the depth of the opening, which is used for scientific purposes. The location of each test pit
shall be coordinated in writing with the Airbase before digging begins. The A&E Bien Hoa Contractor
shall follow Occupational Safety and Health Administration rules for excavation and confined space entry.
The excavated material shall be backfilled immediately after the required information has been recorded.
The first soils out shall be the last in when filling the pit. No test pit shall be left open overnight unless
adequate safety precautions are employed. In vegetated areas, backfilled test pits shall be reseeded with
native grasses. In addition to the general information required for all field forms, the following shall be
recorded for each test pit: (1) the total depth, length, and width; (2) the depth and thickness of distinct
soil or lithologic units; (3) a lithologic description of each unit; and (4) a description of any manmade
materials or apparent contamination encountered.
Excavation shall occur by using either a backhoe or hand shovel. Decontamination of all equipment shall
occur after an excavation is completed or daily following site-specific requirements. Any shoring that is
required shall be described and documented. The dimensions for all test pits that shall be excavated shall
be described in the UFP–QAPP, as necessary.
All field equipment that may directly or indirectly contact samples shall be decontaminated in a designated
decontamination station in accordance with the approved UFP–QAPP. A decontamination station shall
be established at each field site prior to initiating intrusive field activities. It shall consist of a plastic-lined
pad where drilling equipment, such as auger flights, drill rods, and sampling devices, can be steam or
pressure cleaned. In addition, the portion of the drill rig which stands above the boreholes shall be
decontaminated by steam cleaning, pressure washing or handwashing with soapy water at the
decontamination station. Drilling rigs and associated drilling equipment that does not contact samples
shall be decontaminated between sites to minimize the potential for cross-contamination. All downhole
equipment that makes contact with potential sample material shall be decontaminated between sample
intervals/borings.
General decontamination procedures for large pieces of equipment include the following:
• Drill rigs shall be decontaminated upon entering the site, before leaving the site, or when being moved
from one boring location to another;
• HSA flights, drill bits, and rods shall be decontaminated with high-pressure water, steam, and/or
laboratory grade phosphate-free detergent, scrubbed if necessary, rinsed thoroughly with potable
water, and allowed to air dry; diesel fuel may be used to remove any grease, followed by the previous
steps to ensure all diesel is removed, and
• All casings, screws, and other downhole equipment shall be steam-cleaned prior to installation.
Instruments that contact water, such as an electronic water level indicator, shall be decontaminated
following the procedures for sampling equipment described below. Instruments that are sensitive to soap
A Waste Inventory Tracking Log shall be kept during sampling events. Non-investigative waste, such as
litter and household garbage, shall be collected on an as-needed basis to maintain each site in a clean and
orderly manner. This waste shall be containerized and transported to the designated sanitary landfill or
collection bin. Acceptable containers shall be sealed boxes or plastic garbage bags.
Investigation-derived waste (IDW) shall be properly containerized and temporarily stored at each site,
prior to transportation for off-site disposal. Depending on the constituents of concern, fencing or other
special marking may be required. The number of containers shall be estimated on an as-needed basis.
Acceptable containers shall be sealed, U.S. Department of Transportation (DOT)-approved steel 55-gal
drums or small dumping bins with lids. Containers shall be transported in such a manner to prevent
spillage or particulate loss to the atmosphere.
Soil cuttings, groundwater, and decontamination water generated during soil and groundwater sampling
will be sampled and analyzed in accordance with local landfill requirements.
For soil cuttings placed in drums, each drum will be opened and scanned using a PID. A soil column from
each drum will be removed and a composited sample will be collected from grab core samples from up
to eight drums.
• For volatile analyses, four terra core (or similar) aliquots will be randomly collected from each core
sample. Each terra core aliquot will be placed in a 4 ounce (oz) jar for IDW analysis for toxicity
characteristic leaching procedures (TCLPs) VOCs.
• For nonvolatile analysis, the remaining core aliquots will be place in a new disposable bucket-liner and
homogenized for 1 minute. Samples will then be collected directly into the analytical-specific sample
containers.
• Samples will be analyzed TCLP analyses for the same chemical groups analyzed for environmental
purposes. Samples will also be analyzed for corrosivity (pH) and flash point.
IDW will be containerized into one or more drums per site. Water from each drum in the IDW storage
for each site will be composited in a new, clean bucket-liner and then an IDW sample will be collected
from the composited bucket-liner into containers specific for each analysis. Composites from up to eight
drums may be used to characterize the IDW.
Soil and water collection samples will be labeled, preserved, and shipped as per sample handling and
shipping SOP ES-11. These IDW samples will then be treated as any other environmental sample being
sent to the laboratory.
The A&E Bien Hoa Contractor will provide a preliminary waste characterization for the containerized
IDW based on RCRA characteristics and flash point. The A&E Bien Hoa Contractor chemist will review
the analytical data to determine if the waste exhibits a hazardous waste characteristic as identified at 40
Surveying shall be conducted at two levels of precision: (1) General site features, such as property
boundaries, fence lines, utilities locations, and petroleum, oil, and lubricant pipeline locations shall be
surveyed at sub-meter accuracy and precision in Northing, Easting and Elevation. These measurements
may be collected using GPS surveying equipment operated by the A&E Bien Hoa Contractor staff. Soil
boring locations shall be surveyed using GPS, as well. (2) Features that require precise elevation controls,
such as MWs, stream or ditch bottoms, or reference points, shall be surveyed by a licensed surveyor in
the state. MWs and reference points for stream gauging shall be measured at ground level and at the
reference point. MW reference points shall be at the notch located at this northern fencing point on the
PVC casing stickup. Stream gauges shall include a semi-permanent measuring point, depth with top above
ground surface. The horizon and the vertical precision for these survey data shall be ±3.048 centimeter
(cm) and ±0.3048 cm ft, respectively.
Site features and sampling locations shall be surveyed and the results shall be presented in a table
containing the name of the feature/location identifier, date, reference datum, survey method, Northing,
Easting, Elevation, coordinate system, and measurement units. The final survey data shall be submitted in
VN2000, World Geodetic System 84 Transformation 2.
All surveying locations measured by a certified land surveyor in the previously described coordinate
system shall be third order (Urquhart 1962). An XY-coordinate system shall be used to identify locations.
The most reliable type of aquifer test usually conducted is a pumping test. In addition, some site studies
involve the use of short-term slug tests to obtain estimates of hydraulic conductivity, usually for a specific
zone or very limited portion of the aquifer. It should be emphasized that slug tests provide very limited
information on the hydraulic properties of the aquifer and often produce estimates which are only accurate
within an order of magnitude. Slug tests should be used for preliminary studies to develop preliminary
conceptual site models, while engineering studies to develop remedial design documents should use the
more definitive pump test methodologies (USEPA 1993).
Aquifer testing equipment shall be decontaminated and water levels measured according to the
specifications of Section 1.16. The A&E Bien Hoa Contractor shall demonstrate that the assumptions of
the selected analytical methods for deriving the hydraulic properties match the hydrogeological conceptual
site model, and meet the data quality objectives presented in the UFP–QAPP.
The standard slug test methodology is provided by ASTM D4050 and D4104. Slug tests are applicable to
unconsolidated deposits of low hydraulic conductivity. Testing of several wells is necessary to characterize
an aquifer because slug tests only measure aquifer properties immediately adjacent to the borehole or
well. The test shall be performed using a slug or by withdrawing water from the well. No fluid shall be
put in the well (USEPA 1994).
A.1.18.1.1 PRE-FIELD PROCEDURES
Before field work is initiated, the following data shall be gathered:
• A list of the MWs on which slug tests are to be performed;
• Information describing well location, using site-specific or topographic maps or GPS coordinates and
descriptions tied directly to prominent field markers (positional information or maps are also valuable
under severe weather conditions);
• Boring logs and well construction details;
• Survey data that identify the documented point of reference (V-notch or other mark on well casing)
for the collection of depth-to-groundwater as well as total well depth information; and
• Previous depth-to-groundwater measurements.
Equipment specific to the method to be gathered include:
• Electronic water level indicator;
• Organic vapor detector;
• MW keys;
• Tools for well access (such as sockets, wrenches, screw drivers);
• Water pressure transducer;
• Portable computing device to program transducer;
• Solid slug of known volume;
• Stopwatch or clock with second precision; and
• Decontamination equipment.
Before entering the field, the following activities shall be completed:
• Review the well construction records for the well specifically focusing on total depth of the well, well
diameter, and screen position and length;
• Connect water level transducer to the appropriate programmed computer; and
• Synchronize the computer and transducer clocks. Check the battery in the transducer to ensure full
power supply.
Select a logging rate of one reading per second. Set the transducer to start logging data. Record data in
the field log book along with the transducer identification number being used.
Pump tests are valuable in determining design characteristics for groundwater remedial actions, such as
pump and treat, injection of emulsified vegetable oil, or others and are highly dependent on the site
characteristics. A detailed pumping test for the development of a three-dimensional groundwater model
should be designed by an experienced hydrogeologist with specific requirements in mind related to the
chosen remedy design. Pump tests range in complexity from a constant drawdown specific capacity test,
evaluated in a single pumping well, to very complex tests with multiple observation wells. The more
Specific capacity is a quantity that a water well can produce per unit of drawdown. It is normally obtained
from a step drawdown test. Specific capacity (Sc) is expressed as:
Sc = Q/(h0-h),
where
Sc is the specific capacity (gal per day per ft [gal/day/ft])
Q is the pumping rate (gal per day [gal/day]), and
General water sampling will be conducted in accordance with USEPA sampling recommendations.
VOCs, Metals, and other Analytes: In most cases, samples collected for organic compounds and metals
must be collected prior to other samples, with VOC samples being collected first. The VOC samples
must be collected so that no air bubbles remain in the sample container. These samples must be collected
by slowly pouring the sample contents into the vial until a convex meniscus is seen on the surface of the
vial. A Teflon™-lined septum cap must be carefully placed on the vial until finger tight. The sample bottle
should then be inverted to verify that no air bubbles have been trapped inside. Samples for other
constituents should be collected in bottles as per the UFP–QAPP and preserved as per the UFP–QAPP.
Filtering: As a general rule, groundwater samples should not be filtered. However, filtration may be
needed to correct for chronically turbid wells. Filtered samples must not be collected from usable water
supply wells. Filtering is also not recommended when the sample turbidity appears to be chemically-
induced or colloidal. When samples are filtered, such as under conditions of excessive turbidity, both
filtered and unfiltered samples must be submitted for analyses. Samples for organic compounds analysis
must not be filtered. It is recommended that efforts be undertaken to minimize any persistent sample
turbidity problems. These efforts may consist of the following:
1. Implementation of low-flow/low stress purging and sampling techniques, or
MWs shall be sampled in accordance with USEPA recommendations. MWs shall be sampled in order of
anticipated ascending contamination to minimize the potential for cross-contamination between wells. All
sampling activities shall be recorded in the field log book. Additionally, all sampling data shall be recorded
in the appropriate field log.
The following items are required for groundwater sampling:
• Field notebook, purge and sampling forms, and camera;
• PID or similar organic vapor monitor (only if analyzing for VOCs]);
• Electronic water level indicator, (interface meter if LNAPL is present);
• Sample pump (peristaltic, bladder, etc.) and clean disposable tubing (if submersible pumps are used,
decontamination supplies are required as well as disposable bladders, and controller with power
supply);
• Graduated beaker to estimate pump rate;
• PPE (inner and outer gloves, safety glasses, splash apron or water proof Saranex®);
• pH, temperature, turbidity, and specific conductance meters (flow-through cell for low-flow sampling);
• Plastic sheeting;
• 5-gal buckets; and
• Appropriate sample bottles and transport coolers, ice, labels, COC, custody seals, courier service
labels.
Before groundwater sampling begins, wells shall be inspected for signs of tampering or other damage and
appropriately documented. If tampering is suspected, (e.g., casing is damaged, lock or cap is missing) this
information shall be recorded in the field log book and reported to the A&E Bien Hoa Contractor
Supervisory On-site Geologist. Wells that are suspected to have been tampered with shall not be sampled
until the COP has discussed the matter with USAID, and Government of Vietnam.
Before the start of sampling activities, plastic sheeting shall be placed on the ground near the well. The
plastic sheeting shall be used to provide a clean working area around the wellhead and shall prevent any
soil contaminants from contacting sampling equipment. Visible water in the protective casing or in the
vaults around the well casing shall be removed prior to venting and purging.
The first time a well casing cap is removed to measure water level or to collect a groundwater sample,
the ambient air in the breathing zone shall be checked with a PID to determine the potential for fire,
explosion, safety hazards, or other threats to the health of workers (if warranted). Similarly, air in the well
bore shall be checked for organic vapors with a PID and for explosive gases with an explosimeter (if
Wells with in-place plumbing are commonly found at municipal water treatment plants, industrial water
supplies, private residences, etc. Many permanent MWs at active facilities are also equipped with
dedicated, in-place pumps. The objective of purging wells with in-place pumps is the same as with MWs
without in-place pumps, i.e., to ultimately collect a sample representative of the groundwater.
If the pump runs more or less continuously, no purge (other than opening a valve and allowing it to flush
for a few minutes) is necessary. If a storage tank is present, a spigot, valve, or other sampling point should
be located between the pump and the storage tank. If not, the valve closest to the tank should be used.
If the pump runs intermittently, it is necessary to estimate the volume to be purged, including
storage/pressure tanks that are located prior to the sampling location. The pump must then be run
continuously until the required volume has been purged. If construction characteristics are not known,
best judgment should be used in establishing how long to run the pump prior to collecting the sample.
Measurements of pH, specific conductance, temperature, and turbidity may be made and recorded at
intervals during purging and sampling.
Temporary groundwater MWs differ from permanent wells because temporary wells are installed in the
groundwater for immediate sample acquisition. Wells of this type may include a standard well screen and
riser placed in boreholes created by hand auguring, power auguring, or by drilling. They may also consist
of a rigid rod and screen that is pushed, driven, or hammered into place to the desired sampling interval.
As such, the efforts to remove several volumes of water to replace stagnant water do not necessarily
apply in these situations. It is important to note, however, that the longer a temporary well is in place
and not sampled, the more appropriate it may be to apply standard permanent MW purging criteria.
In cases where the temporary well is to be sampled immediately after installation, purging is conducted
primarily to mitigate the impacts of installation. In most cases, temporary well installation procedures
disturb the existing aquifer conditions, resulting primarily in increased turbidity. Therefore, the goal of
purging is to reduce the turbidity and remove the volume of water in the area directly impacted by the
installation procedure. Low turbidity samples in these types of wells can be achieved by the use of low-
flow purging and sampling techniques.
In purging situations where the elevation of the top of the water column is no greater than approximately
25 ft below the pump head elevation, a peristaltic pump may be used to purge temporary wells. Enough
tubing should be deployed to reach the bottom of the temporary well screen. At the onset of purging,
the tubing should be slowly lowered to the bottom of the screen to remove any formation material that
may have entered the well screen during installation. This is critical to ensure rapid achievement of low
turbidity conditions. After the formation material is removed from the bottom of the screen, the tubing
should be slowly raised through the water column to near the top of the column. The tubing must remain
at this level to determine if the pump is lowering the water level in the well. If there is no drawdown, the
tubing must be secured at the surface to maintain this pumping level.
If drawdown is observed on initiation of pumping and a variable speed peristaltic pump is being used, the
pump speed must be reduced to stabilize the draw down in the well, if possible. If the drawdown stabilizes,
the intake point and the pumping rate must be maintained. Sustained pumping at a low rate will usually
result in a relatively clear, low turbidity sample. In situations where the drawdown cannot be stabilized,
the intake point must be continuously lowered to match the water column.
With many of the Direct Push sampling techniques, no purging is conducted. The sampling device is simply
pushed to the desired depth and opened and the sample is collected and retrieved.
Samples must be collected following purging from a valve or cold water tap as near to the well as possible,
preferably prior to any storage/pressure tanks that might be present. Hoses should be removed prior to
sample collection. The flow should be reduced to a low level to minimize sample disturbance, particularly
with respect to VOCs. Samples should be collected directly into the appropriate containers.
Immediately following purging, samples must be collected using the techniques which are described below.
Samples collected for trace organic compounds must be collected at a rate slow enough to eliminate
generation of excessive bubbles and aeration of the water as it enters the bottle.
Peristaltic Pump: All peristaltic pump tubing shall be certified clean by the manufacturer, disposable, and
dedicated to a single well.
Samples for VOC analysis must be collected by filling the tube and allowing it to drain into the sample
vials. The tubing can be momentarily attached to the pump to fill the tube with water. After the initial
water is discharged through the pump head, the tubing is quickly removed from the pump and a gloved
thumb placed on the tubing to stop the water from draining out. The tubing is then removed from the
well and the water is allowed to drain into the sample vials. Alternatively, the tubing can be lowered into
the well to the desired depth and a gloved thumb placed over the end of the tubing. This method will
capture the water contained in the tubing. It can then be removed from the well and the water collected
by draining the contents of the tubing into the sample vials. Under no circumstances must the sample for
VOC analysis be collected from the content of any other previously filled container.
Semivolatile and nonvolatile aliquots shall be sampled directly from the peristaltic pump discharge port
tubing.
Bladder Pumps: All bladder pump tubing shall be certified clean by the manufacturer, disposable, and
dedicated to a single well. In addition, internal bladders shall be certified clean by the manufacturer,
disposable, and dedicated to a single well. Bladder pumps are submersible and shall be decontaminated
both externally and internally between wells and internal disposable parts shall be replaced.
Surface water sampling will be conducted in accordance with USEPA recommendations and are detailed
below. Surface water samples may be collected from standing water in the ditches, creeks, ponds, and
seeps. The equipment required for surface water sampling may include:
• Shallow draft row boat and U.S. Coast Guard approved personal flotation devices;
• Pyrex ladle, Teflon™ dipper, glass beaker, or Kemmer® or Wheaton subsurface water sampling
apparatus (or similar apparatus);
• Nylon rope;
• pH, temperature, turbidity, and specific conductance meters;
• Appropriate sample bottles and ice chest with ice;
• Plastic sheeting; and
• 5-gal buckets with lids.
Special attention should be paid to sampling locations, with locations surveyed using a site map and GPS
device. If no site map is available, a hand drawn map should be developed with the location of site features
A.2.4 METHOD 5035 REQUIREMENTS FOR VOCS IN SOIL AND SEDIMENT SOP (ES-04)
Soil and sediment VOC aliquots shall be collected in accordance with Method 5035. Commercially
available kits should be used, (such as En Novative Technologies, Inc.) to account for both low (less than
200 micrograms per kilogram [µg/kg]) and high (greater than 200 µg/kg) level media. Sample kits should
contain the following:
• One disposable calibrated core sampler (5 or 10 grams);
• One 2-oz container for percent moisture with lid;
• Two 40-milliter (mL) VOA vials with stir bar, 5 mLs of Sodium Bisulfate solution and tare weigh for
low level analyses; and
• One 40-mL VOA vial with 5 mLs of Methanol and tare weight for high level analyses.
The disposable calibrated core sampler shall be used to collect an undisturbed (if possible) sample aliquot
for each of the three preserved VOA vials. Vials are immediately sealed with the caps and placed in a
plastic bag. No labels or seals are placed on the individual containers as they are pre-weighed and doing
so will change the container weight. Labels and seals are instead placed on the plastic bag which holds the
VOAs. In addition, the 2-oz container is filled with the remaining sample to be used to determine the
moisture content of the sample so that the result can be provided in dry-weight.
All soil sampling will be conducted in accordance with USEPA recommendations and are detailed below.
This discussion of soil sampling methodology reflects both the equipment used (required/needed) to
collect the sample, as well as how the sample is handled and processed after retrieval. Selection of
equipment is primarily based on the depth of sampling, but it is also controlled, to a certain extent, by the
Hand auger sampling is the most common manual method used to collect near-surface soil samples.
Typically, auger-buckets with cutting heads are pushed and twisted into the ground and removed as the
buckets are filled. The auger holes are advanced one bucket at a time.
The practical depth of investigation using a hand auger is related to the material being sampled. In sands,
hand-augering is usually easily accomplished, but the depth of investigation is controlled by the depth at
which sands begin to cave. At this point, auger holes usually begin to collapse and cannot be practically
advanced to lower depths, and further samples, if required, must be collected using some type of pushed
or driven device.
Hand-augering may also become difficult in tight clays or cemented sands. At depths approaching 20 ft,
torqueing of hand auger extensions becomes so severe that in resistant materials, powered methods must
be used if deeper samples are required. Some powered methods, discussed later, are not acceptable for
actual sample collection, but are used solely to gain easier access to the required sample depth, where
hand augers or push tubes are generally used to collect the sample.
When a vertical sampling interval has been established, one auger-bucket is used to advance the auger
hole to the first desired sampling depth. If the sample at this location is to be a vertical composite of all
intervals, the same bucket may be used to advance the hole, as well as to collect subsequent samples in
the same hole. However, if discrete grab samples are to be collected to characterize each depth, a new
bucket must be placed on the end of the auger extension immediately prior to collecting the next sample.
The top several inches of soil should be removed from the bucket to minimize the chances of cross-
contamination of the sample from fall-in of material from the upper portions of the hole.
Another piece of soil sampling equipment commonly used to collect shallow subsurface soil samples is the
Shelby or “push tube.” This is a thin-walled tube, generally of stainless steel construction and having a
beveled leading edge, which is twisted and pushed directly into the soil. This type of sampling device is
particularly useful if an undisturbed sample is required. The sampling device is removed from the push-
head, then the sample is extruded from the tube into the pan with a spoon or special extruder. Even
though the push-head is equipped with a check valve to help retain samples, the Shelby tube will generally
not retain loose and watery soils, particularly if collected at lower depths.
Powered sampling devices and sampling aids may be used to acquire samples from any depth but are
generally limited to depths of 20 ft or less. Among the common types of powered equipment used to
collect or aid in the collection of subsurface soil samples are power augers; split-spoon samplers driven
with a drill rig drive-weight assembly or hydraulically pushed using drill rig hydraulics; continuous split-
This SOP is an overview of air monitoring to be performed during site activities. Air monitoring will be
performed to assess if:
• fugitive dust and/or dioxin are migrating offsite as a result of the remediation activities, and
• worker exposure to respirable dust and dioxin remain below established threshold levels.
Ambient air monitoring will be conducted in an area where no site remediation or other activities that
disturb the soil is occurring in addition to perimeter locations around the areas of active site remediation.
The offsite location is to provide baseline data on typical concentrations of fugitive dust and dioxin in the
ambient air at Bien Hoa. The number of sites may vary depending on activities that are occurring and
number of locations of activity at any given time. In addition to monitoring for the pollutants of concern,
appropriate meteorological instrumentation will be included with the sites as well, including wind speed,
wind direction, relative humidity, temperature and precipitation. Site selection will be based on general
guidelines published in 40 CFR 58, Appendix D, Network Design Criteria for Ambient Air Quality
Monitoring, coupled with site and project-specific data.
Fugitive Dust
Fugitive dust will be monitored using instrumentation, such as the Grimm Model EDM180, which operates
based on orthogonal light-scattering, and can be used to detect PM10, PM2.5 and PM1. The data are
collected in real-time, allowing immediate notification of excursions beyond user-established thresholds.
Monitors will be operated in accordance with standard monitoring network requirements for calibration,
maintenance and data collection. At selected site(s), collocation of high-volume (Hi-Vol) samplers will be
used for collection of gravimetric samples for confirmation and quality assurance purposes. Monitoring
will be performed 24 hours per day, 7 days per week for the duration of the ground disturbing activity
period. Isolated periods where data are not being collected at individual sites will occur during
maintenance checks and instrument calibration. Battery backups will be used to minimize downtown from
power failures. Raw data collected by the monitoring system will be transferred from the monitoring sites
using a data acquisition system and will be reviewed daily and quality assured monthly or more frequently
if action items, such as excursion alarms, dictate.
Dioxin
Dioxin monitoring in ambient air will be performed using USEPA Method TO-9A, which uses a high volume
air sampler equipped with a quartz-fiber filter and polyurethane foam (PUF) adsorbent for sampling 325
to 400 m3 ambient air in a 24-hour sampling period. Analytical procedures based on high resolution gas
chromatography-high resolution mass spectrometry (HRCG-HRMS) are used for analysis of the samples.
The dioxin air samplers will be collocated with the fugitive dust samplers as part of perimeter monitoring,
including the baseline sampling site. Specific instructions regarding the handling and operation of the dioxin
sampling system shall be in accordance with the manufacturer’s manual.
Respirable Dust
Continuous Personal Dust Monitors (CPDMs) will be used for monitoring respirable dust exposures for
onsite workers. Monitoring will be done using ThermoFisher Scientific PDM3700 Personal Dust Monitors,
If initial screening results indicate the presence of organic vapors, a headspace analysis shall be conducted
on remaining portions of the sample.
Following collection of split-spoon or equivalent soil samples, headspace screening shall be performed in
the field using a portable PID on the remaining portions of samples selected on the basis of initial screening.
Soil samples collected from the borings shall be field screened by filling a self-closing polyethylene plastic
bag with approximately 250 grams of soil. The soil samples shall then be vigorously shaken for
approximately 30 seconds and allowed to equilibrate a minimum of 15 minutes. The bag headspace shall
then be screened for organic vapors by puncturing the bag exterior with the PID probe, inserting the tip
to a distance approximately one-half the headspace depth, and recording the highest reading displayed on
the instrument meter. The results of field headspace screening shall be recorded on the Drill Log and
used to select samples from each boring for laboratory analysis of selected analytical constituents.
All information regarding field headspace screening results, soil texture, density, consistency, and color
shall be recorded on the Drill Log.
If geotechnical samples are prescribed, 1-ft-long by 3-inch diameter Shelby tube samplers will be pushed
to the required depth. The driller shall remove all equipment from the HSA internal casing. The Shelby
tube sampler shall then be connected to the end of the drilling rod and lowered into the bottom of the
boring, with successive lengths of rod. The full length of the sample shall be pressed into the undisturbed
material at the base of the borehole using the rig hydraulics. Shelby tubes shall not be hammered. The
sampling rod shall then be removed from the borehole and the filled sampler shall be removed from the
rod by the drill crew and handed to the sampling technician. The sampling technician shall take a small
portion of the material and place it in an evacuated Ziploc® bag for lithologic logging and headspace
assessment. The sampling technician shall cut the Shelby tube sampler to remove unfilled portions of
tube, then cover both ends of the sampler with a Teflon™ swatch and plastic cap, label the sampler with
information pertaining to the location where the sample was collected, mark the distance BGS associated
A potentially more reliable indicator of surface water contamination is the underlying stream sediments.
Unlike surface water contamination, which may become diluted or chemically transformed downstream,
contaminants have a tendency to accumulate in sediments. Stream sediment samples shall be obtained
following collection of surface water samples. The order of stream sediment sampling shall begin with the
farthest downgradient sample and move progressively upgradient to minimize potential cross-
contamination between locations and media. Where appropriate, stream sediment samples shall be
collected from the active streambed on the stream side nearest the contamination source. During surface
water and stream sediment sampling, the A&E Bien Hoa Contractor field personnel shall sketch the
approximate sampling locations and record the following field observations on the Surface
Water/Sediment Field Sampling Report:
• Sediment type (e.g., sand, silt, gravel, clay, organic, other);
• The percent recovery, if sediment cores are collected;
• Geomorphology (channel shape, stream bank description, erosional/depositional characteristics);
• Vegetation type;
• Color and/or discoloration;
• Sample depth;
• Odor; and
• The sampling device.
Stream sediment samples shall be collected using a decontaminated scoop, with VOCs collected directly
from the scoop according to Section 2.4 for Method 5035. The remaining non-VOC aliquot will be
transferred to a clean disposable homogenization container where excess water will be decanted and the
remaining material will be thoroughly homogenized, then transferred to the proper container, sealed,
labeled and placed in a cooler on ice to be chilled to 4°C until shipment.
Sample containers are purchased pre-cleaned and treated according to USEPA specifications for the
methods. Sample containers prescribed in the UFP–QAPP and are specific to media sampled and analytical
requirements. Containers are stored in clean areas to prevent exposure to fuels, solvents, and other
Sample volumes, container types, and preservation requirements for the analytical methods performed on
samples are listed in UFP–QAPP.
Sample holding time tracking begins with the collection of samples and continues until the analysis is
complete. Holding times for methods required routinely for work are specified in the appropriate section
of the UFP–QAPP.
Each sample collected will be given a unique sample identifier (sample ID). A record of all sample identifiers
will be kept with the field records and recorded on a COC form. In addition, the sample identifiers will
be used to identify and retrieve analytical results from the laboratory, validation, and upload into the
Environmental Resources Program Information Management System. Sample identifiers will be in
accordance with the appropriate sections of the UFP–QAPP.
Field personnel will use standard sample labeling procedures to maintain sample integrity during collection,
transportation, storage, and analysis. Waterproof sample labels will be affixed to each sample container.
Non-waterproof sample labels will be covered with clear tape. Sample containers can be placed in
resealable plastic bags to protect the sample from moisture during transportation to the laboratory. The
label will be completed with the following information written in indelible ink:
• Project name and location;
• Sample identification number;
• Date and time of sample collection;
• Preservative used;
• Sample collector’s initials; and
• Analysis required.
Documentation during sampling is essential to ensure proper sample identification. Field personnel will
adhere to the following general guidelines for maintaining field documentation:
• Documentation will be completed in permanent black ink;
• All entries will be legible;
• Errors will be corrected by crossing out with a single line and then dating and initialing the lineout;
and
• Unused portions of pages will be crossed out, and each page will be signed and dated.
The Installation Lead is responsible for ensuring that sampling activities are properly documented.
When appropriate, trip blank and EBs will be collected. Trip blanks, prepared by the laboratory using
water demonstrated to be free of chemicals of potential concern, will be placed in the cooler used to ship
volatile samples. One EB will be collected per 10 environmental samples collected using non-dedicated
or non-disposable equipment from each site during soil and groundwater sampling. All field quality control
samples will be collected in accordance with the UFP–QAPP, as summarized below.
An EB is a sample of distilled water of known quality poured into, over, or pumped through a previously
used and decontaminated sampling device, collected in a sample container, and transported to the
laboratory for analysis. EBs are used to assess the effectiveness of equipment decontamination
procedures.
The sampling activity will use decontaminated split-spoon shoes that will be used to collect subsurface soil
samples. These will be thoroughly decontaminated between samples and an EB will be collected prior to
sampling activity by pouring deionized water over the equipment and directly into the sampling container
associated with the analytical types to be collected that day. The EB will be associated with all samples
collected after it and before the next EB.
The use of bladder pumps for low-flow sample collection will require the collection of EBs from the pump
as internal portions of the pump require decontamination. EBs will be collected by running deionized
water through the pump fitted with a new bladder and section of sample tubing.
The sampling activity will use disposable and dedicated equipment for groundwater sampling and surface
soil sampling so no EBs will be necessary for these sample types. EBs shall not be used if sampling
equipment is clean and dedicated or disposable for single use.
EB collection will be at a frequency of 10 percent of investigative samples. The blank shall be analyzed for
all laboratory analyses requested for the environmental samples collected at the site.
The trip blank consists of three VOC sample vials filled in the laboratory with ASTM Type II reagent grade
water, transported to the sampling site, handled like an environmental sample, and returned to the
laboratory for analysis. Trip blanks are not opened in the field. Trip blanks are prepared only when VOC
water samples are taken and are analyzed only for VOC analytes. Trip blanks are used to assess the
potential introduction of contaminants from sample containers or during the transportation and storage
procedures. One trip blank shall accompany each cooler of samples sent to the laboratory for analysis
of VOCs and will be associated with the cooler based on the cooler number. To ensure correct
association, and electronic documentation, the sample manager will write the cooler number in the notes
section of the COC. Trip blanks shall only be used for non-frozen samples.
A field duplicate sample is a second sample collected at the same location as the original sample. Duplicate
samples are collected simultaneously or in immediate succession, using identical recovery techniques, and
treated in an identical manner during storage, transportation, and analysis. Soil sample duplicates will be
collected from the same homogenization lot. Duplicate samples should be collected in locations that are
expected to be contaminated (hot spots) because they measure the variability in field measurements.
The sample containers are assigned an identification number in the field such that they cannot be identified
(blind duplicate) as duplicate samples by laboratory personnel performing the analysis. Specific locations
are designated for collection of field duplicate samples prior to the beginning of sample collection:
Duplicate sample results are used to assess precision of the sample collection process. Precision of soil
samples to be analyzed for VOCs is assessed from collocated samples because the compositing process
required to obtain uniform samples could result in loss of the compounds of interest. The frequency of
field duplicate collection is listed in the appropriate section of the UFP–QAPP. Field duplicates will be
collected from areas known or suspected to be contaminated and will be collected for all methods at a
frequency of 10 percent of investigative samples.
A matrix spike (MS) sample is a QC sample used by the laboratory to evaluate the effect of a particular
sample matrix has on the accuracy of a measurement. A matrix spike duplicate (MSD) is theoretically
equal to the corresponding MS sample and provides a means of measuring method precision. MS/MSD
samples will be collected for all methods. Triple sample volume will be collected for MS/MSDs from
relatively clean sampling locations (e.g., upgradient) to capture effects of the matrix sampled. MS/MSDs
will not be designated on the sample label with a unique modifier. MS/MSD samples will have sample
identifications identical to the parent, or normal sample. However, MS/MSD samples will be designated
on the COC for the benefit of lab personnel. MS/MSD samples will be collected at a frequency of 5
percent of investigative samples.
All field instruments shall be calibrated on a daily basis to a known standard, if they are used that day. In
some instances, calibration shall be performed more frequently. Calibration shall provide QA checks on
all field equipment used during implementation of the field investigations. Each instrument shall have an
individual identification number and each standard will have a lot number and expiration date. These
numbers shall be transcribed on field data records when using a particular instrument for a sampling event.
All calibration, repair, and service records shall be kept in individual equipment log books maintained for
each type of instrument. Field equipment that consistently fails to meet calibration standards or exceeds
manufacturer’s critical limits shall be promptly repaired or replaced. The A&E Bien Hoa Contractor shall
record equipment calibration on a Field Instrument Calibration Check Form.
The following are examples of calibration procedures that may be performed during field investigations.
A.3.2.2.1 PHOTOIONIZATION DETECTOR
The PID shall be calibrated per manufacturer instructions each day prior to the start of field activities.
Instrument calibration shall be performed using isobutylene calibration gas of known concentration (100
or 250 parts per million). All adjustments to instrument settings shall be recorded in a field log book.
A.3.2.2.2 ELECTRICAL CONDUCTIVITY, PH, TEMPERATURE, DISSOLVED OXYGEN, AND TURBIDITY
Each of these water quality parameters shall be calibrated at each groundwater sampling location and
during well development and sample purging. Calibration acceptance criteria is derived from Manufacturer
Specifications may vary with each instrument. Daily calibrations shall be documented in the appropriate
field and will include at least the following:
• Date and time of calibration
• Unique instrument identification and model number
To ensure that sampling and monitoring activities shall meet DQOs, QC checks shall be implemented for
parameters measured in the field. All QC control check information shall be recorded in project-specific
field log books and/or forms. The following sections discuss control parameters, control units, and
corrective actions (CAs) for the field investigation.
A.3.2.3.1 CONTROL PARAMETERS
Several parameters shall be controlled during the field sampling and measurement activities. As previously
described, calibration of field instruments and operational checks shall be conducted periodically. The
frequency of field control check duplicates shall be a minimum of 10 percent of all field measurements.
Temperature, pH, EC, DO, and turbidity shall be checked at the same frequency. As applicable, the
materials used to verify control parameter measurements shall be from certified sources. Instrument use,
maintenance, and calibration shall follow manufacturer guidelines.
A.3.2.3.2 CONTROL LIMITS
Field Equipment control limits are specified in the UFP–QAPP. Field instrument calibration accuracy and
duplicate precision for field measurements must meet acceptance criteria, or instrument readings shall be
considered suspect. Appropriate CAs shall be taken whenever field instruments fail to meet acceptance
criteria for accuracy and precision.
A.3.2.3.3 CORRECTIVE ACTION
The CA required for field instruments that are used to measure water quality parameters shall include
recalibrating and re-measuring the parameter. CA for all field instruments shall involve a review of the
operator’s manual. If necessary, instrument maintenance and repairs shall be performed as CAs in addition
to normally scheduled maintenance operations. Any maintenance shall be recorded on a Field Instrument
Calibration Check Form.
All field measurement equipment shall be decontaminated according to the specifications in Section 1.15
prior to any measurement activities and shall be protected from contamination until ready for use.
During borehole advancement, the air in the breathing zone of on-site personnel shall be evaluated for
the presence of organic (e.g., VOCs, SVOCs, petroleum hydrocarbons) and explosive vapors (lower
explosive limit and oxygen content) using a Photovac 2020 PID and explosimeter (Industrial Scientific
Model MX 251), respectively, or equivalents if warranted by site contaminants. Air monitoring data shall
be tabulated on a Health and Safety Exposure Monitoring Form from the HASP. Procedures provided in
the HASP shall be followed.
In addition to monitoring the breathing zone around the borehole, the PID shall be used to screen for
organic vapors in the well bore each time a well casing cap is removed for developing and purging
Water level measurements shall be taken in all wells and piezometers to determine the elevation of the
water table or piezometric surface at least once within a single 24-hour period. These measurements
shall be taken after all wells and piezometers have been installed and developed and their water levels
have recovered completely. Any conditions (e.g., barometric pressure) that may affect water levels shall
be recorded in the field log. The field log shall also include the previous water level measurement for
each well (to determine if current water level is reasonable).
Water level measurements shall be taken with electric sounders, air lines, pressure transducers, or water
level recorders (e.g., Stevens’s recorder). Devices that may alter sample composition shall not be used.
Pressure gauges, manometers, or equivalent devices shall be used for flowing wells to measure the
elevation of the piezometric surface. All measuring equipment shall be decontaminated according to the
specifications in Section 1.15. Groundwater level shall be measured to the nearest 0.3048 cm ft. (Two
or more sequential measurements shall be taken at each location until two measurements agree to within
+ or - 0.3048 cm.)
SWLs shall be measured each time a well is sampled, and before any equipment enters the well. If the
casing cap is airtight, allow time prior to measurement for equilibration of pressures after the cap is
removed. Repeat measurements until water level is stabilized.
Water level measurements shall be taken from existing and newly installed groundwater MWs prior to
well development and sample purging. Groundwater levels in the bedrock groundwater MWs shall be
recorded to the nearest 0.3048 cm using a cable electronic water level indicator or the equivalent. The
primary objectives of measuring water levels in the groundwater MWs shall be to estimate the volume of
water to facilitate well development and sample purging, and to provide a preliminary evaluation of
principal groundwater flow directions. The total depth of each groundwater MW shall also be measured
after installation to evaluate its usefulness for future monitoring (see FO14).
The Solinst Model 121 Interface Meter or its equivalent shall also be used to monitor the overburden
groundwater table for the presence of an immiscible layer such as petroleum product. Depth and
thickness shall be measured to the nearest 0.3048 cm ft. Measurement of product thickness shall be
conducted as above for water level, but using the indicator for product.
During MW development and sample purging, the above-referenced water quality parameters shall be
monitored using portable field equipment. The A&E Bien Hoa Contractor shall monitor EC, pH,
groundwater temperature, ORP, and DO using a hand-held multi-function water quality meter. A
multiprobe sampling chamber (flow cell) may be used for measuring parameters simultaneously. The
probes of the calibrated meters are attached to the individual sample ports of the flow cell. When
groundwater is pumped inline into the flow cell from the MW, continuous readings of these water quality
indicator parameters shall be recorded until stabilization is reached for each parameter.
A portable turbidimeter with an accuracy of 2 percent of reading or 0.05 NTU, shall be used to facilitate
well development.
The A&E Bien Hoa Contractor shall maintain field records sufficient to recreate all sampling and
measurement activities and to meet all project data loading requirements, and in accordance with USAID
requirements. The requirements listed in this section apply to all measuring and sampling activities.
Requirements specific to individual activities are listed in the section that addresses each activity. These
records shall be archived in digital form and made available to the COR via the data management system.
The following information shall be recorded with indelible ink in a permanently bound notebook with
sequentially numbered pages for all field activities:
• Location;
• Date and time;
• Identity of people performing activity; and
• Weather conditions.
For field measurements, the numerical value and units of each measurement, and the identity of and
calibration results for each field instrument shall also be recorded on field logs.
The following additional information shall be recorded for all sampling activities:
• Sample type and sampling method;
• The identity of each sample and depth(s), where applicable, from which it was collected;
• The amount of each sample;
• Sample description (e.g., color, odor, clarity);
• Identification of sampling devices; and
• Identification of conditions that might affect the representativeness of a sample (e.g., refueling
operations, damaged casing).
Records shall be kept for all activities associated with the field activities as a means to maintain full
documentation of project QA/QC procedures and compliance. In general, all documents shall be
completed in permanent black ink. Errors shall be corrected by crossing them out with a single line and
then dating and initialing. The use of correction fluids shall not be allowed. The documents used during
the field investigation shall remain on site (if possible) during the entire effort so that they can be reviewed
by interested parties. Forms shall be kept organized and in a central file also located on site, if applicable.
Records will be kept in the form of field log books, standardized forms, and copies of original electronic
files.
The A&E Bien Hoa Contractor field personnel shall maintain field log books during the investigation. The
field log books are the master field investigation documents that will be bound books with hard covers
and sequentially numbered pages. The primary objective of the field log books is to maintain, within the
actual field data or references to other field documents that contain a specific description of every activity
The A&E Bien Hoa Contractor will complete and maintain standardized field data forms for specified field
activities. Field data forms may include but are not limited to:
• Employee/Visitor Daily Roster;
• Tailgate Safety Meeting Report;
• Field Instrument Calibration Check Form;
• Water Quality Analyzer Check Form;
• Static Groundwater Measurement Form;
• Field Sampling Report (Soil/Sediment);
• Field Sampling Report (Groundwater/Surface Water);
• Monitoring Well Purge and Sample Form;
. 1990. ASTM D-2488-90. Standard Practice for Description and Identification of Soils (Visual-
Manual Procedure).
Urquhart, L.C. 1962. Civil Engineering Handbook, 4th Edition. Pages 96-97.
U.S. Environmental Protection Agency (USEPA), 1994. Slug Test SOP # 2046. November.
. 1997. Expedited Site Assessment Tools for Underground Storage Tank Sites. March.
. 2007a. Groundwater Sampling Operating Procedure, Science and Ecosystems Support Division
(SESD) SESDPROC-301-R1. November.
. 2007b. Surface Water Sampling Operating Procedure, Science and Ecosystems Support
Division (SESD) SESDPROC-201-R1. November.
chain òpaat
DECEMBER 5, 2019
This publication was produced for review by the United States Agency for International Development.
DISCLAIMER:
THE VIEWS EXPRESSED IN THIS PUBLICATION DO NOT NECESSARILY REFLECT THE VIEWS OF THE UNITED STATES AGENCY FOR
INTERNATIONAL DEVELOPMENT OR THE UNITED STATES GOVERNMENT.
DIOXIN REMEDIATION AT BIEN HOA
AIRBASE AREA PROJECT
PREPARED BY
TRIGON ASSOCIATES, LLC
1515 POYDRAS ST. SUITE 2200
NEW ORLEANS, LA 70112
USA
DISCLAIMER:
THE VIEWS EXPRESSED IN THIS PUBLICATION DO NOT NECESSARILY REFLECT THE VIEWS OF THE UNITED STATES AGENCY FOR
INTERNATIONAL DEVELOPMENT OR THE UNITED STATES GOVERNMENT.
CONTENTS
CONTENTS I
TABLES IV
FIGURES IV
RECORD OF REVISIONS V
ACRONYMS AND ABBREVIATIONS VI
1 SIGNATURE SHEET 1-1
2 BACKGROUND INFORMATION 2-1
2.1 PROJECT INFORMATION AND BACKGROUND 2-1
2.2 CONTRACTOR INFORMATION 2-1
2.3 SCOPE 2-2
3 SAFETY AND HEALTH POLICY STATEMENT 3-1
3.1 PROJECT SAFETY AND HEALTH POLICY STATEMENT 3-1
3.2 PROJECT SAFETY GOALS 3-1
3.3 SITE-WIDE HEALTH AND SAFETY PLAN DESCRIPTION 3-2
4 RESPONSIBILITIES AND LINES OF AUTHORITIES 4-3
4.1 KEY PROJECT PERSONNEL 4-3
4.2 KEY PROJECT PERSONNEL SAFETY AND HEALTH RESPONSIBILITIES 4-2
4.3 DESIGNATED COMPETENT PERSONS 4-1
4.4 PRE-TASK SAFETY AND HEALTH ANALYSIS 4-1
4.5 SAFETY COMPLIANCE AND ENFORCEMENT 4-2
4.5.1 GENERAL SAFE WORK PRACTICES 4-2
4.5.2 SAFE WORK PRACTICES FOR USE OF TOOLS, EQUIPMENT AND
MACHINERY 4-2
4.5.3 SAFE WORK PRACTICES FOR OPERATION OF MOTOR VEHICLES AND
HEAVY EQUIPMENT 4-3
4.5.4 SAFETY RULE ENFORCEMENT 4-3
5 SUBCONTRACTORS AND SUPPLIERS 5-4
5.1 LIST OF SUBCONTRACTORS 5-4
5.2 SELECTION OF QUALIFIED SUBCONTRACTORS 5-4
5.3 SUBCONTRACTOR SAFETY REQUIREMENTS 5-5
6 TRAINING 6-6
6.1 GENERAL TRAINING REQUIREMENTS 6-6
6.2 SITE ORIENTATION BRIEFING 6-7
6.3 DIOXIN MEDICAL SURVEILLANCE PROGRAM ORIENTATION 6-8
6.4 SAFETY MEETINGS 6-8
6.5 EMERGENCY RESPONSE PLAN TRAINING 6-9
7 SAFETY AND HEALTH INSPECTIONS 7-9
7.1 SAFETY INSPECTIONS 7-9
TABLES
Table 4-1.Key Project Personnel ............................................................................................................................... 4-1
Table 4.2 Key Project Personnel Safety and Health Responsibilities ................................................................ 4-2
Table 6-1. Training Requirements ............................................................................................................................. 6-6
Table 7.1. Table of Inspections* ................................................................................................................................. 7-9
Table 9-1. Plans Required by EM 385-1-1 ................................................................................................................ 9-1
Table 9-2. Emergency Contact List ........................................................................................................................... 9-4
Table 9-3. Evacuation Alarm and Assembly Information ..................................................................................... 9-5
Table 9-4. Hygienic Works in Workplaces ........................................................................................................... 9-12
Table 9-5. Heat Stress Conditions .......................................................................................................................... 9-28
Table 9-6. Screening Criteria for TLV and Action Limit for Heat Stress Exposure .................................... 9-29
Table 9-7. General Clearances Required from Energized Overhead High-Voltage Conductors............. 9-43
Table 9-8. Maximum Allowable Sloping ................................................................................................................. 9-47
Table 9-9. OSHA Safety and Health Program Cross-Reference Table .......................................................... 9-49
Table 9-11. Summary of 95th Percentile PCDD/F Congener Serum Lipid Concentrations....................... 9-56
FIGURES
Figure 2-1 Bien Hoa Airbase Site Map ...................................................................................................................... 2-1
Figure 8-1 Incident Reporting Flow Chart............................................................................................................. 8-12
Figure 9-1 Vicinity Map of Dong Nai International Hospital and Emergency Hospital Route: ................... 9-7
Figure 9-2 Site Zones.................................................................................................................................................. 9-62
001 December 5, 2019 All Response to USAID and Trigon Comments USAID CO/COR
001.1 June 23, 2020 9-7, M-10 Updated the map to the hospital Not applicable
001.2 August 10, 2020 2-1 Updated the overview map Not applicable
November 2019
Sal Mansour
Chief of Party
Suzanne Johnson
Contracting Officer
This Health & Safety Plan (HASP) has been prepared to meet the requirements of Government of Vietnam
(GVN) Occupational Safety and Health standards, United States Occupational Safety and Health
Administration (OSHA) standards found in Title 29 Code of Federal Regulations (CFR), Parts 1910 and
1926; and the United States Army Corps of Engineers (USACE) “Safety and Health Requirements Manual”
(30 November 2014 edition) (EM 385-1-1).
This Site-Wide HASP has been prepared for USAID under the Task Order 72044019F00001, Contract
Number AID—OOAA-1-15-00053 by the A&E Bien Hoa Contractor. This Site-Wide HASP presents the
Dioxin Remediation at Bien Hoa Airbase Area Project (Project) health and safety procedures that apply
to Project personnel and activities. This HASP applies to Project activities including site
investigations/evaluations, remediation, construction, and post-construction activities. USAID requires
compliance with this Site-Wide HASP by Project Contractors, base personnel, and associated third parties
to ensure a safe work environment for Project personnel.
The Project location is the Bien Hoa Airbase Area which includes the Bien Hoa Airbase and associated
off-Airbase locations (Figure 2-1). The Bien Hoa Airbase is an active Air Defence Air Force Command
(ADAFC) airbase located in Bien Hoa City, Dong Nai Province, approximately 30 kilometers (km)
northeast of Ho Chi Minh City. The Bien Hoa Airbase property is located within the Tan Phong Ward
and is adjacent to the Trung Dung, Quang Vinh, and Buu Long Wards, which are densely populated
residential neighborhoods.
The Bien Hoa Airbase Area is one of three major dioxin contamination hotspots in Vietnam identified
through studies completed in the 1990s. Bien Hoa, along with Phu Cat and Danang Airport, were used by
the United States (U.S.) military for the import, storage, and loading of Agent Orange between 1961 and
1971. In 2016, USAID, in close collaboration with the GVN, completed the "Environmental Assessment
of Dioxin Contamination at Bien Hoa Airbase". The overall objective of the Environmental Assessment
(EA) was to inform potential future actions at the Bien Hoa Airbase Area to address dioxin-related
contamination. The EA serves as the primary resource documenting characterization of dioxin
contamination on and around the Bien Hoa Airbase Area.
This Health & Safety Plan (HASP) has been prepared to meet the requirements of Government of Vietnam
(GVN) Occupational Safety and Health standards, United States Occupational Safety and Health
Administration (OSHA) standards found in Title 29 Code of Federal Regulations (CFR), Parts 1910 and
1926; and the United States Army Corps of Engineers (USACE) “Safety and Health Requirements Manual”
(30 November 2014 edition) (EM 385-1-1).
One of the primary objectives of the Project safety and health program is incident prevention. The Project
safety and health program strives to maintain incident-free operations, which can only be achieved through
total demonstrated commitment to this safety and health policy from Project personnel. Project personnel
must recognize and understand that incidents and injuries can be prevented.
To establish and maintain an effective safety and health program, Project personnel must:
• Project Contractors must engage in open dialog with site workers to identify and mitigate hazards
that could cause injury, accident, environmental incident, security incident, or property damage.
• Project Contractors will conduct daily inspections to monitor the proper use of personal
protective equipment (PPE), general safe work practices, and housekeeping. The results of
inspections will be presented in Project Contractor meetings, and mitigation measures will be
discussed and implemented.
• Prior to beginning a new work activity, Project Contractors must provide to USAID, through the
A&E Bien Hoa Contractor, an Activity Hazard Analysis (AHA) that describes the work, associated
• Mobilization,
• Site investigations/Evaluations,
• Excavation,
• Maintenance of contaminated material short-term storage,
• General construction,
• Construction of a remedial system,
• Construction of a long-term storage area,
• Remediation,
• Environmental monitoring, and
• Demobilization.
As the Project progresses and additional site data is collected, additional activities may be added to the
scope of the Project. Project Contractors will be identified through awards by USAID to implement the
dioxin remediation activities at the Bien Hoa Airbase Area. USAID is expected to specify particular health
and safety requirements for each contractor in these awards. However, in general, this HASP will be an
essential guide for Project Contractors and establishes the minimum safety and health requirements for
Project Contractors and personnel to follow. Project Contractors (including the A&E Bien Hoa
Contractor) are required to prepare SHASPs for their contract-specific work activities that must comply
with the minimum safety and health requirements established in this Site-Wide HASP. This Site-Wide
HASP will be provided to Project Contractors required to prepare a SHASP. During preparation of
SHASPs and/or review of the Site-Wide HASP, Project Contractors must immediately notify USAID and
the A&E Bien Hoa Contractor if safety and health deficiencies are found in the Site-Wide HASP.
This HASP has been prepared to meet the requirements of: GVN Occupational Safety and Health
standards; OSHA standards as found in Title 29 CFR, Parts 1910 and 1926; and USACE EM 385-1-1. The
implementation of this HASP assists Project personnel to take proactive measures to recognize, evaluate,
and control workplace hazards in order to minimize the potential for injuries and illness. The main
objectives of the Site-Wide HASP are to:
Project Contractors will prepare SHASP for site investigations/evaluations, remediation construction, post
construction, and other activities to be included in the Site-Wide HASP. The A&E Bien Hoa Contractor
will amend the Site-Wide HASP to incorporate SHASPs as annexes once they are approved by USAID.
The A&E Bien Hoa Contractor may recommend, and/or USAID may direct, revision and/or amendment
of the Site-Wide HASP as additional information becomes available regarding the site hazards or when
significant changes occur in the scope of work, operational procedures, site hazards, or hazard control
measures. This Site-Wide HASP may be modified by the A&E Bien Hoa Contractor Lead Safety and
Environmental Compliance Specialist (LSECS) upon review and approval of the A&E Bien Hoa Contractor
Health and Safety Officer (HSO) and Chief of Party (COP), and USAID Contracting Officer (CO). USAID
will inform Project Contractors of changes to the Site-Wide HASP. Project Contractors are required to
inform Project personnel of the changes in the revised/amended Site-Wide HASP through safety meetings
and other means. Safety and health responsibilities of key Project personnel and lines of authority are
presented in the following Section.
For other Project Contracts, the required SHASPs must specify and identify the following positions:
• USAID Contracting Officer’s Representative (COR)
• Contractor Project Manager (CPM)
• Site Contractor Project Manager (SCPM)
• Contractor Safety Officer (CSO)
AHAs will be prepared for work activities and tasks considered potentially hazardous including the initial
work tasks listed below.
• Project personnel must report to work in a ready-to-work state and in suitable work
clothing;
• Illicit drugs, alcohol, and firearms are not allowed on site;
• Horseplay and gambling are not allowed on site;
• Use of personal radios or other items that may distract attention are not permitted;
• Eating, drinking, and smoking are not permitted in work areas;
• The buddy system will be observed while working at the site unless the work activity requires
the work to be conducted alone, the exception has been approved by their CSO, and the
LSECS has been notified;
• PPE and respiratory protection will be properly used by all site workers;
• Harassment, bullying, or physical violence of any kind will not be tolerated and will result in
dismissal.
4.5.2 SAFE WORK PRACTICES FOR USE OF TOOLS, EQUIPMENT AND MACHINERY
Tools, equipment, and machinery inspection and maintenance are required to promote safe working
conditions. Tools (including hand and power tools), equipment, and machinery must be inspected daily or
before each use for defects. Tools that are burred, mushroomed, have split or loose handles, worn or
sprung jaws, or are generally unsafe must be turned in to the CSO and A&E Bien Hoa Contractor LSECS.
Defective or unsafe equipment must be tagged as defective until repaired or otherwise made acceptable.
Defective or unsafe equipment must be removed to a secure place to prevent inadvertent use until
repaired. Repaired items must be re-inspected by the CSO or A&E Bien Hoa Contractor LSECS before
being placed back into service. Damaged or defective machinery must be removed from work until
repaired. Repaired machinery must be re-inspected by the operator and the CSO or A&E Bien Hoa
Contractor LSECS before being placed back into service.
Tools, equipment, and machinery must be used properly for the purpose for which it was designed (do
not use a wrench for a hammer, screwdriver for a chisel, pliers for a wrench, pipe wrenches as a substitute
for other wrenches, a pipe handle-extension or a “cheater” on a wrench, etc.). All modifications,
extensions, replacement parts, or repairs of equipment must maintain at least the same factor of safety as
the original equipment.
Tools, equipment, and materials must not be thrown up or down from one working level to another. A
hand line must be used to lift or lower tools.
Electrical power tools must be properly grounded by using three-wire receptacles and extension cords
rated for the amperage required. Ground-fault circuit interrupters (GFCIs) must be used with temporary
electrical systems or other proper grounding system. An Assured Equipment Grounding Conductor
Program (AEGCP) must be implemented if GFCIs are not exclusively used.
A GFCI must be provided for all electrical tools, and the GFCI must be tested daily. Portable electric tools
must not be lifted or lowered by means of a power cord. Electrical equipment cords must be kept coiled
when not in use. When electrical equipment is in use, cords must be protected and positioned to avoid
being run over by vehicles or equipment.
4.5.3 SAFE WORK PRACTICES FOR OPERATION OF MOTOR VEHICLES AND HEAVY EQUIPMENT
Motor vehicles and heavy machinery must not be operated without proper training and special permission
if it is not a regularly assigned duty. Equipment must be used only for the purpose for which it was designed.
Operators of motor vehicles, passengers riding in motor vehicles, and operators of heavy equipment shall
use passenger restraint systems (e.g., seat belts) at all times. Project Contractors must include the hazards
associated with operation of vehicles and heavy equipment in applicable AHAs.
All Project personnel will report unsafe work practices to the relevant CSO, A&E Bien Hoa Contractor
LSECS, and/or COP to be shared with the USAID CO and COR for correction and mitigation. The CPM
shall designate which of their staff can immediately require their personnel to leave the site who do not
comply with the Project safety and health program requirements. The A&E Bien Hoa Contractor COP,
CM, or LSECS may request to the CPM/SCPM and recommend to USAID that personnel immediately
leave the site who are in violation with the Project safety and health program requirements. Project
personnel must strictly adhere to established safe work practices and work procedures. Violation of a
safety procedure or rule may result in disciplinary action in accordance with the severity of the infraction.
The CSO and the A&E Bien Hoa Contractor COP, CM, or LSECS will immediately report unsafe work
performance to the USAID CO and COR. Disciplinary action may include the following, depending upon
the severity of the safety infraction:
• Verbal warning,
• Written warning notice,
• Termination of employment, or
If Project personnel violate safety procedures or rules, the CSO, A&E Bien Hoa Contractor COP and/or
LSECS will recommend disciplinary action to the worker’s supervisor, in accordance with the severity of
the infraction. The A&E Bien Hoa Contractor COP and LSECS reserve the right to recommend dismissal
of workers who consistently exhibit unsafe work performance.
A prospective contractor seeking qualified subcontractor status shall complete a contractor safety
qualification questionnaire as a supplement to the subcontractor prequalification packet. The
questionnaire will be submitted to the Contracts Administrator, or designee, for initial review and
processing. The questionnaire must also be reviewed by the applicable safety and health personnel (i.e.,
CSO).
If not all criteria are met, then the questionnaire and attachments shall be forwarded to USAID CO/COR
for review/evaluation and acceptance of a variance or non-acceptance.
• Subcontractors are required to follow applicable GVN laws, the requirements of the Site-
Wide HASP, and ADAFC requirements for work at the Bien Hoa Airbase.
• Subcontractors are required to review, understand, and comply with the Site-Wide HASP,
including the requirement for serum dioxin analysis for all site workers in areas where
intrusive activities are conducted.
• Subcontractors are required to enforce applicable Site-Wide HASP requirements with their
employees.
• Before site work, subcontractors are required to provide a hazardous substances inventory
list and copies of applicable SDSs for hazardous substances to be brought on site to the
A&E Bien Hoa Contractor LSECS. Subcontractors will minimize the number and quantity of
hazardous substances brought onto the work site.
• Subcontractors are required to provide copies of required safety and health training and
certification documents to the CSO, as applicable (i.e., licenses, training certifications,
medical clearance [fitness for duty] certification, first aid/CPR training, respirator fit
testing). The CSO must make these documents available to the A&E Bien Hoa Contractor.
• Subcontractor workers are required to follow the instructions of the CSO or other
competent authority.
• Subcontractors are required to provide an AHA for subcontractor work activities to the
CSO. The CSO must make these AHAs available to the LSECS who will share with the
A&E Bien Hoa Contractor HSO. The detail for the AHA must be to the extent that every
phase and the tasks involved in those phases are considered to identify the associated
hazards and risks during the operation. These task and hazard risk analyses must be
modified as needed to address a changing work environment.
• Subcontractor personnel are required to attend a site orientation briefing from the CSO to
review pertinent aspects and safety and health requirements of the Site-Wide HASP and
AHAs as it pertains to their planned site activities. Subcontractor personnel must sign a
form documenting that they have reviewed the Plan and AHAs, understand the Site-Wide
HASP and AHA requirements, and agree to follow the Plan and AHAs.
• Subcontractor personnel must attend the daily safety meeting conducted by the CSO
before starting work to review work operations and to discuss pertinent site safety topics.
• Subcontractor personnel who do not comply with safety and health requirements may be
immediately told to leave the site by the CSO, SCPM, A&E Bien Hoa Contractor LSECS or
COP.
6 TRAINING
Proper training is required to conduct Project activities safely. Project training requirements include safety
and occupational health orientation training at time of initial assignment; mandatory training and
certifications applicable to Project activities and periodic retraining/recertification; and periodic safety and
health training for supervisors and employees.
Copies of applicable safety and health training certificates for all site workers will be maintained on site by
the CSO and available for review by the LSECS and A&E Bien Hoa Contractor HSO. Project personnel
are not allowed to perform fieldwork until the CSO has determined this documentation to be complete
and sufficient.
Project personnel assigned to fieldwork are required to complete the following training (as applicable)
(Table 6-1). Additional training may be required based on work activities to be conducted.
3-Day On-Site Hazwoper Training All Project personnel who will work in Work will be conducted using
contaminated areas where exposure is appropriate PPE and supervised by the
possible CSO unless the training was completed
prior to site work.
40-Hour USACE EM 385-1-1 Training A&E Bien Hoa Contractor LSECS, Online training.
or equivalent CSO, and all site supervisors
30-Hour OSHA Construction Safety A&E Bien Hoa Contractor LSECS and Training is available from online
and Health Training or equivalent CM, CSO, and designees sources
8-Hour Hazwoper Supervisor Training A&E Bien Hoa Contractor LSECS, 40-Hour Hazwoper and 3-day on-site
or equivalent CSO, and all site supervisors training are prerequisites
8-Hour Annual Hazwoper Refresher All 40-Hour Hazwoper Certified 40-Hour Hazwoper is a prerequisite
Training or equivalent workers
Project personnel training information is tracked in Appendix F of this Site-Wide HASP. This list will be
maintained and supplemented as required by work activities. Additional safety training will be conducted
including site orientation training, periodic safety meetings, and emergency response training as discussed
in the following sub-sections.
Project personnel will provide training and medical fitness for duty documentation to the CSO if required
for site work activities. The CSO shall make these documents available to the A&E Bien Hoa Contractor
LSECS. Where required for specific site activities, fitness for duty certification will include clearance for
the use of PPE and respiratory protection.
Before start of work, the CSO or A&E Bien Hoa Contractor LSECS will provide a site orientation briefing
to workers related to Project operations and Site-Wide HASP requirements. The briefing will include
review of (as applicable):
Monthly safety meetings are held by the A&E Bien Hoa Contractor LSECS for CSOs, team
supervisors/leads, where multiple work activities are being conducted at the same location. The LSECS
and/or A&E Bien Hoa Contractor HSO will conduct the meeting and discuss safety-related issues directed
toward supervisor responsibilities. Meetings are documented and attending personnel sign a “Safety
Meeting Attendance Roster” or equivalent form.
Inspections are coordinated by the CSO or A&E Bien Hoa Contractor LSECS with competent persons
completing the inspections. The CSO, LSECS, and/or supervisors will complete periodic safety inspections
of Project sites and work areas. Project Contractor quality control (QC) personnel, as part of their QC
responsibilities, will review and document safety observations. The CSO and A&E Bien Hoa Contractor
LSECS will complete daily safety inspections of work sites to identify and correct hazards and reports the
information on a “Safety Inspection Report” form and/or on the Daily QC Report.
Safety inspections will include work areas, equipment, work practices, and work procedures. Items that
do not comply with Site-Wide HASP requirements will be corrected immediately or in a timely manner
based on the classification of the hazard as imminent or non-imminent. In the case of unsafe or hazardous
machinery, the equipment or area will be “red-tagged” (shut down or removed) until the hazard has been
corrected. Employees are responsible for inspecting their work areas and equipment for unsafe or
hazardous conditions. Employees must correct all unsafe conditions and report them immediately to their
supervisor.
Injured Worker's
CSO LSECS COP CO/COR
Worker Supervisor
All incidents are required to be reported to the CSO and the A&E Bien Hoa LSECS as soon as possible
but not more than 24 hours afterwards. In addition, the LSECS must report all incidents to the A&E Bien
Hoa Contractor COP and HSO as soon as possible but not more than 12 hours afterwards. In addition
to the reporting requirements identified above, property damage, days away injuries, days away illnesses,
and restricted duty/transfer injuries are required to be reported. Every accident shall be thoroughly
investigated by the CSO and the findings of the investigation submitted along with appropriate corrective
actions to the A&E Bien Hoa Contractor LSECS in the prescribed format as soon as possible but no later
than five (5) working days following the accident. Corrective actions shall be implemented as soon as
reasonably possible. Immediate accident notification is required for: a fatal injury; a permanent total
disability; a permanent partial disability; the hospitalization of one or more people resulting from a single
occurrence; three or more individuals become ill or have a medical condition which is suspected to be
related to a site condition or a hazardous or toxic agent on the site; and property damage. The CSO, A&E
Bien Hoa Contractor COP, DCOP, HSO, and/or LSECS are responsible for notifying their CO and COR
of all incidents.
The USAID CO/COR and the A&E Bien Hoa Contractor LSECS must be notified immediately of any
incident that results in the hospitalization of any employees or a fatality. The A&E Bien Hoa Contractor
LSECS is responsible for notifying the A&E Bien Hoa Contractor COP and HSO as soon as possible but
no later than 8 hours after the accident requiring hospitalization. (Note: This notification includes weekend
days as 24-hour emergency reporting access is available). The A&E Bien Hoa Contractor HSO and LSECS
will conduct an immediate investigation, reporting findings to the A&E Bien Hoa Contractor COP. The
A&E Bien Hoa Contractor COP will act as the USAID interface during the investigation.
The resulting report to the A&E Bien Hoa COP, which will be sent to the USAID CO/COR, must include:
It is required that accidents be thoroughly investigated by the contractor and findings of the investigation
submitted along with appropriate corrective actions to their USAID CO and COR and, if required, GVN
in the prescribed format as soon as possible but no later than five (5) working days following the accident.
Corrective actions shall be implemented as soon as reasonably possible. Where required by USAID or
GVN, electronic or written reporting means shall be used by the A&E Bien Hoa Contractor to report all
accidents that involve injuries to employees or subcontractors that result in medical treatment beyond
first aid and damage to property and/or equipment.
The initial report must be prepared and submitted to the USAID CO and COR within 24 hours following
such accidents and include as much information as is available at the time of the report. The final written
report shall be prepared on the forms provided in Appendix A, and shall include:
The CSO, LSECS, and CM will then conduct a safety stand-down to debrief all site personnel, review
preventive measures and hazard mitigation, and discuss lessons learned.
The CSO will obtain a doctor's first report of injury for every injury or illness requiring medical treatment
and will immediately forward the report to the A&E Bien Hoa Contractor LSECS, COP, and HSO. An
injured worker is not allowed back to work until a return to work notice issued by the treating physician
is presented to the CSO. The CSO will provide a copy of the return to work notice to the A&E Bien Hoa
Contractor LSECS immediately. Any injured worker issued a work restriction will be under the direct
supervision of the CSO and will be assigned work activities within the restriction until a full duty status
clearance has been received.
For information purposes, the A&E Bien Hoa Contractor LSECS will record each injury or illness on the
OSHA Form No. 300 “Log of Work Related Injuries and Illnesses” and the OSHA Form 300A “Summary
of Work Related Injuries and Illnesses.” Posting of the OSHA 300 form is not required for injuries or
In accordance with Vietnam Ministry of Health “Guidelines for Occupational Health and Safety
Management” Circular 19/2016/TT-BYT, dated 30 June 2016, Chapter III Reporting, as a business
establishment, A&E Bien Hoa Contractor will submit the first 6-month report by July 5, 2020, with annual
reports by January 10,, 2021, in the form required by the GVN.
Plans that are not required at this time but are may be required due to addition or modification of work
activities will be added as required during the course of all activities at the Bien Hoa Airbase Area.
Required plans are presented in the following Sections.
• Operators of motor vehicles and heavy equipment, while on duty, shall not operate
vehicles for a continuous period of more than 10-hours in any 24-hour period;
DIOXIN REMEDIATION AT BIEN HOA AIRBASE AREA PROJECT
INITIAL SITE-WIDE HEALTH & SAFETY PLAN | 9-2
• No employee, while on duty, may operate a motor vehicle after being in a duty status for
more than 12-hours during any 24-hour period; and
• A minimum of eight (8) consecutive hours shall be provided for rest in each 24-hour
period.
The FMP shall identify affected workers, management responsibility, training, and the controls established
at the worksite.
• symptoms of fatigue,
• habits and actions the worker may take to avoid fatigue,
• actions workers should take if they observe fatigue in a co-worker, and
• controls in place to prevent fatigue.
Controls for fatigue shall include:
• a discussion of driving to and from work and any possible mitigation of driving as a factor of
fatigue,
• work scheduling (limit number of consecutive night shifts),
• rotating jobs to prevent repetitive work,
• breaks at critical times in the work cycle,
• control of environmental factors (heat, cold, use of PPE),
• buddy check-in for individuals working alone, and
• alternate transportation for lengthy commutes.
EVACUATION ALARM
A compressed air horn will be used to communicate the emergency situation to personnel. THREE
LONG BLASTS on the air horn shall signify an evacuation alarm. Personnel will be instructed to report
to the evacuation assembly location and await a head count by the CSO and/or A&E Bien Hoa
Contractor LSECS and SCPM (Table 9-3).
Nonessential personnel will be evacuated from the work area until the CSO determines that it is safe for
work to resume. Personnel will evacuate to a refuge area that has been designated by the CSO in the
initial site safety orientation or tailgate safety meeting. Typically, the on-site assembly area will be at a
parking area, and the off-site assembly area will be at a designated area upwind and outside of the entrance
point into the site. The CSO will notify the facility emergency contact and local fire, police, and/or
emergency medical services as necessary. The CSO and SCPM will complete a head count to make sure
that all site personnel are accounted for.
In the event of a large fire (beyond the immediate control of a small onsite fire extinguisher) the
following five steps will be followed:
FIGURE 9-1 VICINITY MAP OF DONG NAI INTERNATIONAL HOSPITAL AND EMERGENCY HOSPITAL
ROUTE:
Due to restrictions on the use of rented vehicles and A&E Bien Hoa Contractor staff driving in Vietnam,
a car and driver or emergency medical transportation will be used to transport injured workers to the
hospital. Contractors will state their arrangements for transportation to emergency facilities in the SHASP.
The CSO shall ride with a driver along the route to the emergency hospital before start of
fieldwork.
The presence of strong winds requires stoppage of affected work activities at elevated work locations
(e.g., towers, roofs, ladders, scaffolds, platforms) and stoppage of use of equipment whose safe operation
can be affected by high winds or lightning strike (i.e., drill rigs, man lifts, scissor lifts, cranes).
The presence of heavy rain during monsoon season (May through October/November) requires stoppage
of affected work activities where the heavy rain can create safety hazards due to limited visibility, wet
work surfaces, slippery equipment controls, increased electrical hazards, etc.
The presence of thunder requires stoppage of affected work activities where lightning presents an
increased safety hazard of electrocution. A determination shall be made as to the proximity to the
operation being performed. To determine the distance, once lightning is seen, count the number of
seconds until you hear the thunder. Divide number of seconds by five (5) to get the distance the lightning
is away from you. If lightning is 10-miles away or less, take shelter and remain there until 30 minutes after
seeing the last lighting flash or hearing the last thunder.
The occurrence of a typhoon, cyclone, or earthquake requires stoppage of affected work activities and
evacuation of personnel from confined spaces, waterfront areas, and buildings or structures of
questionable stability.
In case of work stoppage due to inclement weather conditions or other adverse environmental conditions,
work will not resume until an “All Clear” signal has been communicated by the CSO to affected personnel.
In case of work stoppage due to lightning, an “All Clear” will not be given until 30 minutes after last show
of lightning or sound of thunder.
In the case of severe weather conditions, emergency evacuation procedures will be established where
high winds, strong storms, cyclones, typhoons, and floods are a potential occurrence. The CSO and A&E
Bien Hoa Contractor LSECS monitor the local weather conditions continuously and advises the SCPM
when severe storm warnings are issued. When a severe weather warning is issued, the CSO and SCPM
take actions to secure the worksite. In the event of impending severe weather conditions, personnel are
advised of the hazard, and an evacuation order is issued by the CSO or A&E Bien Hoa Contractor LSECS.
All site personnel immediately evacuate the work area to a designated location (i.e., operations trailer,
hotel, vehicle). The CSO and the A&E Bien Hoa Contractor LSECS notifies the A&E Bien Hoa Contractor
COP and advises that all site personnel are evacuating the area. The CSO and A&E Bien Hoa Contractor
LSECS maintain contact with site personnel and provides the SCPM with periodic updates as to the
whereabouts of site personnel. Site personnel are to remain outside the evacuated area at a designated
location until notified by the CSO and A&E Bien Hoa Contractor LSECS that it is safe to return to the
work area. After severe weather conditions have passed, the SCPM, CSO, and A&E Bien Hoa Contractor
LSECS will mobilize to the worksite, inspect the condition and security of the site, and make any necessary
response actions to correct unacceptable conditions.
Storage areas will be diked around the containers and designed to hold the entire volume of the material
stored, with added volume in the event of rainfall. Drums and containers must be placed in the diked area
in such a manner that, if the container is breached, the contents will spill into the diked area and not
outside the perimeter.
Cleanup methods for each stored material will be determined based on the chemical information on the
SDS for the compound. Compatible absorbent materials shall be stored nearby to assist in preventing the
spread of the spill.
Containers shall be segregated according to the chemical classification on the SDS. For instance,
flammables will be stored with flammables and segregated from oxidizers by the distances recommended
on the SDS.
As with all incidents, a spill will be reported to the CSO and LSECS as soon as it occurs or is discovered.
Emergency medical assistance will be called and will be informed of the following:
A medical emergency involving chemical exposure will require communication between the CSO, A&E
Bien Hoa Contractor LSECS, and emergency hospital personnel regarding chemicals involved. The CSO
will designate an individual to accompany or follow the victim to the emergency hospital to assist with any
needs that arise and to report back regarding the victim’s status. Follow-up reporting to the Vietnam
Ministry of Health and responsible medical facilities will be required in the event of chemical exposure.
Refer to Guidelines for Occupational Health and Safety Management, No. 19/2016/TT-BYT for reporting
forms and requirements.
First aid kits are required on the work site, with contents meeting the requirements of American National
Standards Institute (ANSI) Z308.1 or comparable local standard. There will be a minimum of one first aid
kit for every 25 (or fewer) employees on the site. The contents of the kit will be supplemented based on
the work tasks and the site hazard evaluations. As supplies are used for treatment, they will be replaced
immediately. First aid kit inspections will be conducted at least monthly.
Refer to Guidelines for Occupational Health and Safety Management, No. 19/2016/TT-BYT for first aid
personnel, emergency response team personnel, first aid kit requirements, and on-site medical treatment
facility requirements.
9.3.1 HOUSEKEEPING
General housekeeping procedures include:
• Work areas and means of access must be maintained orderly and safe;
• Personnel and equipment will be provided to comply with housekeeping requirements;
• Daily inspections will be made of work areas for adequate housekeeping and findings
recorded on daily inspection reports;
• Stairways, passageways, and access ways must be kept free of materials, supplies, and
obstructions at all times;
• All work areas will have sufficient light to ensure worker safety;
• Loose or light material must not be placed on roofs or floors that are not closed in, unless
properly secured;
• Tools, material, extension cords, or debris must not cause tripping or other hazards;
• Tools, material, and debris that could be displaced or fall must be secured;
• Debris must be cleared from work areas and access ways in and around the exterior of
buildings and structures;
• Storage areas must be kept free from combustible material accumulation;
• Liquids, particularly combustible or flammable liquids, must not be allowed to accumulate on
floors, walls, etc.; and
• All spills of combustible or flammable liquids must be immediately cleaned up.
Significantly soiled contaminated waste materials (including PPE and disposable field equipment) will be
properly stored in appropriate containers and sampled for characterization. The potentially contaminated
waste material will be handled as investigation-derived waste (IDW) until it is characterized as non-
Cellular telephones will be used for site and emergency communications. The CSO and A&E Bien Hoa
Contractor LSECS will maintain an “Emergency Contact List” (see Table 9-2). The CSO is responsible
for determining the route to the emergency hospital before the start of field operations and will check
the route with a driver. The Emergency Hospital and Route map will be provided and posted on the site
in several locations. The CSO will establish emergency communication procedures before site work and
will communicate this information to site personnel during site orientation briefings and safety meetings.
Fences will be used to designate various work areas and shall be placed and erected with the approval of
Bien Hoa Airbase command. Adequate ingress/egress will be provided for use during emergencies. For
If nighttime operations are to be conducted, adequate portable lighting is to be provided by the contractor.
Locations of such fixtures are to be included on the site layout plan and moved or changed as needed.
Site maps indicating all temporary construction will clearly indicate the locations of all features and fixtures
and shall be updated as they are moved or removed from the site.
• Eye protection – goggles or safety glasses with side shields and/or full-face shield where
required;
• Hearing protection – in-ear disposable earplugs, changed at least every day or when soiled;
• Head protection – hard hat as needed or USAID-required;
• Protective footwear – hard-toed boots, ankle high, with overboots or boot covers for wet
conditions;
• High-visibility vests;
• Respiratory protection – full- or half-face respirators with appropriate cartridges or
disposable dust masks worn with full-face shield where required;
• Hand protection – leather work gloves or, where required, chemical protective outer and
inner gloves protected by leather work gloves;
• Personal flotation devices to be worn in areas where work is conducted adjacent to
waterways; and
• Chemical protective disposable coveralls.
Specific chemical protective boots, gloves, and coveralls may be recommended by the A&E Bien Hoa
Contractor LSECS based on the level of contamination in each work area. Recommended procedures for
donning and doffing PPE are included in Appendix K. The use of PPE has implications for heat stress
which is discussion in Section 9.12.
9.8.2.2 MONITORING
In most instances, high noise levels at the Project site will be caused by heavy equipment, such as drill rigs
and excavators, or sources associated with the Project site, such as aircraft and vehicles. When noise
exposures at a work site are suspected to equal or exceed an 8-hour TWA of 85 dBA resulting from
noise sources not previously measured, the CSO will conduct an evaluation to characterize the noise
sources and exposure levels.
A portable sound-level meter will be used to survey the Project site work areas and to estimate noise
exposure when the noise levels are relatively constant. Monitoring for occupational noise exposure will
be conducted for each representative task or job position that the CSO or LSECS deems necessary. All
noise measurements will be taken in the hearing zone of the individual. The hearing zone is an area within
a radius not to exceed 12 inches from the ear closest or in most direct proximity to the noise source.
The LSECS will communicate recommended hearing conservation measures to USAID, who will
implement protective measures as required.
In some cases, such as short-term activities, the CSO may forego actual noise level measurements and
use a simple rule-of-thumb test to estimate if noise levels are in excess of 85 dBA. The test requires the
CSO to determine how loud it is necessary to speak to be heard at arm’s length from another person. If
the CSO must raise the voice to be heard, average noise levels likely exceed 85 dBA.
Many varieties of spiders are present in Vietnam, including the Giant Golden Orb, Yellow Sac, Grass
Cross, Jumping, and Tarantula. While their bites are painful and may require first aid and monitoring, none
are considered extremely hazardous.
The Vietnamese Giant Centipede is a poisonous, aggressive arachnid, which grows up to 20 centimeters
in length. One death has been reported in the Pacific as a result of a centipede sting to the head. Although
not normally a medical emergency, their sting is extremely painful and immediate treatment is required.
9.9.2.1.5 Mosquitoes
• Zika Virus
o Causes severe birth defects and diseases in infants born to pregnant women infected with
the virus. Pregnant participants should avoid travel to Vietnam.
o No known treatment or immunization.
• Dengue
o Peak transmission during the rainy season.
o Flu-like symptoms, high fever, pain behind the eyes, muscle, joint, and bone pain, severe
headache, and red rash.
o No known treatment or immunization.
• Chikungunya
o Carriers typically found in and around urban and suburban dwellings.
o Peak transmission during the rainy season.
o Sudden onset high fever, severe muscle and joint pain, headache, fatigue, nausea, vomiting,
and rash. Joint pain can last for several months.
• Assume that every snake you see is poisonous. If you see a snake, avoid it.
• Do not walk through tall vegetation where you cannot see your feet or the path you are
walking.
• Do not reach down into vegetation or any place where you cannot see your hands.
• Be watchful of overhanging vegetation and do not brush against it. Many vipers live in trees and
will drop onto anyone standing or walking under overhanging limbs or vines.
• If you are bitten by any kind of snake, request emergency medical assistance IMMEDIATELY.
• If you are bitten, do not attempt to catch the snake. Request assistance from another person on
the site to identify the species, IF POSSIBLE.
• If you encounter a snake, note the location on site maps for future reference by anyone
performing site activities.
Anyone who has been bitten by a snake must be transported immediately to the nearest hospital facility
while first aid measures are administered:
• Move the victim away from the area where the bite occurred. If the snake is still attached, use a
stick or other tool – NOT hands – to make it detach.
• Remove tight clothing or jewelry from near the bite since severe swelling can occur.
• Reassure the victim.
• Position victim so the bite is at or below heart level.
• Completely immobilize the victim. If bitten on an extremity, immobilize the limb with a splint.
• Clean the wound but don’t flush with water. Apply a clean dry dressing to the bite to keep it
covered.
• Pain near the bite site may be severe, but do not administer anything by mouth.
• Vomiting may occur so monitor the victim and roll them to their left side to prevent choking.
• Closely monitor airway and breathing and administer CPR if needed.
• DO NOT:
o Apply a tourniquet.
Treating medical personnel may prescribe acetaminophen (Paracetamol or Tylenol) for pain, which can
be extreme.
Parasites can be transmitted by simply touching an infected animal. Rabies can be transmitted by
transmission of saliva from the infected animal by biting or licking, or by being scratched by the animal’s
claws or nails.
• Do not approach or touch any animals that approach you. Contact with the animals should be
avoided.
• Report the presence of the animal to the CSO whether or not symptoms of rabies are present.
• Note the location of any animals on site maps for future reference by anyone performing site
activities.
• Do not feed or offer water to any animals on site.
• If a dead animal is found on the site, do not touch it, as it could be infested with parasites.
• Avoid animal droppings.
Anyone who has been bitten or scratched by an animal on site must seek immediate medical attention.
Do not attempt to capture the animal. Report the incident to Vietnamese military official present at the
Airbase.
If visible dust is generated during site activities, Project Contractors responsible for these activities must
implement response actions including engineering controls (wetting of soil to prevent dust), safe work
practices (enhanced precautions to avoid contact with contaminated soils and dust), upgrade or
downgrade in PPE, work stoppage, emergency evacuation, and additional evaluation by the CSO. Response
actions may also include collecting and analyzing samples to monitor the dust and air conditions.
Personal protection equipment is divided into four categories based on the degree of protection
afforded. The four levels of protection (A, B, C, and D) are based on the widely used USEPA
Levels, which are described in Appendix B of the Hazwoper standard (29 CFR 1910.120 and 8 CCR
5192). Level A provides the highest level of protection. Combinations of PPE other than those
described for Levels A, B, C, and D protection may be more appropriate and may be used to
provide the proper level of protection.
The situations requiring the four levels of protections and the PPE for each level of protection are
listed below. An asterisk (*) behind a listed item indicates that its use is optional for that level of
protection.
A. The hazardous substance has been identified and requires the highest level of protection
for skin, eyes, and the respiratory system based on either
• the measured (or potential for) high concentration of atmospheric vapors, gases, or
particulates; or
• the site operations and work functions involve a high potential for splash,
immersion, or exposure to unexpected vapors, gases, or particulates of materials
that are harmful to skin or capable of being absorbed through the skin.
B. Substances with a high degree of hazard to the skin are known or suspected to be present,
and skin contact is possible; or
C. Operations are being conducted in confined, poorly ventilated areas, and the absence of
conditions requiring Level A have not yet been determined.
A. The type and atmospheric concentration of substances have been identified and require the
highest level of respiratory protection, but less skin protection; and/or
B. The atmosphere contains less than 19.5% oxygen; or
C. The presence of incompletely identified vapors or gases is indicated by a direct-reading
organic vapor detection instrument, but vapors and gases are not suspected of containing
high levels of chemicals harmful to skin or capable of being absorbed through the skin.
A. The atmospheric contaminants, liquid splashes, or other direct contact will not adversely
affect or be absorbed through any exposed skin;
• Coveralls,
• Gloves,*
• Boots/shoes, chemical-resistant steel toe and shank;
• Boots, outer, chemical-resistant (disposable);*
• Safety glasses or chemical splash goggles;*
• Hard hat,*
• Escape mask,* and
• Face shield.*
Initial phases of work activities must be closely monitored by the CSO, because some workers may not
be acclimatized to hot conditions. The CSO will try to identify personnel who are more susceptible to
heat exposure and ensure that they are consuming enough fluids, taking adequate rest breaks, and
monitoring themselves for signs of heat-related illness.
Workers are responsible for observing each other and themselves for development of heat stress
symptoms. Personnel will be encouraged to drink a minimum of four liters of water or electrolyte solution
per person per day - even if not thirsty - to prevent dehydration. Adequate shaded areas and cool-down
facilities will be provided to protect personnel from direct sun exposure. Sufficient breaks will be provided
so that personnel can remove protective clothing and cool down. Work/Rest regimens will be adjusted
as required to avoid heat stress.
On exceptionally hot days, supervisors and site workers should be aware of the potential for heat stress
in themselves and coworkers. Warning signs and symptoms include:
9.12.2.1 TRAINING
Training is an important component of heat stress prevention. All employees will receive training on the
policies and procedures outlined to prevent heat-related illness prior to being assigned to work under hot
weather conditions that create a danger to employee safety. Employees are instructed to recognize and
treat heat-related illnesses during annual health and safety refresher courses and in the site-specific
training.
• Ensuring that potable water is available in the volume required to ensure worker safety: a
minimum of one liter of water for each employee, for each hour of the work shift;
• Taking positive steps to ensure all employees have access to and drink plenty of fluids;
• Ensuring that frequent breaks in shaded areas are scheduled so overheating does not occur;
TABLE 9-6. SCREENING CRITERIA FOR TLV AND ACTION LIMIT FOR HEAT STRESS EXPOSURE
Allocation
of Work in
a Cycle of TLV® (WBGT values in °C) Action Limit (WBGT values in °C)
Work and
Recovery
Light Moderate Heavy Very Light Moderate Heavy Very
Heavy Heavy
75-100% 31.0 28.0 -- -- 28.0 25.0 -- --
50-75% 31.0 29.0 27.5 -- 28.5 26.0 24.0 --
25-50% 32.0 30.0 29 28.0 29.5 27.0 25.5 24.5
0-25% 32.5 31.5 30.5 30.0 30.0 29.0 28.0 27.0
Source:
ACGIH “2018 TLVs® and BEIs® Based on the Documentation of the Threshold Limit Values for Chemical Substances and Physical Agents & Biological
Exposure Indices”, 2018.
WetBulb Globe Temperature (WBGT) Values are expressed to the nearest 0.5°C
• Heart Rate: Count the radial (wrist) pulse during a 30-second period prior to the start of
work (to establish the base rate) and as early as possible in each rest period; if heart rate
exceeds 110 beats per minute at the beginning of the rest period, shorten the next work
• Employees (on foot) must wear high visibility safety vests (orange, strong yellow-green, or
fluorescent versions of these colors). During rainy weather, employees exposed to the
hazard of vehicular traffic may wear orange, strong yellow-green, or yellow rainwear.
• During hours of darkness, employees (on foot) must wear reflectorized warning garments
with a minimum of one horizontal stripe around the torso that is visible at a minimum of
1,000 feet.
• Employees (on foot) must be aware of traffic patterns to avoid vehicles and moving
equipment.
• Employees (on foot) must maintain eye contact with nearby equipment operators when in
the vicinity of moving vehicles.
• Use traffic signs, barricades, flashers, delineators, traffic cones, caution tape, or flagmen, as
needed, around work areas with vehicle or equipment traffic.
• Flaggers must be utilized at locations where barricades and warning signs cannot control
the moving traffic. When flaggers are used, they must be placed in relation to the
equipment or operation so as to give effective warning.
• The CPM will establish vehicle and equipment traffic patterns to be used. Traffic haul routes
will be identified during daily safety meetings and will take into account times and locations
of concern for vehicle, heavy equipment, and pedestrian traffic exposures in the work area.
• Vehicle and heavy equipment traffic control patterns, other control measures, and times of
operations will be communicated to Project and Airbase personnel.
The Project Contractor Fire Prevention Plan for the work site will be developed to include:
Fire Hazards
• Combustible Materials
• Wood, including construction materials
• Paper
• Brush and trees removed during site clearing
• Flammable materials
• Fuel for vehicles and heavy equipment
• Compressed gases
• Lubricants
• Paint
• Adhesives
• Trash
• Oxidizers
• Oxygen for welding
• Bleach
• Acids
• Peroxide
Potential Ignition Sources
• The CSO and A&E Bien Hoa Contractor LSECS are responsible for contacting the Bien Hoa
Airbase point of contact and local municipal fire service to advise them of site activities, solicit
their support, and to offer an onsite orientation to the fire-safety aspects of the Project work.
• The CSO, A&E Bien Hoa Contractor CM, and LSECS are responsible for fuel source hazard
control.
Fire Prevention Safe Work Practices
• Smoking is allowed only in designated smoking areas as permitted by Bien Hoa Airbase
personnel.
• Hot work permit required for any spark-producing operations or open flame. Fire watch is
required during hot work and 60 minutes after.
• Fires and open flame devices shall not be left unattended.
• Sources of ignition shall be prohibited within 20 meters of operations with a potential fire
hazard.
• Fire hazard areas shall be conspicuously and legibly posted: “No Smoking, Matches or Open
Flame.”
• Smoking is prohibited in areas where flammable, combustible, or oxidizing materials are
stored.
• If permitted by Bien Hoa Airbase personnel, portable multipurpose fire extinguishers may be
maintained by the facility on site, kept fully charged, inspected monthly, and serviced annually.
Response to Fire Incident
The CSO will consult with the Bien Hoa Airbase Emergency Responders and local municipal fire
department before initiating site activities regarding response to Project site fire incidents.
In the event of a large fire (beyond the immediate control of a small onsite fire extinguisher):
6. Site alarm will be sounded,
7. Work will stop,
8. Personnel will immediately evacuate and assemble at a predetermined upwind site location,
9. Emergency responders will be called, and
10. Personnel will not re-enter the fire area until it is cleared by emergency responders and the
CSO.
The following standard housekeeping rules related to fire prevention must be implemented:
• Project sites must be kept free from combustible material accumulation;
• Trash and other combustible matter must be kept away from areas where combustible or
flammable liquids are stored, handled, or processed;
• Combustible or flammable liquids must not be allowed to accumulate on floors, walls, etc.;
and
• All spills of combustible or flammable liquids must be immediately and properly cleaned up
and reported to the CSO and A&E Bien Hoa Contractor LSECS.
Fire Extinguisher Training
If Bien Hoa Airbase requirements permit or mandate, the CSO shall instruct site personnel on the
basics of fire extinguisher use, including:
• fire classifications;
• extinguisher types;
• inspection, servicing, and proper use; and
• the PASS system for fire extinguisher use defined below.
o “P” Pull the pin
o “A” Aim the nozzle at the base of the flames
o “S” Squeeze the trigger
o “S” Sweep at the base of the flames.
The GFCI device shall be calibrated to trip within the threshold values of 5 milliamperes (mA) +/- 1 mA
(as specified in UL Standard 943). GFCI devices shall be tested before initial use and before use after
modification.
Receptacle outlets that are part of the permanent wiring of the building or structure and are used for
temporary electric power (including portable generators), shall use a portable GFCI if the receptacle
outlets are not already GFCI protected. The portable GFCI shall be as near as practicable to the receptacle
outlet.
Electric tool circuits that are hard-wired directly to an electrical source of power shall be protected by a
GFCI-type circuit breaker.
Exception: In areas of the site where conditions of maintenance and supervision ensure that only qualified
personnel are involved, an AEGCP shall be permitted for only those receptacle outlets used to supply
equipment that would create a greater hazard if power was interrupted or having a design that is not
compatible with GFCI protection. See Appendix I for details of the AEGCP.
GFCIs may be sensitive to some equipment (such as concrete vibrators), or unavailable for the voltage
and current rating. In these instances, an AEGCP is acceptable in lieu of GFCIs if the exception is
documented on an AHA and contains the following:
The following situations are exempt from the requirements of this lockout/tagout program:
• Cord- and plug-connected electrical equipment under sole control of the employee performing
the service or maintenance.
• Installation of power by a utilities service.
9.16.1 DEFINITIONS
Blocking or disconnecting: The physical blocking or disconnecting of de-energized mechanical,
pneumatic, hydraulic, or steam equipment to prevent trapping, crushing, or otherwise injuring an
employee; includes brackets and stands for raised equipment and metal disks that are placed in a pipe to
ensure that no air, steam, or other substance will pass through that point.
Capable of being locked out: An energy isolating device is capable of being locked out if it has a hasp
or other means of attachment to which, or through which, a lock can be affixed, or it has a locking
mechanism built into it. Other energy isolating devices are capable of being locked out, if lockout can be
achieved without the need to dismantle, rebuild, or replace the energy isolating device or permanently
alter its energy control capability.
Place a sign or sticker—"LOCKOUT HERE"— at the disconnecting means to help direct workers
to correct lockout devices. After surveying the operation, additional and more practical means may
be installed. In complicated operations or systems, schematics of only the disconnecting means may
need to be drawn up.
• Commonly, the main disconnect switch has one opening where a lock can be placed.
• If more than one employee works on the equipment, a lockout adaptor suitable for the
installation of several locks must be used, enabling all workers to lock out the machine with
their individual locks.
• If the switches are in a metal box, the box itself must be locked out.
• If a fuse was removed in order to de-energize the equipment, the fuse box must be locked.
• If the controls are in a metal-covered box, a common hasp can be welded or riveted to the
door, along with a lock staple. Then the switch can be "opened" and the door closed and
padlocked. Fuse boxes can also be locked in this way.
• Machines activated by compressed air or steam will have valves that control movement. These
valves will need not only to be locked out, but also bled to release any back pressure.
9.16.3.1 LOCKS
Each worker must have their own lock and the only key to that lock. The lock must be substantial
and durable, and must have the name of the employee on it. In addition, locks can be color-coded
to indicate different shifts or types of crafts. When more than one worker is servicing a piece of
equipment that must be locked out, a lockout adaptor must be used which allows all the workers
9.16.3.2 TAGS
Do not use tags alone unless the requirements in section 9.16.4 are met. Tags are used in addition
to locks and must state the:
Tagout devices shall be capable of enduring at least 50 pounds of pull, and shall be a non-reusable
type. Tagout devices shall be constructed so exposure to weather conditions (or corrosive
environment, when applicable) will not cause the tag to deteriorate or the message to become
illegible.
9.16.3.3 BLOCKS
Suitable blocks are another important safety device for making a piece of equipment safe to be
repaired or serviced. Blocks must be placed under raised dies, lifts, or any equipment that might
inadvertently move by sliding, falling, or rolling.
Blocks, special brackets, or special stands such as those commonly used under raised vehicles, must
be available and always used. Another form of blocking is the placement of a blind. A blind is a disk
of metal placed in a pipe to ensure that no air, steam, or other substance will pass through that point
if the system is accidentally activated.
Before installing blinds or blocks, bleed down steam, air, or hydraulic lines to void any pressure.
Coiled springs, spring-loaded devices, or suspended loads must also be released so that their stored
energy will not result in inadvertent movement.
When tagout only is used, Project personnel must demonstrate that the level of safety for the
tagout system is equivalent to the level of safety obtained by using a lockout system. Additional
means may be necessary such as removal of an isolating circuit element, blocking of a controlling
switch, opening of an extra disconnecting device, or the removal of a valve handle to reduce the
likelihood of inadvertent energization.
Equipment design and performance limitations may dictate that effective alternative worker
protection be provided when the established lockout procedure is not feasible. If machinery must
be capable of movement in order to perform a maintenance task, such as a cleaning operation,
workers can use extension tools—extended swabs, brushes, scrapers—to protect themselves from
Lockout/Tagout Permits must be signed by the CPM before a lockout is begun. A signed permit is
also required if maintenance work is being performed by a subcontractor who may be familiar with
the particular piece of equipment being serviced, but who will not know about the site's overall
operation. The Lockout/Tagout Permit is site-specific and equipment-specific; the permit must
include the equipment to be locked out, the job description, and a checklist of possible hazardous
energy sources and the applicable control measures.
Safe work practices and procedures for lockout/tagout are discussed below.
• Be knowledgeable as to which switch, valve, or other energy isolating devices apply to the
equipment being locked out (more than one energy source [electrical, mechanical, or others]
may be involved);
• Check with the CPM if there are any questionable identification of sources;
• Receive job authorization prior to performing lockout; and
• Be issued a suitable lock (or locks); the lock must have the individual employee's name and
other identification on it and the employee must have the only key to the lock.
Equipment shut-down
To properly shut-down equipment for servicing or maintenance, the following procedures must be
followed:
• Operate the switch, valve, or other energy isolating devices so that the energy source(s) (e.g.
electrical, mechanical, hydraulic) is disconnected or isolated from the equipment.
• All energy sources that could activate the machine must be locked out.
• Each person who will be working on the machinery must put a lock on the machine's lockout
device(s). Each lock must remain on the machine until the work is completed. Only the
worker who placed the lock should remove his/her lock.
Clearance
• The main valve or main electrical disconnect must be tested to be sure that the power to
the machine is off.
• After ensuring that no personnel are exposed and as a check on having disconnected the
energy sources, operate the push button or other normal operating controls to make certain
the equipment will not operate.
• Electrical circuits must be checked by qualified persons with proper and calibrated electrical
testing equipment. An electrical failure could energize the equipment, even if the switch is in
the off position. Stored energy in electrical capacitators must be safely discharged.
• CAUTION: Return disconnects and operating controls to the off or neutral position after
each test.
• Check the machine or equipment and the immediate area around the machine to ensure that
nonessential items have been removed and that the machine or equipment components are
operationally intact.
• Check the work area to ensure that all employees have been safely positioned or removed
from the area.
• Verify that the controls are in neutral.
• Repair or replace defective guards before removing lockouts.
• Review of procedures in use to ensure that the correct procedures are employed and the
requirements of this lockout/tagout program are being followed.
• Review of the authorized employee’s responsibilities under the energy control program.
• Discussion of the limitations of tagout devices, when used.
The CSO and A&E Bien Hoa Contractor LSECS will document the compliance inspections and
identify the machine or equipment on which the energy control procedure was being utilized, the
date of the inspection, the employees included in the inspection, and the person performing the
inspection.
9.16.6 TRAINING
Site-specific lockout/tagout training must be conducted prior to beginning work if lockout/tagout is
anticipated. Appropriate Project personnel and subcontractors must receive lockout/tagout training
and follow the procedures established in this HASP. Training for lockout must cover the following
topics:
Each Project Contractor performing excavation and trenching to a depth of 4 feet (1.25 meters) or more
is responsible for an Excavation and Trenching Plan which includes descriptions of the activities to be
performed, safety procedures to be followed, and methods to prevent injury as a result of excavation
collapse.
The following sections describe the information that each contractor shall include in their plan.
9.17.1 DEFINITIONS
Benching (Benching system): A method of protecting employees from cave-ins by excavating the sides
of an excavation to form one or a series of horizontal levels or steps, usually with vertical or near-vertical
surfaces between levels.
Competent Person: A person who is capable of identifying existing and predictable hazards in the
surroundings, or working conditions which are unsanitary, hazardous, or dangerous to employees, and
who has authorization to take prompt corrective measures to eliminate them.
Excavation: Any man-made cut, cavity, trench, or depression in an earth surface formed by earth
removal.
Shield (Shield system): A structure that is able to withstand the forces imposed on it by a cave-in and
thereby protect employees within the structure. Shields can be permanent structures or can be designed
to be portable and moved along as work progresses. Additionally, shields can be either premanufactured
or job-built. Shields used in trenches are usually referred to as "trench boxes" or "trench shields."
Sloping (Sloping system): A method of protecting employees from cave-ins by excavating to form sides
of an excavation that are inclined away from the excavation so as to prevent cave-ins. The angle of incline
required to prevent a cave-in varies with differences in such factors as the soil type, environmental
conditions of exposure, and application of surcharge loads.
Stable rock: Natural solid mineral material that can be excavated with vertical sides and will remain
intact while exposed. Unstable rock is considered to be stable when the rock material on the side or sides
of the excavation is secured against caving-in or movement by rock bolts or by another protective system
that has been designed by a registered professional engineer.
Trench: A narrow excavation (in relation to its length) that is usually deeper than it is wide but less than
15 feet wide.
Type A Soil: Cohesive soil with an unconfined, compressive strength of 1.5 ton per square foot (tsf) or
greater.
Type B Soil: Cohesive soil with an unconfined compressive strength greater than 0.5 tsf but less than
1.5 tsf.
Type C Soil: Cohesive soil with an unconfined compressive strength of 0.5 tsf or less.
Underground Utilities: Any buried service which could be encountered during excavation activities,
including (but not limited to): water; sewer; storm drainage; electric; telephone; natural gas; steam; and
liquid petroleum fuel.
Contractor is responsible for having all underground utilities accurately located by Bien Hoa Airbase
personnel or by a local underground utilities locator service. Contractor shall notify the owners of
underground utilities at least 48 hours in advance of excavation activities.
The contractor shall provide marking protocols to A&E Bien Hoa Contractor, including:
9.17.5.1 SUPERVISION
The designated Competent Person must provide on-site supervision during excavation activities. The
Competent Person must examine the excavation prior to work in the excavation and document using the
“Daily Excavation Safety Checklist” in Appendix A.
Inspections shall also be made after every rainstorm or other hazard-increasing occurrence. These
inspections are only required when employee exposure can be reasonably anticipated.
Where the Competent Person finds evidence of a situation that could result in a possible cave-in,
indications of failure of protective systems, hazardous atmospheres, or other hazardous conditions,
exposed employees shall be removed from the hazardous area until the necessary precautions have been
taken to ensure their safety.
If water is controlled or prevented from accumulating in an excavation by the use of water removal
equipment, the Competent Person shall monitor water removal equipment and operations to ensure
proper operation.
If water is controlled or prevented from accumulating in an excavation by the use of water removal
equipment, the Competent Person shall monitor water removal equipment and operations to ensure
proper operation.
9.17.10.1 SLOPING
Sloping is a method of protecting employees from cave-ins by excavating to form sides of an excavation
that are inclined away from the excavation so as to prevent cave-ins. The angle of incline required to
prevent a cave-in varies with differences in such factors as the soil type, environmental conditions of
exposure, and application of surcharge loads. Bien Hoa Airbase or local regulatory requirements shall be
referenced for detailed information on sloping protective systems requirements.
In general, maximum allowable sloping when used as an excavation protection system in excavations less
than 20 feet deep shall be as follows (Table 9-8).
9.17.12 TRAINING
Training for excavation sites includes excavation-specific training and site safety meetings.
• Bien Hoa Airbase or local regulatory requirements for trenching and excavation
• Excavation safety hazards
• Soil classifications
• Protective systems for excavation safety
• Duties and authority/responsibility of the Competent Person
9.17.12.2 SAFETY MEETINGS
A site orientation meeting shall be conducted and documented by the CSO for site personnel before site
work begins and shall involve a review of the USAID-approved Project Contractor SHASP. New site
personnel arriving after the initial site orientation briefing shall also receive orientation prior to fieldwork.
The CSO or a designee shall attend the orientation training to answer questions and offer support.
Daily safety meetings (tailgate meetings) shall be conducted and documented by the contractor safety
representative at the start of each workday to emphasize safety for all employees. Daily meetings shall be
documented in the “Daily Tailgate Safety Meeting Form” in Appendix A.
Site operations at the Bien Hoa Airbase Area addressed in this Site-Wide HASP will be conducted in areas
known to be contaminated with varying levels of dioxin and arsenic. The Project requires development
and implementation of an activity-specific SHASP that shall be incorporated into the Site-Wide HASP as
an annex. The minimum requirements of the SHASP are shown in Table 9-9.
Each Project Contractor at the site will be required to submit their SHASP for review of compliance with
the Site-Wide HASP by the A&E Bien Hoa Contractor LSECS, HSO, and COP. The USAID CO and COR
will provide final approval of the SHASP PRIOR TO commencement of work activities. Sufficient time should
be allowed for the review and approval process.
Before participation in the medical surveillance program, medical surveillance program orientation training
must be provided to all participants including Level 1 and Level 2 workers. Medical surveillance orientation
training must also be provided to workers that will be on site during intrusive and/or remedial treatment
operation activities for less than 30 days (8 hours per day) per year. Visitors to the site will not be required
to receive the medical surveillance program orientation training.
• Prior to assignment at the site when intrusive activities have begun (baseline physical and
testing);
• At least once every 12 months;
• At termination of employment at the site;
• As soon as possible if employee develops signs or symptoms of exposure;
• After any worksite injury;
• After exposure during an emergency; or
• At more frequent times if determined necessary by the examining occupational health
physician.
The requirements listed above are the minimum required frequency of examinations. Some site activities
may have higher risks for exposure and warrant more frequent examinations. Project Contractors shall
determine the appropriate frequency of examinations for their contract activities and include it in their
contract-specific medical surveillance program.
• Whether the employee has any medical condition that would increase the risk of health
impairment due to
o Hazardous waste handling or exposure,
o Conditions experienced in an emergency,
o Use of a respirator for a regular work shift, or
o Use of impermeable PPE for a regular work shift.
• Whether the employee is above the Project dioxin blood serum action limit,
• Any recommended limitations for work assignments, and
• Statement that the employee has been informed of the result of testing and of any
conditions which require further investigation.
Specific results of testing or diagnoses shall not be disclosed to anyone but the employee. The dioxin
blood serum results will be anonymously compiled and maintained by USAID throughout the duration of
the Project. Identifying information related to the dioxin blood serum results will only be shared with the
examining occupational health physician and employee.
Since there is no requirement for the use of PPE or respiratory protection, employees examined under
Level 2 shall not be required to produce a written opinion from the attending physician/nurse practitioner.
However, the examining occupational health physician will review the analysis and provide results as stated
above.
The primary source of dioxin at the Bien Hoa Airbase Area is dioxin-contaminated soils and sediments
from past handling, storage, and disposal of Agent Orange and other herbicide compounds. The primary
dioxin congener associated with Agent Orange is 2,3,7,8-TCDD. Dioxin causes health effects in humans
including chloracne, birth defects, weakened immune systems, kidney defects, increased miscarriage rates,
altered hormone levels, reduced sperm production, and cancer.
Dioxin is present at the Bien Hoa Airbase Area in soil, sediment, and surface water. Although not water
soluble or volatile, dioxin will attach to soil which becomes airborne as respirable dust, and in surface
water as suspended solids. Dioxin, whether from Agent Orange or other sources, is also found in food
sources, primarily fish, seafood, meat, and dairy products.
For serum dioxin levels, one source of reference-based values is the National Health and Nutrition
Examination Survey (NHANES) study (Centers for Disease Control and Prevention [CDC] 2019). For
the NHANES study, serum dioxin samples were collected from individuals in the general U.S. population
for six (6) different 2-year sampling periods, 1999/2000, 2001/2002, 2003/2004, 2005/2006, 2007/2008,
and 2009/2010. For the first three sampling periods, individual samples were analyzed and for the last
three, the samples for eight (8) individuals from the same age/gender/ethnicity category were pooled and
analyzed. In general, the 95th percentile calculated using the data from any of these sampling periods
represent the upper bound of serum dioxin levels in the general population for the time period that was
sampled.
The CDC (2019) report presents 95th percentiles for only the individual congeners for the 1999/2000,
2001/2001, and 2003/2004 sampling periods and not for the TEQ values. Also, for the periods that
analyzed pooled samples, 2005/2006, 2007/2008, and 2009/2010, the CDC (2019) only presents the
weighted average and unadjusted standard deviations for the individual congeners and not the 95th
percentiles. The 95th percentiles are not calculated for the pooled samples due to the complexity of the
statistical methods involved. However, other researchers have published the 95th percentile TEQ values
for adults older than 20 years of age for the 1999/2000, 2001/2002, and 2003/2004 sampling periods
(Lakind et al. 2009) and for the 2005/2006 and 2007/2008 sampling periods (Bichteler et al. 2017) using
the same data that are summarized in the CDC (2019) report. The TEQ serum lipid concentrations for
the 1999/2000, 2001/2002, and 2003/2004 sampling periods are 27.9, 44.5, and 30.6 picograms per gram
(pg/g) lipid, respectively, and for the 2005/2006 and 2007/2008 sampling periods are 40.2 and 39.9,
respectively.
Health-based values for human serum have been derived by Aylward et al. (2008) based on the Joint Food
and Agriculture Organization/World Health Organization Expert Committee on Food Additives (JECFA)
tolerable daily intake (TDI) of 2.3 picograms per kilograms per day (pg/kg-day) in TEQ, which is based on
adverse effects on the reproductive tracts of prenatally-exposed male rats (Faqi, Dalsenter et al. 1998,
Ohsako, Miyabara et al. 2001, JECFA 2002). Alyward et al. (2008) derived human serum values based on
this TDI that ranged from 40-70 TEQ pg/g lipid, depending on the assumptions used to extrapolate the
maternal concentrations for the rats in the studies to human equivalent concentrations. This internal dose
The previous health-based action limit of 30 TEQ pg/g lipid used for the Danang Sitewide HASP FY 2017
Update (CDM, 2016) is based on a calculation by the American Chemistry Council (ACC) (2003) to be
protective of a WHO dioxin tolerable daily intake of four (4) TEQ pg/kg-day. This action limit was derived
from the intake of 4 pg/kg-day using a pharmacokinetic model that used conservative assumptions
regarding the percent body fat (25%) and the absorption rate of TCDD of 60% and assumed a steady state
external intake of 4 TEQ pg/kg-day. The pharmacokinetic model was used to convert an external dose to
an internal dose to derive the 30 TEQ pg/g lipid value.
As part of the blood serum dioxin monitoring program, the health-based action limit previously used in
Danang of 30 pg/g TEQ lipid from the 2003 ACC report (Table 9-10) will be the Project dioxin blood
serum action limit. If this value is exceeded, then the congener-specific concentrations (reported along
with the TEQ value) will then be compared to the 2007/2008 NHANES survey 95th percentiles for the
individual congeners to identify which congeners are the source of the elevated TEQ (Table 9-11). As
stated previously, the primary dioxin congener associated with Agent Orange exposure is 2,3,7,8-TCDD,
and, if the serum concentration of this congener is elevated, this may indicate a site-related exposure. The
TEQ value of 30 pg/g lipid from the 2003 ACC report was used because it is the most conservative of the
available reference-based and health-based dioxin blood serum action limits.
The congener-specific 95th percentile values from the NHANES studies are expected to be
representative of the general U.S. population and are consistent with values measured in Vietnamese
men over the age of 55 living in Kim Bang near Hanoi (Manh et al. 2014). Manh et al. (2014) evaluated
differences in men over the age of 55 years living near the former U.S. airbase in Phu Cat and similar
men living in a background location in Kim Bang near Hanoi. In 2010 and 2011, samples were collected
from 97 men in Phu Cat and 85 men in Kim Bang and were analyzed for the 17 2,3,7,8 PCDD/F
congeners along with dioxin like PCB congeners. The men in the area of Phu Cat were expected to
have been exposed to the PCDD/Fs associated with the use of Agent Orange, White, and Blue
herbicides at the airbase from 1961 to 1971.
For the men in the background location of Kim Bang, the 50th and 75th percentiles for the PCDD/F TEQ
were 8.9 and 11.6 ppt, respectively. The 50th and 75th percentile values from the 2007/2008 NHANES
study, which is the data source of the 95th percentile of 39.9 ppt, were 12.8 and 20.7 ppt, respectively. For
2,3,7,8-TCDD serum levels, the men from Kim Bang had 50th and 75th percentiles of 1.5 and 2.0,
respectively. Comparatively, both of the 50th and 75th percentiles for TCDD from the 2003/2004 NHANES
study were less the limit of detection of 3.8 ppt. In general, the Manh et al. (2014) Kim Bang percentiles
for both TEQ and TCDD are lower than the similar percentiles for the NHANES study representing the
general U.S. population indicating that background levels in Vietnam are not expected to be higher than
those in the U.S.
TABLE 9-11. SUMMARY OF 95TH PERCENTILE PCDD/F CONGENER SERUM LIPID CONCENTRATIONS
PCDD/F CONGENER 95TH PERCENTILE – AGES >20 YEARS FOR THE
GENERAL U.S. POPULATION
TCDD 5.30 (4.50; 6.10)
PeCDD 11.3 (10.1; 12.7)
HxCDD,123478 <11.9
HxCDD, 123678 70.8 (60.7; 82.2)
HxCDD, 123789- <12.3
HpCDD 95.0 (76.1; 126)
OCDD 784 (665; 978)
TCDF <6.00
PeCDF, 12378 <7.10
PeCDF, 23478 13.0 (11.4; 14.7)
HxCDF, 123478- 9.50 (8.00; 10.5)
HxCDF, 123678- 9.00 (8.00; 10.1)
HxCDF, 123789- <8.30
HxCDF, 234678- <8.20
HpCDF, 1234678- 18.0 (16.0; 20.9)
HpCDF, 1234789- <8.60
OCDF <12.0
Notes:
– Values for individual congeners taken from CDC (2019), Fourth National Report on Human Exposure to Environmental Chemicals,
Updated Tables.
– ( ) contains 95% confidence interval for the 95th Percentile.
– < indicates the congener was detected and the value is the limit of detection.
Sources:
1. CDC. 2019. Fourth National Report on Human Exposure to Environmental Chemicals, Updated Tables. January.
2. Manh HD, Kido T, Okamoto R, Xianliang S, Anh le T, Supratman S, Maruzeni S, Nishijo M, Nakagawa H, Honma S, Nakano T,
Takasuga T, Nhu DD, Hung NN, Son le K. 2014. Serum dioxin levels in Vietnamese men more than 40 years after herbicide
spraying. Environ Sci Technol. 48(6):3496-503.
If the worker is deemed fit to continue working at the site, retraining will be given in areas where
compliance was weak. The worker will also be closely observed for the first three (3) days on site after
retraining. If the worker is not deemed fit to continue with current tasks, an alternate assignment may be
considered.
Project Contractors should follow the basic format of this Site-Wide HASP, substituting the Project- and
work-specific information for all sections. For non-intrusive activities, such as site reconnaissance activities
which do not require entrance into contaminated areas, a Short Form SHASP form is included in
Appendix M.
• Operations trailers,
• Sanitation facilities (toilets, showers),
• Storage of clean materials,
• Parking for employee vehicles, and
• Eating area and designated smoking area (if allowed by GVN)
Contaminated materials, equipment, vehicles, and personnel will be prohibited from this area except in
extreme emergencies.
Boundaries of the CZ will be clearly marked with signage and barricades directed toward both the CZ
and the Contamination Reduction Zone (CRZ). Entry into the CRZ will be allowed only after personnel
and equipment decontamination (decon) is complete.
• Impermeable ground cover (plastic drop cloths or sheeting) if the CRZ is not placed on an
impervious surface;
• Instrumentation and hand tool drop area;
• Gross decon area for boots, gloves, and PPE;
• Boot decon tubs and scrub brushes;
• Glove decon basins;
• Respiratory protection decon tubs/basins reserved exclusively for respiratory protection;
• Hand tool decon basins or tubs reserved exclusively for that purpose;
• Instrumentation decon materials as recommended by the manufacturer;
• Absorbent pads, toweling;
• Hand and face wash basins, soap, antibacterial wipes, hand sanitizing gel all reserved
exclusively for that purpose;
• Benches and stools for employees to use during decon;
• Shaded cool-down area;
• Shower facilities, if possible; and
• Drums for holding contaminated PPE, expired respirator cartridges, decon materials; and
decon fluids.
A small area near the limit of the CRZ at the CZ will be reserved for cooling down, administration of first
aid, and water consumption. This area may be utilized by workers who have undergone decon but have
not removed their impermeable PPE completely. This will allow for rehydration and cooling to prevent
heat-related illnesses. In the event of injury, a worker will undergo limited decon to allow immediately
administration of first aid, CPR, or advanced treatment administered by emergency responders.
Because the CRZ is an area where contamination is easily spread during cleanup, a specific decon sequence
and protocol will be established which limits the spread of contamination.
The recommended cleaning soap or detergent is one without phosphates, added perfumes, dyes,
softeners, bleach, or oxidizing agents. To allow for proper rinsing of PPE, the minimum amount of cleaner
should be used. For respiratory protection and instrumentation, the manufacturer’s recommendations for
cleaning should be followed, using the recommended type of soap and rinseate.
Reusable sampling tools will be decontaminated using the protocols included in the Site-Wide SAP/QAPP.
Disposable tools will be returned to the CRZ and placed in drums with contaminated PPE.
Anyone conducting equipment decon will be required to wear the appropriate PPE during all decon
activities. When the equipment is cleaned and ready for removal from the site, decon personnel will pass
through the personnel decon area and perform the appropriate sequence of PPE cleaning and removal.
All personnel entering this area shall use the required PPE and respiratory protection as directed by their
CSO. Those entering must also have completed the required training and have current medical clearance
to wear PPE and respiratory protection.
Personnel entry to the EZ will be via one designated point, and heavy equipment and authorized vehicles
will enter by another designated point. Both entrances will be clearly indicated with signs and barricades
preventing re-entry to other zones without first passing through the CRZ.
Boundaries of and signs or barricades on the perimeter of the EZ will move as work areas are declared
“clean” or no longer contaminated. The EZ must remain clearly marked throughout all work activities on
the site.
All personnel entering the EZ will be required to sign in when they enter and sign out when they have
completed the required decontamination.
CONTAMINATION
REDUCTION
ZONE (CRZ)
EQUIPMENT
DECON
ACCESS CONTROL
POINTS
In order to ensure that the formal processes for hazard identification, risk assessment, and control are
followed, documentation will be created during the planning and implementation phases of Project work.
The use of standard HASP forms will facilitate the development and review of the required documentation
as presented in Section 10.1 and facilitate reporting as presented in Section 10.2
Training Location
Date:
Conducted By:
I have reviewed the Site-Wide Health & Safety Plan for the above-indicated site and understand the hazards
and control measures required on this Project.
I agree to follow the procedures outlined in this Plan and to inform the Site Contractor Safety Officer,
Site Contractor Project Manager, or my direct supervisor should any unsafe condition be noted.
I understand that failure to follow safety regulations can be reason for removal from this Project.
Activity/Work Task: Overall Risk Assessment Code (RAC) (Use highest code) M
Project Location: Bien Hoa Airbase, Vietnam
Risk Assessment Code (RAC) Matrix
Contract/Project Number:
Probability
Date Prepared: Severity
Prepared by: Frequent Likely Occasional Seldom Unlikely
Date Reviewed: Catastrophic E E H H M
Reviewed by: Critical E H H M L
Date approved: Marginal H M M L L
Approved by: Negligible M L L L L
Notes: (Field Notes, Review Comments, etc.) Step 1: Review each “Hazard” with identified safety “Controls” and determine RAC (See above)
For general precautions related to all site activities, refer to AHAs “Probability” is the likelihood of causing an incident, near miss, or accident RAC Chart
for “General Site Work” and “Non-Intrusive Site Activities”. and is
“Severity” is the outcome/degree if an incident, near miss, or accident did E = Extremely High
occur and is identified as: Catastrophic, Critical, Marginal, or Negligible H = High Risk
Step 2: Identify the RAC (Probability/Severity) as E, H, M, or L for each M = Moderate Risk
“Hazard” on AHA. Annotate the overall highest RAC at the top of AHA. L = Low Risk
Job Steps Hazards Controls RAC
1. 1. 1. M
2. 1.
2. 1. 1.
2. 1.
3. •
3. 1. 1.
4. 1.
5. 2. 1.
6. 3. 2.
7. 4. 3.
Qualified Personnel
2. Training 1.
Qualified Personnel
3. Training 1.
Qualified Personnel
Training Location
Date:
Conducted By:
The following individuals have reviewed and have agreed to follow the Activity Hazard Analysis prepared
by A&E Bien Hoa Contractor for the above-indicated site and understand the hazards and control
measures required on this phase of the Project.
I agree to follow the procedures outlined in this Plan and to inform the Site Contractor Safety Officer,
Site Contractor Project Manager, or my direct supervisor should any unsafe condition be noted.
I understand that failure to follow safety regulations can be reason for removal from this Project.
Location on Site
Date:
Conducted By:
Page Number:
Legend:
DEFINITIONS:
Bloodborne Pathogens (BBP) means pathogenic microorganisms (such as viruses) that are present in
human blood and body fluids and can cause disease in humans. These pathogens include, but are not
limited to, HBV, HCV, and HIV.
Other Potentially Infectious Materials (OPIMs) means the following human body fluids: semen, vaginal
secretions, cerebrospinal fluid, synovial fluid, pleural fluid, pericardial fluid, peritoneal fluid, amniotic fluid,
saliva in dental procedures, any other body fluid that is visibly contaminated with blood such as saliva or
vomitus, and all body fluids in situations where it is difficult or impossible to differentiate between body
fluids such as emergency response.
HIV
• Fatigue
• Jaundice (yellowing of skin and eyes)
• Severe pain in joints
• Lung disease
• Inflammation of liver
• Inflammation on and ulcers of the colon
• May be asymptomatic (i.e., no symptoms indicated)
2) Modes of transmission of BBP
Pathogens can enter your body through a cut in the skin, through your eyes or mouth, and can be
transmitted sexually.
HIV
• By a sharp object that is contaminated by the virus when it cuts or punctures your skin.
• When you touch a contaminated surface and then touch your eyes, nose, mouth, or open
wounds or inflamed skin.
3) Explanation of the BBP Exposure Control Program and means by which the employee
can obtain a copy
• Do not eat, drink, smoke, apply cosmetics or lip balm, or handle contact lenses in areas
where there is the possibility of exposure to BBP;
• Wash hands and exposed skin with soap and water immediately after contact with blood or
OPIM; and
• Decontaminate all surfaces contaminated with blood or OPIM with a diluted bleach solution
(diluted 1:10).
• Gloves and ventilation device(s) for use during CPR, such as mouthpieces or pocket masks,
will be included in the standard first aid kit in the field and in the offices.
• Remove gloves contaminated with blood or OPIM in manner that prevents skin contact with
the exterior surface of the gloves.
• Disposable gloves and pocket masks will not be washed or decontaminated for reuse and
must be replaced.
• All waste created during administration of first aid, including PPE, shall be disposed of in a
sealable waste bag for disposal.
7) HBV vaccination efficacy, safety, method of administration, benefits, and that the vaccine
and vaccination will be offered free to eligible employees
• Wash hands and any exposed skin immediately with soap and water
9) Procedures to follow in the event of an exposure incident, including method of reporting
and medical follow-up that will be made available
• Report incident using “Post-exposure Evaluation Form” and provide to CSO or direct
supervisor as soon as possible after incident. The CSO is required to submit this information
to the LSECS as soon as possible.
• A confidential medical evaluation and follow-up will be provided immediately to exposed
employees.
10) Details of the post-exposure evaluation and follow-up
• Plastic impermeable bag labeled “Biohazardous Waste” or with the international symbol and
the word “Biohazard.”
Date ____________________________________
Location ________________________________________________________________
Type of Incident and Body Fluid Exchanged (check all that apply):
Body Fluid Action Route of Entry of Exposed Person
☐ Blood ☐ Needle puncture ☐ Eye
☐ Sputum or saliva ☐ Bite that breaks skin ☐ Nose
☐ Urine ☐ Impalement ☐ Mouth
☐ Feces ☐ Splash or splatter ☐ Open wound or break in skin
☐ Semen ☐ Mouth-to-mouth CPR
☐ Vaginal secretions ☐ Cut or wound
☐ Vomitus ☐ Other
Have you been vaccinated against Hepatitis B virus? ☐ No ☐ Yes If yes, what year?
The above information accurately describes the exposure. I request disclosure of the source person’s
body fluid/bloodborne pathogen(s) test results.
Exposed Person’s Signature: Date Signed:
I certify that the incident described above had the potential for the exposed person to have a significant
exposure to blood or other body fluids. I have informed the exposed person about medical conditions
that may require further evaluation or treatment as a result of this exposure.
Location on Site
Conducted By:
Instrument:
Name:
Comments: Readings:
Name:
Comments: Readings:
Name:
Comments: Readings:
Name:
Comments: Readings:
Name:
Comments: Readings:
GENERAL INFORMATION
Date
Location on Site
Competent Person
Excavation Depth / Width
EXCAVATION INFORMATION
Condition Present? Describe
Employees Entering Excavation Yes / No
Hazardous Atmosphere Yes / No
Access / Egress Yes / No
Traffic Control Yes / No
Wet Condition Yes / No
Employee Name:
ALLERGIES
List any health-threatening allergies (i.e., medications, food, bee stings):
MEDICATIONS
List current medications that may affect the ability to safely operate equipment and machinery:
OTHER INFORMATION
List any other information that should be known in case of an emergency:
Name (print):
Signature:
Date:
I understand that because of my occupational exposure to blood or other potentially infectious materials,
I may be at risk of acquiring Hepatitis B virus (HBV) infection.
Location of Incident
Was place of accident or exposure on the Bien Hoa Airbase Area remediation site?
Yes No
What happened? Describe the incident in detail. Use additional pages if needed.
What was your injury? Describe the parts of the body affected and how it was affected. Be specific:
“Sprained left wrist” or “Chemical burn, left hand”.
If no, please state why you did not use the safety equipment you were given.
Phone
Eyewitness? Yes No Was a witness statement provided? Yes No
2. Name
Company
Address
Phone
Eyewitness? Yes No Was a witness statement provided? Yes No
3. Name
Company
Address
Phone
Eyewitness? Yes No Was a witness statement provided? Yes No
4. Name
Company
Address
Phone
Eyewitness? Yes No Was a witness statement provided? Yes No
5. Name
Company
Address
Phone
Eyewitness? Yes No Was a witness statement provided? Yes No
TELEPHONE:
Telephone
Was the employee treated in an emergency room? Yes No
Was the employee hospitalized overnight as an in-patient? Yes No
If Yes, provide the information below if different from facility above.
Facility name and address:
Telephone
Was time off medically required? Yes No
If yes, how many days?
Was job reassignment medically required? Yes No
If yes, for how long?
Was physical therapy medically required? Yes No
If yes, for how long?
Will post-incident blood testing be required? Yes No
If yes, date scheduled:
Has a medical professional provided a “fitness for duty” statement? Yes No
If yes, what is the recommended return to work date?
I have reviewed this investigation report and agree, to the best of my recollection, with its contents. I understand that the
foregoing information may be used for further investigation and reporting.
Report prepared by
Title/Position
Company
Telephone
Signature Date
Company Name
Circle Areas
Of Vehicle 1 F R
Address
Damage
Weather Conditions
Work Telephone
Company Name/Address
Circle Areas
Of Vehicle 2 F R
Damage
Yes / No
Vehicle No. Name Address Witness?
Yes / No
Vehicle No. Name Address Witness?
Yes / No
Vehicle No. Name Address Witness?
Yes / No
Fully State How Accident Occurred (Give details, attach additional sheets if necessary)
Pedestrian
1. Stop immediately.
Stay calm and pull the vehicle as far off the road as possible.
Check all other drivers and passengers for injuries. Call for emergency medical assistance if needed.
Report the accident immediately to your Supervisor or Safety Officer.
If the accident involves an unoccupied vehicle, try to find the owner. If the owner can’t be found,
leave your name, the company’s name, address, and phone number in a visible location, such as
under a windshield wiper blade.
Write down the make, model, year, license plate number and description of the unoccupied vehicle
on the accident report form.
3. Notify Your Supervisor or Safety Officer of the accident. Follow all company rules, be
cooperative and answer all questions posed by your Supervisor, your Contractor Safety
Officer, and/or the LSECS.
4. Notify relevant Bien Hoa Airbase officials. Courtesy and cooperation are important
when notifying Bien Hoa Airbase emergency response personnel.
Date / Time:
Location on Site:
Work Description:
OBSERVATIONS
Project Manager:
Safety Inspector:
Distribution:
Location on Site:
Date:
Topic:
Conducted By:
Signature:
Date:
Date / / Time:
Time
______________________________________ ____________________________________________
Name Title
_________________________________________
Signature
Biological Hazards
Other conditions
Other hazards
USAID requirements
UXO Safety
Special Operations and Equipment
Working around heavy equipment
Lessons Learned
Select topics based on previous day’s operations or new information provided by USAID.
Training Location:
Date:
Topic
Instructor Name:
Signature:
Date:
NOTE: Attach copy of any written handouts.
PROFESSIONAL QUALIFICATIONS
A Board of Certified Safety Professionals (BCSP) Certified instructional Trainer (CIT) with over 30 years
of technical and field experience in the comprehensive practice of occupational health and safety.
Her training experience commenced after completing over 200 hours of training and seven years of hands-
on site work. During her training career, she has developed and presented training to over 2,000 students
worldwide, including: Hazwoper 40-Hour Initial Training; 8 Hour Hazwoper Supervisor Course; 8 Hour
Hazwoper Refresher Course; hazard communication training; Safe Work Practices During Construction
Activities in Contaminated Areas; and Hazardous Waste Sampling in all Medias.
As a Cardno Division HSE Director, Ms. Black is responsible for setting, implementing and monitoring
compliance for all health and safety policies in the Government Environmental, and Asset Management
Services division, and for ensuring that all measures necessary are taken to ensure employee health and
safety in offices and worksites around the globe. She is also responsible for maintaining the division Health
and Safety Program and Manual, review of all HASPs and AHAs, creating and chairing the division HSE
Committee, and updating all requirements as needs arise. Through a program of annual site audits, Ms.
Black is also responsible for audits at five (5) hazardous waste facility operations located on CONUS U.S.
military bases.
Ms. Black’s primary responsibility is to ensure the health and safety of our employees, their families, our
clients, and our communities during our work activities. She works to ensure that employees conduct
their work in compliance with federal, state, and local OSHA regulations and with Department of Defense
and other federal agency regulations, policies and procedures.
EMPLOYMENT HISTORY
Cardno – January 2012 to present
City of Wright, City of Tamarack, MN – 2006 - 2011
Cellular One Construction – 2000 – 2005
American Tower Corporation Construction – 1997 – 2000
Aguilar Associates & Consultants – 1981 - 1997
3. Hired Drivers 1. Use only drivers recommended by the USAID or hotel, or those hired M
via the “Grab” app (similar to Uber and Lyft).
2. Be prepared with final destination address in Vietnamese as well as
English.
3. Prior to departure, ensure that your host at the Bien Hoa Airbase will
allow access to the site by the hired driver.
4. Request the fare amount before departure.
5. Request information on payment method before departure.
6. Receipts for privately hired taxis are not always provided. Be prepared
to request it from your driver.
2. On-site movement 1. Restricted or high-security areas 1. Request information in advance of site access to ensure that no team M
members walk into restricted areas without appropriate escort.
2. Request daily updates of changes in areas where team access is
allowed.
3. Review the information in the Daily Tailgate meeting.
2. UXO Clearance 1. Prior to entering any new area on the site, request UXO clearance M
from the host or from the contractor.
2. Report any sightings of UXO.
3. Avoid contact with any UXO discovered during site operations.
4. Review areas where UXO clearance has been performed during the
Daily Tailgate meeting.
5. Request ongoing updates when UXO clearance has been performed
or when new hazards have been sighted.
5. Trip and fall hazards 1. Watch the ground for any unsafe footing or trip hazards. M
2. Whenever possible, remove the trip hazard from the walking path to
prevent injury of team members.
3. If not possible to remove or otherwise mitigate the hazard, mark the
area with high-visibility flagging or caution tape and report it to the
CSO.
4. Map areas where hazards cannot be mitigated.
5. Discuss trip hazards during Daily Tailgate meetings.
On-site Movement: First Aid Training 1. Routes to hospital with hired drivers.
Kit; AED; appropriate PPE; PPE – Use and Maintenance 2. Adequate drinking water supply with individual drinking cups or bottles.
UXO contractor; drinking First Aid/CPR/AED Training 3. New site work areas for hazards.
water supply; sunscreen; Site Evacuation Procedures 4. Cool-down and shaded areas.
insect repellent; canopies to 5. PPE supplies.
provide shade; Qualified Personnel
40-Hour Hazwoper trained personnel in any areas
where intrusive work is being conducted
First Aid/CPR certified personnel to administer
immediate treatment
Working in Site Operations Training 1. Personnel identification information
Trailer(s) Office Safety 2. Utility services
Office Ergonomics 3. Free of wildlife
Bloodborne Pathogens 4. Floors and sanitation facilities
5. Lighting
Qualified Personnel 6. Temperature control
All Team Members with clearance to be on the 7. Windows, doors, locks, screens
site.
3. Airborne particulates (dust) 1. Check areas for other operations upwind that could produce M
airborne dust and particulates.
2. Stop work and leave the area if dust from other operations
approaches the haul road location sites.
3. Report the condition and request watering for the areas where dust
originates.
4. If dust approaches office trailers, close all windows and doors, and
turn on air conditioning. Evacuate site if possible until dust subsides.
5. Working in high heat conditions 1. Ensure a plentiful supply of clean drinking water. Plan for at least 4 H
liters per person per day.
2. Drink water or electrolyte replacement beverage in adequate
quantities.
3. Wear the lightest weight clothing possible.
4. Wear light colored clothing and head covering.
5. Use sunscreen to prevent sunburns, causing additional dehydration.
6. Acclimate to working in the heat slowly.
7. Whenever possible, work in shaded areas, being careful to monitor
overhanging vegetation for snakes and insects.
8. Know the signs of the onset of heat-related illnesses including heat
rash, heat cramps, heat stress, and heat stroke.
9. Report any signs of heat-related illness to the CSO immediately.
10. Discuss precautions during Daily Tailgate meetings.
11. Identify the members of the team who are first aid/CPR certified.
7. Heavy Equipment 1. When working around heavy equipment, always be sure that the M
operator can see you and you can see the operator.
2. Wear the appropriate hearing and eye protection.
3. Wear a high-visibility vest.
4. Do not walk behind any machine in operation.
5. Do not operate or ride on any heavy equipment unless trained and
certified to operate.
6. Stay upwind of equipment during earthmoving activities when soil is
dry and dusty.
7. Learn the appropriate hand or audible signals to stop operation in an
emergency.
2. Groundwater Sampling 1. Exposure to contaminants in • Refer to steps in 1.1.1 thru 7 above. In addition: M
groundwater 1. Wear water repellent disposable full body cover to prevent
contamination of skin and clothing.
2. Have an adequate supply of disposable paper towels to dry outside of
sample containers.
3. Avoid stepping in spilled groundwater whenever possible.
3. Surface Water Sampling 1. Exposure to contaminants in surface • Refer to steps 1.1.1 thru 7 and 2.1.1 thru 3 above. In addition: M
water 1. When working at or near the edge of a body of water (pond, lake,
stream, river, etc.), wear a PFD at all times over the disposable full
body cover.
2. In the event that a team member falls into the water, all work will stop
until the member is extracted from the water and in the
decontamination zone.
3. When working at the edge of the water, a rope will be attached to the
PFD at all times to effect quick extraction.
4. PFDs will be decontaminated with soap and water as directed by the
manufacturer and left in the decontamination area to dry.
5. At the conclusion of surface water, sediment and pond sampling, all
PFDs used during the Project will be air-dried and held for disposal
pending results of water analysis.
4. Sediment and Pond Sampling 1. Exposure to contaminants in • Refer to steps 1.1.1 thru 7, 2.1.1 thru 3, and 3.1.1 thru 5 above. M
sediment and ponds
5. Vegetation Sampling 1. Exposure to contaminants • Refer to steps 1.1.1 thru 7 and 2.1.1 thru 3 above. In addition: M
accumulated on vegetation 1. Seal vegetation samples in bags or containers to prevent exposure to
contaminants when processing samples.
2. Do not remove contaminated vegetation from the EZ unless in sealed
containers which are marked to prevent reopening without the use of
PPE.
3. Immediately report any signs of skin rash or irritation and begin first
aid measure.
4. Thoroughly wash hands and arms BEFORE washing face or any other
body part.
3. Exposure to irritant or poisonous • Do not handle any plants with bare hands. M
plants • If cutting samples, decontaminate or dispose of any instruments used
for cutting.
• Do not “sniff” plants to identify aromas or odors.
• Be cautious when handling plants with thorns or thistles. Use heavy
work glove over chemical protective gloves.
• Always check for wildlife before disturbing any vegetation.
• Immediately report any signs of skin rash or irritation and begin first
aid measures.
• Thoroughly wash hands and arms BEFORE washing face or any other
body part.
6. Fish and Shellfish Sampling 1. Exposure to potentially 1. Refer to steps in 1.1.1 thru 7 above. In addition: M
contaminated or diseased aquatic 2. Wear water repellent disposable full body cover to prevent
wildlife specimens contamination of skin and clothing.
3. Have an adequate supply of disposable paper towels to dry outside of
sample containers.
4. Do not handle any specimens with bare hands.
5. Decontaminate or dispose of instruments used for cutting samples.
6. Do not “sniff” specimens to identify aromas or odors.
7. Check specimen for spines, bony protrusions, or teeth which could
damage PPE and cut skin.
8. Seal all specimens in containers prior to leaving the EZ. Do not
reopen containers outside of EZ.
9. Report to CSO if you are allergic to shellfish or seafood.
10. Immediately report any signs of skin rash or irritation and begin first
aid measures.
11. Thoroughly wash hands and arms BEFORE washing face or any other
body part.
7. Decontamination Fluid and 1. Exposure to contaminants in liquid • Refer to steps in 1.1.1 thru 7 above. In addition: M
Investigation-Derived Waste and solid wastes 1. Wear water repellent disposable full body cover to prevent
Sampling contamination of skin and clothing.
2. Have an adequate supply of disposable paper towels to dry outside of
sample containers.
3. Avoid stepping in spilled groundwater whenever possible.
As the subcontractors to be used on this Project are identified, they will be added to the list. A written
HASP will be required for each subcontractor which addresses each task to be performed. Work will not
begin until the subcontractor’s HASP has been approved by USAID.
All medical records related to BBP exposure incidents shall be maintained with other medical records for
the employee. Training records associated with this standard shall be maintained with other training
records.
The CSOs and the A&E Bien Hoa Contractor LSECS is responsible for implementation of this Plan on the
work site and will review the final selection of appropriate PPE and evaluate reported exposure incidents.
The BBP standard requires that the BBP exposure control program detail the methods of implementation
for the various elements of the standard. The program elements are discussed below.
It is currently anticipated that exposure to potentially infectious material will include employees who are
trained in first aid or CPR and members of the site emergency response team administering care to
coworkers, guests, visitors, or other worksite personnel. All personnel who are trained in first aid or CPR
must receive training on the BBP Exposure Control Plan and complete a training course addressing BBP
risks, control, and exposure monitoring.
UNIVERSAL PRECAUTIONS
“Universal Precautions” is an approach to infection control. According to the concept of Universal
Precautions, all human blood and certain human body fluids are treated as if known to be infectious for
human immunodeficiency virus (HIV), hepatitis B virus (HBV), hepatitis C virus (HCV), and other BBP.
The proactive use of universal precautions shall be implemented during all first aid activities whenever
contact with blood or OPIM may be reasonably anticipated. All blood or OPIM shall be considered
infectious regardless of the source individual. Universal precautions should be attained by using engineering
controls, work practice controls, and PPE.
Disposable gloves and pocket masks will be included in every standard first aid kit at all work sites and
offices for every contractor on the site. Gloves shall be worn whenever employees will have hand contact
with blood, broken skin, mucous membranes, or OPIM, and when handling or touching contaminated
items or surfaces.
Disposable gloves and pocket masks will not be washed or decontaminated for reuse and must be replaced
when they become contaminated, torn, or punctured, or when their ability to function as a barrier is
compromised.
HOUSEKEEPING
In general, work areas are not expected to be contaminated with blood or OPIM unless in the event of a
severe injury. In that case, all surfaces and equipment shall be cleaned and disinfected after contact with
blood or OPIM as soon as possible with a diluted bleach solution (diluted 1:10) or other appropriate
disinfectant.
If contaminated sharp objects or broken glassware are encountered, these items shall not be picked up
by hand. Mechanical means of retrieval (such as use of a broom and dustpan, tongs, or forceps) shall be
Clothing contaminated with blood or OPIM shall be bagged, labeled, and discarded as regulated waste.
Nonregulated waste can be disposed of along with regular waste. This waste must be placed in a leak-
proof container, closed tightly, and promptly placed into a garbage receptacle.
HEPATITIS B VACCINATION
A pre-exposure HBV vaccination does not have to be offered to employees who are designated only as
first aid providers and those whose primary job assignment is not rendering first aid but administering first
aid only as a collateral duty to their routine work assignments. The HBV vaccination series will be made
available to any unvaccinated first aid provider who has rendered assistance in any situation involving the
presence of blood or OPIM, regardless of whether an actual exposure incident occurred.
• A description of the exposed employee’s duties as they relate to the exposure incident;
• Documentation of the routes of exposure and exposure incident circumstances;
• Results of source individual’s blood testing, if available;
• All medical records relevant to the appropriate medical treatment, including vaccination
status; and
• A copy of Post-Exposure Evaluation Form.
All training conducted shall be documented and the training records kept for 3 years. Training
documentation shall include the dates of the training, the contents or summary of the training session,
names and qualifications of persons conducting the training, and the names of those attending.
The harmonized standard classifies chemicals according to their health and physical hazards and establishes
consistent labels and SDSs for all chemicals produced globally and imported from abroad.
Employee hazard communication rights include the right to personally receive information regarding
hazardous substances to which the employee may be exposed; the right for the employee’s physician to
receive such information; and the right of protection against discharge or discrimination due to employee’s
exercise of rights provided by the Hazardous Substance Information and Training Act.
Chemical manufacturers/importers, distributors, employers, and employees each have a role in Hazard
Communication:
• Chemical manufacturers or importers assess the hazards of chemicals that they produce or
import.
• Chemical distributors must transmit required information to employers.
• Employers must provide information to employees about the hazardous chemicals to which
they are exposed.
• Employees must attend training and follow all Hazard Communication directives in the
workplace.
For this Project’s work activities, hazard communication requirements apply to any chemical that is known
to be present, stored, or used at the site. Each chemical is to be assessed in such a manner that employees
• Ensure that each container of hazardous chemicals in the workplace is labeled, tagged or
marked with the identity of the hazardous chemical, appropriate hazard warnings, and name
and address of the chemical manufacturer, importer, or other responsible party;
• Ensure that labels and other forms of warning do not conflict with those required by the
relevant federal or global transportation laws and regulations;
As of June 1, 2015, the HCS requires new SDSs to be in a uniform format, and include the section numbers,
the headings, and associated information under the 16 headings below:
Section 2: Hazard(s) identification includes all hazards regarding the chemical; required label
elements.
Section 4: First aid measures include important symptoms/ effects, acute, delayed; required
treatment.
Section 5: Firefighting measures list suitable extinguishing techniques, equipment; chemical hazards
from fire.
Section 6: Accidental release measures list emergency procedures, protective equipment, proper
methods of containment and cleanup.
Section 7: Handling and storage lists precautions for safe handling and storage, including
incompatibilities.
Section 8: Exposure controls and personal protection list the PEL; threshold limit value (TLV);
appropriate engineering controls; PPE.
Section 10: Stability and reactivity lists chemical stability and possibility of hazardous reactions.
Section 11: Toxicological information includes routes of exposure; related symptoms, acute and
chronic effects; numerical measures of toxicity.
Section 16: Other information; includes the date of preparation or last revision.
The chemical manufacturer or importer must provide an SDS with their initial shipment and with the first
shipment after an SDS is updated. The SDS must be provided with the shipped containers or be sent to
the distributor or employer prior to or at the time of shipment. The SDS must be provided to distributors
or employers upon request. Where employees must travel between workplaces during a work shift, the
SDSs may be kept at the primary workplace facility provided that the required information can be obtained
immediately in an emergency.
PROGRAM OVERVIEW
If an AEGCP is used in place of GFCIs for ground-fault protection, the CSO shall develop a AEGCP which
shall consist of: written procedures for equipment inspections, tests, test schedule and results to assure
equipment grounding conductors for all cord sets, receptacles that are not a part of the permanent wiring
of the building or structure, and equipment connected by cord and plug are installed and maintained to
protect employees on construction sites. AEGCP must be in compliance with GVN, OSHA, NESC and
National Electrical Code requirements.
These procedures shall be made available to LSECS and affected persons. An AEGCP shall be continuously
implemented and enforced at the site by one or more designated competent persons.
VISUAL INSPECTIONS
Visually inspect all cord sets, attachment caps, plugs and receptacles, and any equipment connected by
cord and plug before each day's use for external damage (i.e., deformed or missing pins, damaged
insulation) and for indication of possible internal damage. Ensure flexible cords are being inspected and
those arriving onsite between tests are identified and tested.
REMOVING EQUIPMENT
Equipment found to be damaged or defective or which fails any of the prescribed inspections or tests shall
not be used until repaired or replaced.
TESTING
Perform two required tests on all electrical equipment: a continuity test and a terminal connection test.
Tests are required:
RECORDKEEPING
All inspections and tests shall be documented to identify all equipment that passed the inspection or test,
the date of inspection or test, and the individual responsible for the inspection or test.
A&E Bien Hoa Contractor has designated personnel to act in the capacity of first aid responders for
medical emergencies on this Project as indicated below.
Legend:
Prior to using any PPE or respiratory protection, each worker will check the PPE for signs of wear,
tears, breaks in seams, functionality of the zippers or other closures, and cleanliness. PPE that is
damaged or dirty shall not be used.
In general, if PPE and respiratory protection are being used on the site, the following elements will
be required:
After checking all PPE and respiratory protection for the suggested donning sequence is:
1. Disposable coverall. Check the fit and use duct tape folded in half to make a belt to hold suit in
place.
2. Boot covers. Pull suit leg over the top of boot cover and tape in place with duct tape, leaving a
folded end for easy removal.
3. Respirator. Ensure that cartridges are properly seated. Perform negative and positive fit checks:
a. Cover both cartridges and inhale. Mask should collapse against the face.
b. Cover exhalation port and exhale normally. Mask should inflate and no air should
escape around the facepiece seal.
4. Inner gloves.
5. Outer gloves. Pull coverall sleeve up to expose wrists. Tape coverall over the top of the glove
with duct tape, and fold over the end of the tape to make a tab for easy removal. If working in
decon or any area handling liquids where arms will be lifted while wet, an additional outer glove
should be placed over the top of the sleeve and duct tape to prevent rinseate from running
underneath duct tape.
The following sequence is a basic guideline to be used by the contractor to develop a specific
personnel decon procedure to include in the Supplemental Health and Safety Plan (SHASP) for
amendment to this HASP. For a general site layout, refer to Figure 9-2 Site Zones. All personnel
decon will be conducted in the Contamination Reduction Zone (CRZ) in an area set up exclusively
for personnel decon. Activities shall be conducted under the supervision of the contactor’s decon
technician, who will assist in the process to ensure completion of the appropriate prescribed steps.
SEQUENCE
1. Place tools, instrumentation, and equipment in the tool drop area inside the CRZ at the hot
line.
2. Using absorbent toweling or pads, wipe gross contamination off outer gloves, hard hat,
respirator, disposable coverall, and boots or boot covers in that sequence. Place soiled
absorbents in waste container.
3. Wash outer gloves and boots in basins or tubs using brushes or other scrubbers provided.
4. Rinse and check outer gloves and boots or boot covers. Re-wash and re-rinse if needed.
5. Remove hard hat. Wash and rinse in basin or tub using brushes or other scrubbers provided.
Place hard hat on clean absorbent pads to dry.
6. Remove ankle tape and disposable boot covers, if used.
7. Remove wrist tape and outer gloves, leaving inner gloves in place.
8. Remove disposable coverall, beginning at the neck and shoulders, rolling the suit inside out and
turning the sleeves inside out. Continue rolling the suit down the legs, taking care not to
recontaminate clothing or boots. Step out of the suit, which should be inside out at the ankles.
Step on the clean inner side of the suit to remove feet from the legs.
9. Roll the suit into a ball, taking care not to touch clothing. Place suit in a container for disposal.
10. Remove respirator. And remove and crush cartridges. Place used cartridges in container for
disposal.
11. Wash and sanitize respirator, taking care to thoroughly rinse and re-check all surfaces. Place
clean respirator on clean absorbent pads to dry.
12. Remove inner gloves, inside out, one inside the other. Place gloves in a container for disposal.
13. Wash hands and face with clean water and soap.
MATERIALS AND EQUIPMENT NEEDED. ALL OF THESE MATERIALS WILL BE SUPPLIED BY THE
LABORATORY EXCEPT THE PACKING TAPE AND DRY ICE.
Large zipper - close plastic bag to hold samples bottle holder with bottles in place.
Large absorbent pad to fit in plastic bag
Hard sided cooler to hold dry ice and specimen bottles during shipment
Styrofoam holders for specimen bottles
Dry ice
Dry ice label
Diagnostic Specimen label
Completed FedEx airbill
Completed commercial invoice
Packing material (bubble wrap)
Clear Packing tape
PACKING INSTRUCTIONS:
All specimens should be placed in the Styrofoam bottle holder provided. Each bottle should fit snuggly
into its own slot. A second Styrofoam holder is provided to serve as a cap over the first one to
protect the tops of the bottles. Place the holder containing the vials inside a zipper lock plastic bag
with an absorbent pad under the specimens holder inside the bag. Seal the bag.
Place 10-15 lbs of dry ice in the bottom of the shipping cooler.
Place the zipper bag inside the shipping cooler on top of the dry ice. Ensure the specimens are in an
upright position and use extra packing material around the specimens to secure them in an upright
position. Fill the cooler with as much bubble wrap as possible to minimize the empty air space in the
cooler.
Place custody seals (signed and dated) over the cooler lid (one on each side) and cover them with
clear packing tape for security. Apply the seal over the closure of the lid ensuring that the date and
signature are over the opening.
The original signed copy of the COC needs to be supplied in envelope affixed to the outside of the
cooler. Place a copy of the COC in a sealed plastic bag inside the cooler. The original COC should
be relinquished to the courier (signature of shipper and courier required on COC) before it is placed
in the sealed envelope and taped to the outside of the cooler.
Place a Dry Ice Label and a Diagnostic Specimen Label on the outside of the shipping box containing
the Serum Specimens and write in the weight of the dry ice.
Prepare a Federal Express airbill for shipping and mark the appropriate boxes including the one for
dry ice for the Serum shipment and overnight delivery.
Employee Name
Case Number
Interviewer
Was questionnaire
completed?
1.12 Have you ever smoked tobacco? (If you smoked less than 20 packs of cigarettes in your
lifetime or less than 1 cigarette per day for a year, please answer “No”.)
Yes No Don’t know
1.13 How old were you when you started smoking tobacco?
Age Don’t know
1.14 Do you smoke tobacco now or within the past month?
Yes No Don’t know
1.15 On average, how many cigarettes do you smoke per day?
# Cigarettes/Day Don’t know
1.16 What is the total number of years you have smoked?
# Years Don’t know
1.17 If you have stopped smoking complete for more than a month, how old were you when you
stopped?
Age when stopped Don’t know
1.18 What is the total number of years you smoked?
# Years Don’t know
1.19 If you have stopped smoking for more than a month, what is the average number of
cigarettes you smoked per day?
# Cigarettes/Day Don’t know
From To
2.3 Previous address
From To
2.4 Previous address
From To
2.5 Previous address
From To
2.6 Previous address
From To
2.7 Previous address
From To
3.1 Do you or does anyone else in your household have a vegetable garden on the property
where you currently reside?
Yes No Don’t Know
Comments
3.2 Did you ever use weed killers on your property?
Yes No Don’t Know
Comments
3.3 Did you ever live on a property where trash or yard waste was burned?
Yes No Don’t Know
Comments
3.4 Did you ever live on a property where a wood-burning stove or fireplace was used regularly?
Yes No Don’t Know
Comments
3.5 Was a property that you lived in ever damaged by a fire while you lived there?
Yes No Don’t Know
Comments
3.6 To your knowledge, has any portion of your property ever been flooded during the monsoon
rains?
Yes No Don’t Know
Comments
3.7 Did flood waters ever enter into any of the living areas in your home?
Yes No Don’t Know
Comments
Additional Comments
Comments
5.7 How much fish do you buy from local markets each week?
0 <1 kg 1-2 kg 2-5 kg 5-10 kg >10 kg Don’t
know
Comments
5.8 Do you grow your own fruits and vegetables at your home?
Yes No Don’t Know
Comments
5.9 Did you ever grow rice or vegetables on Bien Hoa Airbase?
Yes No Don’t Know
Comments
None
1st grade
2nd grade
3rd grade
4th grade
5th grade
6th grade
7th grade
8th grade
9th grade
10th grade
11th grade
12th grade, high school graduate
12th grade, no diploma
Some college, no degree
Associate degree – vocational/occupational program
Associate degree – academic program
Bachelor degree, such as BA, BS, AB
Masters degree, such as MA, MS, MENg, Med, MSW, MBA
Doctorate degree, such as PhD, EdD
Professional school degree, such as MD, DDS, DVM, LLB, JD
Prefer not to answer
Don’t know
8.1 Have you read any reports about dioxin in the newspaper?
Yes No Don’t know
8.2 Have you heard any reports about dioxin on the radio?
Yes No Don’t know
8.3 Have you seen or heard any reports about dioxin on the television, including community
access TV?
Yes No Don’t know
8.4 Have you read any reports about dioxin on the Internet?
Yes No Don’t know
Any additional comments?
Per USAID: “In 2016, the United States Agency for International Development (USAID), in close collaboration with the Government of Vietnam (GVN), completed the
"Environmental Assessment of Dioxin Contamination at Bien Hoa Airbase" which meets the requirements of Title 22 CFR Part 216. The overall objective of the Environmental
Assessment (EA) was to inform potential future actions on and around Bien Hoa Airbase to address dioxin-related contamination.
The EA serves as the primary resource documenting characterization of dioxin contamination on and around the Bien Hoa Airbase
(https://www.usaid.gov/vietnam/documents/environmental-assessment-dioxin-contamination-bien-hoa-airbase)...
“The EA estimated the volume of dioxin-contaminated soils and sediments as approximately 408,500 (baseline estimated volume) to 495,300 cubic meters (m3) (baseline
estimated volume plus contingency). This consists of approximately 315,700 to 377,700 m3 of contaminated soil and 92,800 to 117,600 m3 of contaminated sediment found both
on and around the Airbase. Of the dioxin-contaminated baseline volume of 408,500 m3, 42% is in the Pacer Ivy Area, 24% is in the Z1 Area (including the Z1 Landfill), and 15% is
in the Southwest Area (see Figure 1 next page). The remaining 19% is located in the ZT, Northwest, and Northeast Areas. Approximately 5% of the dioxin-contaminated
baseline volume is located off of the Airbase.”
The Short Form Health and Safety Plan (HASP) is for non-intrusive site reconnaissance activities ONLY.
Site reconnaissance will be in clean (uncontaminated) areas and/or on improved surfaces only, and conducted during times when airborne dust is not
present.
Herbicide mixtures (Agents Orange, White, Blue, Pink, Purple, Green and others) were stored on, used in the vicinity of, and deployed from the Bien Hoa Airbase Area. Three
(3) large storage tanks were used for storage, but agents were also stored on the Airbase in drums/barrels. All but Agent Blue contained dioxin. Agent Blue contained organic
arsenic. Due to spillage and use of herbicide mixtures, the grounds at the Bien Hoa Airbase Area were contaminated with dioxin and arsenic, including several “hot spots”
where herbicide mixtures were stored and handled. In particular, dioxin containing herbicide mixtures were re-drummed, repackaged, and shipped to Johnson Atoll from the
Pacer Ivy Area. No herbicide mixtures are known to remain in storage on the site. Because the Airbase was used for military purposes, there is a potential for unexploded
ordnance (UXO) The GVN, Ministry of National Defense (MND) is responsible for clearing UXO.
☐ Landfill gases – monitor with methane and hydrogen sulfide ☒ Petroleum Hydrocarbons
meter
☐ Surface tanks ☐ Underground storage tanks
Notes: Contaminants identified in screening sampling performed by others. Area was known to be a storage area for various defoliant agents used during the Vietnam conflict.
1
Source: CDM International. “Environmental Assessment of Dioxin Contamination at Bien Hoa Airbase,” Section 1, pg. 11. 03 May 2016.
2
Source: CDM International. “Environmental Assessment of Dioxin Contamination at Bien Hoa Airbase,” Section 3, pg. 53. 03 May 2016.
*OTHER 12. All steps will be taken to prevent heat-related illness including
Drinking water as required; sunscreen; insect repellent. consumption of water, dressing to suit weather conditions, taking breaks in
air-conditioned vehicles or in shaded areas other than under trees, and
Long pants and long-sleeved shirt recommended; head covering are recommended. monitoring each other for signs of heat stress.
Hard-toed footware and high-visibility vests are required.
13. Additional SOPs and site information are included in HASP attachments.
20 June 2019
Contractor PM Date
I have read, understood, and agree with the information set forth in this Health and Safety Plan and will follow the direction of the CSO and LSECS as well as
procedures and guidelines established in the appropriate HASP annex and SHASP. I understand the training and medical requirements for conducting field work
and have met these requirements.
I have read, understood, and agree with the information set forth in this Health and Safety Plan and will follow the direction of the Site Safety Coordinator as well
as procedures and guidelines established in the Site-Wide Health & Safety Plan. I understand the training and medical requirements for conducting field work and
have met these requirements.
I have read, understood, and agree with the information set forth in this Health and Safety Plan and will follow the direction of the Site Safety Coordinator as well
as procedures and guidelines established in the Site-Wide Health & Safety Plan. I understand the training and medical requirements for conducting field work and
have met these requirements.
I have read, understood, and agree with the information set forth in this Health and Safety Plan and will follow the direction of the Site Safety Coordinator as well
as procedures and guidelines established in the Site-Wide Health & Safety Plan. I understand the training and medical requirements for conducting field work and
have met these requirements.
Biological hazards, or “biohazards,” include plants, animals or their products, and parasitic or infectious
agents that may present potential risks to participant health. This SOP discusses procedures for working
with biohazards, preventive guidelines, and first aid procedures for the most common hazards field staff
are likely to encounter at the Bien Hoa Airbase Area.
Stinging or biting insects or arachnids in the area of Bien Hoa Airbase Area include mosquitoes, centipedes,
bees, wasps, ticks, and various spiders. SOPs for reducing the chance of insect bites or stings and for
treating bites or stings are listed below.
Preventive Measures
• Participants should keep as much skin area covered as possible by wearing long-sleeved shirts,
long pants, and a hat. Pant legs should be tucked into socks or boots and shirts into pants. In
addition, participants should wear light colored clothing.
• Insect repellent containing 20-30% DEET or 20% Picaridin should be used on exposed skin, and
permethrin should be sprayed on or soaked into clothing. Application of DEET or permethrin
on skin should be repeated if perspiring or if working in rainy conditions.
• Avoid areas of standing water where mosquitoes generally breed and inhabit.
• Tall grasses and brush that could harbor mosquitoes, ticks, spiders, and centipedes should be
avoided.
• Several times during the day and at the end of the day, each participant should perform a check
for evidence of imbedded ticks or previous bites. Particular attention should be paid to the
scalp, neck, ankles, back of the legs, and waist.
• When opening well covers, vaults, or other closed items, participants should watch for hornet
or wasp nests, spiders, and centipedes. Participants should never reach into spaces where they
cannot clearly see their hands and arms.
• Participants should watch carefully for stinging insects around open beverages or food.
• Participants with known allergic response to insect stings must inform the CSO and LSECS at
the beginning of each field effort and must carry an antidote kit if so advised by their physician.
• A person suspected of being stung or bitten by a centipede, spider, or a scorpion must receive
immediate medical attention. The sting of the giant Vietnamese centipede is particularly painful,
and the venom of several spiders and scorpions can cause various illnesses if not treated
properly and immediately.
Treatments
Many varieties of spiders are present in Vietnam, including the Giant Golden Orb, Yellow Sac, Grass
Cross, Jumping, and Tarantula. While their bites are painful and may require first aid and monitoring, none
are considered extremely hazardous.
The Vietnamese Giant Centipede is a poisonous, aggressive arachnid, which grows up to 20 cm in length.
One death has been reported in the Pacific as a result of a centipede sting to the head. Although not
normally a medical emergency, their sting is extremely painful and immediate treatment is required.
o Extreme swelling;
Redness;
Pain;
Face, neck or tongue swelling;
Difficulty breathing.
Seek immediate advanced medical care for the pain or for secondary infection.
Mosquitoes
Zika Virus
Causes severe birth defects and diseases in infants born to pregnant women infected with the virus.
Pregnant participants should avoid travel to Vietnam.
Of approximately 140 species of snakes identified in Vietnam, at least 37 are poisonous and potentially
harmful to humans, including:
Preventive Measures
Assume that every snake you see is poisonous. If you see a snake, avoid it.
Do not walk through tall vegetation where you cannot see your feet or the path you are walking.
Do not reach down into vegetation or any place where you cannot see your hands.
Be watchful of overhanging vegetation and do not brush against it. Many vipers live in trees and will
drop onto anyone standing or walking under overhanging limbs or vines.
If you are bitten by any kind of snake, request emergency medical assistance IMMEDIATELY.
If you are bitten, do not attempt to catch the snake. Request assistance from another person on the
site to identify the species IF POSSIBLE.
If you encounter a snake, note the location on site maps for future reference by anyone performing
site activities.
First Aid for Snake Bites
Anyone who has been bitten by a snake must be transported immediately to the nearest hospital facility
while first aid measures are administered:
Move the victim away from the area where the bite occurred. If the snake is still attached, use a stick
or other tool – NOT hands – to make it detach.
Dogs, other house pets, and bats are considered potential carriers of rabies, whether domesticated house
pets or stray/feral animals. The population of stray/street dogs in Vietnam has grown in recent years, and
encounters with them are likely on the site. Many of the dogs are feral and have always lived on streets
or in open areas. Some are also stray house pets that have been released into the area. None of the dogs
should be considered approachable, as many are not human-friendly. In addition, because they are not
properly cared for by veterinarians, they are infested with various parasites and rabies.
Parasites can be transmitted by simply touching an infected animal. Rabies can be transmitted by
transmission of saliva from the infected animal by biting or licking, or my being scratched by the animal’s
claws or nails.
Preventive Measures
Do not approach or touch any animals that approach you. Contact with the animals should be
avoided.
Report the presence of the animal to the CSO and LSECS whether or not symptoms of rabies are
present.
Note the location of any animals on site maps for future reference by anyone performing site
activities.
Do not feed or offer water to any animals on site.
If a dead animal is found on the site, do not touch it, as it could be infested with parasites.
Avoid animal droppings.
Anyone who has been bitten or scratched by an animal on site must seek immediate medical attention.
Do not attempt to capture the animal. Report the incident to Vietnamese military official present at the
Airbase.
The following section includes Safety Data Sheets (SDSs) for Dioxin (2,3,7,8-Tetrachlorodibenzo-p-Dioxin
or 2,3,7,8,-TCDD) and Arsenic Compounds. Sources are:
For the Contractor Site Walk at the Bien Hoa Airbase Area, the following are examples of the PPE
considered optional under this Site Walk HASP.
Site Walk includes only non-intrusive activities. Participants will remain in vehicles or on
improved/paved/hard-surfaced areas.
• Do not wander away from the group. Remain with your USAID escorts.
• Standing water (puddles) are to be avoided to prevent slipping and minimize spread of
sludge/soil onto clothing and boots.
• If conditions are windy, use eye protection to prevent injury by flying small debris.
• Do not enter any vegetation-covered areas or stand under trees or vines to prevent
snakebite or contamination.
• Treat all snakes as poisonous. Do not approach or attempt to handle.
• Do not approach or touch any stray animals, as they may carry parasites and rabies.
• Check your skin for ticks during and after the site walk.
• Use mosquito/tick repellent prior to site entry. Reapply as needed.
• Use sunscreen and reapply as needed.
• Report any injury to the CSO and LSECS immediately. Any break in the skin will require
attention. A first aid kit is available on site.
• In the event of thunderstorms, site walk activities will be discontinued immediately and
shelter taken in vehicles or solid structures. Do not take shelter under trees or open canopy
structures.
• In the event of dusty conditions, personnel will remain in vehicles. Site walk activities may be
cancelled if conditions persist.
• All steps will be taken to prevent heat-related illness including consumption of water, dressing
to suit weather conditions, taking breaks in air-conditioned vehicles or in shaded areas other
than under trees, and monitoring each other for signs of heat stress.
• Keep your head and neck shaded as much as possible.
• If the site is wet, any permeable materials dropped on the ground will require disposal. Gloves
will be required to retrieve such materials to place in garbage bags.
• Care shall be taken to prevent contamination of clothing, boots, and vehicle interiors during
the site walk.
• If you are injured or ill, request assistance from the SHSP immediately.
• Be watchful of others in your group. Monitor for signs of heat stress or other illness.
• Check all clothing for dust and brush it off (brushing downward and away from the face).
Assist the other members of the group is removing as much dust as possible.
• Check boots for soil or mud. Clean off as much as possible until a water source can be
located to remove with water.
• If soil or dust is sticking to clothing, remove clothing and place into plastic bag. Brush hair to
remove dust, and place brush in plastic bag with soiled clothing. Wash hands, face, and other
exposed skin with soap and water. If not available, use wet wipes. Last, change into clean
clothes and shoes (see “Before Site Walk”).
• Do not wear soiled clothing again until after laundering.
• Do not wear boots again until thoroughly clean and dry.
• Check skin and clothing for ticks. Report any tick bites and request first aid.
• Ensure that any PPE, plans, notes, books, phones, or other materials brought onto the site
are free of dust and mud.
PREPARED BY
TRIGON ASSOCIATES, LLC
1515 POYDRAS ST. SUITE 2200
NEW ORLEANS, LA 70112
USA
DISCLAIMER:
THE VIEWS EXPRESSED IN THIS PUBLICATION DO NOT NECESSARILY REFLECT THE VIEWS OF THE UNITED STATES AGENCY FOR
INTERNATIONAL DEVELOPMENT OR THE UNITED STATES GOVERNMENT.
CONTENTS
CONTENTS I
TABLES I
RECORD OF REVISIONS II
ACRONYMS AND ABBREVIATIONS III
1 SIGNATURE SHEET 1-1
2 BACKGROUND INFORMATION 2-2
2.1 PROJECT INFORMATION AND BACKGROUND 2-2
2.2 CONTAMINANT OF CONCERN 2-2
3 POTENTIAL EXPOSURE 3-3
3.1 EXPOSURE ROUTES 3-3
3.1.1 DERMAL (SKIN) CONTACT 3-3
3.1.2 INHALATION 3-4
3.1.3 INGESTION 3-4
3.1.4 OFF-SITE EXPOSURE ROUTES 3-4
3.2 SYMPTOMS OF EXPOSURE 3-5
4 MEDICAL SURVEILLANCE PROGRAM 4-5
4.1 ACTIVITY HAZARDS AND LEVELS OF PPE 4-5
4.2 LEVELS OF MONITORING 4-6
4.3 MEDICAL SURVEILLANCE PROGRAM REQUIREMENTS 4-6
4.3.1 EXAMINATION REQUIREMENTS AND FREQUENCY 4-6
4.3.2 MEDICAL SURVEILLANCE PROGRAM ORIENTATION TRAINING 4-9
4.4 BLOOD SERUM DIOXIN MONITORING 4-9
4.4.1 ASSURANCE OF CONFIDENTIALITY 4-9
4.4.2 BLOOD TEST RESULTS 4-10
5 REFERENCES 5-1
APPENDIX A. MEDICAL SURVEILLANCE PROGRAM ORIENTATION
TRAINING MATERIAL 0
APPENDIX B. DIOXIN REFERENCE LIST 0
APPENDIX C. BLOOD SERUM DIOXIN RESULT SUMMARY 0
APPENDIX D. CONSENT FORM FOR BLOOD SAMPLING AND ANALYSIS 0
APPENDIX E. FOLLOW-UP LETTER 0
TABLES
Table 4-1. Level 1 Medical Surveillance Examinations and Frequency .............................................................. 4-7
Table 4-2. Level 2 Medical Surveillance Examinations and Frequency .............................................................. 4-8
Table 4-3. Level 3 Medical Surveillance Examinations and Frequency .............................................................. 4-8
March 2020
Sal Mansour
Chief of Party
Suzanne Johnson
Contracting Officer
This Health & Safety Plan (HASP) has been prepared to meet the requirements of Government of Vietnam
(GVN) Occupational Safety and Health standards, United States Occupational Safety and Health
Administration (OSHA) standards found in Title 29 Code of Federal Regulations (CFR), Parts 1910 and
1926; and the United States (U.S.) Army Corps of Engineers (USACE) “Safety and Health Requirements
Manual” (30 November 2014 edition) (EM 385-1-1).
This Supplemental Health and Safety Plan (SHASP) has been prepared for USAID under the Task Order
72044019F00001, Contract Number AID—OOAA-1-15-00053 by the Architecture & Engineering (A&E)
Bien Hoa Contractor. This SHASP complies with the Project health and safety procedures established in
the Site-Wide HASP. This SHASP presents additional details of the Bien Hoa Medical Surveillance Program
and includes training materials for the Medical Surveillance Program Orientation. The purpose of this
document is to provide guidance and reference for the Project Contractors in the development of their
own contract-specific medical surveillance programs and describe in detail the Bien Hoa Medical
Surveillance Program. This document is not meant to replace the Site-Wide HASP but is an addition to
the Site-Wide HASP as an annex. The Site-Wide HASP and this SHASP are meant to be used in
conjunction.
The Project location is the Bien Hoa Airbase Area which includes the Bien Hoa Airbase and associated
off-Airbase locations. The Bien Hoa Airbase is an active Air Defence Air Force Command airbase located
in Bien Hoa City, Dong Nai Province, approximately 30 kilometers northeast of Ho Chi Minh City. The
Bien Hoa Airbase property is located within the Tan Phong Ward and is adjacent to the Trung Dung,
Quang Vinh, and Buu Long Wards, which are densely populated residential neighborhoods.
The Bien Hoa Airbase Area is one of three major dioxin contamination hotspots in Vietnam identified
through studies completed in the 1990s. Bien Hoa, along with Phu Cat and Danang Airport, were used by
the United States (U.S.) military for the import, storage, and loading of Agent Orange between 1961 and
1971. In 2016, USAID, in close collaboration with the GVN, completed the "Environmental Assessment
of Dioxin Contamination at Bien Hoa Airbase". The overall objective of the Environmental Assessment
(EA) was to inform potential future actions at the Bien Hoa Airbase Area to address dioxin-related
contamination. The EA serves as the primary resource documenting characterization of dioxin
contamination on and around the Bien Hoa Airbase Area (GVN/USAID 2016).
Seventeen of the dioxin and furan congeners are considered to be toxic and those are the ones with
chlorines in the 2, 3, 7, or 8 positions of their structure with 2,3,7,8-TCDD (TCDD) considered to
be the most toxic. Because of this, the concentrations of dioxins/furans are often reported in terms
of TCDD toxicity equivalents (TEQ), which are calculated using toxicity equivalence factors, and are
measures of how toxic each congener is relative to TCDD.
The primary source of TCDD at the Bien Hoa Airbase Area is dioxin-contaminated soils and
sediments from past handling, storage, and disposal of Agent Orange and other herbicide compounds.
The primary dioxin congener associated with Agent Orange is TCDD. TCDD was not intentionally
added to Agent Orange but was a byproduct produced during manufacturing. TCDD causes health
effects in humans including chloracne, birth defects, weakened immune systems, kidney defects,
increased miscarriage rates, altered hormone levels, reduced sperm production, and cancer. In
humans, dioxin is stored in body fat, blood, and breast milk. On average, serum dioxin levels will
decrease by half after seven years with no additional exposure.
3 POTENTIAL EXPOSURE
Dioxin is present at the Bien Hoa Airbase Area in soil, sediment, and surface water. Although not
water soluble or volatile, dioxin will attach to soil which becomes airborne as respirable dust, and in
surface water as suspended solids. Dioxin, whether from Agent Orange or other sources, is also
found in food sources; primarily fish, seafood, meat, and dairy products. The primary exposure
potential is anticipated to be from inhalation or direct contact with contaminated soil, sediment or
groundwater. The hazards are minimized by limiting dust-generating activities and by protecting
against skin contact with contaminated soil, sediment and water.
3.1.2 INHALATION
Inhalation exposure occurs through breathing contaminated air, respirable dust, fumes, mists, vapors,
aerosols, or particulates. Inhalation is generally the most serious route of exposure because the
inhaled contaminant can be deposited in the lungs and/or directly absorbed into the bloodstream.
Although not volatile, dioxin will attach to soil which becomes airborne as respirable dust. At the
Bien Hoa Airbase, air contaminants are of concern during dust generating activities including
excavation, earthmoving, and transport of contaminated soil as well as during treatment (thermal
treatment facility emissions). The hazards can be minimized by wearing appropriate PPE during dust
generating activities and treatment activities, implementing engineering controls to reduce dust
generation, monitoring dust and air concentrations, and filtering the thermal treatment facility
emissions.
3.1.3 INGESTION
Ingestion exposure occurs through the consumption of contaminated food, water, other liquids, soil
and sediment or mouthing of contaminated objects. Ingestion is the least likely on-site exposure route
for Project workers at the Bien Hoa Airbase Area. Accidental ingestion of contaminated soil,
sediment, groundwater, or surface water should not occur on the site if appropriate PPE is worn
during site activities. In addition, the use of lakes and ponds on the Airbase for aquaculture purposes
was banned in 2010 (GVN/USAID 2016). However, there is the potential for respirable dust, soil,
sediment, and surface water to be ingested if appropriate PPE is not worn during site activities. While
ingestion is not a major exposure pathway on the Bien Hoa Airbase, the ingestion of contaminated
food off the Airbase is the most significant exposure pathway. Off-site exposure routes are discussed
below.
• Liver damage that can be detected through changes in blood and urine, and
• Gastrointestinal disturbances.
Long-term exposure of dioxins independent of the exposure route can cause impairment to the
immune system, nervous system, endocrine system and reproductive function. Studies have also
shown that dioxin exposure is linked to several types of cancer.
The purpose of the medical surveillance program is to monitor the health of employees over the course
of the Project to ensure protective measures at the site are appropriate and are being utilized properly
by the employees. Protective measures include the use of appropriate PPE and site control measures. The
goal of the Project is to protect workers and limit or prevent their exposure to hazardous substances,
such as TCDD, that could cause adverse health effect.
Hazardous material PPE is divided into four categories based on the degree of protection afforded. The
four levels of protection (A, B, C, and D) are based on the widely used USEPA Levels, which are described
in Appendix B of the Hazwoper standard (29 CFR 1910.120 and 8 CCR 5192). Level A provides the
highest level of protection, and Level D the least. Combinations of PPE other than those described for
Levels A, B, C, and D protection may be more appropriate and may be used to provide the proper level
of protection.
Level 1 – Workers who will wear Level C PPE or more stringent for more than 30 days (8
hour days) per year while conducting site activities under any of the following conditions:
a. When exposure is at or above the permissible exposure limit (PEL) for more than 30
days per year;
b. When a respirator is worn more than 30 days per year;
c. When a worker performs site activities with a risk of exposure to a chemical without a
PEL (e.g., dioxin) for more than 30 days per year;
d. When employee is injured, ill, or develops symptoms of exposure; or
e. When employee is a member of a hazardous materials response team.
Level 2 – Workers who will wear Level D or no hazardous material PPE but will work at
the site for more than 90 days (8 hours per day) per year while intrusive and/or remedial
treatment operation activities are being conducted including:
a. Office personnel working on site;
b. Occasional site workers such as subcontractors or vendors who do not enter any
disturbed areas or exclusion zones; or
c. Personnel as designated by USAID or GVN.
Level 3 – Workers who will wear Level B or more stringent PPE for 15 days or more per
year (8 hour days) while conducting site activities with the highest risk for dioxin exposure potential.
The following schedule of examinations applies to all three levels of the medical surveillance and will
include periodic sampling based on the employee’s medical surveillance level:
• Baseline – prior to assignment at the site;
• Annual (six months for Level 3); and
• At termination of employment or reassignment to a job offsite.
Project Contractors shall include a description of their medical surveillance program orientation
training in their contract-specific medical surveillance programs. The A&E Bien Hoa Contractor’s
medical surveillance program orientation training slide deck with narration is included in
Appendix A as an example and reference for Project Contractors.
Each Project Contractor shall develop their own contract-specific medical surveillance program that
includes blood serum dioxin monitoring. The minimum requirements for blood serum dioxin
monitoring are detailed in Sections 9.18.1 and 9.18.2 of the Site-Wide HASP and discussed in Section
4.2.1 of this SHASP. Project Contractors can choose to collect more frequent blood serum dioxin
samples based on employees’ duration of work, the possible exposure potential of the task being
performed, and the concentration of dioxin at the work site. Blood serum dioxin samples should also
be collected after potential exposure incidents. Each Project Contractor’s Health and Safety
professional or occupational health physician will determine what level of exposure would trigger a
post-exposure sample.
A references list for additional background information related to dioxins in blood and blood serum
analysis is included in Appendix B. Additional background information on dioxins is also included in
the medical surveillance program orientation training slide deck and narration (Appendix A).
The information detailed above providing assurance of confidentiality will be included in a Consent
Form for Blood Sampling Analysis that participating parties of the blood serum dioxin monitoring will
sign and date prior to having their blood drawn. The consent forms will be provided in employee’s
native language. An example of a consent form is included in Appendix D.
The occupational health physician will provide the Project Contractor’s Health and Safety professional
a clearance form for each participant of the blood monitoring program that they were under the
Project action limit (30 pg/g TEQ lipid) and can begin or continue work in contaminated areas, such
as exclusion zones and decontamination areas. These clearance forms should be sent to the A&E
Bien Hoa Contractor LSECS to be shared with USAID.
If a participant of the blood serum dioxin monitoring exceeds the Project action limit or if their blood
serum dioxin level increases by 30% or more, the occupational health physician will notify the
individual participant with a detailed letter discussing their results and outlining the required additional
testing. Small changes up to ± 20% can occur without indicating an issue. The Project Contract Health
and Safety professional will be notified that the participant either exceeded the Project action limit
or had a marked increase in blood serum dioxin levels and required additional testing. These
notification letters should be sent to the A&E Bien Hoa Contractor LSECS to be shared with USAID.
4.4.2.2 ACTIONS
If baseline blood serum dioxin results are above the Project action limit, the occupational
health physician will be consulted for recommend further action, which could include:
o Determination of symptoms,
o Liver and kidney function screening, or
o Dermal assessment
• Employee consultation with the examining occupational health physician to understand the
sampling results and related health risks,
• Sampling and analysis to confirm serum dioxin level,
• Additional or more frequent health monitoring over an extended period,
• Recommendation that the employee be restricted from performing tasks with potential dioxin
exposure, or
• Recommendation that the employee does not begin work on the site.
If interim (including post-exposure incident) or exit blood serum dioxin sampling results
exceed the Project action limit or indicate an increase of 30% or more, the occupational health
physician will be consulted for recommended further action, which could include:
• Identification of which dioxin congener is the source of the elevated levels by comparing the
congener-specific concentrations to the 95th percentiles,
• Further blood testing and analysis to assess general health condition,
o Determination of symptoms,
o Liver and kidney function screening, or
o Dermal assessment
• Employee consultation with the attending occupational health physician to understand the
sampling results and related health risks,
• Sampling and analysis to confirm serum dioxin level,
• Additional or more frequent health monitoring over an extended period,
• Recommendation that the employee be assigned to another task,
• Recommendation that the employee be restricted from performing tasks with potential dioxin
exposure, or
• Recommendation that the employee stop working on the site.
Hatfield and Office 33. 2011. Environmental and Human Health Assessment of Dioxin
Contamination at Bien Hoa Airbase, Vietnam.
Hatfield and VRTC. 2009. Evaluation of Contamination at the Agent Orange Dioxin Hot Spots in
Bien Hoa, Phu Cat and Vicinity, Vietnam.
USAID/Trigon. 2020. Architect-Engineer Services for Dioxin Remediation at Bien Hoa Airbase Area
Project (Revised) Draft Technical Memorandum Site Conceptual Model and Data Gap Analysis.
1
PURPOSE OF THIS PRESENTATION
• Overview of the Medical Surveillance Program including…
– Health Risk Communication
– Risk Management
– Medical Surveillance Program
– Potential Exposure
– Dioxin Hazard Communication
– Frequently Asked Questions
• Introduction to Risk
• How a Health Risk is Determined
• Introduction to Health Risk Communication
• Health Risk
• Hazard Toxicity
Introduction to Risk
• Risk is an intrinsic part of life; any activity has some associated risk
• For a risk to exist there needs to be some kind of hazard or danger
(e.g., chemical, explosive, mechanical)
• Risk (likelihood) of harm (effect or outcome)
RISK
How great
HAZARD the chance
Anything that that someone
can cause harm (e.g., dioxin will be
contamination, electricity, harmed by
ladders, etc.) the hazard
Health Risk
• Represents the probably (or possibility) that a health effect can occur
after exposure
HEALTH
HAZARD EXPOSURE RISK
to anything that may cause a health How great the
effect (e.g., dioxin, smoking chance that a
cigarettes, etc.) health effect will
occur
Health Effect
• These can vary in severity, duration, and reversibility (among others)
• For a disease, you may have heard the term health outcome
Public Health
Expertise
Public Health
Research
Resources
Hazard Toxicity
• What are the adverse biological effects caused by a chemical, physical,
or biological agent (hazard)?
• How poisonous or toxic is it?
• How will it cause me harm?
Project Objective
• Project Safety
Goal = Zero
Injury!
• Prevent/limit
exposure of
dioxin to levels
below those that
are likely to have
health effects
Levels of Monitoring
• Based upon nature of work activities, activity hazard analysis (AHA), and
required PPE
• Four PPE levels of protection from hazardous materials (A, B, C, & D):
– Level A highest level of protection
– Level D the lowest
– Based upon USEPA Hazwoper standard (29 CFR 1910.120 and
8 CCR 5192).
• Level of PPE determined through AHA and may change based on new
information.
Type of Examinations
Level 1 and Level 3 Examination:
• Baseline medical and work history questionnaire with updates
completed annually or as triggered by exposure or injury event
• Hazardous substance handling history
• Blood testing
– Complete blood count (CBC) / Sequential Multi-Channel Analysis
– Serum dioxin with Health / Lifestyle questionnaire
Assurance of Confidentiality
• Consent form will be signed before blood is drawn
– Will be written in native language
• Anonymous Employee Identification Number will be assigned
– Only the person drawing the blood and the occupational health
physician will know the Employee Identification Number
• Dioxin 101
– Sources
– Properties
– Major Site Exposure Routes
– Off-site Exposure Routes
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AEA (AEA Technology plc). 1999. Compilation of EU Dioxin Exposure and Health Data. Task 7 ‐
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Chlorinated Dibenzo-p-Furans. Agency for Toxic Substances and Disease Registry, U.S. Department
of Human Health Services.
ATSDR. 1998. Toxicological Profile for Chlorinated Dibenzo-p-Dioxins. Agency for Toxic
Substances and Disease Registry, US Department of Health and Human Services.
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Available at https://www.cdc.gov/biomonitoring/DioxinLikeChemicals_FactSheet.html. April.
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Srogi, K. 2008. Levels and congener distributions of PCDDs, PCDFs and dioxin‐like PCBs in
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Notes:
1 - Sample results reported using pg/g on a lipid weight basis and WHO 2005 TEFs
2 - Sample results reported using pg/g on a lipid weight basis, with ND=1/2 RL and WHO 2005 TEFs
3 - Lipid % is a number used to determine the amount of actual dioxin in a person’s body. It is taken from the blood analysis from the lab and is the percent of lipid in a defined amount of sample. The results are corrected based on the lipid number.
Total TEQ concentration is under Project Action Limit (30 pg/g)
2,3,7,8-TCDD or Total TEQ concentration increased by 30% or more
Total TEQ concentration is above Project Action Limit (30 pg/g)
Notes:
1 - Sample results reported using pg/g on a lipid weight basis and WHO 2005 TEFs
2 - Sample results reported using pg/g on a lipid weight basis, with ND=1/2 RL and WHO 2005 TEFs
3 - Lipid % is a number used to determine the amount of actual dioxin in a person’s body. It is taken from the blood analysis from the lab and is the percent of lipid in a defined amount of sample. The results are corrected based on the lipid number.
Total TEQ concentration is under Project Action Limit (30 pg/g)
2,3,7,8-TCDD or Total TEQ concentration increased by 30% or more
Total TEQ concentration is above Project Action Limit (30 pg/g)
This is to certify that I consent to and authorize the A&E Bien Hoa Contractor to collect my blood for
analysis of dioxin as part of the Blood Serum Dioxin Monitoring Program delineated in the Dioxin
Remediation at Bien Hoa Airbase Area Project Site-Wide Health and Safety Plan (HASP), Sections 9.18.1
and 9.18.2.
I understand that the venipuncture process involves a small medical risk and may result in bruising
around the area from which the blood is taken.
I understand that the results of this test will be provided only to me and to the designated responsible
Occupational Health Physician. My name will not be associated with any laboratory results, sample
containers, or other materials or information. However, the A&E Bien Hoa Contractor will compile
anonymous blood sample results that will be shared with USAID.
If results are outside of the action limits stated in the aforementioned Project Site-Wide HASP, I will
be notified by the Occupational Health Physician and given the opportunity to discuss the results and
determine further actions required.
I understand that, as with medical testing of any nature, the potential for falsely elevated, lowered,
positive, or negative laboratory values is present.
Patient’s Name
Date
(printed)
Email or phone
Patient’s Signature
(for results)
THIS SECTION FOR USE BY SAMPLER ONLY
[Date]
Based on your work activities during the remediation of dioxin at the Bien Hoa Airbase Area, you are required
to participate in a medical monitoring program to document the levels of dioxin in your blood. A sample of your
blood was collected and sent for analysis to the Center of Analytical Services and Experimentation HCMC
(CASE), a division of Ho Chi Minh City Department of Sciences and Technology with financial independence,
an ISO 17025, ISO 14001:2015 and IQNET certified laboratory that conducts analysis of human blood and
other environmental samples. The purpose of this letter is to provide the results of your blood chemistry
analysis.
Dioxins are absorbed by fat, so concentrations of different dioxins are presented as parts per trillion (ppt) of
dioxin on a lipid‐weight basis (i.e., based on how much fat is in the blood sample) and are summarized as a
total value called Toxic Equivalents (TEQ).
The American Chemistry Council (ACC) has developed a guideline value of 30 ppt in human serum lipid that
may be used for comparative purposes in various populations. However, as noted below, results may vary
significantly among individuals from different countries, and based on other factors such as work history, diet,
age, health status and age. The ACC guideline is based on the World Health Organization’s (WHO) Tolerable
Daily Intake guidelines (1998).
The following is a summary of your baseline (if applicable) and follow‐up Total Dioxin results for comparison
purposes:
There is no current standard of comparison to quantify the health risk of varying levels of dioxins and furans
found in the human body. The ACC Guideline is general and should not be interpreted as a health-based
standard. Actual blood serum dioxin levels vary significantly among individuals.
The most important consideration is the potential change in a person’s blood serum dioxin level over time. Small
changes may be expected and are not cause for concern. The analytical method may also produce up to a 20
percent difference between readings and can be influenced by one’s blood chemistry at the time of sampling.
Lipid levels can change from day-to-day or even meal-to-meal because blood lipid content is closely linked to diet.
Please contact your Contractor Safety Officer (CSO) if you would like to discuss the results in greater detail.
You may also wish to share this information with your personal physician if you have specific personal medical
questions.
1 2, 3, 7, 8‐TCDD is the dioxin of concern to the site due to its association with Agent Orange.
2 TEQ is a measure of all dioxin compounds together including 2, 3, 7, 8‐TCDD.
ANNEX 4 – SITE-WIDE ENVIRONMENTAL MITIGATION AND
MONITORING PLAN (SWEMMP) INCLUDING THE SITE-
WIDE STORMWATER POLLUTION PREVENTION PLAN
(SWPPP)
SITE-WIDE ENVIRONMENTAL
MITIGATION AND MONITORING PLAN
(SWEMMP)
SITE-WIDE ENVIRONMENTAL
MITIGATION AND MONITORING
PLAN (SWEMMP)
PREPARED BY
TRIGON ASSOCIATES, LLC
1515 POYDRAS ST. SUITE 2200
NEW ORLEANS, LA 70112
USA
DISCLAIMER
THE VIEWS EXPRESSED IN THIS PUBLICATION DO NOT NECESSARILY REFLECT THE VIEWS OF THE UNITED STATES AGENCY
FOR INTERNATIONAL DEVELOPMENT OR THE UNITED STATES GOVERNMENT.
CONTENTS
USAID STANDARD METADATA ........................................................................................................................ IV
LIST OF ACRONYMS AND ABBREVIATIONS ................................................................................................. V
1 PURPOSE ................................................................................................................................................................ 1
1.1 BASIS OF EMMP .......................................................................................................................................... 1
1.2 USAID TEMPLATE EMMP ......................................................................................................................... 3
1.3 SWEMMP ORGANIZATION................................................................................................................... 3
1.4 SWEMMP REVIEW AND AMENDMENT ............................................................................................. 4
2 PROJECT SUMMARY .......................................................................................................................................... 5
2.1 PROJECT OWNER AND IMPLEMENTING AGENCIES .................................................................. 5
2.2 PROJECT ACTIVITIES AND POTENTIAL NEGATIVE ENVIRONMENTAL IMPACTS .......... 5
2.3 ROLES AND RESPONSIBILITIES FOR SWEMMP IMPLEMENTATION ....................................... 6
2.4 ACTIVITY-LEVEL EMMPS ......................................................................................................................... 7
3 SITE-SPECIFIC INFORMATION ....................................................................................................................... 8
4 ANNUAL REPORTING .................................................................................................................................... 10
5 SWEMMP TABLES WITH DETAIL ................................................................................................................ 11
5.1 WATER QUALITY.................................................................................................................................... 11
5.2 AIR QUALITY ............................................................................................................................................ 12
5.3 AMBIENT NOISE / VIBRATION ........................................................................................................... 13
5.4 GREENHOUSE GASES (GHG) EMISSIONS / WEATHER.............................................................. 13
6 REFERENCES ....................................................................................................................................................... 15
TABLES ...................................................................................................................................................................... 1
TABLE 1A. WATER QUALITY – MITIGATION AND MONITORING .............................................. 1
TABLE 1B. AIR QUALITY – MITIGATION AND MONITORING ..................................................... 11
TABLE 1C. AMBIENT NOISE AND VIBRATION – MITIGATION AND MONITORING........... 19
TABLE 1D. GREENHOUSE GAS (GHG) EMISSIONS AND WEATHER – MITIGATION AND
MONITORING .......................................................................................................................................... 23
TABLES
Table 1A Water Quality – Mitigation and Monitoring
Table 1A.1 ……. Surface Water Quality Monitoring Locations
Table 1A.2 ……. Surface Water Quality Monitoring Parameters, Methods, Project Action Limits, and
Frequencies
Table 1A.3 ……. Groundwater Quality Monitoring Locations
Table 1A.4 ……. Groundwater Quality Monitoring Parameters, Methods, Project Action Limits, and
Frequencies
Table 1A.5 ……. Process Water Monitoring Locations
Table 1A.6 ……. Process Water Monitoring Parameters, Methods, Project Action Limits, and Frequencies
FIGURES
Figure 1A Water Quality Monitoring Locations
Figure 1B Air Quality and Weather Monitoring Locations
Figure 1C Ambient Noise/Vibration Monitoring Locations
ANNEX
SITE-WIDE STORMWATER POLLUTION PREVENTION PLAN (SWPPP)
ORGANIZATIONAL/ADMINISTRATIVE DATA*
*Standard metadata fields for the USAID Environmental Compliance Database (ECD) and planned
Development Information System (DIS).
40 CFR 216.8, Monitoring, requires “to the extent feasible and relevant, projects and programs
for which Environmental Impact Statements (EISs) or Environmental Assessments (EAs) have been
prepared should be designed to include measurement of any changes in environmental quality,
positive or negative, during their implementation. This will require recording of baseline data at the
start. … Monitoring implementation of projects, programs and activities shall take into account
environmental impacts to the same extent as other aspects of such projects, programs and activities.”
Together the Government of Vietnam (GVN) and USAID prepared an Environmental Assessment
(EA) for the Dioxin Contamination at Bien Hoa Airbase in 2016 that documents the nature and
extent of dioxin contamination at the Bien Hoa Airbase Area and evaluated five major remedial
alternatives ranging from no action through complete containment to complete treatment.
“Given the current and foreseen land use of a large majority of the contaminated area as a military
airbase, a hybrid alternative that treats the highest risk material and contains all other excavated
material is a reasonable option that balances USG and GVN regulatory preferences for treatment
with more practical, lower cost options for management of the lower risk material (GV/UASID 2016).”
For all alternatives, the EA identified potential environmental impacts, mitigation measures, made
a determination of significance, and then presented a preliminary conceptual EMMP.
The Ministry of National Defence (MND) / Air Defence – Air Force Command (ADAFC), with
limited USAID engagement 1, conducted an EIA, identified the preferred alternative as EA
Alternative 4, and developed the 2019 Report of Environmental Impact Assessment (EIA)
outlining two phases of the Project:
- Project Phase 1 - focusing on remediation of the Pacer Ivy Area at Bien Hoa Airbase; and
The EIA provides data on water, air, and soil quality, addresses Project activities, and the
environmental mitigation measures and monitoring actions to be implemented during Project
activities. The EIA was approved by the Ministry of Natural Resources and Environment
(MONRE) in Decision No. 702/QD-BTNMT, Approval of Environmental Impact Assessment
Report, the Dioxin Remediation at Bien Hoa Airbase Area Project, dated March 25, 2019.
Subsequent to the EIA, MND Decision No. 3869/QD-BQP on Approval of the Investment project
and the plan for selection of the “Dioxin Remediation in Bien Hoa Airbase – Phase 1” Project
with non-refundable Official Development Assistance from the United States of America, was
made on September 6, 2019. This Decision (Project Approval) required the implementation of
environmental protection measures and environmental monitoring, as well as the utilization of
appropriate construction and management methods to mitigate pollution during Project
implementation. The Project Approval specifically addresses ensuring compliance with air quality
and air emission standards, noise and vibration standards, and water quality and water discharge
standards.
On June 19, 2019, the USAID/Vietnam Mission Director approved and the USAID Asia Bureau
Environmental Officer concurred on an Initial Environmental Examination (IEE) for the Dioxin
Remediation at Bien Hoa Airbase Area Project (reference number ASIA-19-052). The IEE
requires Activity-specific EMMPs to address environmental mitigation measures and monitoring
actions to be implemented during all Project interim measures, treatment, and civil works
activities.
The IEE further specifies that the Activity-Specific EMMP’s must be reviewed by the relevant
Contracting Officer’s Representative (COR), the USAID/Vietnam Mission Environmental Officer
(MEO), Climate Integration Lead (CIL), and the Regional Environment Adviser (REA) before BEO
concurrence is sought. Finally, the IEE specifies that no interim measures, treatment, or civil
works efforts will proceed without BEO concurrence on the relevant EMMP. In addition to this
required USAID internal review and approval process, USAID/Vietnam will share the Site-wide
1
Award of an Architect and Engineering Services contract did not occur until after the GVN EIA and
report were complete.
2. Monitoring indicators. Criteria that demonstrate whether mitigation measures are suitable
and implemented effectively.
The USAID EMMP template contains a standard page for USAID metadata (to facilitate USAID
tracking) and section headings for:
- Project/Activity Summary;
- Site-specific Information;
- Annual Reporting; and
- EMMP Table for Project Activity(ies).
The EMMP table has standard column headings for Project/Activity/Sub-Activity, Identified
Environmental Aspects/Impacts, Mitigation Measures, Monitoring Indicators, Monitoring and
Reporting Frequency, Responsible Parties, and Field Monitoring/Issues.
- Section 1, Purpose
- Section 2, Project/Activity Summary
- Section 3, Site-specific Information
- Section 4, Annual Reporting
EMMP tables developed for this SWEMMP are referenced within Section 5 and collectively
presented as an Attachment. Supporting figures to these tables are also collectively presented as
an Attachment.
Accordingly, this SWEMMP will be reviewed by the A&E Bien Hoa Contractor annually, in
conjunction with the development of the Activity Annual Work Plan (AWP) and in consideration
of Project plans, designs, and monitoring and results. USAID will update and amend this SWEMMP
as warranted, including updates to maintain conformance with the GVN/MND EIA. The A&E Bien
Hoa Contractor must also discuss the SWEMMP implementation and any recommended updates
during quarterly technical review meetings held with USAID to gain agreement on any resulting
amendments.
A Record of Revisions page is included as a forward to this SWEMMP. The Record of Revisions
page documents the conduct of SWEMMP reviews and any resulting amendments.
MND expectations for Project Phase 1 activities are described in Decision No. 3869/QD-BQP
as:
- Excavation and on-Airbase thermal treatment of approximately 150,000 cubic meters (m3) of
dioxin-contaminated soils and sediments from different decision units (DUs) with dioxin
concentrations at or above 1,200 parts per trillion (ppt) Toxicity Equivalent (TEQ) to below
a 100 ppt remedial treatment threshold;
Phase II activities would address the remaining dioxin-contaminated soils and sediments.
MND is the GVN Project Owner assigned by Prime Minister decision for the Project. Through
Decision No. 3869/QD-BQP, MND assigned ADAFC as the GVN Project Management Unit and
the lead GVN agency responsible for ensuring Project activities are conducted in accordance with
applicable or relevant and appropriate requirements (ARARs) and with established Project plans
and procedures.
1. Preparation;
2. Construction;
3. Remediation Operations; and
4. Environmental Restoration.
EIA Chapter 4 addresses measures to mitigate potential negative impacts. Negative impacts
identified in the EIA relate to a broad range of concerns, not just environmental, to include
minimizing dioxin exposure and ensuring worker health and safety, unexploded ordinance
clearance, gender, minimizing impacts to Airbase activities and operations, accident and fire
prevention, flight safety, and others. The EA identified potential negative impacts from unexploded
ordnance clearance, solid waste generation, recontamination of treated lakes, and resettlement
as additional potential impacts as well as potential negative effects to groundwater. Potential
negative environmental impacts in MND’s EIA identified with respect to Project activities
generally relate to:
EIA Chapter 5 presents a planned management and supervision program addressing the range of
potential negative environmental impacts. USAID will specify how the EIA-identified potential
non-environmental impacts are addressed in the Site-Wide Health & Safety Plan (HASP) and
Activity-level Waste Management Plans. Dong Nai Province will address others in their local
resident resettlement plans for off-base work areas.
The environmental mitigation measures and monitoring actions presented in this SWEMMP are
organized by the EIA project activities (Preparation, Construction, Remediation Operations, and
Environmental Restoration) and the associated potential negative environmental impacts (see
Section 5).
USAID has or will procure the services of Implementing Contractors to execute Project activities
(e.g., excavation and temporary storage of soils/sediments from targeted Decision Units [DUs],
construction of Long-term Storage Area [LTSA] for soils/sediments, and the construction and
operation of thermal treatment facility). USAID will require all Implementing Contractors to
implement Activity-level monitoring and/or mitigation measures in accordance with this
SWEMMP for remedial construction activities. USAID will either require individual Implementing
USAID will direct the A&E Bien Hoa Contractor to review and comment on any Implementing
Contractor developed Activity-level EMMPs to ensure consistency with this SWEMMP. USAID
will also provide any environmental monitoring observations, data, and/or results from
Implementing Contractors’ environmental monitoring actions to the A&E Bien Hoa Contractor
to allow for monitoring of EMMP implementation progress and in support of SWEMMP annual
reporting (Section 4).
The TM SCM and DGA (USAID 2020a) describes the Bien Hoa Airbase Area site definition
and environmental setting, sources of contamination and distribution, migration pathways and
exposure routes, and sensitive receptors. Salient conclusions of the SCM relevant to the
implementation of environmental mitigation measures and monitoring actions contained in this
SWEMMP include:
- Secondary sources of dioxin contamination remain at the Bien Hoa Airbase Area in the
form of dioxin-contaminated soils/sediment, with a significant fraction in the Pacer Ivy and
Z1 areas.
- Groundwater flow is not a significant physical transport mechanism as dioxin is not very
soluble and is prone to partitioning to organic solids.
The Tabulated Summary of ARARs (USAID 2020b) forms a basis for establishing programs
and procedures to achieve and maintain regulatory compliance during Dioxin Remediation of
the Bien Hoa Airbase Area Project implementation. USAID reached consensus with GVN
stakeholders on these ARARs during the February 27 – 28, 2020 Masterplan Roadmap Meeting
3 and through subsequent communications clarifying applicability of certain ARARs. All Project
activities must be conducted in accordance with the ARARs.
ARARs support the development of the environmental mitigation measures contained in this
SWEMMP and are directly relevant to the establishment of the environmental monitoring
frequencies, parameters, methods, and thresholds. Where appropriate, ARARs are referenced
in the presentation of SWEMMP environmental monitoring actions (see Section 5).
The Initial Site-wide HASP (USAID 2019) provides a comprehensive health and safety plan
and procedures that apply to all Project activities, including site preparation, construction,
remediation operations, and environmental restoration. USAID requires compliance with this
Site-Wide HASP by Project Contractors and personnel. The Initial Site-wide HASP clearly
presents exposure mitigation measures and personal and other monitoring with respect to
ensuring the health and safety of all Project workers. The Initial Site-wide HASP provides
activity-specific hazard analyses, work practices and engineering controls, personal protective
equipment, monitoring and inspection, and medical surveillance, to include blood serum dioxin
monitoring.
A CQA is to be prepared by the engineer of record for each Project design activity funded by
USAID during Project implementation. Relevant to the environmental mitigation measures and
monitoring actions contained in this SWEMMP, the CQA provides: descriptions of inspection
activities, including tests and observations used to monitor construction practices; construction
monitoring requirements, to include documentation and reporting requirements; and control
procedures for ensuring that inspection, measuring, and testing equipment are properly
calibrated by qualified technicians at specific frequencies to maintain accuracy within required
tolerances.
Annually, the USAID A&E Bien Hoa Contractor will prepare an Environmental Mitigation and
Monitoring Report (EMMR) to be submitted to the USAID Contracting Officer’s Representative
(COR).
EMMRs will be submitted to the USAID COR by September 1st of each calendar year (coinciding
with the submission of the USAID A&E Bien Hoa Contractor AWPs). EMMRs are to address, but
are not limited to, the following content:
- Summary of engagement with MND on the SWEMMP, including summary of MND monitoring
activities, frequency of data sharing between MND and USAID, any issues MND has raised,
and how they were/are being resolved.
As appropriate, attachments supporting EMMR content will be included with the submissions.
The SWEMMP tables also specify Project Action Limits for all monitored environmental
parameters. USAID will require all contractors to halt their operations and implement additional
mitigation measures if monitoring results suggest that any Project Action Limit is being exceeded
as a result of Project activities. USAID will only allow operations to resume when implemented
mitigation measures suggest that Project Action Limits will no longer be exceeded as a result of
Project activities.
Critical to the environmental mitigation measures and monitoring actions to prevent negative
impacts to water quality is the Site-wide Stormwater Pollution Prevention Plan (SWPPP) for the
Project (see Annex). The Site-wide SWPPP for the Project addresses discharges during and post
remedial construction until such sites are considered stabilized. The Site-wide SWPPP identifies
potential sources of stormwater pollution based on Project activities and requires the
implementation of erosion and sediment control best management practices (BMPs), good
housekeeping practices, training, and inspection, maintenance, and record keeping measures. Any
Activity-level SWPPPs and Activity-level EMMPs must be consistent with the Project Site-wide
SWPPP and include environmental mitigation measures and monitoring actions to prevent
negative impacts to water quality specific to the activities of all Implementing Contractors.
Table 1A provides the site-wide environmental mitigation measures and monitoring actions for
potential impacts to water quality relevant to Project activities.
Tables 1A.1 through 1A.6 are referenced from within Table 1A and provide monitoring locations
and frequencies as well as monitoring parameters, methods, and Project Action Limit references.
Tables 1A.1 through 1A.6 provide the minimum monitoring frequencies and monitoring
parameters for Activity-level EMMPs. Activity-level EMMPs may include the installation and
monitoring of additional groundwater monitoring wells in support of Activity-specific
groundwater monitoring. These tables note several deviations from the monitoring called for in
the GVN EIA. In some cases, USAID is proposing more frequent monitoring than called for in
The Bien Hoa Airbase encompasses an area of approximately 1,000 hectares (ha) immediately to
the east and northeast of the Dong Nai River. Elevations on the Airbase range from 4 to 30
meters (m) with a general topographic slope to the west and south towards the tidally influenced
Dong Nai River, and a major southwest-northeast-oriented drainage divide cross cutting the
Airbase (USAID 2016). The elevation of the Dong Nai River varies between -2.00 and +2.08
meters above sea level (Data for Dong Nai River at Bien Hoa from 2007 through 2015,
http://lvsdongnai.cem.gov.vn). There are three major catchments on the Airbase. Drainage from
on-Airbase to off-Airbase areas generally flows west from the Pacer Ivy Area, west and partly
south from the Southwest Area and Z1 Area, and southeast from the Southeast Area and
Northeast Area, with the respective drainage waterways eventually leading to the tidally
influenced Dong Nai River. Stormwater runoff is identified as a significant dioxin migration
pathway (USAID 2020a), in particular along drainage paths from the Pacer Ivy Area to adjacent
off-Airbase land areas. Stormwater discharging from the Pacer Ivy Area to the surrounding land
areas is through a rock gabion structure into a drainage canal that equipped with a rock weir near
its confluence with the Dong Nai River.
Figure 1A shows site-wide water quality monitoring locations which were chosen to capture the
major discharges from the Airbase that are anticipated to have potentially significant Project
activities upstream.
Ambient air quality monitoring will be conducted on a Site-wide basis using active air monitoring
equipment that operate for 24-hours up to 7-day intervals on an established schedule.
Table 1B provides the site-wide environmental mitigation measures and monitoring actions for
potential impacts to air quality relevant to Project activities.
Tables 1B.1 through 1B.5 are referenced from within Table 1B and provide monitoring locations
and frequencies as well as monitoring parameters, methods, and Project Action Limit references.
Tables 1B.1 through 1B.5 provide the minimum monitoring frequencies and monitoring
parameters for Activity-level EMMPs.
Climate at the Bien Hoa Airbase area is described in the EIA (MND/ADAFC 2019). Bien Hoa
Airbase is in an area of Asian monsoon tropical climate; influenced by the Northeast monsoon
and Southwest monsoon and the Pacific Ocean tropic atmosphere from April to October with
two distinct rainy and dry seasons. The rainy season lasts 6 to 7 months, from approximately 1
May through 1 December. The main wind directions during the dry season are to the South and
Southeast; whereas, during the rainy season is to the Southwest. Maximum wind speeds range
from 3 meters per second (m/s) to 7 meters per second (m/s). Wind direction and speed are
graphically summarized on Figure 1B.
Table 1C provides the site-wide environmental mitigation measures and monitoring actions for
potential impacts to ambient noise/vibration relevant to Project activities.
Tables 1C.1 and 1C.2 are referenced from within Table 1C and provide monitoring locations and
frequencies as well as monitoring parameters, methods, and Project Action Limit references.
Tables 1C.1 and 1C.2 provide the minimum monitoring frequencies and monitoring parameters
for Activity-level EMMPs. Figure 1C shows site-wide ambient noise / vibration monitoring
locations that were chosen based on potentially significant Project activities occurring nearby and
that are in close proximity to residents outside the Airbase.
As previously noted, Bien Hoa is in an area of Asian monsoon tropical climate; influenced by the
Northeast monsoon and Southwest monsoon and the Pacific Ocean tropic atmosphere from
April to October with two distinct rainy and dry seasons. The rainy season lasts 6 to 7 months,
from approximately 1 May through 1 December. Rainfall during the rainy season accounts for
approximately 80 percent (%) of the annual total rainfall, with rainfall intensities increasing
gradually from the beginning of the season in June to the middle of the season, and peaking in the
concluding month of November. With respect to climate change, the EA (USAID 2016)
documents that current long-term predictions are: for an increase in mean annual temperature
and mean annual precipitation of 1 degree Celsius and 0.7%, respectively, by 2050 for the southern
portion of the Dong Nai Province; that Bien Hoa City and the Dong Nai Province will be relatively
unaffected by inundation from sea level rise occurring as a result of climate change; and that
higher-intensity typhoons and extreme weather events may become more frequent.
USAID will establish a single weather station (temperature, relative humidity, wind speed and
direction, precipitation, and barometric pressure) at the Dioxin Remediation of the Bien Hoa
Airbase Area Project Office in support of site-wide monitoring. Weather station data collection
Table 1D provides the site-wide environmental mitigation measures and monitoring actions for
potential impacts to GHG emissions resulting from Project activities.
Tables 1D.1 and 1D.2 are referenced from within Table 1D and provide the weather monitoring
location and frequency as well as weather monitoring parameters.
Figure 1D shows the weather monitoring station located at the Project field office.
MND. 2019. Decision No. 3869/QD-BQP on Approval of the Investment project and the plan
for selection of the “Dioxin Remediation in Bien Hoa Airbase – Phase 1” Project with non-
refundable Official Development Assistance from the United States of America, September 6,
2019
MND/ADAFC. 2018. Project Pre-Feasibility Report, Dioxin Remediation at Bien Hoa Airbase
Area Phase I. October 2018.
MND/ADAFC. 2019. Report of Environmental Impact Assessment for the Dioxin Remediation
at Bien Hoa Airbase Area Project. February 27, 2019.
USAID (Trigon Associates, llc). 2019. Initial Site-Wide Health and Safety Plan. December 5, 2019.
USAID (Trigon Associates, llc). 2020a. Technical Memorandum Site Conceptual Model and Data
Gaps Analysis. May 2020.
USAID (Trigon Associates, llc). 2020b. Tabulated Summary of Applicable or Relevant and
Appropriate Requirements (ARARs). May 2020.
USAID (Trigon Associates, llc). 2020c Initial Site-Wide Sampling and Analysis Plan–Quality
Assurance Project Plan. May 2020.
LOCATION
DESCRIPTION
REFERENCE
SURFACE1 West from Northern Edge of Runway
SURFACE2 West from PI Area toward Dong Nai River
SURFACE3 Southwest from PI Area toward Buu Long Ward
SURFACE4 South from SW & Z1 Areas toward Quang Vinh Ward
SURFACE5 South from NE Area toward Tan Phong Ward
SURFACE6 Bao Hang River entering NE Area from the North
SURFACE7 South from Z1 Area toward Trung Dung Ward
SURFACE8 Channel entering NE Area from the East
Dewatering Discharge To Be Determined – Point of discharge with reasonable potential to impact
surface water quality
See Figure 1A
LOCATION
DESCRIPTION
REFERENCE
MW1 (Existing) Monitoring Well 1
MW5 (Existing) Monitoring Well 5
MW6 (Existing) Monitoring Well 6
MW8 (New Installation) Monitoring Well 8
MW9 (New Installation) Monitoring Well 9
MW10 (New Installation) Monitoring Well 10
See Figure 1A
POTENTIAL
NEGATIVE MONITORING MONITORING AND
SUB-ACTIVITY MITIGATION MEASURES RESPONSIBLE PARTIES
AIR QUALITY INDICATOR REPORTING FREQUENCY
IMPACT
Preparation and Construction
Site-wide Detrimental Changes Establish pre-construction ambient air quality conditions (baseline) and Tables 1B.1 and 1B.2 Tables 1B.1 and 1B.2 USAID A&E Bien Hoa
Monitoring from Baseline initiate site-wide ambient air quality monitoring. Contractor
Conditions
Activity-level Detrimental Changes Activity-level EMMPs will include air quality monitoring. Minimum Tables 1B.1 and 1B.2 Tables 1B.1 and 1B.2 Implementing Contractor, or
Monitoring from Baseline monitoring parameters and frequencies for Activity-level EMMPs are A&E Bien Hoa Contractor as
Conditions specified in the referenced tables. directed by USAID
Clearing Site and Dust; Excavation is to be done according to an Excavation Plan; excavated areas Compliance with Monitoring and reporting as per Implementing Contractor;
Excavating Vehicle/Equipment are to be frequently watered or sprayed for dust control with water or a Project CQA Plan and Project CQA Plan and Activity- USAID A&E Bien Hoa
Contaminated Exhaust Emissions biodegradable dust suppressant; used oil or other oils are not to be used as Activity-level level CQC Plan. Contractor CM oversight
Soils/Sediments dust suppressants; exposed soils/sediments are to be covered after each Construction Quality
excavation activity workday or during other periods of low excavation Control (CQC) Plan.
activity.
All vehicles and construction equipment are registered as appropriate and
meet GVN / Vietnam Register emission standards; vehicles and
construction equipment are to be routinely inspected and properly
maintained.
Activities are to be conducted during favorable weather conditions (low
wind conditions, <30 kilometers / hour); during unfavorable weather
conditions activities generating dust are to be avoided.
Transporting Dust; Transportation of contaminated soils/sediments is to be done according to Compliance with Monitoring and reporting as per Implementing Contractor;
Contaminated Vehicle/Equipment an Excavation Plan that designates haul routes. Project CQA Plan and Project CQA Plan and Activity- USAID A&E Bien Hoa
Soils/Sediments Exhaust Emissions All transport vehicles are registered as appropriate and meet GVN / Activity-level CQC level CQC Plan. Contractor CM oversight
Vietnam Register emission standards; vehicles and construction equipment Plan.
are to be routinely inspected and properly maintained.
Exposed soils/sediments in transport vehicles are to be covered while being
transported to avoid windblown dust; transport vehicles to remain on
designated haul routes and limits speeds to Airbase speed limits; transport
vehicles are to avoid unnecessary idling; surfaces of designated haul routes
are frequently watered or sprayed for dust control with water or a
biodegradable dust suppressant.
Stockpiling/Placing Dust; Same as described for Clearing Site and Excavating Contaminated Same as above. Same as above. Implementing Contractor;
of Contaminated Vehicle/Equipment Soils/Sediments above. USAID A&E Bien Hoa
Soils/Sediments Exhaust Emissions Stockpiled contaminated soils/sediments are to be watered or sprayed for Contractor CM oversight
dust control.
Stockpiled contaminated soils/sediments are to be covered daily.
LOCATION
DESCRIPTION OCCURRENCE
REFERENCE
AIR1 Background Location/Airbase Interior Project Duration
AIR2 Long-Term Storage Area When Project activities in the area
AIR3 Downwind of Pacer Ivy/near Binh Hoa Ward (or anticipated during the month/quarter)
LOCATION
DESCRIPTION
REFERENCE
T Emission Point, TCH Treatment Plant
T–N Northern perimeter
T–E Eastern perimeter
T–S Southern perimeter
T–W Western perimeter
Locations to be determined
MONITORING FREQUENCY
EMISSION POINT PROJECT ACTION LIMIT
WHEN POTENTIAL IMPACT FROM
PARAMETER (STACK) TEST (HOURLY AVERAGES, EXCEPT AS PROJECT ACTION LIMIT REFERENCE
ACTIVE PROJECT
METHOD NOTED)
CONSTRUCTION ACTIVITY 1
Continuous Emission 120 mg/Nm3 (Kp =1, Kv =0.6, at
Total Dust QCVN 19:2009/BTNMT Continuously
Monitor (CEM) 25ªC, 760 mm mercury)
Total Dioxin Method TO-9A Baseline or 0.6 TEQ pg/m3 TCVN 10843:2015
USEPA Regional Screening Levels (RSLs)
2,4-D Method TO-4A Calculated based on USEPA RSLs
for Chemical Contaminants
2,4.5-T Method TO-4A Calculated based on USEPA RSLs USEPA RSLs for Chemical Contaminants
Chlorophenol Method TO-4A Calculated based on USEPA RSLs USEPA RSLs for Chemical Contaminants
3
Weekly (1 time/week) when
22 µg/m 1-hour mean; heating
Benzene Method TO-15 QCVN 06:2009/BTNMT
10 µg/m3 annual mean
260 µg/m3 24-hour mean;
Styrene Method TO-15 QCVN 06:2009/BTNMT
190 µg/m3 annual mean
1,000 µg/m3 1-hour mean;
Toluene Method TO-15 QCVN 06:2009/BTNMT
500 µg/m3 annual mean
Xylene Method TO-15 1,000 µg/m3 1-hour mean QCVN 06:2009/BTNMT
CO CEM 1,000 mg/Nm3 QCVN 19:2009/BTNMT If using a thermal oxider or similar
SO2 CEM 500 mg/Nm3 QCVN 19:2009/BTNMT combustion process, then
continuously when heating
3
NOX (as NO2) CEM 850 mg/Nm QCVN 19:2009/BTNMT
NOTES:
QCVN 06:2009/BTNMT, Hazardous Substances in Ambient Air
QCVN 19:2009/BTNMT, Maximum Allowable Concentration for Stack Emissions, Column B (facilities operating beyond January 1, 2015)
TCVN 10843:2015, Air Quality – Maximum Concentration of Dioxin in Ambient Air
USEPA Regional Screening Levels (RSLs) – Users Guide. November 2019
1 Potential Impact – Samples only collected when there is active Project construction activity occurring, or anticipated to occur, upwind of the monitoring location.
– Actual air emissions monitoring locations dependent on facility configuration; upon final design, this SWEMMP may be amended as warranted (see Section 1.4).
MONITORING FREQUENCY
PROJECT ACTION LIMIT
WHEN POTENTIAL IMPACT
PARAMETER TEST METHOD (HOURLY AVERAGES, EXCEPT AS PROJECT ACTION LIMIT REFERENCE
FROM ACTIVE PROJECT
NOTED)
CONSTRUCTION ACTIVITY 1
Automated
Baseline or 150 µg/m3 24-hour mean;
PM10 Measuring System QCVN 05:2013/BTNMT
50 µg/m3 annual mean
(AMS)
Total Dioxin Method TO-9A Baseline or 0.6 TEQ pg/m3 TCVN 10843:2015
2,4-D Method TO-4A Calculated based on USEPA RSLs USEPA RSLs for Chemical Contaminants
2,4.5-T Method TO-4A Calculated based on USEPA RSLs USEPA RSLs for Chemical Contaminants
2-Chlorophenol Method TO-4A Calculated based on USEPA RSLs USEPA RSLs for Chemical Contaminants
3
Weekly
22 µg/m 1-hour mean;
Benzene Method TO-15 QCVN 06:2009/BTNMT
10 µg/m3 annual mean
260 µg/m3 24-hour mean;
Styrene Method TO-15 QCVN 06:2009/BTNMT
190 µg/m3 annual mean
1,000 µg/m3 1-hour mean;
Toluene Method TO-15 QCVN 06:2009/BTNMT
500 µg/m3 annual mean
Xylene Method TO-15 1,000 µg/m3 1-hour mean QCVN 06:2009/BTNMT
NOTES:
QCVN 05:2013/BTNMT, National Technical Regulation on Ambient Air Quality
QCVN 06:2009/BTNMT, Hazardous Substances in Ambient Air
TCVN 10843:2015, Air Quality – Maximum Concentration of Dioxin in Ambient Air
USEPA Regional Screening Levels (RSLs) – Users Guide. November 2019
1 Potential Impact – Samples only collected when there is active Project construction activity occurring, or anticipated to occur, upwind of the monitoring location.
– Actual air emissions monitoring locations dependent on facility configuration; upon final design, this SWEMMP may be amended as warranted (see Section 1.4).
POTENTIAL
NEGATIVE
MONITORING MONITORING AND
SUB-ACTIVITY AMBIENT NOISE MITIGATION MEASURES RESPONSIBLE PARTIES
INDICATOR REPORTING FREQUENCY
AND VIBRATION
IMPACT
Preparation and Construction
Site-wide Ambient Noise; Initiate site-wide ambient noise and vibration monitoring. Tables 1C.1 and 1C.2 Tables 1C.1 and 1C.2 USAID A&E Bien Hoa Contractor
Monitoring Vibration
Activity-level Ambient Noise; Activity-level EMMPs will include ambient noise and vibration monitoring. Tables 1C.1 and 1C.2 Tables 1C.1 and 1C.2 Implementing Contractor, or A&E
Monitoring Vibration Minimum monitoring parameters and frequencies for Activity-level EMMPs are Bien Hoa Contractor as directed by
specified in the referenced tables. USAID
Clearing Site and Ambient Noise; All vehicles and construction equipment are registered as appropriate and meet Compliance with Project Monitoring and reporting as per Implementing Contractor;
Excavating Vibration GVN / Vietnam Register standards. CQA Plan and Activity- Project CQA Plan and Activity- USAID A&E Bien Hoa Contractor
Contaminated All vehicles and construction equipment with an internal combustion engine are level CQC Plan. level CQC Plan. CM oversight
Soils/Sediments fitted with an appropriate muffler system.
Preference is given to vehicles and construction equipment with the lowest noise
and vibration meeting QCVN 26:2010/BTNMT (noise) and QCVN
27:2010/BTNMT (vibration) to the maximum extent practical.
Noise/vibration generating equipment are to inspected regularly and properly
maintained.
Noise/vibration generating equipment are to be operated to the maximum
extent practical during daylight hours, preferably not later than 6pm.
Noise/vibration generating equipment are to be positioned to minimize the
propagation of noise and vibration.
Consideration should be given to advising nearby Airbase personnel and off-
Airbase residents of the potential for noise-generating activities.
Transporting Ambient Noise; All transport vehicles are to be registered as appropriate and meet GVN / Same as above. Same as above. Implementing Contractor;
Contaminated Vibration Vietnam Register standards. USAID A&E Bien Hoa Contractor
Soils/Sediments Transport vehicle drivers are to limit speed and observe speed limits on the CM oversight
Airbase.
Transport vehicle drivers are to avoid excessive use of horns.
Stockpiling/Placing Ambient Noise; Same as described for Clearing Site and Excavating Contaminated Soils/Sediments Same as above. Same as above. Implementing Contractor;
of Contaminated Vibration above. USAID A&E Bien Hoa Contractor
Soils/Sediments CM oversight
Constructing Ambient Noise; Storage areas are to be constructed in accordance with MND/ADAFC approved Same as above. Same as above. Implementing Contractor;
Storage Areas Vibration designs. USAID A&E Bien Hoa Contractor
Same as described for Clearing Site and Excavating Contaminated Soils/Sediments CM oversight;
above. MND/ADAFC oversight (LTSA)
Constructing TCH Ambient Noise; TCH Treatment Plant to be constructed in accordance with MND/ADAFC Same as above. Same as above. Implementing Contractor;
Treatment Plant Vibration approved designs. USAID A&E Bien Hoa Contractor
Same as described for Clearing Site and Excavating Contaminated Soils/Sediments CM oversight
above.
LOCATION
DESCRIPTION
REFERENCE
NOISEVIB1 Airbase Perimeter at Buu Long Ward
NOISEVIB2 Airbase Perimeter at Tan Phong Ward
NOISEVIB3
NOISEVIB4
Active Work Site Perimeter Location (varies)
NOISEVIB5
NOISEVIB6
See Figure 1C
PROJECT
PARAMETER/
TEST METHOD ACTION PROJECT ACTION LIMIT REFERENCE MONITORING FREQUENCY
TIME PERIOD
LIMIT
Noise
Vibration
POTENTIAL
NEGATIVE
MONITORING MONITORING AND
SUB-ACTIVITY GHG EMISSIONS/ MITIGATION MEASURES RESPONSIBLE PARTIES
INDICATOR REPORTING FREQUENCY
WEATHER
IMPACT
Preparation and Construction
Site-wide Weather Conditions Initiate site-wide weather monitoring. Tables ID.1 and ID.2. Tables 1D.1 and 1D.2. USAID A&E Bien Hoa
Monitoring Contractor
Clearing Site and GHG Emissions All vehicles and construction equipment are to be registered as Compliance with Monitoring and reporting as Implementing Contractor;
Excavating appropriate and meet GVN / Vietnam Register standards. Project CQA Plan and per Project CQA Plan and USAID A&E Bien Hoa
Contaminated Vehicles and construction equipment are not to idle unnecessarily. Activity-level CQC Activity-level CQC Plan. Contractor CM oversight
Soils/Sediments Plan.
Maximize use of newer more fuel-efficient vehicles and construction
equipment to the extent practical.
Maximize use of biodiesel fuels or other alternative fuels (propane) for
generators and construction equipment to the extent practical.
Recycle construction debris such as steel, asphalt and concrete to the
extent practical.
Transporting GHG Emissions Drivers are to limit speed and observe speed limits on the Airbase. Compliance with Monitoring and reporting as Implementing Contractor;
Contaminated Drivers are to be trained on designated haul routes and the importance of Project CQA Plan and per Project CQA Plan and USAID A&E Bien Hoa
Soils/Sediments minimizing haul distances. Activity-level CQC Activity-level CQC Plan. Contractor CM oversight
Transport vehicles are to transport a full load to the greatest extent Plan.
practical to minimize numbers of vehicle trips.
Haul distances for transport vehicles are to be minimized through
appropriate Excavation Planning.
Stockpiling/Placing GHG Emissions Same as described for Clearing Site and Excavating Contaminated Same as above. Same as above. Implementing Contractor
of Contaminated Soils/Sediments above.
Soils/Sediments
Constructing GHG Emissions Same as described for Clearing Site and Excavating Contaminated Same as above. Same as described for Clearing Implementing Contractor;
Storage Areas Soils/Sediments above. Site and Excavating USAID A&E Bien Hoa
Contaminated Soils/Sediments Contractor CM oversight
above.
Use of energy-efficient lighting
and equipment to the maximum
extent practical.
Use of locally sourced
construction materials to the
extent practical.
LOCATION
DESCRIPTION
REFERENCE
WEATHER1 Weather Station at Project Office
See Figure 1D
SITE-WIDE STORMWATER
POLLUTION PREVENTION PLAN
(SWPPP)
PREPARED BY
TRIGON ASSOCIATES, LLC
1515 POYDRAS ST. SUITE 2200
NEW ORLEANS, LA 70112
USA
DISCLAIMER
THE VIEWS EXPRESSED IN THIS PUBLICATION DO NOT NECESSARILY REFLECT THE VIEWS OF THE UNITED STATES AGENCY
FOR INTERNATIONAL DEVELOPMENT OR THE UNITED STATES GOVERNMENT.
CONTENTS
LIST OF ACRONYMS AND ABBREVIATIONS ................................................................................................ III
1 INTRODUCTION................................................................................................................................................ 1
1.1 PURPOSE....................................................................................................................................................... 1
1.2 DOCUMENT ORGANIZATION ........................................................................................................... 1
1.3 REVIEW AND AMENDMENT................................................................................................................. 2
1.4 SWPPP AVAILABILITY .............................................................................................................................. 2
1.5 SITE CHARACTERISTICS ......................................................................................................................... 2
2 STORMWATER MANAGEMENT .................................................................................................................... 9
2.1 IMPLEMENTING ORGANIZATION ROLES AND RESPONSIBILITIES....................................... 9
2.2 ACTIVITY-LEVEL STORMWATER POLLUTION PREVENTION................................................ 10
2.3 STORMWATER MANAGEMENT TEAM ........................................................................................... 10
3 POTENTIAL SOURCES OF STORMWATER POLLUTION................................................................... 12
3.1 PROJECT ACTIVITIES ............................................................................................................................. 12
3.2 STORMWATER POLLUTANT SOURCES ......................................................................................... 12
3.3 ALLOWABLE STORMWATER DISCHARGES ................................................................................. 14
3.4 ALLOWABLE NON-STORMWATER DISCHARGES ..................................................................... 14
4 EROSION AND SEDIMENT CONTROLS .................................................................................................. 15
4.1 MINIMUM EROSION AND SEDIMENT CONTROLS.................................................................... 15
4.2 REPRESENTATIVE DESIGNS FOR EROSION AND SEDIMENT CONTROLS ....................... 17
5 BEST MANAGEMENT PRACTICES .............................................................................................................. 19
6 GOOD HOUSEKEEPING PRACTICES ........................................................................................................ 21
7 INSPECTION, MAINTENANCE AND RECORDKEEPING MEASURES ............................................. 22
7.1 VISUAL INSPECTIONS............................................................................................................................ 22
7.2 DISCHARGE MONITORING ................................................................................................................ 23
7.3 EROSION AND SEDIMENT CONTROLS MAINTENANCE ....................................................... 26
7.4 RECORDKEEPING ................................................................................................................................... 27
8 TRAINING ........................................................................................................................................................... 29
9 REFERENCES ....................................................................................................................................................... 30
FIGURES
Figure 1. Annual and Seasonal Rainfall at Bien Hoa Station in Years 1994–2019. ............................. 3
Figure 2. Monthly Rainfall at Bien Hoa Station in Years 1994–2019. .................................................... 3
Figure 3. Rainy Days per Month at Bien Hoa Station in Years 1994–2019. ........................................ 3
Figure 4. Weather Monitoring Location at Project Field Office ............................................................ 4
Figure 5. Topography of Bien Hoa Airbase (2009 Survey Data). ........................................................... 7
Figure 6. Surface Water/Stormwater Monitoring Locations................................................................. 25
ATTACHMENTS
Representative Designs for Erosion and Sediment Controls
1.1 PURPOSE
Expanding on the Site-wide Environmental Mitigation and Monitoring Plan (SWEMMP) (USAID
2020), this Site-wide SWPPP identifies potential source(s) of storm water pollution based on
planned Project remedial construction activities and documents required site-wide erosion and
sediment controls, best management practices (BMPs), good housekeeping practices (GHPs),
inspection, maintenance and recordkeeping measures, and personnel training. This Site-wide
SWPPP also prescribes minimum pollution prevention practices and measures that
are to be incorporated into Activity-level SWPPPs and/or Activity-level EMMPs
developed for Project remedial construction activities by either the Implementing Contractor or
the A&E Bien Hoa Contractor.
- Section 1, Introduction
- Section 2, Stormwater Management
- Section 3, Potential Sources of Stormwater Pollution
- Section 4, Erosion and Sediment Controls
- Section 5, Best Management Practices
- Section 6, Good Housekeeping Practices
- Section 7, Inspection, Maintenance, and Record Keeping Measures
- Section 8, Training
- Section 9, References
Figures and representative designs for the erosion and sediment controls that are identified in
Section 4 are collectively presented as Attachments.
USAID A&E Bien Hoa Contractor must also discuss the Site-wide SWPPP implementation and
any recommended updates during quarterly technical review meetings held with USAID to gain
agreement on any resulting amendments.
A Record of Revisions page must be included as a forward. The Record of Revisions page
documents the conduct of the annual Site-wide SWPPP reviews and any resulting amendments.
The climate at Bien Hoa Airbase area is most recently described in the Environmental Assessment
(EA) (GVN/USAID 2016). Bien Hoa is located in an area of Asian monsoon tropical climate;
influenced by the Northeast monsoon and Southwest monsoon and the Pacific Ocean tropic
atmosphere from April to October with two distinct rainy and dry seasons. The rainy season
lasts approximately six (6) months, from May 1 through November 30. April and November are
transitional months with variable dry and rainy weather conditions. Precipitation data was
obtained for the Bien Hoa Station from the Government of Vietnam (GVN) Hydrometeorological
General Bureau, Hydrometeorological Monitoring Center for the years 1994 through 2019.
Rainfall during the rainy season accounts for approximately 84 percent (%) of the annual total
rainfall, with rainfall intensities varying as shown in Figure 1 (annual and seasonal rainfall), Figure
2 (monthly rainfall), and Figure 3 (rainy days per month).
Activities with the potential to expose soils or sediments (clearing, grading, excavating) must be
reduced or eliminated to the greatest extent practical during the rainy season (see Section 4.3,
Minimum Controls, see also Section 5, Best Management Practices) in an overall Project effort to
minimize surface erosion, scouring, and sedimentation from stormwater runoff.
A single weather monitoring station (WMS) recording temperature, relative humidity, wind speed
and direction, precipitation, solar radiation and barometric pressure located at the USAID Project
Office will support site-wide monitoring. Figure 4 shows the location of the WMS at Bien Hoa
Airbase. WMS data collection will be real-time with data recorded for duration of the Project.
The A&E Bien Hoa Contractor will systematically notify Implementing Contractors of current or
pending weather events (e.g., rainfall events).
FIGURE 3. RAINY DAYS PER MONTH AT BIEN HOA STATION IN YEARS 1994–2019.
Geology at the Bien Hoa Airbase is formed by sediments from river-sea-swamp of Pleistocene
with components of clay, loam, mixed sand and clay. The thickness of this sedimentary complex
reaches 22 m to 25 m, with lower bedrock formed by Mesozoic grey-blue clay shale or greenish
silt shale (Dekonta 2014). The Pleistocene sedimentary complex consists of three (3) layers:
1st layer. Red-brown sandy clay of laterite, semi-hard. Thickness of layer varies from 3.8 m
to 5.2 m and increases in depth from the north to south of the Airbase. The composition
of layer averages approximately 44% clay, 25% sand, and 17% silt, with the remainder
comprised of lateritic rock.
2nd layer. Grey-brown silty clay. Thickness of layer varies from 8.2 m to 10.5 m. The
composition of layer averages 41% clay, 10% sand, and 49% silt.
3rd layer. Yellow-brown soft, silty clay. Thickness of layer is up to 23.5 m. The composition
averages 47.8% clay; 18% sand, and 33% silt.
As a generalization, surficial soils on the Airbase are primarily sandy with lower and relatively
similar amounts of silt and clays and small amounts of gravel, down to depths of more than 1 m
(GVN/USAID 2016). This reflects the fact that the Airbase is situated in a depositional zone of
the Dong Nai River.
Table 1 summarizes the soil composition and characteristics in areas of the Bien Hoa Airbase
relevant to Project remedial construction activities.
COMPOSITION/PHYSICAL CHARACTERISTICS 1
AIRBASE SAND SILT CLAY GRAVEL MOISTURE ORGANIC CARBON
MEDIA PH
AREA (%) (%) (%) (%) (%) (MG/KG)
Northeast Soil 48.4 38.7 1.0 11.9 7.4 6.11 2,100
Pacer Ivy Soil 80.2 12.6 0.2 7.0 5.1 5.40 9,100
The Bien Hoa Airbase encompasses an area of approximately 1,000 hectares (ha) immediately to
the east and northeast of the Dong Nai River. Currently, a Vietnamese surveying firm is
conducting a comprehensive topographic survey at the Bien Hoa Airbase at the direction of
USAID Bien Hoa Contractor. The topographic survey is being conducted to an accuracy of 25
cm across Airbase areas that are to be disturbed (excavated, graded, etc.) during the Project
remedial construction activities Resulting topographic data will be used to more accurately
Figure 5 shows the topography of the Bien Hoa Airbase from 2009 survey data (Vietnam
Department of Survey, Mapping, and Geographic Information). Elevations on the Airbase range
from 4 to 30 meters (m) with a general topographic slope to the west and south towards the
tidally influenced Dong Nai River, and a major southwest-northeast-oriented drainage divide
cross cutting the Airbase (USAID 2017). The elevation of the Dong Nai River varies between -
2.00 and +2.08 meters above sea level (Data for Dong Nai River at Bien Hoa from 2007 through
2015, http://lvsdongnai.cem.gov.vn).
Drainage from on-Airbase to off-Airbase areas generally flows west from the Pacer Ivy Area, west
and partly south from the Southwest Area and Z1 Area, and southeast from the Southeast Area
and Northeast Area, with the respective drainage waterways eventually leading to the tidally
influenced Dong Nai River. Figure 5 also shows the Bien Hoa Airbase drainage divides and
proximity to the Dong Nai River.
A number of lakes, ponds, and wetlands are located along the perimeter of the Airbase. Most of
these are man-made, but others are remnants of historical wetlands in the Dong Nai River basin.
The water depths of these lakes and ponds varies from approximately 50 centimeters (cm) to >
2 meters (m) with some water depths having been previously managed for aquaculture purposes
(GVN/USAID 2016).
MND documented a total of 23 lakes and ponds at the Airbase during the development of the
EIA (MND 2019). The size and extent of these Airbase lakes and ponds varies by dry or rainy
season, with some ephemeral having no water present during the dry season and others perennial
containing water throughout both seasons. In general, the hydraulic connectivity of these lakes
and ponds to the drainage canals and intermittent streams leading to the tidally-influence Dong
Nai River are not well defined. MND also documented the following with respect to drainage at
the Airbase to surrounding Wards (MND 2019):
• Waters from the Western and Northeastern areas of the Airbase flow through the drainage
system of the Buu Long Ward located to the Southwest to the Dong Nai River;
• Waters from the Eastern areas of the Airbase flow through the drainage systems of the Tan
Phong and Tong Nhat Wards located to the Southeast to the Dong Nai River; and
• Waters from the Southern areas flow partly into Gate 2 Lake (G2L) and through the drainage
systems of the Quang Binh and Trung Dung Wards located to the South to the Dong Nai
River.
Stormwater runoff has been identified as a significant dioxin migration pathway (USAID 2020),
particularly along drainage paths from the Pacer Ivy Area to adjacent off-Airbase land areas.
Stormwater discharging from the Pacer Ivy Area to the surrounding land areas is primarily
through a rock gabion structure into a drainage canal that equipped with a rock weir near its
confluence with the Dong Nai River. Figure 5 shows the topography of the Pacer Ivy Area.
Overall, remediation activities in the Project Masterplan are to be sequenced due to stormwater
runoff being a significant dioxin migration pathway. In that, remedial actions are generally to be
completed in upstream or upgradient Decision Units (DUs) before downstream or downgradient
DUs, to eliminate the potential for recontamination of the downstream or downgradient DUs.
1.5.4 VEGETATION
Vegetation at the Airbase is largely composed of secondary and planted forests and shrubs largely
the result of disturbance and alteration from Airbase agriculture and infrastructure activities
(GVN/USAID 2016).
MND evaluated both flora and fauna in the development of the EIA for the Project with a
document review and field investigations identifying 496 species of fauna in 3 divisions at the Bien
Hoa Airbase and in surrounding areas (Polypodiophyta, Pinophyta and Magnoliophyta). Flora was
identified as being diverse; however, species are of very little conservation value with none of the
identified species named in the Vietnam Red Data Book (MND 2019). Vegetation is documented
in the EIA as grasslands and shrublands, planted forest, and agricultural/landscaping.
• Grassland and shrubland areas are scattered on low hills, along perimeters of lakes and ponds,
along banks of rivers, streams and canals, and scattered in fields and forested areas.
Components of grassland and shrubland flora include native Cogon grass (Imperata cylindrica)
and invasive grass species such as Ageratum conyzoides, Chromolaena odorata. Mimosa pigra.
• Planted forests includes species of Acacia spp. and Hevea brasiliensis (rubber tree).
• Agricultural and landscaping includes: different types of rice, corn, bean, vegetable, cassava,
sweet potato, etc.; fruit trees such as jackfruit, durian avocado, mango, papaya, coconut,
guava, grapefruit, and bananas; silviculture trees for construction materials include Melia
azedarach and Bambusa; different ornamental plants such as Barrongtonia ancutagula and Ficus
benjamina; and plants used for spices such as Ipomoea aquatica, Brassica, Ocimum basilicum,
Allium ascolonicum, A. sativum, Zingiber officinale, and Curcuma longa.
An analysis was conducted by A&E Bien Hoa Contractor to determine DUs with dioxin
concentration above Project Cleanup Action Levels and their vegetative cover. This was to
consider developing interim measures with respect to phyto-stabilization. It was estimated that
7.18 hectares (ha) of exposed soils (barren areas) are associated with Bien Hoa Airbase DUs PI-
18, PI-20, Z1-2, ZI-3, ZI-9, ZI-10, NE-9, NE-11, NE-15, NF-4, SW-3, and SW-7.
The A&E Bien Hoa Contractor has observed that the Regiment uses proscribed burning during
the dry season to manage vegetation growth on the Airbase.
Decision No. 3869/QD-BQP establishes the Government of Vietnam (GVN) Authority in Charge
and the Project Owner for the Dioxin Remediation at Bien Hoa Airbase Area Project. As the
GVN Project Owner, the ADAFC within the MND is the agency responsible for ensuring Project
remedial construction activities are conducted in accordance with applicable or relevant and
appropriate requirements (ARARs) and with established Project plans and procedures.
USAID has or will procure the services of multiple Implementing Contractors to execute Project
remedial construction activities (e.g., excavation and temporary storage of soils/sediments from
targeted Decision Units [DUs], construction of a Long-term Storage Area [LTSA] for
soils/sediments, construction and operation of a thermal conductive heating (TCH) Treatment
Plant). USAID will require all Implementing Contractors to implement Activity-level stormwater
pollution prevention procedures in accordance with this Site-wide SWPPP for their respective
remedial construction activities (see Section 2.2). USAID will either require these individual
Implementing Contractors to prepare an Activity-level SWPPP and/or a Activity-level EMMP or
direct the A&E Bien Hoa Contractor to develop such as part of contract requirements.
IMPLEMENTING
STORMWATER MANAGEMENT ROLE(S) AND RESPONSIBILITY(IES)
ORGANIZATION
This Site-wide SWPPP prescribes the minimum erosion and sediment controls (see Section 4),
BMPs (see Section 5), GHPs (see Section 6), inspection, maintenance and recordkeeping measures
(see Section 7), and training (see Section 8) for all Project activities.
The A&E Bien Hoa Contractor will be responsible for visual inspection and directly monitoring
or overseeing Implementing Contractor monitoring of discharges and implementation progress
in support of Site-wide SWPPP annual reviews and updates.
The listed individuals may delegate responsibilities for Site-wide SWPPP implementation to
other(s) within their respective organization as necessary and appropriate; however, this
delegation must be documented in writing and be accessible at the USAID Project Office location
with this Site-wide SWPPP.
IMPLEMENTING
NAME, TITLE CONTACT INFORMATION
ORGANIZATION
Suzanne Johnson, Contracting Officer +84.243.935.1231 (office)
(CO) [email protected] (email)
USAID/Vietnam Anthony (Tony) Kolb, +84.243.935.2190 (office)
A&E Contracting Officer +84.96.200.2758 (mobile)
Representative (COR) [email protected] (email)
• Excavation and on-Airbase thermal treatment of ~150,000 cubic meters (m3) of dioxin-
contaminated soils and sediments with dioxin concentrations at or above 1,200 parts per
trillion (ppt) Toxicity Equivalent (TEQ) to below a 100 ppt remedial treatment threshold;
Decision No. 3869/QD-BQP notes overall Project Phase I and Phase 2 activities encompasses the
excavation and on-Airbase treatment of ~250,000 m3 of dioxin-contaminated soils and sediments,
and the excavation and isolation in a constructed on-Airbase storage facility of ~300,000 m3 of
dioxin-contaminated soils and sediments (MND 2019).
A Project Masterplan is being developed by USAID that documents the overall Project approach
for the dioxin remediation at the Bien Hoa Airbase Area and a detailed work breakdown
structure (WBS) that includes Project remedial construction activities and sequencing of the
Project activities into a master project schedule. With the development of the Project Masterplan,
construction plans showing construction activities for each major phase of Project activities and
additional site maps can be incorporated into this Site-wide SWPPP.
This Site-wide SWPPP is currently a draft. The timeline for revision from Draft to a Final Site-
wide SWPPP accommodates the finalization of the Project Masterplan that is under development.
After approval of the Project Masterplan by USAID, the implementation of Project activities in
accordance with the Masterplan will be monitored by USAID and GVN with respect to protecting
water quality, in part, via the implementation of this Site-wide SWPPP and Activity-level SWPPPs
and/or EMMPs. Project remedial construction activities are currently anticipated to commence
late in calendar year 2020.
Dioxins are a family of compounds that share distinct chemical structures and characteristics and
have significant toxicity. The singular term dioxin and the chemical name dioxin refers to the most
toxic compound, 2,3,7,8-TCDD. Dioxins exhibit very low water solubility (i.e., are hydrophobic)
and when released to the ground surface, partition to the organic fractions of soils and sediment.
Given these characteristics, dioxin as a stormwater pollutant is primarily associated with
suspended sediment.
PESITCIDES, HERBICIDES3
SEDIMENT (DIOXIN)
OTHER CHEMICALS
FLOATING SOLIDS
DIESEL, GASOLINE
HEAVY METALS2
OIL, GREASE
NUTRIENTS
PROJECT ACTIVITY1
Excavating Soils/Sediments X X X X X X
Dewatering Soils/Sediments X X X X
Transporting Soils/Sediments X X X X X
Stockpiling/Placing Soils/Sediments X X X
Rinsing/Cleaning of Equipment/Vehicles X X X
Refueling of Equipment/Vehicles X
Maintenance of Equipment/Vehicles X X X
Loading/Storing Materials/Waste X X X X
Grading, Backfilling X X X X
Revegetating Site X X X
1 Project activities organized as per SWEMMP and MND/ADAFC EIA (MND/ADAFC 2019)
2 Arsenic has been identified as a Chemical of Concern (COC) in soils and sediments
3 Pesticides (2,4-D and 2,4,5-T) have been identified as COCs in soils and sediments
Stormwater discharges listed above are allowed provided the appropriate stormwater pollution
prevention controls and measures are implemented and maintained in accordance with this Site-
wide SWPPP.
1) Controlling the volume and velocity of stormwater runoff from Project sites, including peak
flow rates and total stormwater volume, to minimize soil erosion and sedimentation;
2) Controlling the volume and velocity of stormwater at discharge points to minimize scouring
and stream bank erosion;
5) Minimizing sediment discharges from Project sites in a manner that addresses (i) the amount,
frequency, intensity, and duration of precipitation; (ii) the nature of resulting stormwater
runoff; and (iii) soil characteristics;
6) Providing and maintaining natural buffers and direct stormwater whenever feasible to
vegetated areas to increase sediment removal and maximize stormwater infiltration;
8) Ensuring stabilization of disturbed areas after clearing, grading, excavating, or other land
disturbing activities have ceased.
1) Minimize disturbed areas and protecting natural features and native soils to the
greatest extent practical.
2) Provide and maintain natural buffers and/or equivalent erosion and sediment
controls when disturbance within 15 meters of surface waters:
b. Provide and maintain an undisturbed natural buffer less than 15 meters supplemented by
erosion and sediment controls that achieve, in combination, the sediment reduction
equivalent to a 15-meter undisturbed natural buffer.
a. Restrict vehicles and construction equipment to use designated entry and exit points;
b. Use stabilization techniques (e.g., aggregate stone with an underlying geotextile or non-
woven filter fabric, and turf mats) at all exit points;
c. Implement additional sediment track-out controls (e.g., wheel washing, rumble strips,
rattle plates) as necessary to ensure that sediment removal occurs prior to vehicle exit.
a. Locate piles outside of natural buffers and away from stormwater conveyances, drain
inlets, and areas where stormwater flow is concentrated;
b. Install sediment barriers (e.g., berms, dikes, fiber rolls, silt fences, sandbags, riprap, or
straw bales) along downgradient perimeter areas; and
c. Cover piles (e.g., example, tarps, blown straw, or hydro-seeding) or temporary stabilize
piles when not transferring soils/sediments.
7) Minimize dust by applying water or other dust suppression techniques to exposed soils.
a. Restrict vehicle and equipment use in these locations before seeding or planting; and
b. Use techniques that rehabilitate and condition soil to support vegetative growth (final
grading plans must incorporate soil compaction standards and BMPs such as use of
erosion control fabrics, to facilitate post-remediation plant establishment periods.)
10) Protect storm drain inlets that remove sediment from stormwater discharges (e.g., install
silt fencing, rock-filled bags, or block and gravel).
11) Install velocity dissipation devices as needed (e.g., check dams, sediment traps) to
minimize drainage channel and streambank erosion and scour in vicinity of discharges.
12) Install sediment basins or impoundments as needed to reduce discharge volume and
velocity and minimize drainage channel and streambank erosion and scour:
b. Design the basin to provide storage for a minimum of a 2-year, 24-hour storm event;
c. Utilize outlet structures that withdraw water from the surface (unless infeasible); and
13) Stabilize exposed soils (e.g., seeding, sodding, mulching, erosion control blankets, hydro
mulch, gravel) when clearing, grading, excavating, or other land disturbing activities have
permanently ceased, or temporarily ceased on any portion of the site and will not resume
for a period exceeding 14 days:
b. Complete stabilization measures as soon as practical but no later than 14 calendar days
after stabilization has been initiated.
14) Provide final stabilization for any areas not covered by improved surfaces or permanent
structures:
a. Establish uniform, perennial vegetation (i.e., evenly distributed, without large bare areas)
that provides 70 percent (%) or more of effective cover provided by vegetation native to
local undisturbed areas; and/or
The Compendium contains standard sections for anticipated earth work and temporary facilities,
including but not limited to temporary roads, laydown areas, stockpile areas, and sedimentation
basins. The Representative Designs included with this Site-wide SWPPP are intended to serve in
the absence of standard specifications and sections in the Compendium.
Required minimum BMPs specific to particular construction activities are listed in Table 5. These
BMPs are organized by Project activity.
Clearing, Grading • Clearing, grading, excavating activities must occur during the dry season to the extent
Site; Excavating practical to minimize potential for runoff, erosion, and sedimentation.
Soils/Sediments
• Dust minimization measures as per SWEMMP must be implemented.
Stockpiling/Placing • Stockpiling of soils/sediments must be done at areas located away from surface waters and
Soils/Sediments stormwater inlets or conveyances.
• Stockpiled soils/sediments must be covered daily.
Refueling of • Refueling must be done at designated areas that are located away from surface waters and
Equipment/Vehicles stormwater inlets or conveyances.
• Refueling during precipitation events must be avoided.
• Fuels must be stored in appropriate containers marked as to their contents and securely
closed when not transferring fuels.
• Adequate spill containment and response supplies must be available to respond to a fuel
spill or leak.
• Fuel spills must be cleaned up as soon as possible using dry cleanup measures (do not
washdown spills) and eliminate the source of the spill.
• Fueling operations must not be left unattended.
Maintenance of • Drip pans or absorbent pads must be used under vehicles/equipment stored outside
Equipment/Vehicles awaiting maintenance.
• Vehicle/equipment maintenance must be performed indoors to the greatest extent
practical.
Rinsing/Cleaning of • Rinsing/cleaning of vehicles and equipment must be done at designated areas that are
Equipment/Vehicles located away from surface waters and stormwater inlets or conveyances.
Storage and Handling • Materials and wastes must be stored in containers on impervious surfaces, under cover,
of Materials and and/or with secondary containment to the extent practical.
Wastes
• Liquid materials and wastes that are water endangering must be stored in securely closed
containers on impervious surfaces with a means of secondary containment sufficient for at
least 110% of the largest container.
• Materials and wastes must be stored separately.
• Materials and wastes must be stored in containers marked as to their contents and
constructed of suitable materials to prevent leakage and corrosion.
• All wastes must be disposed in accordance ARARs.
• Adequate spill containment and response supplies must be available to respond to a spill
or leak of materials and wastes.
• Spills of materials and wastes must be cleaned up as soon as possible using dry cleanup
measures (do not washdown spills).
Use of Fertilizers • Ensure fertilizer use in conformance with USAID ADS 312, Eligibility of Commodities,
Section 312.3.3.7, Fertilizer.
• If used, apply only per approved plans and specifications and at a rate and in amounts
consistent with manufacturer’s specifications.
• Must be applied at the appropriate time of year for maximum vegetation growth.
• Must avoid applying before heavy rains that could cause excess nutrients to be discharged
with stormwater.
• Never apply to stormwater drainage channels or conveyances.
USAID implementing contractors must implement the GHPs specific to their construction
activities listed in Table 6.
General - All work areas must be kept neat and well organized.
Improved Surfaces - Improved surfaces such as parking lots and walkways must be cleaned
periodically (at least weekly) to remove accumulated debris.
- Improved surfaces must not be washed down.
- Trash or litter must be picked up from improved surfaces daily.
Solid Waste - An adequate number of solid waste collection containers must be provided
and ensure collection frequency to prevent overtopping or spillage of trash
and debris.
- Solid waste collection containers must be inspected periodically and repair
or replace containers as warranted.
- All solid waste collection containers must have a functioning lid or cover
and the lid must be maintained closed when not transferring solid wastes.
- Litter routinely must be picked up from outside areas, in particular from
areas adjacent to stormwater inlets or conveyances.
• Areas that have been cleared of vegetation, graded, or excavated that are not yet completed
final stabilization/revegetation measures;
• Stormwater controls, including erosion and sediment controls;
• Stormwater drainage channels, conveyances, and discharge points (effectively all areas where
stormwater typically flows at the site)
• Designated vehicle and equipment washing areas;
• Vehicle and equipment storage and maintenance areas; and
• Material and waste storage areas.
As noted previously, the A&E Bien Hoa Contractor must maintain the WMS at the USAID Project
Office location in accordance with the SWEMMP and make available real-time data from the WMS
to Implementing Contractors. The term “within 24 hours of the occurrence of a storm event”
means within 24 hours once a storm event has produced 1 cm or greater precipitation within a
24-hour period, even if the storm event is continuing.
Visual inspections are only required to be conducted during normal working days/hours.
Visual inspections must be performed only by qualified individuals who are knowledgeable in the
principles and practices of stormwater pollution prevention, erosion/sediment controls, and
BMPs, and who possesses the appropriate skills and training to assess conditions at a construction
site that could impact stormwater quality and to assess effectiveness of established controls and
BMPs. See also Section 8, Training.
• Assess whether the established erosion and sediment controls and stormwater BMPs are
properly installed and operational;
• Observe for the presence of conditions that could lead to spills and leaks or other sources
of stormwater pollution;
• Identify areas where new or modified erosion or sediment controls or stormwater BMPs are
necessary;
Documenting the visual quality of stormwater includes taking note of the characteristics of the
stormwater discharge, including:
• Color;
• Odor;
• Floating, settled, or suspended solids;
• Foam;
• Oil/petroleum sheen; and
• Other indicators of stormwater pollutants.
An inspection report or form is not mandated by this Site-wide SWPPP; however, records of
visual inspections conducted must be maintained in accordance with Section 7.4, Recordkeeping.
Visual inspection records must include, at a minimum, the following information:
• Date of inspection;
• Name and title of inspector(s), including an indication they are a qualified individual;
• Summary of visual inspection observations and findings including locations of erosion and
sediment controls necessitating maintenance, failing to operate as designed, or proved
inadequate;
• Locations where additional erosion and sediment controls are needed but do not exist;
• Corrective actions required to resolve deficiencies;
• Digital photographs of locations and visual inspection observations (as appropriate); and
• Weather conditions and a description of any discharges occurring at the time of inspection
(including the WMS reading triggering the inspection if due to a 1 cm or greater storm event).
If it is determined that it is unsafe to inspect any portion of the site, the record of inspection must
include a description of the reason it was unsafe and specify the locations as to which the
condition applies.
Stormwater discharge monitoring per this Site-wide SWPPP must be conducted by USAID A&E
Bien Hoa Contractor for Project remedial construction activities as part of overall water quality
monitoring conducted as a component of SWEMMP implementation.
LOCATION
DESCRIPTION
REFERENCE
SURFACE1 West from Northern Edge of Runway
SURFACE2 West from PI Area toward Dong Nai River
SURFACE3 Southwest from PI Area toward Buu Long Ward
SURFACE4 South from SW & Z1 Areas toward Quang Vinh Ward
SURFACE5 South from NE Area toward Tan Phong Ward
SURFACE6 Bao Hang River entering NE Area from the North
SURFACE7 South from Z1 Area toward Trung Dung Ward
SURFACE8 Channel entering NE Area from the East
Dewatering Discharge To Be Determined – Point of discharge with reasonable potential to impact
surface water quality
Table 8 identifies the stormwater monitoring parameters, methods, Project action limits,
references, and frequencies that were developed in consideration of the sources of stormwater
pollutants (see Section 3). These tables are consistent with the stormwater quality monitoring
that is conducted as a component of SWEMMP implementation. Initial monitoring events in both
the dry and rainy seasons based on the prescribed monitoring frequencies will establish baseline
conditions.
A specific discharge monitoring report is not mandated by this Site-wide SWPPP; however,
USAID will direct either the A&E or implementing contractors to maintain records of discharge
monitoring events in accordance with Section 7.4, Recordkeeping. Records of discharge
monitoring events are to include, at a minimum, the following information:
• Sample location;
• Sample date;
• Sampling method, including sample volume collected, collection method, and preservation
method, as applicable;
• Analytical test method;
• Analytical date; and
• Analytical results.
Total Dioxin Method 1613B Baseline NA Monthly AND collect and store
weekly samples for up to one month,
analyze when warranted based on
Arsenic Method 6020A 0.01 mg/L QCVN 08-MT:2015/BTNMT
Project activity
2,4-D Method 8151 0.2 mg/L QCVN 08-MT:2015/BTNMT
Monthly
2,4,5-T Method 8151 0.1 mg/L QCVN 08-MT:2015/BTNMT
NOTES:
QCVN 08-MT:2015/BTNMT National Technical Regulation on Surface Water Quality, A1 values; EIA Section 5.2.2
references B values; proposed is more stringent.
NA = not applicable
1 Potential Impact – Samples only collected when there is active Project construction activity occurring, or
anticipated to occur, upstream of the monitoring location.
– EIA Table 5.3 water quality parameters of DO, BOD5, Total P, Total N, Ammonium N, Ferric, Coliform, Lead,
Mercury, Cadmium, Chrome (VI), and Chrome (III) and EIA Table 5.7 with identical water quality parameters as well
as Dioxin/Furan and Phenol Chloride not included. These are not water quality parameters of concern with respect
to monitoring Project activities.
– EIA Sections 5.2.1, 5.2.2 and 5.2.3 reference quarterly [4 times/year] monitoring frequency for preparation,
construction, and remediation operation phases and EIA Section 5.2.4. references semi-annual [2 times/year]
monitoring frequency for environmental restoration phase based on Circular No. 24/2017/TT-BTNMT. Proposed is
more frequent.
USAID has developed a Site-wide SAP-QAPP (USAID 2019) to provide a comprehensive planning
and guidance document for environmental sampling, field analysis, and environmental laboratory
analyses for all work to be conducted during Project implementation. The Site-wide SAP-QAPP
is applicable to USAID A&E Bien Hoa Contractor and all Implementing Contractors who will be
performing stormwater discharge monitoring in accordance with this Site-wide SWPPP and
Activity-level SWPPPs and/or Activity-level EMMPs. The Site-wide SAP-QAPP must be utilized
during field sampling and laboratory analyses to ensure that collected environmental monitoring
data meets specified data quality objectives (DQOs).
• Removing accumulated debris and sediment from controls as warranted to assure continued
performance of their intended functions;
• Removing accumulated sediment before it has accumulated to one-half of the above-ground
height of any perimeter control;
• Removing accumulated sediment from sediment basins or impoundments to maintain at least
one-half the design capacity and conduct other maintenance to ensure the basin or
impoundment remains in effective operating condition;
• Cleaning, or removing and replacing any storm drain inlet filters as sediment accumulates and
filters become clogged impacting performance;
• Replacing damaged controls, such as silt fences, that no longer operate effectively; and
• Conducting maintenance recommended by manufacturers of equipment or devices.
A specific maintenance form or report is not mandated by this Site-wide SWPPP; however,
USAID implementing contractors must maintain records of erosion and sediment control
maintenance in accordance with Section 7.4, Recordkeeping. Records of erosion and sediment
control maintenance are to include, at a minimum, the following information:
7.4 RECORDKEEPING
This Site-wide SWPPP and any amendments must be readily accessible at the USAID Project
Office location.
All records required by this Site-wide SWPPP must also be maintained for at least 3 years from
the date of the record and accessible at the USAID Project Office location.
Records required by this Site-wide SWPPP include, but are not limited to the following:
In addition, all individuals assigned with responsibilities for BMP installation, inspection,
maintenance, or repair must be trained on the installation and purpose, maintenance procedures,
and inspection and recordkeeping requirements for the respective BMP(s).
SWPPP training must be provided prior to an individual performing the assigned stormwater
management responsibilities. SWPPP training must commensurate with the individual’s work
assignments. SWPPP training must be instructor-led and include participation and discussion, as
well as field observation or demonstration as appropriate.
Refresher SWPPP training must be provided to individuals at least once every three (3) years.
A specific training log or form is not mandated by this Site-wide SWPPP; however, USAID
contractors must maintain a record of training for each individual in accordance with Section 7.4,
Recordkeeping. Records of training are to include, at a minimum, the following information:
• Name of employee;
• Training content received;
• Training duration;
• Date of training completion; and
• Signed statement of certification and notification.
Dekonta. 2014. Report on the construction of the groundwater monitoring system at Bien Hoa
Airbase.
USAID (CDM International, Inc. and Hatfield Consultants). 2016. Environmental Assessment of
Dioxin Contamination at Bien Hoa Airbase. May 3, 2016.
MND. 2019. Decision No. 3869/QD-BQP on Approval of the Investment project and the plan
for selection of the “Dioxin Remediation in Bien Hoa Airbase – Phase 1” Project with non-
refundable Official Development Assistance from the United States of America, September 6,
2019
MND/ADAFC. 2019. Report of Environmental Impact Assessment for the Dioxin Remediation
at Bien Hoa Airbase Area Project. February 27, 2019.
MONRE. 2019. Approval of Environmental Impact Assessment Report, the Dioxin Remediation
at Bien Hoa Airbase Area Project. March 25, 2019.
USAID. 2017. Generalized Hydrogeological Framework of the Bien Hoa Airbase Area including
Abandoned Hard Rock Quarry Area.
USAID 2020. the Dioxin Remediation at Bien Hoa Airbase Area Project, Draft Site-wide
Environmental Mitigation and Monitoring Plan, April.
USEPA. 2007. Developing your Stormwater Pollution Prevention Plan, a Guide for Construction
Sites, EPA-833-R-06-004. May 2007.
USEPA. 2017. National Pollution Discharge Elimination System (NPDES) General Permit for
Discharges from Construction Activities (as modified) Construction General Permit (CGP).
PREPARED BY
TRIGON ASSOCIATES, LLC
1515 POYDRAS ST. SUITE 2200
NEW ORLEANS, LA 70112
USA
DISCLAIMER
THE VIEWS EXPRESSED IN THIS PUBLICATION DO NOT NECESSARILY REFLECT THE VIEWS OF THE UNITED STATES AGENCY
FOR INTERNATIONAL DEVELOPMENT OR THE UNITED STATES GOVERNMENT.
CONTENTS
CONTENTS i
RECORD OF REVISIONS ii
LIST OF ACRONYMS AND ABBREVIATIONS iii
8 HISTORICAL BACKGROUND 1
8.1 BIEN HOA AIRBASE AREA ENVIRONMENTAL ASSESSMENT 1
8.2 OTHER USAID AND GVN EFFORTS ADDRESSING DIOXIN CONTAMINATION 1
8.3 ENVIRONMENTAL IMPACT ASSESSMENT AND PROJECT APPROVAL 2
9 SITE CONCEPTUAL MODEL, DATA GAPS ANALYSIS, BASELINE RISK
ASSESSMENT 3
9.1 SITE CONCEPTUAL MODEL AND DATA GAPS ANALYSIS 3
9.2 BASELINE RISK ASSESSMENT 4
10 APPLICABLE RELEVANT AND APPROPRIATE REQUIREMENTS 4
ANNEXES
ANNEX 5 – TABULATED APPLICABLE AND RELEVANT OR APPROPRIATE
REQUIREMENTS
ANNEX 6 – SITE CONCEPTUAL MODEL AND DATA GAPS ANALYSIS
ANNEX 7 – BASELINE RISK ASSESSMENT
ANNEX 8 – TECHNICAL MEMORANDA
– LONG-TERM STORAGE AREA SUMMARY RISK ASSESSMENT
– TECHNOLOGY EVALUATION AND RECOMMENDED
TREATMENT METHODS
– PROJECT MATERIAL DISPOSITION APPROACH
ANNEX 9 – THE PROJECT’S ACRONYMS AND ABBREVIATIONS
The EA stated that elevated dioxin concentrations had also been found (prior to 2014, when USAID
initiated the sampling program that was part of the EA) in lake sediments in the NW Area, NE Area,
and outside the Airbase (Gate 2 Lake, Bien Hung Lake, and in the drainage canal west of the Pacer Ivy
Area). Analysis of samples collected outside the Airbase during the EA indicated that Gate 2 Lake
surface sediments [166 parts per trillion in toxic equivalents, ppt Toxic Equivalency (TEQ)] were
above the GVN dioxin contamination standard for sediments (150 ppt TEQ), and Bien Hung Lake
sediments (83 ppt TEQ) were below the GVN standard for dioxin contamination.
The EA used collected data to generate remedial alternatives for USAID and GVN consideration
ranging from no action, to complete containment/isolation, complete treatment, and a mixture of
containment/isolation and treatment. The alternatives were developed considering 28 treatment and
containment technologies identified from a literature review and that met screening criteria for
maturity, cost competitiveness, and GVN acceptance. Conceptual designs for the alternatives were
developed and evaluated for effectiveness, implementability, cost, and environmental and social impact.
Since the EA was completed, Alternative 4 (i.e., thermally treat soil and sediment above 1,200 ppt
dioxin and consolidate/contain in long-term storage soil and sediment between the land use limits for
dioxin and 1,200 ppt TEQ) has been advanced as the preferred alternative.
• Dong Nai Department of Natural Resources and Environment (DONRE) off-Airbase sampling
from 2012 to 2016 (162 soil and sediment samples) for monitoring potential off-Airbase migration
of dioxin (Unpublished data; however, shared with Air Defence – Air Force Command (ADAFC)
in 2019 and in DONRE/USAID meeting minutes). Additionally, DONRE has reportedly
implemented dioxin monitoring in several City of Bien Hoa wards surrounding the Airbase since
2009, and the monitoring has shown migration of dioxin from on-Airbase to off-Airbase areas
(USAID/DONRE 2019). DONRE conducted soil and sediment sampling along migration pathways
associated with stormwater and surface water drainage from the Airbase: west of the Airbase,
heading toward the tidally-influenced Dong Nai River; from Z1 Area of the Airbase toward the
Tan Phong Ward; and from the southern end of the Airbase to the Gate 2 Lake. Off-Airbase
contamination was identified in all three (3) areas
• Since publication of the EA in 2016, several remedial treatment technologies have undergone pilot
testing at Bien Hoa Airbase and/or have been evaluated using soils/sediments originating from the
Airbase. These efforts are discussed in the Technical Memorandum (TM) on Technology
Evaluation and Recommended Treatment Methods provided in Annex 8.
The EIA outlines four (4) Project activities and discusses the environmental aspects and impacts (i.e.,
Preparation, Construction, Remediation Operations, and Environmental Restoration). Potential
negative environmental impacts were identified for air quality (dust, vehicle/equipment emissions,
thermal treatment plant emissions), water quality (erosion, stormwater drainage to surface waters,
process water discharges), ambient noise and vibration (vehicle/equipment noise and vibration),
greenhouse gases (GHGs) (vehicle/equipment emissions, GHG effect) and weather. The EIA includes
environmental mitigation measures and monitoring requirements to be implemented during the
construction activities to address these potential negative impacts. It also provides the initial
Environmental Management Plan (EMP).
The Project is packaged into two (2) phases by the EIA: Phase 1 – focusing on remediation of the
Pacer Ivy Area, plus nearby areas, and Phase 2 – focusing on remediation of the Z1 Area, plus nearby
areas. The EIA was approved by MONRE under Decision No. 702/QD-BTNMT and submitted to
GVN and MND for Project approval.
The Prime Minister approved Phase 1 of the Project under Decision No. 425/QD-TTg and MND
approved under Decision No. 3869/QD-BQP. Key aspects of the Project were defined as follows:
• Fully treat 150,000 m3 of dioxin contaminated soil and sediment with high concentration of over
1,200 ppt TEQ to below 100 ppt TEQ;
• Safely isolate 150,000 m3 of dioxin contaminated soil and sediment above the allowable dioxin
threshold (1,200 ppt for industrial/commercial land, 300 ppt for urban land; 150 ppt for sediment
land and 100 ppt for land with forest and perennial trees) in accordance with the land use planning
for the Bien Hoa Airport Area; and
In addition, the A&E Bien Hoa Contractor developed a Baseline Risk Assessment (BRA) that evaluates
dioxin and arsenic concentrations (including arsenic speciation, distribution, and bioavailability as it
relates to human health and ecologic risk) and presents Airbase Area-specific data that support a
human health and ecological risk assessment. Both non-carcinogenic and carcinogenic health effects
are addressed in the BRA.
• Identify perceived gaps in existing data and information and recommend SI and other
evaluation activities to resolve critical data gaps needed to improve the SCM and
Masterplan implementation.
The SCM is described in the context of the Airbase Area site definition and setting, sources of
contamination and distribution, migration pathways and exposure routes, and sensitive receptors. The
SCM is presented in a narrative format and illustrated in a pictorial manner to facilitate communication
of dioxin contamination and exposure issues. It is expected to facilitate communication of dioxin
contamination and exposure issues with GVN and other stakeholders in support of Masterplan
approval and initiation of Project activities. The SCM/DGA was presented at Roadmap Meeting 2, and
consensus was reached with GVN stakeholders on its structure and contents.
Available data and information were integrated into the SCM to assist in the identification of absent
or insufficient data. The analysis considered documented, as well as perceived, data gaps with respect
to the SCM, location and potential migration of dioxin contamination in the Airbase Area, and the
expected remedial actions. The analysis determined critical data gaps and developed recommendations
for resolving the data gaps through supplemental site investigations and other evaluations early in
Masterplan implementation.
Further details are provided in Annex 6, Site Conceptual Model and Data Gaps Analysis.
The purpose of the hazard identification is to evaluate the nature and extent of constituent releases
at a site and to select a subset of constituents, identified as Chemicals of Potential Concern (COPCs),
for quantitative evaluation of the risk assessment. This process involves data evaluation and selection
of the COPCs through relevant screening steps. The primary COPCs for the Project are dioxin and
arsenic.
The purpose of the toxicity assessment is to identify the types of adverse effects a COPC may cause
and define the relationship between the dose of a constituent and the likelihood and magnitude of an
adverse effect. These relationships are represented mathematically as cancer slope factors (SFs) or
inhalation unit risks (IURs) for carcinogenic effects and as reference doses (RfDs) or inhalation
reference concentrations (RfCs) for non-carcinogenic effects. Noncancer toxicity criteria were
selected for both chronic and subchronic exposures.
The purpose of the exposure assessment is to predict the magnitude and frequency of potential human
exposure to each of the COPCs for quantitative evaluation in the risk assessment. This exposure
assessment was based on the SCM, which characterized the sources, release, and distribution of
COPCs to receptors through exposure pathways
The potential exposure scenario considered was the current conditions on and off the Airbase. The
potential receptor groups assumed for this risk assessment were local residents, resident Airbase
personnel and families, and nonresident Airbase personnel.
The risk characterization provides a quantitative evaluation and qualitative discussion of the risks and
hazards posed by the COPCs in each environmental medium for each scenario. Both non-carcinogenic
and carcinogenic health effects are addressed. Non-carcinogenic health effects are characterized by
comparing estimated doses to the maximum acceptable doses, and carcinogenic health risks are
characterized with respect to cancer risks that typically trigger regulatory concern.
During the Masterplan Roadmap Meeting 2, consensus was reached with GVN stakeholders on the
initial ARARs. Then the A&E Bien Hoa Contractor consolidated the Stakeholder feedback, and, ahead
of the Roadmap Meeting 3, prepared an updated list of ARARs. Stakeholders provided written
comments, and at Meeting 3, verbal comments during a final review to ensure the context of the input
had been understood correctly.
The Tabulated Summary of ARARs, including further details on their development, is provided in
Annex 5.
TABULATED SUMMARY OF
APPLICABLE OR RELEVANT AND
APPROPRIATE REQUIREMENTS
PREPARED BY
TRIGON ASSOCIATES, LLC
1515 POYDRAS ST. SUITE 2200
NEW ORLEANS, LA 70112
USA
DISCLAIMER
THE VIEWS EXPRESSED IN THIS PUBLICATION DO NOT NECESSARILY REFLECT THE VIEWS OF THE UNITED STATES
AGENCY FOR INTERNATIONAL DEVELOPMENT OR THE UNITED STATES GOVERNMENT.
CONTENTS
CONTENTS I
TABLES I
LIST OF ACRONYMS AND ABBREVIATIONS II
EXECUTIVE SUMMARY III
1 INTRODUCTION 1
2 DEFINITION OF ARARS 1
2.1 TYPES OF ARARS 1
2.2 ARAR RELEVANCY 2
2.3 ARAR APPLICATION 2
3 PURPOSE 3
4 ARARS IDENTIFICATION METHODOLOGY 3
4.1 STEP 1 – IDENTIFICATION AND ACQUISITION 4
4.2 STEP 2 – EVALUATION 4
4.3 STEP 3 – REFINE ARARS 5
4.4 STEP 4 – STAKEHOLDER REVIEW 5
4.5 STEP 5 – STAKEHOLDER FEEDBACK 5
4.6 STEP 6 – FINAL APPROVED ARARS 5
5 RESULTS 6
6 ARARS IN THE CONTEXT OF PROJECT PROGRESSION 16
6.1 STAKEHOLDER ENGAGEMENT 16
6.2 ARARS REVISIONS 16
TABLES
Table 5-1. Potential ARARs...................................................................................................................................... 7
USAID’s intent in developing the ARARs list is to ensure application of applicable, relevant, and
appropriate requirements to the Project in the protection of human health and the environment.
Maintaining the ARARs list will be an ongoing process that will be revisited at critical points throughout
the Project. The initial approved list of ARARs reflects Project goals and requirements approved to
date by USAID and GVN. As the Project progresses, it is possible that conditions may change, new
information may become available, or new/amended laws may be enacted or promulgated. If such
changing conditions create an opportunity to better meet the objectives of protecting human health
and the environment, USAID may update the ARARs list and related Project goals and implementation
practices will be modified, as applicable.
This ARARs Summary covers the first four steps of a six-step process to develop an Approved ARARs
list. These first three steps were completed by the USAID/Vietnam Architect–Engineer Services for
Dioxin Remediation at Bien Hoa Airbase Area Contractor and included the identification of potential
requirements to review for relevancy, followed by the acquisition of electronic copies of the
requirement-related documents, which included obtaining English translations of some Vietnamese
requirements, and an evaluation of the requirements to determine their applicability or relevancy to
the Project.
This ARARs Summary includes an initial list of recommended ARARs derived from the numerous
requirements considered and evaluated. The next three steps will include further evaluation from a
broader set of reviewers, finalization of the Table of Requirements, and approval of the ARARs by
USAID.
The Project is a collaborative effort of USAID and the Government of Vietnam (GVN) to select and
implement a remedy for the Bien Hoa Airbase Area, which is the last major dioxin contaminated site in
Vietnam identified for remediation following the successful collaboration in dioxin remediation of Danang
Airport. Air Defence-Air Force Command (ADAFC) is the MND assigned project owner and counterpart
to USAID. Based on previous remediation efforts at other sites in Vietnam, USAID and GVN have
identified some lessons learned that will be applied to the Project. One notable lesson from remediation
efforts elsewhere in Vietnam was recognition of the need for an approved list of specific requirements
and standards to which design and implementation would be measured. Therefore, this Project includes
the development of this list of requirements, as described in this ARARs Summary.
2 DEFINITION OF ARARS
The process of identifying ARARs for this remediation project is intended to inform USAID consultations
with Project stakeholders and implementers of the remedial actions on standards that could be utilized
to protect human health and the environment. This process requires a comprehensive approach to: a)
review requirements potentially applicable to or deemed relevant and appropriate to apply to Project
implementation; and b) to engage in an evaluation process that results in the selection of protective
standards to guide the Project. The ARARs also provide the basis for establishing the programs and
procedures for achieving and maintaining regulatory compliance while the work progresses in Vietnam.
This section defines the different types of ARARs and how relevancy is described. The methodology
implemented to evaluate and ultimately select the requirements to be included in the final list of project-
specific ARARs is presented in Section 4.
CHEMICAL-SPECIFIC
Standards that are chemical-specific typically regulate how a material contaminated with a particular
concentration of a chemical or chemical compound must be handled. These concentration thresholds, or
action levels, are typically established based on human and/or environmental risk-based criteria.
With respect to dioxin, requirements are typically established for the “reference congener” compound
2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD), because it is known to be the most toxic. The human
exposure and environmental limits for dioxin and “dioxin-like compounds” are expressed in terms of
ACTIVITY-SPECIFIC
Requirements that are activity-specific (or sub-activity specific) are typically associated with technologies
employed or actions that need to be performed with respect to contaminated materials. For the purposes
of the Project, an activity is a specific remediation or remediation support activity. A sub-activity is unique
to a specific location or type of work that require focused tracking and delivery efforts. A specific action
or operation will require activity-specific ARARs. Activity-specific requirements may not factor into which
Project remedial alternatives are selected, but they will help establish how remediation should be
implemented. Some worker health and safety regulations fall into this category.
LOCATION-SPECIFIC
Location-specific standards dictate preferred activities based on the specific geographic location or specific
physical position of the site. These ARARs guide design of remediation activities based on their location
within the environment, such as restricting certain activities within a floodplain.
Applicable: Cleanup standards or regulations that specifically address a hazardous substance, pollutant,
contaminant, remedial action, or location specific to the Bien Hoa Project.
Relevant and Appropriate: Cleanup standards or regulations while not specifically “applicable” to a
hazardous substance, pollutant, contaminant, remedial action, location, or situations sufficiently similar
to those encountered at the site that their use is well suited to the Bien Hoa Project.
To Be Considered (TBC): Consists of advisories, criteria, or guidance that were developed by regulatory
agencies that may be useful in developing the Bien Hoa remediation Masterplan.
• Action taken is only part of a total remediation that will attain ARARs upon completion;
• Remedial action selected will attain a standard of performance that is equivalent to the ARAR; and
In order to move forward with developing plans for remediating the site, it is imperative that there is a
set of standards in place to define the acceptable concentrations of contaminants in the environment and
acceptable methods for remediation. Ultimately, these standards will help define the level of cleanup
required, treatment goals and objectives, volume of material to be treated, and waste classifications for
disposal. Therefore, the process to select the ARARs is a cornerstone to successfully developing and
implementing the Project.
The selection of ARARs is not a one-size-fits-all approach. There are many factors that impact the
applicability of existing standards. As such, ARARs selection requires a comprehensive approach. While
the ARARs for one site may be similar to another site, the existing conditions at each site must be assessed
to define the site-specific ARARs. In the case of the Bien Hoa Airbase Area, to ensure the local conditions
and are considered and local procedures adhered to, the research into applicable requirements
encompassed both Vietnamese and US laws. Other key site-specific considerations are the inclusion of
labor and gender opportunities. The ARARs for this Project must bring about the assurance that women
will be provided with equal opportunity to participate in all facets of the Project and ensure that identified
potential gender-based impacts are accounted for and managed.
As the selection of ARARs is such an important component to the successful progression of the project,
it is imperative that all stakeholders be engaged in the selection process. This required an iterative
approach to ARAR assessment and selection. Additional details on the methodology for ARAR
identification, evaluation, and selection are covered in Section 4.
A/E Bien Hoa Contractor – Implement the Identification and Evaluation of ARARs process. Work in
coordination with USAID to solicit and collect stakeholder input through engagement-oriented meetings
and other collaborative efforts.
Subject Matter Experts (SMEs) – Members of the Project implementation team, including independent
consultants, enlisted to provide expertise in the areas of technical importance to the Project design and
implementation such as environmental impacts (air quality, water quality, hazardous waste management,
etc.), occupational health and safety, and gender issues.
2 Locate and review the requirements for applicability to the Airbase conditions A&E Bien Hoa
Contractor/SMEs
3 Narrow down the list of potential regulations and develop an initial ARARs list A&E Bien Hoa
of potential regulations in tabular form to share with Project stakeholders Contractor/SMEs
4 At Masterplan Roadmap Meeting 2, stakeholders review the list of ARARs and Stakeholders and A&E
discuss with the A&E Bien Hoa Contractor the relevancy and completeness of Bien Hoa Contractor
the regulations listed
5 Before and during Masterplan Roadmap Meeting 3, feedback from stakeholders Stakeholders and A&E
applied to finalize ARARs list Bien Hoa Contractor
6 Final ARARs list approved with the Final Implementation Masterplan USAID in consultation
with ADAFC
Many of the GVN requirements were readily found through Internet searches; however, acquiring English
translations of the Vietnamese regulations and standards required the use of the Vietnam Legal Documents
Database service. The A&E Bien Hoa Contractor also directly translated some of the Vietnamese
regulations. Electronic copies of requirements acquired through this process will be maintained for use by
USAID and SMEs throughout the Project.
5 RESULTS
The Project ARARs are included as Attachment I. This attached table identifies the citations and titles, as
well as a general description of the applicable portion of each that includes the requirement. The date that
the citation was promulgated and information on the source of the citation, such as the country of origin,
issuing organization, and document URL address are also provided, for reference, where it was available.
A summary of the detailed ARARs that represent key decision points anticipated to be critical for initial
Project activities/sub-activities is provided in Table 5-1. The “Origin” column indicates the country that
promulgated the citation, so the entries are GVN and USG, respectively.
The terminology used in some of the standards includes reference to total dioxin, which indicates the
value represents the sum of the following isomers: TCDD (tetrachlorodibenzo-p-dioxin); PeCDD
(pentachlorodibenzo-p-dioxin); and HxCDD (hexachlorodibenzodioxin).
ACTIVITY 1: CLEANUP LEVELS FOR CONTAMINATED SOIL AND SEDIMENT (A = Applicable R&A = Relevant & Appropriate)
NO. CITATION TITLE DATE ORIGIN DESCRIPTION ACTION A OR R&A
1 QCVN National Technical 2012 GVN Defines seven land use types and provides Utilize the maximum allowable limits A
45:2012/BTNMT Regulation on a limit on dioxin allowable in soils for the based on land use to determine the
Allowed Limits of protection of human health and the decision units needing remediation.
Dioxin in Soils environment. Four land use types (and Utilize the Maximum Allowable Limit of
maximum allowable dioxin limits) are dioxin in soils for the Land Use category
applicable to the Project site: of Forest land, land for perennial trees
– Land Use No. 2 Forest land, land for (100 ppt TEQ), as the maximum dioxin
perennial trees: level for reuse in formerly contaminated
100 ng/kg TEQ (ppt TEQ) areas. In addition, apply other screening
– Land Use No. 4 Urban residential land: criteria related to soil condition and
300 ppt TEQ content (e.g., exclusion of debris such as
– Land Use No. 6: Commercial land: wood, asphalt, concrete, metal, plastic)
1,200 ppt TEQ sized larger than gravel.
– Land Use No. 7: Industrial land:
1,200 ppt TEQ
2 QCVN National Technical 2017 GVN To protect waterbodies with aquaculture, No action per Decision No. 702/QD- A
43:2017/BTNMT Regulation on the allowable limit for dioxin is 21.5 ng/kg BTNMT. Per Decision No. 3869/QD-
Sediment Quality TEQ (ppt TEQ) and for arsenic is 17.0 BQP use this in aquaculture lakes and
mg/kg in freshwater sediments. Sediment is ponds; however, no Project areas have
defined as material particles located at a been identified with aquaculture as the
depth of not more than 15 cm from the land use.
bottom surface of the water, the particles
with size of smaller than 2 mm or passing
through a sieve with 2 mm diameter hole
(U.S. # 10 sieve).
3 TCVN 8183:2009 Dioxin Threshold in 2009 GVN This requirement establishes maximum Utilize this cleanup level for sediment in A
Soil and Sediment allowable concentrations of waterbodies not designated for
polychlorinated dibenzo-p-dioxins aquaculture, including stormwater
(PCDDs) and polychlorinated management features.
dibenzofurans (PCDFs) as 150 parts per
trillion (ppt) toxicity equivalent (TEQ) for
sediment.
5 Decision Document Approval of 25 March GVN Approves the EIA report developed by Utilize the treatment requirement of A
No. 702/QD-BTNMT Environmental Impact 2019 ADAFC for the Dioxin Remediation at <100 ppt TEQ, this represents the
Assessment Report – Bien Hoa Airbase Area Project including lowest of the limits established for
The Dioxin Remediation treatment requirement to <100 ppt TEQ, the land use categories anticipated
and Bien Hoa Airbase maximum storage threshold of 1,200 ppt for future development of Bien Hoa
Area Project TEQ, and initial location of long-term Airbase.
storage in the quarry area. Utilize the maximum storage
threshold of 1,200 ppt TEQ. Location
of storage area modified in Decision
No. 3869/QD-BQP.
9 NRC (National Acceptable Levels of 1988 USG This document outlines a proposed Use the wipe test limit to determine R&A
Research Council) Dioxin Contamination in sampling strategy and appropriate unrestricted reuse.
Committee on an Office Building cleanup action following a fire in a
Toxicology - National Following a Transformer NASA office building, that involved a
Academy Press Fire transformer containing
polychlorinated biphenyls (PCBs)
– Dioxin: <25 ng TCDD/m2
10 Journal of Exposure PCB and Dioxin Re- 1994 USG Document provides some guidelines Use the wipe test limit of to determine R&A
Analysis and Entry Criteria for for re-entry criteria for PCB and its acceptability for offsite disposal as scrap.
Environmental Building Surfaces and Air pyrolysis and combustion by- Need to achieve the more stringent limit
Epidemiology, Vol. 4, products for buildings requiring for unrestricted use.
No. 2, 1994 decontamination after a PCB fire.
– Dioxin: <125 ng TCDD/m2
11 QCVN 03- National Technical 2015 GVN Maximum allowable limits of heavy Utilize the agricultural/residential limit to R&A
MT:2015/BTNMT Regulation on Limit of metals in soil based on land use. determine unrestricted reuse. Utilize the
Some Heavy Metals in Most stringent requirement: industrial/commercial limit to determine
Soils – Arsenic: 15 mg/L (agricultural or restricted reuse.
residential land)
Least stringent requirement:
– Arsenic: 25 m/L
(commercial/industrial land)
The list of Requirements in Attachment 1 includes references that the SMEs have identified and
reviewed to determine if they are potentially applicable or relevant to the Project. In some cases,
the regulations are more than 10 years old. The research completed to date has resulted in the
acquisition of updated regulations and standards. The ARARs were a topic of discussion during
Masterplan Roadmap Meeting 2, which took place from November 14–15, 2019. During
stakeholder review of the laws, regulations, and standards identified for evaluation as potential
ARARs for the Project, it was requested that each stakeholder identify any regulations and
standards that are known to have more recent versions, as well as provide feedback on
requirements to be excluded or additional requirements to be included.
Prior to Meeting 3, the participating stakeholders were provided information regarding ARARs and
requested to provided written comments. During the meeting on February 27–28, 2020,
stakeholders provided additional comments and reviewed the ARARs list provided by USAID to
determine if any further changes were needed. This included reaching consensus on ARARs for all
phases of the Project including reuse and disposal of materials at the end of the Project.
FINAL TECHNICAL
MEMORANDUM SITE CONCEPTUAL
MODEL AND DATA GAP ANALYSIS
PREPARED BY
TRIGON ASSOCIATES, LLC
1515 POYDRAS ST. SUITE 2200
NEW ORLEANS, LA 70112
USA
DISCLAIMER
THE VIEWS EXPRESSED IN THIS PUBLICATION DO NOT NECESSARILY REFLECT THE VIEWS OF THE UNITED STATES AGENCY
FOR INTERNATIONAL DEVELOPMENT OR THE UNITED STATES GOVERNMENT.
CONTENTS
CONTENTS.................................................................................................................................................................. I
RECORD OF REVISIONS ....................................................................................................................................... III
LIST OF ACRONYMS AND ABBREVIATIONS ................................................................................................ IV
EXECUTIVE SUMMARY ........................................................................................................................................... 1
1 INTRODUCTION AND PURPOSE ................................................................................................................ 3
2 EXISTING DATA.................................................................................................................................................. 4
3 SITE CONCEPTUAL MODEL ........................................................................................................................... 5
3.1 SITE DEFINITION AND SETTING ........................................................................................................ 5
3.2 SOURCES OF CONTAMINATION AND DISTRIBUTION ......................................................... 10
3.3 MIGRATION PATHWAYS AND EXPOSURE ROUTES ................................................................ 20
3.4 SENSITIVE RECEPTORS .......................................................................................................................... 23
3.5 SITE CONCEPTUAL MODEL................................................................................................................ 25
4 IDENTIFICATION OF DATA GAPS, DETERMINATION OF CRITICALITY, AND
RECOMMENDATIONS FOR RESOLUTION ............................................................................................. 29
4.1 ORGANIZATION OF IDENTIFIED DATA GAPS ........................................................................... 29
4.2 DETERMINATION OF CRITICALITY................................................................................................. 29
4.3 RECOMMENDATIONS FOR RESOLUTION.................................................................................... 30
5 CONCLUSIONS ................................................................................................................................................. 36
5.1 SITE CONCEPTUAL MODEL................................................................................................................ 36
5.2 CRITICAL DATA GAPS .......................................................................................................................... 37
5.3 NEXT ACTIONS FOR CRITICAL DATA GAP RESOLUTION ................................................... 37
6 REFERENCE LISTING OF DATA AND INFORMATION ....................................................................... 38
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FIGURES
FIGURE 1 BIEN HOA AIRBASE AREA ........................................................................................................ 7
FIGURE 2 BIEN HOA AIRBASE AREA 2009 TOPOGRAPHY AND DRAINAGE AREAS ............ 8
FIGURE 3 HISTORICAL 1968 TOPOGRAPHIC AND INFRASTRUCTURE MAP .......................... 9
FIGURE 4 IDENTIFIED DECISION UNITS WITH LAND USE .......................................................... 12
FIGURE 5 DONRE OFF-AIRBASE SAMPLING AND RESULTS ......................................................... 16
FIGURE 6 DONRE OFF-AIRBASE AREAS IDENTIFIED WITH ELEVATED DIOXIN
CONCENTRATIONS ................................................................................................................. 18
FIGURE 7 SURFACE DIOXIN CONCENTRATIONS AT BIEN HOA AIRBASE AREA .............. 19
FIGURE 8 DIAGRAM FOR SITE CONCEPTUAL MODEL .................................................................. 26
FIGURE 9 ILLUSTRATIVE SITE CONCEPTUAL MODEL .................................................................... 27
TABLES
TABLE 1 SUMMARY OF BIEN HOA AIRBASE SCM ELEMENTS ...................................................... 28
TABLE 2. DATA GAPS, CRITICALITY, AND RECOMMENDED ACTIVITIES FOR
RESOLUTION ............................................................................................................................... 31
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RECORD OF REVISIONS
PAG SUMMARY OF
REVISION DATE APPROVAL
ES REVISIONS
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LIST OF ACRONYMS AND ABBREVIATIONS
ADAFC Air Defence - Air Force Command
A&E Architect & Engineer
AMST Academy of Military Science and Technology
ASTM American Society for Testing and Materials
bgs below ground surface
BHL Bien Hung Lake
BRA Baseline Risk Assessment
bw body weight
bw/d body weight per day
cm Centimeter
CIFA Canadian Food Inspection Agency
CLIN Contract Line Item Number
COC Contaminant of Concern
d Day
DGA Data Gaps Analysis
DONRE Department of Natural Resources and the Environment
DU Decision Unit
EA Environmental Assessment
EIA Environmental Impact Assessment
ESS Environmental Scoping Statement
EU European Union
G2L Gate 2 Lake
GIS Geographic Information System
GVN Government of Vietnam
HASP Health and Safety Plan
kg kilogram
m3 Cubic Meters
MCL Maximum Contaminant Level
MIS Multi-Increment® Sampling
MND Ministry of National Defence
MONRE Ministry of Natural Resources and the Environment
PAD Project Appraisal Document
Pb Lead
pg pico-gram
PPE Personal Protective Equipment
ppt parts per trillion
ppq parts per quadrillion
QAPP Quality Assurance Project Plan
SAP Sampling and Analysis Plan
SCM Site Conceptual Model
SI Site Investigation
SOW Statement of Work
SVOC Semi-volatile Organic Compound
SWEMMP Site-wide Environmental Monitoring and Mitigation Plan
SWPPP Storm Water Pollution Prevention Plan
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TCH Thermal Conductive Heating
TDS Total Dissolved Solids
TEQ Toxicity Equivalent
TM Technical Memorandum
TSS Total Suspended Solids
ug/L micrograms per liter
UNDP United Nations Developmental Programme
US United States
USAID United States Agency for International Development
USEPA United States Environmental Protection Agency
UXO Unexploded Ordnance
VOC Volatile Organic Compound
VRTC Vietnam Russia Tropical Center
WHO World Health Organization
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EXECUTIVE SUMMARY
This Technical Memorandum (TM) documents the Architecture & Engineering (A&E) Bien Hoa
Contractor evaluation of existing data and advances the Site Conceptual Model (SCM) for the
Bien Hoa Airbase Area to guide Masterplan development and implementation.
The SCM is described in the context of the Bien Hoa Airbase Area site definition and setting,
sources of contamination and distribution, migration pathways and exposure routes, and sensitive
receptors. The SCM is presented in a narrative format and illustrated in a pictorial manner to
facilitate communication of dioxin contamination and exposure issues. The SCM substantiates:
• Secondary sources of contamination remain at the Bien Hoa Airbase Area in the form of
dioxin-contaminated soils and sediments, with a significant fraction of these dioxin-
contaminated soils and sediments being located in the Pacer Ivy and Z1 areas (site of the
most significant historical primary sources of contamination by Agent Orange and other
herbicides that were handled and used on the Airbase during the war).
• Dioxin-contaminated soils and sediment have migrated from their original source sites
through physical transport mechanisms, especially storm water runoff. This migration
pathway has been mitigated by GVN interim measures over the past decade, but some storm
water-borne migration is likely ongoing.
• Off-Airbase dioxin contamination is mostly within soils and sediments located in land areas
adjacent to the Pacer Ivy Area which appear largely contaminated by water-borne erosion of
contaminated soil from that on-base area.
• Groundwater flow is not a significant dioxin migration pathway as dioxin is not very soluble
and is prone to partitioning to suspended organic solids. Measured dioxin concentrations in
groundwater are in picograms per liter.
• Some contaminated soils have been intentionally excavated or unintentionally disturbed both
before and since the performance of an Environmental Assessment (EA) in 2014 and 2015
(GVN/USAID 2016) (e.g., Southwestern Area Decision Units SW-01 and SW-02 and off-base
areas outside of Pacer Ivy).
The Data Gaps Analysis identifies gaps in available data and information guided by the SCM.
The identified critical data gaps should be addressed early in Masterplan implementation include:
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• Physical and basic chemical properties of soils and sediments;
• Groundwater/aquifer characteristics;
• Nature and extent of dioxin contamination in soils and sediments in decision units currently
incompletely characterized and those areas that the SCM suggests may have been missed by
the EA, including XD2 landfill;
• Baseline dioxin and other key water quality parameters and characteristics of surface water,
storm water runoff, and groundwater in the Airbase area;
• Surface water and storm water quality, runoff drainage patterns, and discharge points; and
In addition, measuring dioxin concentrations in flora and fauna in the Airbase area not assessed
during the EA should be considered since this would allow a more thorough risk assessment
As next steps, USAID plans to jointly review these critical data gaps and proposed solutions
with GVN stakeholders and reach consensus on additional site investigation and evaluation
activities.
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1 INTRODUCTION AND PURPOSE
Trigon Associates, LLC (A&E Bien Hoa Contractor) developed this Technical Memorandum (TM)
Site Conceptual Model (SCM) and Data Gaps Analysis (DGA) for the US Agency for International
Development (USAID) under Contract No. AID-OAA-I-15-00053, Task Order No.
72044019F00001, in accordance with Section C – Description/Specifications/ Statement of Work
(SOW), Subsection C.5 Statement of Work, Component 1 (CLIN 1), Task 1.3, Site Conceptual
Model (SCM), Baseline Risk Assessment, and Data Gaps Analysis.
The purpose of this Technical Memorandum (TM) Site Conceptual Model (SCM) and Data Gaps
Analysis (DGA) is to:
• Advance a SCM to guide development and implementation of the Dioxin Remediation of the
Bien Hoa Airbase Area Project (Project) Implementation Masterplan (Section 3);
• Identify perceived gaps in existing data and information and recommend site investigation
(SI) and other evaluation activities to resolve critical data gaps needed to improve the SCM
and Masterplan implementation (Section 4).
Concurrent with development of this TM for SCM and DGA is development of a TM for Baseline
Risk Assessment (BRA) for the Project. The BRA encompasses an evaluation of dioxin and arsenic
concentrations (including arsenic speciation, distribution, and bioavailability as it relates to human
health and ecologic risk) and presents Bien Hoa Airbase Area-specific data that support a human
health and ecological risk assessment. It is expected that the findings and conclusions from the
TM BRA could result in revisions to the SCM presented herein.
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2 EXISTING DATA
Appreciable data and information relevant to dioxin contamination and remediation in the Bien
Hoa Airbase Area has been generated as a result of past efforts of Government of Vietnam
(GVN), USAID, and other entities with respect to characterizing and addressing dioxin
contamination and evaluating ecological and human health impacts in the Bien Hoa Airbase Area
Early efforts and the data they generated include: Works undertaken by the 10-80 Division, Office
33, Hatfield, Vietnam Russia Tropical Center (VRTC), various international organizations, e.g.,
United Nations Development Programme [UNDP], Ford Foundation, and the GVN to conduct
surveys and research, and evaluate the extent of arsenic and dioxin contamination from 1993
through 2011. Many publications developed from these works and referenced in Section 6.
• Project XD1, implemented by the Chemical Command from 2005 to 2010, which completed
excavation and containment of approximately 62,500 m3 across 4.3 hectares (ha) of dioxin-
contaminated soils in the Z1 area at the Bien Hoa Airbase in the Z1 Landfill.
• GVN/USAID Environmental Assessment (EA) of Dioxin Contamination at Bien Hoa Airbase,
prepared in 2016 documents the nature and extent of dioxin contamination at the Bien Hoa
Airbase Area and evaluates exposure pathways, short-term mitigation measures, and
remediation alternatives (treatment and/or containment measures). It also summarizes
historical data collected prior to the EA
• Project XD2, implemented by the Chemical Command from 2015 to 2016, which excavated
approximately 51,500 m3 of dioxin-contaminated soils at the Southwestern Area and the Z1
Area of the Airbase and placed it in the XD2 Landfill (located adjacent to and on the east side
of the Z1 Landfill and understood to be of similar design).
• Vetiver grass project, initiated in 2014 by Vietnam Institute of Geosciences and Mineral
Resources / Ministry of Natural Resources and Environment (MONRE), entailing the
experimental planting of Vetiver grass on 300 m2 of Pacer Ivy area for the purpose of
mitigating dioxin contamination.
• Dong Nai Department of Natural Resources (DONRE) off-Airbase sampling from 2012 to
2016 for monitoring off-Airbase migration of dioxin in drainage areas identifying three off-
Airbase areas with elevated dioxin concentrations in soils and sediment, including one
residential area. Unpublished data; however, shared in DONRE/USAID meeting minutes.
• MND/ADAFC Report of Environmental Impact Assessment (EIA) for the Dioxin Remediation
at Bien Hoa Airbase Area Project in 2019 with the expected implementation of Alternative
4 in the EA outlining two phases of the project: Phase 1 - focusing on remediation of the
Pacer Ivy Area; and Phase 2 - focusing on remediation of the Z1 Area. The EIA provides
additional data on water, air, and soil quality, and includes environmental mitigation measures
and monitoring requirements to be implemented during the construction activities.
Section 6 lists information and data from these efforts relevant to the development of this TM
and/or that are referenced herein. Section 6 is not intended to serve as a comprehensive registry
of available data and information.
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3 SITE CONCEPTUAL MODEL
This SCM synthesizes relevant, existing data with respect to site definition and setting, sources
of contamination, transport mechanism and migration pathways, exposure routes, and sensitive
receptors for the Bien Hoa Airbase Area.
ASTM International E1689-95 (2008) Standard Guide for Developing Conceptual Site Models for
Contaminated Sites, defines a SCM as ‘a written or pictorial representation of an
environmental system and the biological, physical and chemical processes that
determine the transport of contaminants from sources through environmental
media to environmental receptors in the system.’ The SCM provides a foundation for the
evaluation of human health and ecological risks to dioxin contamination at the Bien Hoa Airbase
Area. Furthermore, by supporting the identification of data gaps, the SCM assists in the
determination of additional site investigation (SI) and evaluation requirements. As noted in ASTM
E1689-95 (2008), the SCM is to be ‘used to enable experts from all disciplines to
communicate effectively with one another, resolve issues concerning the site and
facilitate the decision-making process.’
The SCM established in this TM for the Bien Hoa Airbase Area during the Masterplan
development is expected to facilitate communication of dioxin contamination and exposure issues
with GVN and other stakeholders in support of Masterplan approval and initiation of Project
activities. It is recognized that as data gaps relevant to the SCM are resolved and/or additional
data and information become available, the SCM may necessitate revision to reflect the current
understanding of the Bien Hoa Airbase Area, dioxin contamination, and exposure issues.
The establishment of the SCM is discussed in the context of four major elements: Site
Definition and Setting (Subsection 3.1), Sources of Contamination and Distribution
(Subsection 3.2), Migration Pathways and Exposure Routes (Subsection 3.3), and Sensitive
Receptors (Subsection 3.4).
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purposes. Northern portions of the Airbase are used for agriculture (cattle grazing) and Northern
and Western portions of the Airbase for forestry (rubber tree and acacia tree plantations).
The topography in the Northern portion of the Airbase is slightly more elevated, and drainage
from the on-Airbase to off-Airbase areas generally flows west from the Pacer Ivy Area, west and
partly south from the Southwest Area and Z1 Area, and southeast from the Southeast Area and
Northeast Area, with the respective drainage waterways eventually leading to the tidally-
influenced Dong Nai River. A White Paper titled, Generalized Hydrogeological Framework of the
Bien Hoa Airbase Area including Abandoned Hard Rock Quarry Area (USAID 2017) documents
elevations on the Airbase as ranging from 4 to 30 meters (m), a general topographic slope to the
west and south towards the Dong Nai River, and a major southwest-northeast-oriented drainage
divide cross cutting the Airbase. The elevation of the Dong Nai River varies between -2.00 and
+2.08 meters above sea level 1. Since 2017, water leaving Pacer Ivy at PI-8/PI-9 exits through a
rock gabion structure into the drainage canal, and the drainage canal has had a rock weir near its
mouth with the Dong Nai River since June 2019. Figure 2 presents a topographic image from the
2009 GVN survey data showing topography at one meter (m) contours and the Airbase drainage
areas. For comparison, Figure 3 shows topography and Airbase infrastructure from 1968.
There are a number of lakes and ponds on the Airbase that were previously used for aquaculture
purposes, primarily raising Tilapia (Nile Tilapia), also ducks, and other aquatic animals. Use of the
lakes and ponds on the Airbase for aquaculture purposes was banned in 2010; however,
enforcement of the ban is been challenging and it has been reported as recently as 2016 that
fishing still occurs (GVN/USAID 2016).
1
Data for Dong Nai River at Bien Hoa from 2007 through 2015 (http://lvsdongnai.cem.gov.vn/)
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FIGURE 1 BIEN HOA AIRBASE AREA
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FIGURE 2 BIEN HOA AIRBASE AREA 2009 TOPOGRAPHY AND DRAINAGE AREAS
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FIGURE 3 HISTORICAL 1968 TOPOGRAPHIC AND INFRASTRUCTURE MAP
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3.2 SOURCES OF CONTAMINATION AND DISTRIBUTION
Dioxins are a family of compounds that share distinct chemical structures and characteristics.
Dioxins have two phenyl rings connected by two oxygen atoms. One or more chlorine atoms
can attach to any available carbon atom. Numerous dioxin-like compounds have been identified
that are considered to have significant toxicity. The singular term dioxin and the chemical name
dioxin refers to the most toxic compound, 2,3,7,8-tetrachlorodibenzo-para-dioxin (TCDD).
Dioxins have very low water solubility (i.e., are hydrophobic), tend to combine with or dissolve
in lipids or fats (i.e., are highly lipophilic), and when released to the ground, partition to the
organic fractions of soils and sediment (with little potential for leaching or volatilizing to air).
Dioxins are categorized as persistent organic pollutants (POPs), meaning dioxin takes a long time
to break down once present in the environment. These characteristics affect the relative
importance of migration and exposure routes as well as the effects on receptors.
Combined these properties lead to dioxin bioaccumulating in lipid rich areas of biota at
concentrations higher than the surrounding environmental media. Furthermore, individuals or
organisms located at higher trophic levels in the food chain will tend to have even higher levels
of dioxin from consuming organism that have directly bioaccumulated dioxin from the
environment. This food chain process of increased dioxin concentration is called biomagnification
and explains why humans are even more vulnerable to dioxin exposure than the fish and livestock
they consume.
3.2.2 PAST HANDLING, STORAGE, AND DISPOSAL OF HERBICIDES AT BIEN HOA AIRBASE
Past handling, storage, and disposal of Agent Orange and other herbicide compounds is the
primary source of dioxin-contaminated soils and sediment at the Bien Hoa Airbase Area
(GVN/USAID 2016).
During the US - Vietnam War, over 80,000,000 liters of herbicides were sprayed over southern
Vietnam to defoliate forests and crops during a mission termed Operation Ranch Hand (Cecil
1986). Bien Hoa Airbase was reportedly the largest and most active Operation Ranch Hand site
in Vietnam. Many of the herbicide mixtures were contaminated with 2,3,7,8-tetrachlorodibenzo-
p-dioxin (TCDD, or dioxin). Three storage tanks were used for herbicide storage at the Airbase;
one each for Agent Orange, Agent White, and Agent Blue and reportedly the Airbase stored or
handled 98,000 45-gallon (170-liter) barrels of Agent Orange, 45,000 barrels of Agent White and
16,000 barrels of Agent Blue (Department of Defense [DOD] 2007). Agent Blue did not contain
dioxin but organic arsenic was in the formulation.
Following the US – Vietnam War, a mission termed Pacer Ivy was initiated in September 1971 to
consolidate, re-package, and transport all remaining Agent Orange and other herbicide
compounds from southern Vietnam to Johnston Atoll in the central Pacific Ocean. This removed
any remaining primary sources of dioxin tied to Agent Orange use.
A detailed summary of the handling, storage, and disposal practices of Agent Orange and other
herbicide compounds at the Bien Hoa Airbase during the US – Vietnam War is presented in a
report titled Evaluation of Contamination at the Agent Orange Dioxin Hot Spots in Bien Hoa,
Phu Cat, and Vicinity, Vietnam (Hatfield/VRTC 2009).
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3.2.3 DIOXIN SOURCE AREAS
During 2014 to 2016, USAID collaborated with the GVN to conduct an Environmental
Assessment (EA) of dioxin contamination across the Bien Hoa Airbase Area and develop the
resulting report, Environmental Assessment of Dioxin Contamination and Bien Hoa Airbase,
dated May 3, 2016 (GVN/USAID 2016). Known dioxin source areas (i.e., areas where Agent
Orange and other herbicides were reported to have been stored, transferred, or otherwise
handled at Bien Hoa Airbase) were researched and documented.
• Z1 Area. Located in the southern portion of the Airbase, the Z1 Area was the main storage
area for Agent Orange, Agent Blue, and Agent White herbicides in tanks and drums and
initially contained the most heavily contaminated soils at the Airbase. The Z1 Landfill was
constructed by MND at Bien Hoa Airbase in 2009 specifically to isolate heavily contaminated
soils excavated from the Z1 Area.
• Southwest Area. Located west of the Z1 Area along the boundary of the Airbase, The
Southwest Area is reported to have been used as an Agent Orange storage area during the
Pacer Ivy Mission at the Bien Hoa Airbase. Dioxin contamination was identified in Southwest
Area soils in 2008 and 2010.
• Pacer Ivy Area. Located along the western portion of the Airbase at the end of the current
runway, the Pacer Ivy Area was used to store, re-drum and package approximately 11,000
containers of Agent Orange for shipping to Johnston Atoll in the central Pacific Ocean during
Operation Ranch Hand.
In addition to these three source areas, the EA documented the identification of elevated dioxin
concentrations in sediments in ponds located in the Northwest Area, Northeast Area, and
outside the Airbase in areas referred to as the Gate 2 Lake, Bien Hung Lake, and a drainage
canal west of the Pacer Ivy Area.
Guided by information on dioxin contamination collected over the years by different researchers
and an initial Site Conceptual Model developed for the EA, USAID with GVN partners undertook
an extensive sampling program under the EA to more fully characterize the nature and extent of
dioxin contamination across the source and other areas identified with elevated dioxin
concentrations. Soil and sediment sampling was conducted in nine general areas (Z1 Area, Z1
Taxiway [ZT] Area, Southwest Area, Pacer Ivy Area, Northwest Area, Northern Forest Area,
Northeast Area, Southeast Area, and the lakes outside of the Airbase). These nine areas were
divided into Decision Units (DUs) that were considered in the EA sampling approach to be a
reasonable size to assess average dioxin concentrations.
Thirty (30) soil/sediment aliquots were collected in each DU at a specific depth interval and
composited into one multi-increment® sampling (MIS) sample that was then analyzed and used
to estimate the average dioxin concentration for the DU soils or sediments. Each DU was further
divided into three screening level sub-decision units (sub-DUs) based on ten (10) aliquots
composited into a single MIS soil/sediment sample and used to generate contaminated soil and
sediment volume estimates relying on modeled assumptions of contamination depth when the
vertical extent of dioxin contamination had not been identified through sampling.
Figure 4 shows the DUs and Sub-DUs for on and off the Airbase and the associated land uses.
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FIGURE 4 IDENTIFIED DECISION UNITS WITH LAND USE
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In addition to soil and sediment samples, fish tissue samples were obtained during the EA sampling
program from select lakes and ponds located within DUs, particularly those that were historically
used for aquaculture purposes. Fish tissue dioxin concentrations were compared against
guidelines for human consumption from the European Union (EU) 3.5 ppt standard and the
Canadian Food Inspection Agency (CFIA) guideline of 20 ppt (68.3 ppt in whole fish).
3.2.4 SOIL, SEDIMENT, AND AQUATIC ECOSYSTEM SAMPLING RESULTS
Results from the EA sampling program identified the most dioxin contaminated soils and
sediments to be located within the three primary source areas, i.e., the Pacer Ivy Area, followed
by dioxin concentrations identified in soils and sediments within the Southwest Area and the
Z1 Area. Relevant notes made in the EA with respect to sampling all nine areas are as follows.
• Pacer Ivy Area. Numerous DUs in the Pacer Ivy Area exhibited soils and sediments with
dioxin concentrations above the GVN regulatory limits, particularly along the western
boundary of the Airbase with a maximum soil dioxin concentration recorded at DU PI-2, i.e.,
11,400 ppt at 30-60 cm depth bgs. Contamination extends outside the Airbase along the
drainage canal west of the Pacer Ivy Area, with a maximum soil dioxin concentration of 3,370
ppt. The source of this dioxin contamination was determined to be the transport of
contaminated soil/sediment along the drainage canal from the Pacer Ivy Area, which flows
westward through a series of drainage canals to the Dong Nai River. Very low contamination
was identified in Dong Nai River sediments sampled downstream of the canal with a maximum
of 69.1 ppt in the river sediments. Catfish from a Pacer Ivy Area pond exhibited high dioxin
concentrations (57.7 ppt in muscle; 3,550 ppt in fat; 69.5 ppt in whole fish) above EU and
CIFA guidelines for human consumption, 3.5 ppt and 20 ppt respectively. It was documented
that the pond present in the Pacer Ivy Area was previously used for aquaculture (tilapia, and
for the raising of ducks and other aquatic animals) with operations ceasing in 2015.
• Southwest Area. Identified dioxin concentrations in the Southwest Area included the
highest observed dioxin concentration of all sub-DU locations, i.e., 110,000 ppt at a 30-60 cm
depth bgs, down to the maximum depth sampled, i.e., 2,690 ppt at 120-150cm depth bgs.
Contamination in the Southwest Area appears to be concentrated in three DUs (i.e., the SW-
1, SW-2A and B, and SW-3A and B areas); however, dioxin concentrations exceeding MND-
approved dioxin limits were recorded in two additional sub-DUs, i.e., 674 ppt at SW-7A and
311 ppt at SW-7B. As presented in Section 2, during the XD2 Project soils from SW-1 and
SW-2 were excavated by MND in the springs of 2015 and 2016 and placed in a new landfill
(XD2) adjacent to the existing Z1/XD1 Landfill. The extent and depth of any remaining soil
contamination in the Southwest Area in these DUs is unknown. MND excavation surveys
and post-excavation confirmatory sampling has not yet been made available to USAID for
SW-1, SW-2.
• Z1 Area. Identified dioxin concentrations were low (especially in soils) with the exception
of soils in the Z1/XD1 Landfill and sediment in the lakes (maximum of 1,578 ppt in sediments
at 15-30 centimeter [cm] depth below ground surface [bgs]). Excavation of dioxin
contaminated soils and construction of the Z1 Landfill appears to have been effective in
significantly reducing overall dioxin concentrations in the Z1 area. Maximum soil dioxin
concentration recorded, excluding the Z1 Landfill, was at 901 ppt. Tilapia from lakes in the
Z1 Area exhibited dioxin concentrations (68.3 ppt in whole fish) above the guidelines for
consumption. Identified dioxin concentrations in the Z1 Landfill soils (1,510 ppt) were lower
than what was expected given the high concentrations of soils reportedly placed in the landfill
(up to 262,000 ppt). The Z1 Landfill has a reported construction waste thickness of 1.5
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meters (m) over a measured area of approximately 4.0 ha and is estimated to contain
approximately 61,500 m3 of contaminated soils (previous volume estimates indicated up to
100,000 m3).
• ZT Area. Identified dioxin concentrations in soils and sediments were below GVN
regulatory dioxin limits for industrial land use, with the exception of one sub-DU estimated
to have a concentration of 3,440 ppt.
• Northern Forest Area. Identified dioxin concentrations in soil samples from this area were
below applicable GVN regulatory dioxin limits, except two sub-DUs with a maximum soil
dioxin concentration of 465 ppt.
• Northwest Area. Identified dioxin concentrations in sediments from two ponds were
above the MND-approved dioxin limits, i.e., 477 ppt at 0-15 cm, and 262 ppt at 15-30 cm
depth, and 385 ppt at 0-15 cm, and 587 ppt at 15-30 cm depth bgs, respectively. Both ponds
were being used for aquaculture operations in 2015. Tilapia collected from these ponds had
the highest dioxin concentration of all fish sampled during the EA well above the guidelines
for consumption (49.9 ppt in muscle; 760 ppt in eggs; 3,780 ppt in fat).
• Northeast Area. Sediments in lakes were identified with dioxin concentrations above the
GVN regulatory standard of 150 ppt. The highest sediment dioxin concentrations identified
were 1,300 ppt at 0-15 cm and 765 ppt at 30-45 cm depth. Tilapia sampled exhibited dioxin
concentrations (837 ppt in fat) above the guidelines for consumption. Bighead Carp also
sampled exhibited dioxin concentrations (1,440 ppt in fat; 33.9 ppt in muscle) above the
guidelines for consumption. These lakes were being used for aquaculture in 2015 reportedly
producing significant quantities of fish for consumption and sale on- and off-Airbase
(GVN/USAID 2016).
• Southeast Area. Identified dioxin concentrations in soil samples from this area were below
applicable GVN land use regulatory dioxin limits, with a maximum of 64.5 ppt in one sub-DU.
• Gate 2 Lake (G2L) and Bien Hung Lake (BHL). Gate 2 Lake surface sediments were
identified with a dioxin concentration of 166 ppt, above the GVN dioxin contamination
standard for sediments of 150 ppt. No fish were sampled from Gate 2 Lake; however,
historical data for Gate 2 Lake indicates dioxin concentrations in whole Tilapia above
guidelines for consumption (Hatfield and Office 33 2011). Bien Hung Lake sediments were
identified with dioxin concentration below the GVN standard of 150 ppt with a maximum
dioxin concentration in sediments of 83 ppt. Reportedly, dredging of Bien Hung Lake
sediment occurred in 1995 (Nguyen et al 2005) and the dredging appears to have been an
effective measure in mitigating dioxin contamination of sediment; however, fish from Bien
Hung Lake sampled had dioxin concentrations in fat above the guidelines for consumption
(40.6 ppt in fat), but dioxin concentrations in other tissues below the guidelines (0.8 ppt in
muscle and 9.4 ppt in eggs).
In addition to soil, sediment and fish tissue sampling, drinking water samples were collected from
off-site production wells as well as on-site drinking water source wells as part of the EA sampling
program. There is no GVN standard for dioxin in surface water or groundwater; however, the
U.S. Environmental Protection Agency (USEPA) maximum contaminant level (MCL) for 2,3,7,9-
TCDD in drinking water is 30 parts per quadrillion (ppq) or picograms per liter (pg/L). No dioxin
concentrations were identified in the drinking water samples collected from these wells that were
above the USEPA MCL or applicable GVN wastewater discharge standard of 10 pg/L TEQ.
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3.2.6 GROUNDWATER SAMPLING RESULTS
Groundwater monitoring studies had been conducted at the Bien Hoa Airbase prior to the
conduct of the EA by Dekonta in association with DONRE and Office 33 (Urban et al. 2012).
These studies included the installation of groundwater monitoring wells at seven locations in and
around the Bien Hoa Airbase: four located in the vicinity of the Z1 Area; one located in the
Southwest Area; and two located in the Pacer Ivy Area (Dekonta 2014). Six of the seven
monitoring wells are screened at depths of 3 to 15 m below ground surface (bgs) and the last is
screened at depths of 2 to 6 m bgs. Sampling of these wells showed detectable but very low
dioxin concentrations, ranging in groundwater, ranging from 0.18 ppq to 17 ppq, in five of the six
wells (Dekonta 2014). All results were below the USEPA MCL, but some were above the GVN
discharge standard of 10 ppq.
Unfiltered and filtered groundwater samples were collected from six of these existing
groundwater monitoring wells as part of the EA (GVN/USAID 2016). Unfiltered groundwater
samples were identified with dioxin concentrations above the USEPA MCL and a GVN discharge
standard, as well as lead (Pb) concentrations above the USEPA MCL. Picloram (a component of
Agent Orange) was detected at concentrations below the USEPA MCL of 500 micrograms per
liter (ug/L); however, it was previously reported that MCL exceedances for Picloram were in
groundwater samples from these wells (Dekonta 2014). In filtered water samples, dioxin
concentrations in groundwater samples were below the USEPA MCL, but remained above the
GVN discharge standard of 10 ppq. The appreciable decrease of dioxin concentrations in filtered
groundwater samples from unfiltered groundwater samples from the same monitoring well is
expected given that dioxin is not very soluble and as previously noted is prone to partitioning to
suspended organic solids.
In the EA, it is noted that DONRE conducted dioxin monitoring for soil, sediments and
groundwater at several locations around the Airbase between 2005 to present (2015 at the time
of the EA preparation) and a table in the EA indicates analysis of 162 soil and sediment samples
in 2011. However, the EA states the laboratory analytical results were not available for review
(GVN/USAID 2016). DONRE provided their results to ADAFC in 2019.
The DONRE implemented dioxin monitoring was conducted in several City of Bien Hoa wards
surrounding Bien Hoa Airbase since 2009. The monitoring confirmed EA documented migration
of dioxin from on-Airbase to off-Airbase areas and identified some additional areas of migration
(USAID/DONRE 2019). DONRE conducted soil and sediment sampling along migration pathways
associated with storm water and surface water drainage from the Airbase: west of the Airbase,
heading to the tidally-influenced Dong Nai River and from Z1 Area of the Airbase toward the
Tang Phong Ward. Figure 5 provides maps of the DONRE monitoring of the off-Airbase sampling
locations with legends containing tables of the associated results. These maps collectively identify
three additional off-Airbase areas with elevated dioxin concentrations in soils and sediments:
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FIGURE 5 DONRE OFF-AIRBASE SAMPLING AND RESULTS
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2. DONRE-A2: An area of approximately 1,626 m2 of contaminated soils (reported with a
maximum of 4,023 ppt dioxin in soils) on open land located to the south-east of Pacer Ivy
Area near the access road to the Tran Bien Temple; and
3. MND-A42: An area of approximately 155 m2 of contaminated sediments reportedly dredged
from Bien Hung Lake years ago (maximum of 4,023 ppt dioxin) and placed on open land that
is located outside the Airbase entrance to the south of the EA’s Z1 Area.
The first area identified by the DONRE monitoring encompasses, but expands, the areal extent
of EA’s DU PI-12. The second area is a newly identified area of off-Airbase dioxin contamination
located southeast of Pacer Ivy Area DU PI-10 outside the Airbase security fence. The third area
was identified by DONRE in the aforementioned; however, this area was not noted in the meeting
minutes from recent meetings with USAID and the A&E Bien Hoa Contractor (USAID/DONRE
2019). In addition, DONRE has revised the estimation of contamination in G2L and now excludes
the areal extent of the Tax Department building currently under construction.
Figure 6 was developed using the DONRE maps (without having the coordinates of the polygons
depicting the contaminated areas) overlaid on the Bien Hoa Airbase Area map to illustrate the
three off-Airbase areas, and the revision to G2L, in relation to the Airbase boundaries and the
surrounding City of Bien Hoa wards.
It should be noted that CDM Smith conducted an assessment of the DONRE sampling program
(CDM Smith 2018a) and conducted a site visit on behalf of USAID to the DONRE laboratory
facility in Bien Hoa, Vietnam in specific reference to the facility's interest in acquiring dioxin
analytical capability (CDM Smith 2018b). The assessment is documented in a report titled,
Assessment of Dong Nai Department of Natural Resources and Environment Sampling Program,
and concluded that: DONRE sampling plans (combination of their Master Sampling Plans and Field
Sampling Guides) included appropriate detail on the number of samples, sampling methods,
sampling procedures, analyses performed, QC sample requirements, and decontamination
procedures; DU maps were appropriately detailed and reflected use of the MIS® sampling
methodology; and samples were correctly labelled, stored, and shipped to the laboratory (CDM
Smith 2018a). The site visit to the DONRE laboratory is documented in a letter report with the
expressed purpose to: obtain a better understanding of the structure, the analytical capability, the
quality plan, and future plans of the laboratory; and conduct a training session for DONRE staff
on the basics of quality assurance/quality control (QA/QC) and general requirements of a
dioxins/furans data package. Overall, some non-compliance in QA/QC was identified; however,
the laboratory staff were observed to be following good recordkeeping and document
organization practices and nearly all the non-compliances issues , including deficiencies in support
infrastructure, can be mitigated with additional capital investments (CDM Smith 2018b).
Figure 7 shows surface dioxin concentrations throughout the Airbase Area. The three historically
contaminated areas (Pacer Ivy, Southwest, and Z1) are all evident; although the area in Southwest
with high concentrations has decreased due to the XD-2 project and the contaminated soil
relocated to the Z1-XD2 landfill. Pacer Ivy remains the primary area to have contributed to off
Airbase contamination through surface water/storm water erosion. The DONRE-A2 results
show the (minor, given the contaminated area) importance of an additional off Airbase migration
pathway through drainage from the south of Pacer Ivy.
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FIGURE 6 DONRE OFF-AIRBASE AREAS IDENTIFIED WITH ELEVATED DIOXIN CONCENTRATIONS
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FIGURE 7 SURFACE DIOXIN CONCENTRATIONS AT BIEN HOA AIRBASE AREA
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Since the XD-2 Landfill is a mixture of material coming from different areas and depths, MND
documentation of remedial activities should be reviewed to understand any remaining
contamination adjacent to excavated area, as well as the concentration of material in the five
XD-2 landfill cells.
DONRE has not been able to formally share their data and sampling procedures, so additional
sample collection is needed to verify these results. It is not anticipated that the contaminated
volumes in DONRE-A2 or MND-A42 will change substantially since the sampling was
comprehensive across the entire area. In DONRE-A1, however, the sampling conducted was
localized within the larger area to address selected areas that residents had the greatest contact
with. It is not yet known whether the areas between the selected locations have similar
contamination levels. If, upon additional sampling, this is confirmed, then the contaminated volume
in DONRE-A1 will increase substantially (potentially double or triple in volume). Finally, it is
recommended that G2L be re-sampled now that the tax building construction has reduced the
area by approximately half.
Also evident in Figure 7 is the contamination in Northeast, particularly in NE-02 and NE-04.
The contamination in this area is under the industrial threshold but is high enough to cause
concern about potential recontamination of downstream areas in Northeast or off Airbase.
These are large decision units (approximately 24 hectares total) and additional site
characterization with smaller DU sizes should be conducted here. Two possibilities should be
considered when doing so. First, the western edge of each DU includes the Bao Hang River that
flows through the Northeast Area. Sediment area can become localized and concentrated traps
of fine particles containing high dioxin concentrations that have eroded from adjacent areas.
New DU(s) should be created that assess the Bao Hang River in Northeast. Second, there was
a large fire with burning aircraft in this area in 1965, and this area is at the end of the runway
and may have been the location of aircraft crashes. The new DU(s) should also consider flight
paths. In addition, there is historical grab sampling in the area that is provided in Appendix A to
the EA data that should be reviewed as well.
The EA postulates that contaminated soil and sediments have migrated from their primary source
sites of storage, handling, and spills at Bien Hoa Airbase through various physical transport
mechanisms, including storm water runoff from rainfall events; surface water flow; wind
erosion and deposition; and excavation and movement of contaminated materials
during the course of Airbase activities and have become secondary sources of dioxin
(GVN/USAID 2016).
As noted, dioxin compounds are hydrophobic and associate with the organic fraction of Airbase
soils and sediment, and these contaminated soils and sediments are then subjected to physical
transport mechanisms, including storm water runoff and surface water flow and sedimentation,
as well as wind-induced erosion and deposition. Sampling results from DUs located downstream
from the Pacer Ivy Area and Z1 Area as well as outside the Airbase have been identified with
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high dioxin concentrations, particularly in sediment collected along drainage canals and the
sediment in the Gate 2 Lake and the Bien Hung Lake.
A Preliminary Contaminant Transport Study for the Bien Hoa Dioxin Hotspots was made by
Dynamic Solutions International, LLC (Craig 2009). The objectives of the study were to
determine the fate and transport of dioxin around the known hotspots within the Bien Hoa
Airbase and provide preliminary mitigation options. Conclusions of the study included: dissolved
phase transport of dioxin is negligible; dioxins sorbed to mobilized soils/sediments is the primary
mechanism of dioxin physical transport; volatility of dioxin is low and not a primary mechanism
of dioxin loss; and that dioxin decomposes in ultraviolet light.
Anthropological (human) disturbances associated with Bien Hoa Airbase land uses (e.g.,
agriculture activities, aquaculture, construction activities, and infrastructure improvements) have
influenced the distribution of dioxin contamination in soils and sediments. Disturbance and the
physical movement of soils and sediments on the Bien Hoa Airbase has resulted in the migration
of dioxin contamination from primary source areas. This is evidenced by some of the
heterogeneity that is observed in dioxin contaminant distribution at the Airbase. The Preliminary
Contaminant Transport Study for the Bien Hoa Dioxin Hotspots further concluded that the
spread of dioxin on the Airbase is also attributed to human disturbances in addition to mobilized
soils/sediments transport (Craig 2009).
The raising and harvesting of fish and other aquatic animals in the lakes and ponds at Bien Hoa
Airbase, and the transport of the harvested contaminated food items to restaurants and end
consumers who may be located on- or off-Airbase is also a well-documented migration pathway
for human exposure to dioxin (Hatfield and Office 33 2009, 2011; GVN/USAID 2016; Nguyen et
al. 2018b).
As discussed in Section 3.2.8, soil surface concentrations at the Airbase Area support that the
primary migration pathway has been erosion of contaminated material from storm water runoff
from rainfall events and surface water flow.
In general, there are three primary routes of exposure for humans, or other living organisms like
terrestrial and aquatic animals, to come into contact with environmental contaminants are in
general: breathing (inhalation); eating or drinking (ingestion); and contact with the skin (dermal
contact). Contaminants can enter the body by inhaling an airborne substance in the form of gas,
fumes mists, vapors, aerosols, dusts, or particulates (inhalation). Once inhaled, contaminants may
be deposited in the lungs and/or enter the circulatory system. The act of swallowing contaminated
media through eating, drinking, or mouthing an object allows contaminants to enter the digestive
system (ingestion) and circulatory system. Direct contact of contaminated media with skin
(dermal contact) allows contaminants to absorb into skin.
With respect to dioxin concentrations in soils and sediments at the Bien Hoa Airbase Area,
exposure routes are well documented (Hatfield and Office 33 2009, 2011; Nguyen et al. 2011;
Canh 2012; Durant et al. 2014; GVN/USAID 2016; Nguyen et al. 2018b). Exposure routes are
identified as: 1) dietary exposure/ingestion; 2) inhalation of fugitive airborne particulate (dust); 3)
dermal absorption; and 4) soil/sediment ingestion.
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1. Dietary exposure/ingestion. Dioxin is integrated into the ecosystem via natural biological
processes (e.g., respiration) and aquaculture. Dioxin exposure occurs primarily to human and
ecological receptors via ingestion of contaminated food sources or contaminated drinking
water. The lipophilic properties of dioxin cause bioaccumulation and exposure to those who
consume contaminated food sources. The EA noted that given the difficulties of enforcing
aquaculture bans, it is likely that dietary exposure/ingestion has resulted in significant dioxin
exposure in the Bien Hoa Airbase Area and is a high priority for mitigation to address future
potential exposure. Whole fish, as well as fish fat, and muscle tissue samples analyzed from
lakes and waterways within and outside of the Bien Hoa Airbase have exceeded acceptable
limits (Hatfield and Office 33 2009, 2011; GVN/USAID 2016). Samples collected from
important food items such as pork, beef, chicken, chicken eggs, fish, rice, and vegetables were
collected in Buu Long, Quang Vinh, Trung Dung and Tan Phong Wards and among the four
wards, the highest 2,3,7,8-TCDD concentrations were identified in free-range chicken from
Buu Long Ward (Nguyen et al. 2018a). Dioxin has also been recorded in blood serum and
breast milk in the human population in the Bien Hoa Airbase Area, with highest
concentrations recorded in individuals who regularly consumed Tilapia and other fish species
from the Airbase (Hatfield and Office 33 2009, 2011; Nguyen et al. 2011; Nguyen et al. 2018b).
These studies confirmed the exposure route for dioxin was through consumption of fish and
other aquatic organisms on the Airbase (Durant et al. 2014). As noted, no dioxin
concentrations have been identified in drinking water samples collected above the USEPA
MCL or GVN discharge standard; however, filtered and unfiltered groundwater samples from
monitoring wells screened at shallow depths (much too shallow for aquifer use as potable
water source) have shown elevated concentrations.
2. Inhalation of fugitive airborne particulate (dust). Dioxin is not volatile; however,
dioxin concentrations present in airborne particulates such as soil, dust, and ash provide an
inhalation exposure route to humans. Dioxin-contaminated soils may become airborne due
to wind erosion and/or vehicular and construction-related disturbances. This is particularly
true in many contaminated areas at the Airbase that are minimally vegetated. In addition, bush
burning has traditionally been carried out to clear ground at the Airbase; this provides a non-
Agent Orange exposure risk of dioxin congeners (e.g., OCDD) entering the environment
(Canh 2012). Inhalation of airborne substances containing dioxins, particularly fugitive
airborne particulates, represents an exposure pathway for dioxin via inhalation to on-Airbase
personnel and residents and off-Airbase persons exposed to such particulates.
3. Dermal absorption. Dioxin concentrations in sediments and soils can result in exposure
to human and ecological receptors via direct contact of contaminated media with skin (dermal
contact). This is an exposure pathway for Airbase personnel or other workers conducting
intrusive work activities with soils or sediments on the Airbase and/or adults and/or children
who come in close and regular contact with contaminated soils or sediments in off-Airbase
areas.
4. Soil / sediment ingestion. Soil ingestion can result in exposure to human and ecological
receptors. Airbase personnel or other workers conducting intrusive work activities with soils
or sediments on the Airbase or adults and/or children who come in close and regular contact
with contaminated soils and sediments (including contact with wind-blown particulate) may
ingest small amounts of soil.
It should be noted that surface water runoff/sedimentation was recognized as a major migration
pathway and dietary exposure/ingestion was recognized as a significant exposure route for dioxin
contamination in soils and sediments at Bien Hoa Airbase to humans (Craig 2009; Hatfield and
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Office 33 2009, 2011; Nguyen et al. 2011). A ban on aquaculture was made in 2010 and a drainage
control project was executed in 2013, i.e., the United Nations Development Programme (UNDP)
Global Environment Facility (GEF) Dioxin Project, which included the construction of a series of
drainage ditches and diversion/retention structures around the perimeter of the Pacer Ivy Area.
Both of these efforts were focused on eliminating the migration pathways and associated dioxin
exposure routes. Drainage controls are present at Pacer Ivy Area; however, it has been reported
in the past years that the enforcement of the aquaculture ban has been challenging and some
fishing still occurs (GVN/USAID 2016).
As indicated under Site Definition and Setting, the Bien Hoa Airbase is surrounded by an urban
population. The current or recent land uses on the Airbase include agriculture (cattle grazing,
rubber plantations), aquaculture (tilapia and other fish species, ducks) in addition to ADAFC
military training and operations.
Hatfield and Office 33 (2011) conducted investigations of soils and sediments, fish tissues, human
blood serum, and breast milk from Bien Hoa Airbase personnel and Bien Hoa City residents
deemed at high risk from dioxin exposure (e.g., personnel and residents who consumed
fish/aquatic organisms from Bien Hoa Airbase lakes and ponds). Dioxin levels in blood serum in
all but one person sampled as part of that investigation exceeded the World Health Organization
(WHO) 1998 standard of 30 ppt TEQ. Dioxins were also recorded in breast milk samples
analyzed from Bien Hoa City residents and the average daily intake of breast milk per infant was
calculated to range from 5 to 172 pg TEQ / kilograms body weight per day (kg bw/d) exceeding
the WHO standard of 4 pg TEQ/kg bw/d. The highest levels of dioxin were recorded in
breastfeeding mothers who had consumed fish raised on the Airbase. These results indicated a
risk for dioxin contamination in local Bien Hoa City residents and confirmed that the main
exposure pathway for human receptors appears to be through consumption of fish and other
aquatic organisms on the Airbase (Hatfield and Office 33 2011, Nguyen et al. 2011, Durant et al.
2014).
Sensitive human and ecological receptors at the Bien Hoa Airbase Area are identified in the SCM
as: Off-Airbase Adults (particularly women of child-bearing age)/Children; On-Airbase Personnel
and On-Airbase Residents; and Terrestrial and Aquatic Animals.
Residential and urban areas are in close proximity to several contaminated areas, especially south
of the Z1 Area, west of the Pacer Ivy Area and southeast of the Northeast Area. Areas not
occupied by residential communities or urban infrastructure are used for raising livestock (e.g.,
cattle, chickens), aquaculture (fish, ducks), or cultivation of food and/or products for sale (e.g.,
vegetables, rubber trees). Fish and ducks raised in dioxin-contaminated ponds and lakes on the
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Airbase are reported to have been sold in markets in Bien Hoa City. Local adults, children, and
elderly are currently or historically have been potentially exposed to dioxin through direct dermal
contact with contaminated soils through agriculture, construction, and forestry; consumption of
contaminated food sources such as fish and ducks raised in areas with elevated dioxin
concentrations; ingesting contaminated soil particles that adhere to vegetables and other
cultivated food items; and through respiration of potentially contaminated fugitive airborne
particulates. However, studies at another dioxin hotspot (Danang, Vietnam) have shown that the
length of residency was the most important risk factor associated with increased dioxin body
burdens of mothers (Nguyen TNA et al. 2013).
Airbase personnel (workers and military members that commute) and residents (military
members and -spouses/families) may potentially be exposed to dioxin in a similar manner to local
adults, children, and elderly, i.e., through consumption of contaminated food sources (especially
fish), dermal contact, ingestion and inhalation. The Southwest Area of the Airbase previously
housed a residential area for military staff and their families (Hatfield and VRTC 2009). When
dioxin contamination was confirmed in the area, residents were moved elsewhere and new
residential areas were constructed west of the Southwest Area. TCDD concentrations in human
blood serum collected from Airbase personnel and aquaculture farmers exhibited elevated 2
TCDD and TEQ levels; elevated levels were also recorded in human breast milk, especially in
individuals who had consumed fish raised on the Airbase (Hatfield and Office 33 2011).
It should be noted that Remedial Workers who will be active in site remediation activities
represent a group of human receptors with a potentially high exposure risk if involved long-term
in the disturbance, excavation, transport, and treatment of dioxin-contaminated soils and
sediments during Project activities. The exposure routes for these workers are similar to other
human receptors, i.e., dietary exposure/ingestion, inhalation of fugitive airborne particulate,
dermal absorption, soil/sediment ingestion. However unlike other human receptors in the area,
USAID will enforce use of engineering controls and personal protective equipment (PPE) during
remedial activities to mitigate exposure to these individuals.
As discussed in Section 3.2.1, dioxins tend to biomagnify in the food chain. Dredging, flooding,
agricultural practices, and construction activities may disturb the contaminated soils and
sediments, which in turn may increase the bioavailability and bioaccumulation of dioxins in
terrestrial and aquatic animals. Some organisms are more susceptible to bioaccumulating dioxin
based on their behavior, such as free-range chickens raised in off Airbase contaminated areas and
invertebrates, snails, ducks, or other bottom feeders in ponds and streams with elevated dioxin
2
The typical range of TCDD in the general population of industrialized countries has been reported as 3
to 7 pg/g (lipid-based)(ATSDR 1998). ATSDR also indicated that TCDD in human blood rarely exceeds
10 pg/g and that typically, lower levels of this contaminant are recorded in less industrialized countries.
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FINAL TM SITE CONCEPTUAL MODEL AND DATA GAPS ANALYSIS
concentrations. Consumption of these organisms leads to biomagnification and represents a
significant human exposure pathway for dioxin.
Figure 8 presents a flow diagram for the SCM identifying secondary sources of dioxin
contamination, transport mechanisms, exposure routes, and potential sensitive receptors. The
diagram shows exposure pathways which are the means by which dioxin contamination in soils
and sediments migrates through the environment via the document transport mechanisms and
exposure routes to sensitive receptors. Receptors identified in the flow diagram are as discussed
in Section 3.4 (i.e., off-Airbase adults/children, on-Airbase personnel, on-Airbase residents,
terrestrial and aquatic Animals). Exposure pathways can be complete or incomplete. A complete
exposure pathway must have a source of contamination, the mechanism for transport of the
contaminant from the source to a point where human or ecological receptors come in contact
with the contaminant, and a route of entry into the body of the receptor. If any part of the
exposure pathway is absent, the pathway is said to be an incomplete exposure pathway and
limited or no exposure or risk is present. In some cases, although an exposure pathway is
complete, the likelihood that significant exposure will occur is small. The flow diagram takes the
components of the SCM and highlights those exposure pathways that are most likely to produce
significant exposure.
Fish biota samples exceeding their respective dioxin limits were also seen at almost all locations
where samples were collected. A variety of natural and, to some extent, anthropological transport
mechanisms contribute to the contaminant migration pathways at the Airbase, resulting in dioxin
exposure to key environmental receptors including local residents, Airbase personnel and
residents, and terrestrial and aquatic animals through dermal absorption, dietary
exposure/ingestion, soil/sediment ingestion, and inhalation of contaminated materials.
Figure 9 presents an SCM illustrating sources of contamination, migration pathways and exposure
routes, and receptors. As discussed in Section 3.2.8, there are three new issues that have come
to light since the EA. The first is the existing of an additional, minor storm water migration
pathway from the south of Pacer Ivy to off Airbase. This increases the exposure risk to nearby
residents. Second is the completion of the XD-2 project which greatly decreases the risk to on-
Airbase personnel by excavating and safely isolating highly dioxin-contaminated soils. The third is
the need to design recontamination prevention and control measures in the Northeast area after
further site characterization. Table 1 provides a table summarizing SCM elements to include the
significant migration pathways and exposure routes identified in Subsection 3.3 and the sensitive
receptors identified in Subsection 3.4. It should be noted that concurrent with the development
of this TM for Data Gaps Analysis and Site Conceptual Model is the development of the Baseline
Risk Assessment (BRA) for the Bien Hoa Airbase Area.
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FINAL TM SITE CONCEPTUAL MODEL AND DATA GAPS ANALYSIS
RELEASE AND RECEPTORS
EXPOSURE
TRANSPORT PATHWAYS
MECHANISMS
Surface Water Contact with
Runoff / Contaminated
Erosion Surface Water
Flow / Consumption of
Groundwater Movement of Contaminated
Groundwater Drinking Water
KEY
– Significant exposure pathway
– Insignificant exposure pathway
– Incomplete exposure pathway
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FINAL TM SITE CONCEPTUAL MODEL AND DATA GAPS ANALYSIS
FIGURE 9 ILLUSTRATIVE SITE CONCEPTUAL MODEL
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FINAL TM SITE CONCEPTUAL MODEL AND DATA GAPS ANALYSIS
TABLE 1 SUMMARY OF BIEN HOA AIRBASE SCM ELEMENTS
Some contaminated areas (e.g., Excavation and Movement Soil / Sediment Terrestrial Animals
SW-1 and SW-2) disturbed of Materials Ingestion
since the EA
Aquatic Animals
Notes: Bold indicates the pathway of greatest potential concern under existing conditions.
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4 IDENTIFICATION OF DATA GAPS, DETERMINATION OF
CRITICALITY, AND RECOMMENDATIONS FOR
RESOLUTION
The analysis used the working knowledge of the A&E Bien Hoa Contractor SMEs, as well as input
from USAID, GVN, and other Stakeholders. The available data and information was integrated
into the development of the SCM as a tool to assist in the further identification of absent or
missing data for the SCM and thus Project decisions. The analysis considered documented actual
or perceived data gaps with respect to dioxin contamination in the Bien Hoa Airbase Area and
the performance of remedial actions as addressed in previous studies and published reports. The
analysis identified data that is definitively needed (i.e., critical data) and supported the
development of recommendations for resolving the data gaps associated with critical data.
The determination of criticality was made through an analysis using the working knowledge of
the A&E Bien Hoa Contractor project team SMEs coupled with knowledge of the site and
surrounding environment, the need for a complete and comprehensive SCM, the development of
interim measures and the assessment of remedial alternatives, the requisite content for the
Masterplan, and the initiation of Project activities. Considerations in making the determination of
criticality for a particular data gap are varied; however, they centered on responding to the
questions of “Is data gap resolution necessary for:”
• Completing the SCM (i.e., to define site definition or setting, source contamination, migration
pathways, exposure routes, or sensitive receptors)?
• Mitigating a significant health and safety risk or critical to the development of the BRA?
• Establishment of environmental baseline conditions in advance of intrusive remedial activities
(e.g., storm water runoff quality in advance of remedial activities and implementation of storm
water control BMPs)?
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• Evaluation of dioxin remedial alternatives?
• Placement and design of treatment facilities (e.g., Pacer Ivy Treatment Design) or containment
systems (e.g., LTSA, vegetative disposal area)?
• Soil or sediment excavation planning purposes (e.g., development of accurate topographic
data and establishing pre-remedial action ground elevations)?
• Development of the Masterplan?
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TABLE 2. DATA GAPS, CRITICALITY, AND RECOMMENDED ACTIVITIES FOR RESOLUTION
SCM
IDENTIFIED DATA GAP CRITICALITY / RATIONALE RECOMMENDED SI AND EVALUATION ACTIVITIES
RELEVANCE
1. Site Physical properties of Critical. Limited data are available from prior sampling events with respect Develop a SI Workplan and conduct limited soil and
Definition & soil and sediments in to the physical properties of the soils and sediments that are to be excavated sediment sampling to determine physical properties of
Setting areas targeted for and managed for treatment or containment. Data is critical for: soils and sediments to be excavated and managed for
excavation (moisture treatment or containment. The priority areas are Pacer
content, density/bulk √ Excavation Planning Ivy and Z1 since the majority of the contaminated material
density, particle size √ Evaluation of Remedial Alternatives is in these locations. Additional sampling may occur for
distribution, permeability, areas that could potential be a source of recontamination.
plasticity, resistivity, pore √ Design of Treatment System(s) Develop SAP and QAPP to ensure soil and sediment
water concentration). samples collected produce statistically defendable data for
√ Storm Water Management Planning all targeted parameters.
1. Site Basic chemical Critical. Limited data is available from prior sampling events with respect to Develop a SI Workplan concurrent with the SI Workplan
Definition & properties of soil and the (non-contaminant) chemical properties of the soils and sediments that are recommended above and conduct limited soil and
Setting sediments in areas to be excavated and managed for treatment or containment. Data is critical sediment sampling to ensure statistically defendable data
targeted for excavation for: for all targeted parameters.
(pH, EC, K, total organic
carbon, free available √ Understanding of Dioxin Partitioning & Transport
carbon, cations/anions). √ Evaluation of Remedial Alternatives
√ Design of Treatment System(s)
1. Site Groundwater / aquifer Critical. Limited data is available across the Bien Hoa Airbase area regarding Develop SI Workplan and conduct Airbase-wide
Definition & characteristics across the depths to groundwater, chemical properties of groundwater, and underlying groundwater monitoring to evaluate aquifer
Setting site (depth to groundwater, aquifer characteristics (e.g., flow direction). Such data is necessary in characteristics. SI Workplan to define locations and
range of groundwater table completing the site definition and setting for the SCM, evaluating groundwater parameters for groundwater monitoring. The monitoring
fluctuation, porosity and as a dioxin migration pathway, and evaluating the extent groundwater table program should use a combination of permanent
effective porosity, gradient, will be encountered during near-term Project Phase 1 excavation activities. monitoring wells and temporary piezometers for aquifer
hydraulic conductivity, Data is critical for: testing and monitoring including slug and pump testing.
groundwater velocity and Develop SAP and QAPP to ensure groundwater samples
flux, pH, EC, ORP, DO, √ Understanding Groundwater Flow collected produce statistically defendable data for all
temperature, turbidity, √ Establishing Baseline Groundwater Quality targeted parameters.
cations/anions).
√ Excavation Planning
√ Dewatering of Excavated Soils
√ Evaluation of Remedial Alternatives
√ Design of Treatment System(s)
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SCM
IDENTIFIED DATA GAP CRITICALITY / RATIONALE RECOMMENDED SI AND EVALUATION ACTIVITIES
RELEVANCE
1. Site Topographic data across Critical. Topographic data available is not comprehensive or reflective of Conduct topographic surveys to an accuracy of 25 cm
Definition & the site. current elevations. Accurate topographic data across the Bien Hoa Airbase across Airbase areas that are to be disturbed (excavated,
Setting area is necessary for understanding surface water drainage as a migration graded, etc.) during the Project and adjacent areas
pathway in the SCM, storm water management, designing excavation work, as upstream and downstream when necessary to conduct
well as establishing existing ground surface elevations in the DUs where storm water analysis.
excavation will occur for the eventual restoration of excavated areas. Data is
critical for:
√ Understanding Migration Pathway
√ Understanding Surface Water Drainage
√ Storm Water Management Planning
√ Establishing Baseline Ground Elevations
2. Sources & Dioxin contamination: Critical. The current estimates of the nature and extent of dioxin Meet with DONRE for more detailed review of off-
Distribution Nature and extent (i.e., contamination in soils and sediments and soil volume estimates are based on Airbases sampling data, to include sample collection
lateral and vertical extent) the EA’s one-round of MIS methodology (composite) sampling and limited methodology. Obtain and review MND excavation
in soils and sediments data from Dong Nai DONRE. In many cases, the lateral and vertical extent of surveys and post excavation confirmatory sampling for the
throughout the Airbase contamination in the DUs was not established via sampling. In other instances, XD-2 project and landfill. Develop a SI Workplan to
area. there is evidence that some DUs may have been poorly defined and have conduct limited soil and sediment sampling to validate
considerable variability in dioxin concentration within the DUs. Better existing data and define lateral and vertical extent of
definition of the nature and extent via additional site characterization across excavation designs. In addition, refine size and location of
the DUs and Sub-DUs is needed to complete excavation designs and existing DUs to address potential sediment areas (from
improved estimates of contaminated soil and sediment volumes that will 1968 map) and to determine the need for
ultimately necessitate treatment or containment. Since the XD-2 Landfill is a recontamination prevention and control measures.
mixture of material coming from different areas and depths, MND Develop SAP and QAPP to ensure soil and sediment
documentation of remedial activities should be reviewed to understand any samples collected produce statistically defendable data for
remaining contamination adjacent to excavated area, as well as the all targeted parameters.
concentration of material in the five XD-2 landfill cells. Data is needed for:
√ Improved Soil Volume Estimates
√ Excavation Planning/Design
√ Evaluation of Remedial Alternatives
√ Design of Treatment System(s)
√ Design of Containment Structure
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SCM
IDENTIFIED DATA GAP CRITICALITY / RATIONALE RECOMMENDED SI AND EVALUATION ACTIVITIES
RELEVANCE
2. Sources & Arsenic contamination: Critical. Very limited sampling for arsenic was conducted in soils and Develop a SI Workplan concurrent with the SI Workplan
Distribution Nature and extent (i.e., sediments in Pacer Ivy Area and Z1 Area DUs with the speciation of the recommended above for determining physical and
lateral and vertical extent) arsenic. Arsenic has previously been identified in areas of dioxin chemical properties of soils and conduct limited soil and
in soils and sediments in contamination at Bien Hoa Airbase. Arsenic concentrations in soils and sediment sampling to determine representative arsenic
areas to be excavated as sediments are critical to conducting the Baseline Risk Assessment (BRA) and concentrations in soils and sediments to be excavated.
part of remedial measures. could potentially impact design of remedial alternatives for treatment and the
consideration/handling of soils and sediments for reuse or placement. Data is
critical for:
√ Definition of Sources of Contamination
√ Conduct of Baseline Risk Assessment
√ Design of Treatment System(s)
√ Management/Reuse of Excavated Materials
2. Sources & Non-dioxin Not critical. Although limited sampling for VOCs, SVOCs, target metals, None.
Distribution contamination: Nature pesticides/herbicides was conducted in soils and sediments in Pacer Ivy Area
and extent (i.e., lateral and and Z1 Area DUs; no compounds were identified as contaminants of concern Some additional data collection will take place separately
vertical extent) of non- (COCs) with the exception of arsenic noted above. Data is needed for: as part of a treatability study that will assist in the
dioxin contamination (e.g., procurement of a thermal conductive heating (TCH)
VOCs, SVOCs, target √ Understanding of Other COCs treatment contractor.
metals, pesticides, √ Evaluation of Remedial Alternatives
herbicides) in soils and
sediments in the Airbase √ Design of Treatment System(s)
Area.
√ Management/Reuse of Excavated Materials
2. Sources & Total Dissolved Solids Critical. Very little sampling and analysis data is available regarding surface Following development of Topographic Survey data,
Distribution (TDS), Total Suspended water and storm water quality in the Bien Hoa Airbase area. Such data is develop SI Workplan and conduct limited surface water
Solids (TSS), turbidity, and critical, in particular TDS, TSS, and associated baseline dioxin concentrations and storm water sampling (during rainfall events) to
baseline dioxin in evaluating the drainage patterns as migration pathways and exposure routes evaluate TDS and TSS concentrations in surface water and
concentrations in surface and providing a baseline for site-wide monitoring and measurement to be storm water drainage, and associated dioxin
water and storm water implemented during remedial activities with respect to preventing the concentrations at the points of discharge from the Airbase
runoff migration of dioxin via surface water and storm water drainage. Data is to the surrounding community. Develop SAP and QAPP
critical for: to ensure surface and storm water samples collected
produce statistically defendable data for all targeted
√ Understanding Dioxin Migration Pathway parameters.
√ Establishing Baseline Storm Water Quality
√ Storm Water Management Planning
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SCM
IDENTIFIED DATA GAP CRITICALITY / RATIONALE RECOMMENDED SI AND EVALUATION ACTIVITIES
RELEVANCE
3. Migration & Surface water and Critical. Surface water and storm water runoff drainage patterns are not well Develop foundational maps and data related to surface
Exposure storm water runoff defined on the Bien Hoa Airbase area. Hydraulic connectivity of the ponds water and storm water drainage patterns and discharge
drainage patterns and and lakes at the Bien Hoa Airbase area to the drainage canals and streams points from infrastructure inventory, water quality, and
discharge points in the Bien leading to the tidally-influence Dong Nai River and other areas is not defined. flow data. These foundational maps and data will be
Hoa Airbase Area. Development of a topographic map and foundational drainage map illustrating incorporated into Site-wide Environmental Monitoring and
hydraulic connectivity is critical for evaluating runoff drainage patterns as Mitigation Plan (SWEMMP) and the Storm Water
migration pathways and exposure routes for dioxin and providing a baseline Pollution Prevention Plan (SWPPP).
for site-wide monitoring and measurement, storm water control and
management, and suitability of locations for LTSA and other remedial facilities.
Data is critical for:
√ Understanding Migration Pathway
√ SWEMMP
√ Storm Water Management Planning
√ Establishing Baseline Ground Elevations
4. Receptors Flora and fauna survey of Not critical but recommended. No ecological surveys been located for Obtain information from MND on historical ecological
Airbase area (diversity and the Bien Hoa Airbase that document local biodiversity and impacts from survey in the Bien Hoa Airbase area and consider
dioxin contamination). dioxin contamination. Areas on the Airbase appear to have negligible measuring dioxin concentrations in flora and fauna in the
terrestrial biodiversity value. Aquatic biodiversity varies in areas by season, Airbase area not assessed during the EA;
with some areas being ephemeral with no water present in the dry season
and other areas contain water year-round. Biological surveys (terrestrial and
aquatic) could be conducted prior to the commencement of remedial
activities to ensure there are no threatened or endangered species. Data is
needed for:
√ Understanding Sensitive Receptors
√ Documenting Baseline Biodiversity
√ SWEMMP
√ Understanding Ecological Impacts of Dioxin
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SCM
IDENTIFIED DATA GAP CRITICALITY / RATIONALE RECOMMENDED SI AND EVALUATION ACTIVITIES
RELEVANCE
5. Other Sub-surface utility Critical. Sub-surface utility locations in excavation areas are necessary to Develop Workplan to evaluate the presence of sub-
locations. quantify infrastructure prior to land handover. Such locations are also surface utilities in excavation. Sub-surface utilities may
necessary from an excavation and remedial action sequencing and scheduling include use of ground penetrating radar (GPR) or other
standpoint. Data is critical for: investigative means.
√ Excavation Planning
√ Health and Safety of Site Workers
√ Design of LTSA Containment Structure
5. Other Sub-surface structures. Critical. Sub-surface structures are likely under former homes off-Airbase Develop Workplan to evaluate the presence of sub-
and in some on-base areas. Need to determine the types and volumes of such surface structures in excavation areas. Sub-surface
(e.g., pipes, septic tanks, foundations, etc.) in order to plan proper disposal. structures identification may include use of ground
Such identification is also necessary from an excavation and remedial action penetrating radar (GPR) or other investigative means.
sequencing and scheduling standpoint. Data is critical for:
√ Excavation Planning
√ Health and Safety of Site Workers
√ Design of LTSA Containment Structure
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5 CONCLUSIONS
This TM documents the A&E Bien Hoa Contractor’s evaluation and sufficiency of existing data
and establishes an initial SCM for the Bien Hoa Airbase Area prior to the development of the
Masterplan and the initiation of Project activities.
• Secondary sources of contamination remain at the Bien Hoa Airbase Area in the form of
dioxin-contaminated soils and sediments, with a significant fraction of these dioxin-
contaminated soils and sediments being located in the Pacer Ivy and Z1 areas (site of the
most significant historical primary sources of contamination by Agent Orange and other
herbicides that were handled and used on the Airbase during the war).
• Dioxin-contaminated soils and sediment have migrated from their original source sites
through physical transport mechanisms, especially storm water runoff. This migration
pathway has been mitigated by GVN interim measures over the past decade, but some storm
water-borne migration is likely ongoing.
• Off-Airbase dioxin contamination is mostly within soils and sediments located in land areas
adjacent to the Pacer Ivy Area which appear largely contaminated by water-borne erosion of
contaminated soil from that on-base area.
• Groundwater flow is not a significant dioxin migration pathway as dioxin is not very soluble
and is prone to partitioning to suspended organic solids. Measured dioxin concentrations in
groundwater are in picograms per liter.
• Some contaminated soils have been intentionally excavated or unintentionally disturbed both
before and since the performance of an Environmental Assessment (EA) in 2014 and 2015
(GVN/USAID 2016) (e.g., Southwestern Area Decision Units SW-01 and SW-02 and off-base
areas outside of Pacer Ivy).
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The BRA addresses the relative importance of these exposure routes and the receptors affected
under existing conditions. The analysis used the working knowledge A&E Bien Hoa Contractor,
as well as input from USAID, GVN, and other Stakeholders, to identify gaps in the available data
and information and use the integration of the available data and information into the SCM as a
tool to assist in the identification of data gaps.
A determination was made as to which data gaps are ‘critical data gaps’ and are recommended
for resolution during the timeframe for development of the SCM, BRA and resulting Masterplan.
Other data gaps may be resolved following Masterplan development.
• Groundwater/aquifer characteristics;
• Nature and extent of dioxin contamination in soils and sediments in decision units currently
incompletely characterized and those areas that the SCM suggests may have been missed by
the EA, including XD2 landfill;
• Baseline dioxin and other key water quality parameters and characteristics of surface water,
storm water runoff, and groundwater in the Airbase area;
• Surface water and storm water quality, runoff drainage patterns, and discharge points; and
In addition, measuring dioxin concentrations in flora and fauna in the Airbase area not assessed
during the EA should be considered since this would allow a more thorough risk assessment.
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Health Concern.
Urban O, Rebelo F, Musil V, Svoboda D, and Office 33. 2012. Support to Overcoming of
Consequences of Herbicides/Dioxins in Vietnam: Conceptual Model for Bien Hoa Airbase.
USAID. 2013. Country Development Cooperation Strategy for Vietnam, 2014-2019. July 25,
2013.
USAID. 2017. Generalized Hydrogeological Framework of the Bien Hoa Airbase Area including
Abandoned Hard Rock Quarry Area.
USAID. 2019. USAID Dioxin Remediation at Bien Hoa Airbase Area Project, Project Appraisal
Document. February 12, 2019.
USAID/DONRE. 2019. Meeting Minutes, USAD/DONRE Meeting on July 23, 2019, Subject:
Discussing and reaching agreement in terms of providing information about the dioxin-
contaminated areas and the remediation plan for off-base contaminated area. September 9, 2019.
WHO. 1998. Assessment of the health risk of dioxins: re-evaluation of the Tolerable Daily Intake
(TDI).
WHO. 2010. Exposure to Dioxins and Dioxin-like Substances; A Major Public Health Concern.
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FINAL TM SITE CONCEPTUAL MODEL AND DATA GAPS ANALYSIS
ANNEX 7 – BASELINE RISK ASSESSMENT
PREPARED BY
TRIGON ASSOCIATES, LLC
1515 POYDRAS ST. SUITE 2200
NEW ORLEANS, LA 70112
USA
DISCLAIMER THE VIEWS EXPRESSED IN THIS PUBLICATION DO NOT NECESSARILY REFLECT THE VIEWS OF THE UNITED
STATES AGENCY FOR INTERNATIONAL DEVELOPMENT OR THE UNITED STATES GOVERNMENT.
CONTENTS
CONTENTS I
RECORD OF REVISIONS III
LIST OF FIGURES IV
LIST OF TABLES IV
LIST OF ACRONYMS AND ABBREVIATIONS V
EXECUTIVE SUMMARY 1-VII
1 INTRODUCTION 1
2 SITE BACKGROUND 2
2.1 GENERAL DESCRIPTION AIRBASE AND SURROUNDING AREA 2
2.2 SUMMARY OF HISTORICAL CONTAMINATION AT SITE 2
2.2.1 USE OF AGENTS ORANGE, WHITE, AND BLUE 2
2.2.2 BRIEF SUMMARY OF PAST STUDIES 4
2.3 ENVIRONMENTAL STANDARDS FOR PCDD/FS 4
2.4 HISTORICAL AREAS OF CONTAMINATION 7
2.5 CURRENT AREAS OF CONTAMINATION 7
3 HAZARD IDENTIFICATION 10
3.1 AVAILABLE DATA SETS 10
3.1.1 HATFIELD AND 10-80 DIVISION (2006) 10
3.1.2 HATFIELD AND VRTC (2009) 10
3.1.3 HATFIELD AND OFFICE 33 (2011) 10
3.1.4 VEA AND MONRE (2012) 11
3.1.5 VRTC (2013A,B) 11
3.1.6 DEKONTA (2014) 11
3.1.7 TUYET-HAHN ET AL. (2015) 11
3.1.8 GVN/USAID (2016) 12
3.2 SELECTION OF CHEMICALS OF POTENTIAL CONCERN 13
3.2.1 IDENTIFICATION OF CHEMICALS OF POTENTIAL CONCERN IN SOIL
AND SEDIMENT 13
3.2.2 IDENTIFICATION OF CHEMICALS OF POTENTIAL CONCERN IN
GROUNDWATER 13
3.3 DATA SUMMARY 14
4 TOXICITY ASSESSMENT 18
4.1 HIERARCHY FOR SELECTING TOXICOLOGICAL CRITERIA 18
4.2 PCDD/FS 18
4.2.1 NONCARCINOGENIC EFFECTS 18
4.2.2 CARCINOGENIC EFFECTS 19
4.3 ARSENIC 20
4.3.1 NONCARCINOGENIC EFFECTS 20
4.3.2 CARCINOGENIC EFFECTS 20
4.4 PCB 1260 21
4.4.1 NONCARCINOGENIC EFFECTS 21
4.4.2 CARCINOGENIC EFFECTS 21
4.5 LEAD 22
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4.6 SUMMARY OF TOXICOLOGICAL CRITERIA 22
5 EXPOSURE ASSESSMENT 24
5.1 EXPOSURE SCENARIOS 24
5.2 POTENTIALLY EXPOSED POPULATIONS 24
5.3 EXPOSURE PATHWAYS 25
5.3.1 DIRECT CONTACT EXPOSURE TO SOIL/SEDIMENT 25
5.3.2 EXPOSURE TO GROUNDWATER 25
5.3.3 INDIRECT/DIETARY EXPOSURE 25
5.3.4 INFANT INGESTION OF BREAST MILK 25
5.4 EXPOSURE CALCULATIONS 26
5.4.1 EXPOSURE POINT CONCENTRATIONS 26
5.4.2 DOSE EQUATIONS 27
5.4.3 EXPOSURE PARAMETERS 31
6 RISK CHARACTERIZATION 35
6.1 CALCULATION OF RISK AND HAZARD 35
6.1.1 NONCANCER HAZARD INDEX 35
6.1.2 CANCER HAZARD INDEX 36
6.1.1 INCREMENTAL LIFETIME CANCER RISK 36
6.2 RISK AND HAZARDS UNDER BASELINE CONDITIONS 37
6.2.1 SOIL 37
6.2.2 SEDIMENT 40
6.2.3 GROUNDWATER 42
6.2.4 DIET 43
6.2.5 BASELINE CONDITIONS OVERALL 44
6.3 UNCERTAINTY ANALYSIS 49
6.3.1 HAZARD IDENTIFICATION 49
6.3.2 TOXICITY ASSESSMENT 49
6.3.3 EXPOSURE ASSESSMENT 49
6.3.4 RISK CHARACTERIZATION 50
7 CONCLUSIONS 51
8 REFERENCES 52
APPENDIX A 57
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RECORD OF REVISIONS
SUMMARY OF
REVISION DATE PAGES APPROVAL
REVISIONS
Development of USAID
001 10 August 2020 All
Final TM COR
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LIST OF FIGURES
Figure 2-1 Bien Hoa Airbase Area................................................................................................................. 3
Figure 2-2 Land Use at Bien Hoa AIrbase Area ......................................................................................... 6
Figure 2-3 Surface Dioxin Concentrations at the Bien Hoa Airbase Area .......................................... 9
LIST OF TABLES
Table 2-1 Maximum Allowable Dioxin by Land Use and Decision Unit .............................................. 5
Table 3-1 Data Summary for Dioxins/Furans ........................................................................................... 15
Table 3-2 Data Summary for Other COPCs ............................................................................................ 16
Table 4-1 Cancer Toxicological Criteria ................................................................................................... 22
Table 4-2 Noncancer Toxicological Criteria ............................................................................................ 23
Table 5-1 Identification of Potentially Exposed Populations and Pathways ....................................... 25
Table 6-1 Noncancer Hazard Index Summary for Local Residents and Resident Airbase
Personnel and their Families ...................................................................................................... 45
Table 6-2 Cancer Hazard Index Summary for Local Residents and Resident Airbase Personnel
and their Families .......................................................................................................................... 45
Table 6-3 Increased Lifetime Cancer Risk Summary for Local Residents and Resident Airbase
Personnel and their Families ...................................................................................................... 46
Table 6-4 Noncancer Hazard Index Summary for Nonresident Airbase Personnnel .................... 47
Table 6-5 Cancer Hazard Index Summary for Nonresident Airbase Personnel .............................. 48
Table 6-6 Increased Lifetime Cancer Risk Summary for Nonresident Airbase Personnel ............ 48
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LIST OF ACRONYMS AND ABBREVIATIONS
ADAFC Air Defense - Air Force Command
ADD Average daily dose
A&E Architect & Engineer
As Arsenic
ASTM American Society for Testing and Materials
ATSDR Agency for Toxic Substances and Disease Registry
BRA Baseline Risk Assessment
BW Body weight
cm Centimeter
CLIN Contract Line Item Number
COC Contaminant of Concern
COPC Chemical of Potential Concern
CSF Cancer Slope Factor
d Day
DU Decision Unit
EA Environmental Assessment
EC Exposure concentration
EFH Exposure Factors Handbook
EIA Environmental Impact Assessment
EPC Exposure Point Concentration
EU European Union
EVSA Excess Volume Stockpile Area
g gram
G2L Gate 2 Lake
GIS Geographic Information System
GVN Government of Vietnam
ha hectare
HI Hazard index
HQ Hazard quotient
ILCR Increased lifetime cancer risk
IUR Inhalation Unit Risk
JECFA Joint FAO/WHO Expert Committee on Food Additives
kg kilogram
km kilometer
LADD Lifetime average daily dose
LTSA Long Term Storage Area
m meter
MCL Maximum Contaminant Level
MND Ministry of National Defence
MONRE Ministry of Natural Resources and the Environment
OEHHA Office of Environmental Health Hazard Assessment
OSWER Office of Solid Waste and Emergency Response
Pb Lead
PCB Polychlorinated biphenyl
PCDD Polychlorinated dibenzodioxins
PCDF Polychlorinated dibenzofurans
PEF Particulate emission factor
pg picogram
PPEPPRTV Personal protective equipment
ppt parts per trillion (ng/kg)
PTMI Provisional tolerable monthly intake
RfC Reference Concentration
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RfD Reference Dose
RSL Regional Screening Level
SA Skin surface area
SAF Soil adherence factor
SCM Site Conceptual Model
SI Site Investigation
SOW Statement of Work
SVOC Semi-volatile Organic Compound
TCDD 2,3,7,8-Tetrachlorodibenzo-p-dioxin
TCDF 2,3,7,8-Tetrachlorodibenzofuran
TDI Tolerable Daily Intake
TEF Toxic Equivalency Factor
TEQ Toxicity Equivalent
TM Technical Memorandum
UCL Upper confidence limit
ug/L micrograms per liter
UNDP United Nations Development Programme
US United States
USAID United States Agency for International Development
USEPA United States Environmental Protection Agency
VEA Vietnam Environment Administration
VOC Volatile Organic Compound
VRTC Vietnam Russia Tropical Center
WHO World Health Organization
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EXECUTIVE SUMMARY
SITE DESCRIPTION AND BACKGROUND
Between 1962 and 1971, military forces used herbicides in Vietnam to defoliate inland hardwood
forests, coastal mangrove forests, cultivated lands, and military base perimeters (IOM 2014).
Herbicides were identified by orange, white, blue, pink, green, and purple bands on the containers
in which they were transported; herbicides contained cacodylic acid, an organic arsenic
compound, and 2,4,5-trichlorophenoxyacetic acid, or 2,4,5-T, which was contaminated with
2,3,7,8-tetrachlorodibenzo-p-dioxin, or TCDD (IOM 2014). The use of these herbicides during
the U.S.-Vietnam War was termed Operation Ranch Hand, and it was reported that Bien Hoa
Airbase was the largest and most active Ranch Hand site in Vietnam (Cecil 1986, GVN/Hatfield
2016).
The Bien Hoa Airbase is located in Bien Hoa City, Dong Nai Province. Bien Hoa city is
characterized by industrial activity, rapid urbanization, and reduced land allocation for agricultural
uses (GVN/USAID 2016). The Bien Hoa Airbase is an active Air Defense – Air Force Command
(ADAFC) airbase and encompasses an area of approximately 1,000 hectares (ha) immediately to
the east and northeast of the Dong Nai River. In addition to ADAFC military training activities
and operations, land areas on-Airbase are being used for agriculture and forestry purposes.
DATA SUMMARY
The baseline dataset for this risk assessment was drawn from multiple sampling programs
consisting of soil, sediment, groundwater, biota tissue, and breast milk data; these data sources,
used to evaluate potential exposures, were summarized and described in detail in Environmental
Assessment of Dioxin Contamination at Bien Hoa Airbase (EA) (GVN/USAID 2016). Data
characterizing dioxin/furan concentrations in commonly consumed foods was collected in seven
wards surrounding the Bien Hoa and Da Nang Airbases; these data were used to assess the health
risk of exposure to dioxin/furans though food consumption (Tuyet-Hanh, Minh et al. 2015).
In accordance with USEPA guidance, individual chemicals were eliminated from further evaluation
in this risk assessment through a screening process that was aimed at focusing the risk assessment
on only those chemicals that may contribute significantly to risks at the site (USEPA 1989). Several
factors were considered when selecting COPCs in soil for a site, including a comparison to
background concentrations, frequency of detection, and comparison to risk-based screening
levels for soil, sediment, and groundwater (USEPA 1989). Chemicals detected in soil and sediment
in each area were carried through the Baseline Risk Assessment (BRA) if they had either a
detection frequency above 5% among more than 20 samples or at least one detection among less
than 20 samples, and a maximum concentration exceeding the USEPA Regional Screening Levels
(RSL) for Resident and Industrial Soil. Chemicals detected in groundwater were carried through
the BRA if the maximum concentrations in groundwater were greater than either USEPA
Maximum Contaminant Levels (MCL) or the USEPA Residential Tap Water RSL, if the MCL was
not available.
Based on this screening process, dioxins/furans, arsenic, and PCB 1260 were identified at COPCs
in soil and sediment. Dioxins/furans and arsenic are COPCs in all site areas while PCB 1260 is
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only a COPC for the Pacer Ivy Area because it was only detected above its USEPA RSL in that
area.
TOXICITY ASSESSMENT
Toxicological criteria were selected according the hierarchy of sources established by USEPA
(2003).
PCDD/FS
No Tier 1 or Tier 2 toxicological criteria were available for oral TCDD exposure; therefore, a
Tier 3, threshold-based tolerable daily intake (TDI) of 2.3 pg/kg-day was used to evaluate potential
carcinogenic effects of TCDD exposure (JECFA 2002). A Tier 3 oral slope factor of 130,000
(mg/kg/day)-1 was also used to evaluate potential carcinogenic effects of TCDD exposure; this
value was derived by the California Office of Environmental Health Hazard Assessment (OEHHA)
based on the nonthreshold dose assumption (OEHHA 2011). No Tier 1, Tier 2, or Tier 3
toxicological criteria was available for TCDD inhalation based upon the threshold dose
assumption. No Tier 1 or Tier 2 toxicological criteria was available for TCDD based upon the
linear dose assumption. The California Office of Environmental Health Hazard Assessment
(OEHHA), a Tier 3 source, has established an inhalation unit risk of 38 (µg/m3)-1 for TCDD
(OEHHA 2015).
USEPA’s Integrated Risk Information System, IRIS, has established a chronic oral reference dose
of 7 x 10-10 mg/kg-day for noncancer effects of TCDD exposure (USEPA 2012). No Tier 1 or
Tier 2 noncancer toxicological criteria are available for TCDD inhalation exposures. According
to OEHHA, a Tier 3 data source, the recommended exposure level for chronic inhalation of
TCDD is 4 x 10-8 mg/m3 (OEHHA 1999, OEHHA 2014).
ARSENIC
The arsenic identified in the data evaluation was not speciated; therefore, toxicity criteria were
conservatively identified and selected for inorganic arsenic for use in this baseline risk assessment.
IRIS provides an oral cancer slop factor of 1.5 (mg/kg/day)-1 and an inhalation unit risk of 4.3 x 10-
3 (µg/m3)-1 for inorganic arsenic exposure (USEPA 1995).
IRIS provides a reference dose of 3 x 10-4 mg/kg/day for inorganic arsenic (USEPA 1995). No Tier
1 or Tier 2 toxicological criteria are available for inorganic arsenic inhalation exposures.
According to OEHHA, a Tier 3 data source, the recommended exposure level for chronic
inhalation of inorganic arsenic is 0.015 µg/m3 (OEHHA 2014).
PCB 1260
IRIS provides an oral cancer slope factor of 2.00 (mg/kg-day)-1 for high risk and high persistence
PCBs (USEPA 1996). This value represents the upper limit of a range of upper-bound cancer
slope estimates for multiple PCBs, including Aroclors 1254 and 1260. IRIS recommends using the
same high risk and high persistence cancer slope factor of 2.00 (mg/kg-day)-1, applied to oral
exposures, for the inhalation of PCB-contaminated aerosols and/or dusts (USEPA 1996). This
converts into an inhalation unit risk of 5.7 x 10-4 µg/m3.
IRIS provides a chronic oral reference dose of 2 x 10-5 mg/kg-day for evaluation of noncancer
effects of PCB 1254 (USEPA 1994). PCB 1254 was deemed appropriate as a surrogate for PCB
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1260 as it is highly chlorinated and is therefore likely to have comparable toxicity. No Tier 1, Tier
2, or Tier 3 inhalation criteria were available for PCBs 1260 or 1254; therefore, PCB 1260 was
evaluated for its carcinogenic potential and oral toxicity only.
LEAD
USEPA has not reached a consensus regarding toxicity criteria for inorganic lead; therefore, the
95% UCL values for lead in applicable media were compared against appropriate screening levels
per USEPA guidance (USEPA 2019). A residential screening level of 400 mg/kg was identified as
appropriate for assessment of lead in soil and the USEPA Action Level of 15 µg/L was identified
for assessment of lead in water (USEPA 2019).
EXPOSURE ASSESSMENT
This exposure assessment was based on the site conceptual site model (SCM), which
characterized the sources, release, and distribution of COPCs to receptors (potentially exposed
populations) through exposure pathways.
EXPOSURE SCENARIO
The main potential exposure scenario explored for the risk assessment is:
• Baseline Conditions – reflecting the baseline conditions on the Airbase, this scenario includes
evaluations of local residents, resident Airbase personnel and families, and nonresident
Airbase personnel under pre-remediation exposure conditions.
Multiple potential receptor groups were assumed for this risk assessment, representing segments
of the population rather than actual people. The Local Resident and Resident Airbase Personnel
and Families receptor groups are comprised of infants, children, and adults potentially exposed
to COPCs through consumption of contaminated food sources, dermal contact with surface soil
and sediment, incidental ingestion of surface soil, sediment, and groundwater, and inhalation of
surface soil and sediment throughout their time living and working on the Airbase. Further, infants
may be exposed to COPCs through ingestion of breastmilk. The Nonresident Airbase Personnel
receptor group represents adults potentially exposed to COPCs through dermal contact with
surface soil and sediment, incidental ingestion of surface soil and sediment, and inhalation of
surface soil and sediment throughout their time working on the Airbase.
EXPOSURE CALCULATIONS
Exposure of receptors to COPCs was quantified using equations recommended by USEPA, which
require both an estimate of the concentration of each COPC in potentially exposed media, and
an estimate of receptors’ contact with those media.
Exposure point concentration (EPCs) for each medium were calculated as the appropriate 95%
UCL per USEPA guidance. If the 95% UCL was greater than the maximum concentration for a
site area or decision unit then the maximum concentration was used. If the sample size for the
data set was less than three, the maximum concentration was used. For values reported below
the limit of detection, one half of the detection limit was used.
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Exposure parameters were selected or calculated using Vietnamese population-specific sources
where available. Where Vietnamese population-specific parameters were not available, exposure
parameters were selected using the recommended USEPA values.
RISK CHARACTERIZATION
NONCANCER HAZARD
Non-cancer hazards were characterized using the hazard quotient approach (USEPA 1989). The
hazard quotient (HQ) is the ratio of the estimated average daily exposure (ADD or EC) for a
specific chemical to the maximally acceptable safe dose for that chemical (RfD or RfC). An HQ
of less than 1.0 indicates that there is no appreciable risk of noncancer health effects associated
with that exposure for a particular COPC (USEPA 1989). Because different chemicals may cause
similar adverse health effects, it is appropriate to combine HQs associated with different
substances that affect the same target organ or organ system (e.g., lung, kidney, liver, etc.) or
result in the same health endpoint (e.g., respiratory irritant) to generate a Hazard Index (HI).
Chemicals with HIs of 1.0 or greater will be identified as chemicals of concern.
CANCER HAZARD
In parallel to the carcinogenic risk, the carcinogenic potential of dioxin/furans was estimated using
a hazard metric similar to that described for noncancer hazards, which is the ratio of the average
daily dose to the tolerable daily intake. Hazard quotients representing single exposure routes
were summed to express a hazard index for each receptor. Similar to the noncancer hazard, if
the cancer hazard for dioxin is greater than 1.0 it was identified as a chemical of concern.
CANCER RISK
Carcinogenic health risks are defined in terms of the probability of an individual developing cancer
as the result of exposure to a given chemical at a given concentration (USEPA 1989). The
incremental probability of developing cancer (i.e., the theoretical excess cancer risk) is the
additional risk above and beyond the cancer risk an individual would face in the absence of the
exposures characterized in this risk assessment, and is calculated as the product of the lifetime
average daily exposure (LADD or EC) and the oral cancer slope factor (SF) or inhalation unit risk
(IUR). For each receptor, the risks due to exposure to carcinogens were summed across each
chemical and pathway, regardless of the carcinogenic mode of action. For the residential receptor,
risks for children and adult risks were summed to calculate lifetime exposures. Chemicals having
a cancer risk less than 1 x 10-6 are considered not to be of concern while cancer risks above 1 x
10-4 are considered unacceptable. For this Project, given the small to moderate number of
potentially affected people, a cancer risk threshold of 1 x 10-5 was chosen.
The main results conclusions of the baseline risk assessment are as follows:
BASELINE CONDITIONS
• Under baseline conditions, there are a number of decision units (DUs) with noncancer and
cancer hazards greater than one and increased lifetime cancer risks outside the acceptable
risk range of 10-6 to 10-4, which indicates that remediation will be required for many of these
areas.
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• Under baseline conditions, the noncancer hazards and cancer risks associated with PCDD/F
exposure are higher than those associated with exposure to the other COPCs.
• Under baseline conditions, soil and diet exposures are the predominant contributors to the
overall noncancer hazard, cancer hazard, and cancer risk for all areas and DUs at this site.
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1 INTRODUCTION
This Final Technical Memorandum (TM) Baseline Risk Assessment (BRA) has been developed by Trigon
Associates, LLC (A&E Bien Hoa Contractor) for the US Agency for International Development (USAID)
under Contract No. AID-OAA-I-15-00053, Task Order No. 72044019F00001, in accordance with
Section C – Description/Specifications/ Statement of Work (SOW), Subsection C.5 Statement of Work,
Component 1 (CLIN 1), Task 1.3, Site Conceptual Model (SCM), Baseline Risk Assessment, and Data
Gaps Analysis.
• Perform a human health and ecological risk assessment using site-specific data;
• Use standard USEPA methods to identify the chemicals of concern in each of the affected
environmental media (soil, sediment, biota, surface water, or groundwater);
• Incorporate input from local stakeholders so that all exposure pathways and receptors that may be
of concern are considered, and;
• Use either site-specific or Vietnam-specific exposure factors to evaluate human health and ecological
risks;
Project Phase 1 activities were recently approved by Government of Vietnam (GVN) Ministry of
National Defense (MND) in Decision No. 3869/QD-BQP on Approval of the Investment project and
the plan for selection of the “Dioxin Remediation in Bien Hoa Airbase – Phase 1” Project with non-
refundable Official Development Assistance from the United States of America, dated September 6,
2019 (MND 2019). Project Phase 1 activities are the excavation and on-Airbase treatment of
approximately 150,000 m3 of dioxin-contaminated soils and sediments from the Pacer Ivy Area and the
Z1 Area with dioxin concentrations at or above 1,200 parts per trillion (ppt) to below a 100 ppt remedial
threshold; excavation and isolation of approximately 150,000 m3 of dioxin-contaminated soils and
sediments with a concentration below 1,200 ppt but above applicable MND land-use thresholds (300
ppt for urban lands, 150 ppt for sediment, 100 ppt for forested land and other lands with perennial trees)
in a constructed on-Airbase facility; and treatment of any dioxin-contaminated wastewater and surface
waters generated from Project activities with concentrations exceeding permitted thresholds (MND
2019).
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2 SITE BACKGROUND
The Bien Hoa Airbase (Figure 2-1) is an active ADAFC airbase and encompasses an area of
approximately 1,000 hectares (ha) immediately to the east and northeast of the Dong Nai River. Air
Defense – Air Force Command (ADAFC) reported a population of up to 2,200 persons working on the
Airbase, including approximately 1,200 persons residing on the Airbase (GVN/USAID 2016). In addition
to ADAFC military training activities and operations, land areas on-Airbase are being used for agriculture
and forestry purposes. Northern portions of the Airbase are used for agriculture (cattle grazing) and
Northern and Western portions of the Airbase for forestry (rubber tree and acacia tree plantations).
Agricultural activity, including gardening, cattle grazing, and raising rubber plantations, occurs in the
northern areas of the Airbase, and aquaculture occurred in the northeast area prior to a 2010
aquaculture ban on base (GVN/USAID 2016). However, despite the aquaculture ban, fishing activity has
been observed on the Airbase as recently as December 2015 (Thien-Le Quan 2015).
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FIGURE 2-1 BIEN HOA AIRBASE AREA
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2.2.2 BRIEF SUMMARY OF PAST STUDIES
According to GVN/USAID (2016), the first recorded examination of dioxin present at the Bien Hoa Airbase
was conducted by VRTC in 1990 (followed by MND in 1995 and 1996). Subsequent studies were performed
and reported by Dr. Arnold Schecter in 1999, Hatfield and colleagues between 2006 and 2011, and
GVN/USAID in 2016. Generally, concentrations of dioxin recorded exceeded both Vietnamese and
international standards: results from the 1999 study by Schecter showed concentrations of dioxin in soil
from Bien Hoa City and the Airbase ranging from below to detection to exceeding one million ppt TEQ.
Study results from 2003 through 2008 (Hatfield et al.) exhibited excessive concentration of dioxin in soil
and sediments in specific hotspots around the Airbase including the Northeast area, Gate 2 Lake, Bien Hung
Lake, Southwest area, Pacer Ivy Area, and Z1 area; concentrations observed in some of these areas were
found to range up to 262,000 ppt TEQ (Z1 landfill site). However, some studies found variable
concentrations of dioxin in soils, in some cases at levels below Vietnamese federal guidelines (studies
conducted by VEA, MONRE in 2011, and VRTC in 2013).
Groundwater wells were installed and monitored at seven sites around the Airbase in a 2011 project, which
generally reached depths of 3-15 m belowground. Results from monitoring efforts showed that
concentrations of TCDD were detectable, but below USEPA MCL levels for drinking water. Fish tissue
samples were gathered under a 2010 study by Hatfield and Office 33, which were harvested from fish in the
Northeast, Northwest, Pacer Ivy, and Z1 areas. These tissue samples showed dioxin concentrations
between 1.4 and 33 ppt TEQ in muscle and 4.54 to 4,040 ppt TEQ in fat.
Dioxin Thresholds in Soil and Sediment (TCVN 8183:2009) established maximum allowable concentrations
for dioxins/furans in soil at 1,000 ppt TEQ and in sediment at 150 ppt TEQ. National Technical Regulations
on Allowed Limits of Dioxin in Soils (QCVN 45:2012/BTNMT), which supersedes TCVN 8183:2009,
established maximum allowable concentrations of dioxins/furans in soil for multiple land use conditions
ranging from 40 ppt to 1,200 ppt, but did not specify maximum allowable conditions for sediment.
Table 2-1 summarizes the maximum allowable soil and sediment concentration for each Decision Unit based
on land use, as identified in the Environmental Assessment of Dioxin Contamination at Bien Hoa Airbase
(GVN/USAID 2016). The location of the different decision units (DUs) and sub-decision units (sub-DUs)
and the associated land use is provided in Figure 2-2.
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TABLE 2-1 MAXIMUM ALLOWABLE DIOXIN BY LAND USE AND DECISION UNIT
MAXIMUM
ENVIRONMENTAL GVN LAND USE ALLOWABLE
DECISION UNITS
MEDIA CATEGORY DIOXIN LIMIT
(PPT TEQ)
Forest Land 100 NF-1; NF-2; NF-3; NF-4
Z1-9; Z1-10
PI-15; PI-16; PI-17; PI-18; PI-19; PI-20; PI-21
NW-1; NW-2; NW-3; NW-4
Sediment Non-Aquaculture 150
NE-6; NE-7; NE-8; NE-9; NE-10; NE-11; NE-12; NE-13;
NE-14; NE-15
BHL-1; G2-1
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FIGURE 2-2 LAND USE AT BIEN HOA AIRBASE AREA
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2.4 HISTORICAL AREAS OF CONTAMINATION
The body of literature related to dioxin contamination at Bien Hoa Airbase identifies multiple areas of
contamination, as summarized by GVN/USAID (2016) and shown on Figure 2-1:
• Z1 Area – located at the southern point of the Airbase, this area served as the main storage area for
Agents Orange, Blue, and White. Dioxin has been detected in soil, sediment, construction materials,
and aquatic organisms in this area as well as downgradient and offsite of this area; soil and sediment
concentrations were above allowable limits.
• ZT Area – directly north of the Z1 Area, the ZT area served as a taxiway for herbicide transport, as
well as an aircraft and equipment staging area. This area was not investigated prior to 2014, at which
time dioxin was detected above the allowable limit in one DU in this area.
• Southwest Area – located on the southwest side of the Airbase, this area may have been used as an
herbicide storage area during Pacer Ivy mission activity. Dioxin has been detected in soil and
construction materials in this area; concentrations in soil were above allowable limits, although the depth
profile of contamination is variable.
• Pacer Ivy Area – located on the western end of the Airbase, this area was used to store, re-drum and
package Agent Orange during the Pacer Ivy mission. Dioxin has been detected in soil, sediment, and
aquatic organisms in this area; concentrations in soil and sediment were above allowable limits.
• Northwest Area – located within the northwest perimeter of the Airbase; dioxin has been detected in
sediment above the allowable concentration in this area.
• Northern Forest Area – located along the northern boundary of the Airbase, this is area has been used
for rubber plantation forests as well as limited agriculture and livestock activity. Dioxin has been
detected above allowable limits in soil in this area.
• Northeast Area – located east of the northern runways, this area has been used for aquaculture. Dioxin
has been detected in soil, sediment, and aquatic organisms in this area.
• Outside Airbase – it has been demonstrated that dioxin contamination extends beyond the perimeter
of the Airbase, through overflow of contaminated-sediment bearing water during the rainy season.
Among these areas of known contamination, Pacer Ivy, Southwest Area, and Z1 Area have been identified
as areas with the most extensive dioxin contamination.
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• DONRE-A2 – An area of approximately 1,626 m2 of contaminated soils (reported with a maximum of
4,023 ppt dioxin in soils) on open land located to the south-east of Pacer Ivy Area near the access road
to the Tran Bien Temple; and
• MND-A42 – An area of approximately 155 m2 of contaminated sediments reportedly dredged from Bien
Hung Lake years ago (maximum of 4,023 ppt dioxin) and placed on open land that is located outside the
Airbase entrance to the south of the EA’s Z1 Area.
In addition, DONRE has revised the estimation of contamination in Gate 2 Late (G2L) and now excludes
the areal extent of the Tax Department building currently under construction.
Figure 2-3 shows surface dioxin concentrations throughout the Airbase Area. The three historically
contaminated areas (Pacer Ivy, Southwest, and Z1) are all evident; although the area in Southwest with high
concentrations has decreased due to the XD-2 project and the contaminated soil relocated to the Z1-XD2
landfill. Pacer Ivy remains the primary area to have contributed to off Airbase contamination through surface
water/stormwater erosion. The DONRE-A2 results show the (minor, given the contaminated area)
importance of an additional off Airbase migration pathway through drainage from the south of Pacer Ivy.
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FIGURE 2-3 SURFACE DIOXIN CONCENTRATIONS AT THE BIEN HOA AIRBASE AREA
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3 HAZARD IDENTIFICATION
The purpose of the hazard identification is to evaluate the nature and extent of constituent releases at
a site and to select a subset of constituents, identified as Chemicals of Potential Concern (COPCs), for
quantitative evaluation of the risk assessment. This process involves data evaluation and selection of the
COPCs through relevant screening steps. In this section, the environmental data sets that will be used
in the risk assessment are identified; the process used to select the COPCs is described; and the data
that were used to identify the COPC are summarized.
Soil and sediment samples were collected in November of 2010 from the Pacer Ivy Area, the Southwest
Corner of the Airbase, the Z1 Area, and the northeastern, and northern perimeters of the Airbase
(Hatfield and Office 33 2011). Fish tissue samples (muscle, fat, eggs, or whole fish) were collected in
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November 2010 from lakes and ponds inside and outside the Bien Hoa Airbase. Blood serum samples
were collected in November 2010 from members of the population deemed at high risk, such as Bien
Hoa Airbase workers and those that consumed fish and aquatic organisms from local lakes and ponds,
and included people residing both inside and outside of the Airbase. Breast milk samples were collected
in November 2010 from members of the population deemed at high risk, such as Bien Hoa Airbase
workers and those that consumed fish and aquatic organisms from local lakes and ponds, and included
people residing both inside and outside of the Airbase (Hatfield and Office 33 2011).
Total dioxin/furan concentration (pg TEQ/g) was quantified in 46 pooled samples, each consisting of five
to 15 individual food samples and weighing at least 200 g (Tuyet-Hanh, Minh et al. 2015). Samples were
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collected from potentially ‘high-risk’ foods including free range chicken meat and eggs, free range duck
meat and eggs, freshwater fish, snail, beef, and pumpkin, as well as from potentially ‘low-risk’ foods
including caged chicken meat and eggs, caged duck meat and eggs, fish and prawns from the sea, pork,
vegetables (including leafy vegetables), fruit, and rice (Tuyet-Hanh, Minh et al. 2015). Food samples were
cleaned with tap water and non-edible portions of vegetables were removed prior to sample processing
(Tuyet-Hanh, Minh et al. 2015).
3.1.8.1 SOIL/SEDIMENT
Soil and sediment sampling for dioxin/furan analysis at the Airbase was conducted at the following
locations: Z1 Area (n=330), ZT Area (n=102), Southwest Area (n=121), Pacer Ivy Area (n=380),
Northwest Area (n=63), Northern Forest Area (n=44), Northeast Area (n=224), Southeast Area
(n=21), and Offsite Lakes (n=21); however, only 507 soil/sediment samples were analyzed for dioxins
and furans (GVN/USAID 2016). The 22 total soil/sediment samples collected and analyzed for VOCs,
SVOCs, metals, PCBs, and herbicides analysis consisted of the following: Z1 Area (n=7), ZT Area (n=1),
Southwest Area (n=3), Pacer Ivy Area (n=8), Northeast Area (n=1), and Offsite Lakes (n=2)
(GVN/USAID 2016). The six total soil/sediment samples collected for physical properties analysis
consisted of the following: Z1 Area (n=2), Southwest Area (n=1), Pacer Ivy Area (n=1), and Northeast
Area (n=2) (GVN/USAID 2016).
3.1.8.2 GROUNDWATER
Samples of drinking water and shallow groundwater from inside and outside the Bien Hoa Airbase were
collected and dioxin/furan, herbicide, VOC, SVOC, metals, and PCB analyses were performed
(GVN/USAID 2016). Specifically, 22 samples were subjected to dioxin/furan analyses, 15 samples were
subjected to herbicide analyses, and eight samples were analyzed for VOCs, SVOCs, metals, and PCBs
(GVN/USAID 2016). Groundwater samples were collected from 14 locations (8 onsite locations and six
offsite locations): onsite locations included six monitoring wells (MW-1 through MW-6) and two
locations at the Airbase water supply well (one before treatment system, and one after treatment
system); the six offsite locations were distributed around the perimeter of the Airbase (GVN/USAID
2016). Five of the monitoring wells were screened at depths of 3 m to 15 m below ground surface and
one well was screened at 2 m to 6 m, all of which are too shallow for providing drinking water
(GVN/USAID 2016).
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3.1.8.3 BIOTA
Fish tissues (whole body, muscle, fat and eggs) and snail tissue (whole body) samples were collected
from ten lakes within and outside of the Airbase (GVN/USAID 2016). A total of 33 samples were
collected from the Z1 Area (n=4), Pacer Ivy Area (n=4), Northwest Area (n=6), Northeast Area (n=16),
and Offsite Lakes (n=3) (GVN/USAID 2016). Fish species samples consisted of catfish (Pacer Ivy area),
bighead carp (Northeast area), basa (Northwest area), and tilapia (Z1 area, Northeast area, Northwest
area, Bien Hung Lake); the species of snail (Pacer Ivy area and Northwest area) was unspecified
(GVN/USAID 2016).
For this risk assessment, the most recent data collected by GVN/USAID (2016) were used to
characterize exposures to soil, sediment, groundwater, fish, and snails while the data on various other
diet items presented in Tuyet-Hanh et al. (2015) were used to characterize exposure from those items.
• Detection Frequency: Only chemicals that were detected with a frequency of more than 5% in
any site area were carried through the BRA. In the event that a dataset had less than 20 samples in
a particular medium (e.g., subsurface soil), chemicals detected at least once were carried through.
• Comparison to Screening Levels: The maximum concentration of chemicals detected at a
frequency of greater than 5% were compared to both USEPA Regional Screening Levels (RSL) for
Resident and Industrial Soil (USEPA 2019). These screening levels are based on a target hazard
index of one and a target risk level of 1 x 10-6 and included exposures from soil ingestion, dermal
contact, and inhalation.
Constituents in soil and sediment that were present at a detection frequency of greater than 5% and
that had a maximum concentration exceeding an RSL were considered COPCs and were further
evaluated quantitatively in the BRA.
Based on this screening process, dioxins/furans, arsenic, and PCB 1260 were identified at COPCs in soil
and sediment. Dioxins/furans and arsenic are COPCs in all site areas while PCB 1260 is only a COPC
for the Pacer Ivy Area because it was only detected above its USEPA RSL in that area.
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Chemical of Concern and will be further considered in the BRA. Based on this the only COPCs in
groundwater are dioxins/furans and lead.
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TABLE 3-1 DATA SUMMARY FOR DIOXINS/FURANS
NUMBER INDUSTRIAL
DETECTION MEAN MINIMUM MAXIMUM CONCENTRATION
AREA MEDIUM OF RSL / USEPA
FREQUENCY CONCENTRATION CONCENTRATION CONCENTRATIONA UNIT
SAMPLES MCL
Southeast Area Soil 4 100% 41.9 31.8 64.5 ppt TEQ 22 ppt
Pacer Ivy Area Sediment 51 100% 890 2.4 5410 ppt TEQ 22 ppt
Northwest Area Sediment 27 100% 413 0.8 644 ppt TEQ 22 ppt
North Forest Area Soil 14 100% 104 1 465 ppt TEQ 22 ppt
Gate 2 Lake Area Sediment 3 100% 108 57 166 ppt TEQ 22 ppt
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TABLE 3-2 DATA SUMMARY FOR OTHER COPCS
Northeast
Soil 100% 3.1 3.1 3.1 mg/kg 3 mg/kg
Area
Gate 2
Sediment 100% 5.7 5.7 5.7 mg/kg 3 mg/kg
Lake
Bien Hung
Sediment 100% 11 11 11 mg/kg 3 mg/kg
Lake
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DETECTION MEAN MINIMUM MAXIMUM CONCENTRATION INDUSTRIAL RSL /
COPC AREA MEDIUM
FREQUENCY CONCENTRATION CONCENTRATION CONCENTRATIONA UNIT USEPA MCL
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4 TOXICITY ASSESSMENT
The purpose of the toxicity assessment is to identify the types of adverse effects a COPC may cause
and define the relationship between the dose of a constituent and the likelihood and magnitude of an
adverse effect. These relationships are represented mathematically as cancer slope factors (SFs) or
inhalation unit risks (IURs) for carcinogenic effects and as reference doses (RfDs) or inhalation reference
concentrations (RfCs) for non-carcinogenic effects. Noncancer toxicity criteria were selected for both
chronic and subchronic exposures.
4.2 PCDD/FS
Polychlorinated dibenzo-p-dioxins (PCDDs) and polychlorinated dibenzo-p-furans (PCDFs) are a family
of 75 polychlorinated dioxin and 135 furan compounds, or congeners (ATSDR 1994, ATSDR 1998).
These congeners may be divided into groups based on the number of chlorine atoms, referred to
homologue groups. Dioxins and furans are named based on the number and position of chlorine atoms
in the compound; for instance, 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD) has four chlorine atoms at
positions 2, 3, 7, and 8. PCDD/Fs are formed during the chlorine bleaching process and during the
manufacture of chlorinated organic chemicals, and are commonly released into the environment during
combustion and incineration processes (ATSDR 1994, ATSDR 1998).
The toxicities of individual PCDD/F congeners vary greatly, with TCDD recognized as one of the most
well-studied and toxic congeners (ATSDR 1998). As a result, the concept of toxic equivalency was
developed to relate the toxicity of PCDD/F congeners to the toxicity of TCDD using a relative effect
potency, in order to generate toxic equivalency factors (TEF) (Van den Berg, Birnbaum et al. 2006). The
products of congener-specific concentrations and TEFs represent the toxic equivalent (TEQ)
concentrations of TCDD, and are then summed to generate a total TEQ value (Van den Berg, Birnbaum
et al. 2006).
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concentration (Baccarelli, Giacomini et al. 2008, Mocarelli, Gerthoux et al. 2008, USEPA 2012). A
cumulative uncertainty factor of 30 was applied to the data, which did not include any adjustment from
subchronic to chronic exposures; therefore, the chronic reference dose was used to evaluate subchronic
exposures (USEPA 2012).
4.2.1.2 INHALATION
No Tier 1 or Tier 2 noncancer toxicological criteria are available for TCDD. According to OEHHA, a
Tier 3 data source, the recommended exposure level for chronic inhalation of TCDD is 4 x 10-5 µg/m3
(OEHHA 1999, OEHHA 2014). The chronic target organ groups included the liver, reproductive system,
development, endocrine system, respiratory system, and hematopoietic system (OEHHA 1999). This
value is derived from a study on rats, which established a NOAEL of one ng/kg-body weight/day (Kociba,
Keyes et al. 1978, OEHHA 1999). OEHHA applied a cumulative uncertainty factor of ten to the data,
including a factor of one to adjust from subchronic to chronic exposure; therefore, the chronic reference
concentration was used to evaluate subchronic exposures (OEHHA 1999).
4.2.2.1 ORAL
No Tier 1 or Tier 2 toxicological criteria was available for oral TCDD exposure based upon either a
nonthreshold or threshold dose assumption. Therefore, a Tier 3, threshold-based tolerable daily intake
(TDI) of 2.3 pg/kg-day was used to evaluate potential carcinogenic effects of TCDD exposure (JECFA
2002). The TDI was converted from a provisional tolerable monthly intake (PTMI) of 70 pg/kg-month
by dividing the value by 30 (JECFA 2002). The Joint Food and Agriculture Organization/World Health
Organization Expert Committee on Food Additives (JECFA) derived the PTMI by assessing the adverse
effects on the reproductive tracts of prenatally-exposed male rats (Faqi, Dalsenter et al. 1998, Ohsako,
Miyabara et al. 2001, JECFA 2002). As part of their evaluation, the committee established that TCDD
carcinogenicity is not linked to mutagenicity or DNA binding and occurred at a higher threshold than
noncancer effects, and concluded that the PTMI based on noncancer effects also addresses carcinogenic
risk (JECFA 2002).
A Tier 3 oral slope factor of 130,000 (mg/kg/day)-1 was also used to evaluate potential carcinogenic
effects of TCDD exposure; this value was derived by the California Office of Environmental Health
Hazard Assessment (OEHHA) based on the nonthreshold dose assumption (OEHHA 2011). Following
the determination that the available epidemiologic data was insufficient for a carcinogenicity
determination, this value was derived based on male mouse hepatocellular adenoma/carcinoma tumor
data (OEHHA 2011). The animal exposure data were converted to equivalent human exposures through
the application of scaling factors; further, assumptions were made that the oral and inhalation routes
were equivalent, the route of exposure did not affect absorption, and there was no metabolic or
pharmacokinetic difference between animals and humans (NTP 1982, OEHHA 2011).
4.2.2.2 INHALATION
No Tier 1, Tier 2, or Tier 3 toxicological criteria was available for TCDD inhalation based upon the
threshold dose assumption. No Tier 1 or Tier 2 toxicological criteria was available for TCDD based
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upon the linear dose assumption. The California Office of Environmental Health Hazard Assessment
(OEHHA), a Tier 3 source, has established an inhalation unit risk of 38 (µg/m3)-1 for TCDD (OEHHA
2015). Following the determination that the available epidemiologic data was insufficient for a
carcinogenicity determination, this value was derived based on mouse hepatocellular
adenoma/carcinoma tumor data (NTP 1982, OEHHA 2011).
4.3 ARSENIC
Arsenic is found naturally in soil, water, and air, and can be a contaminant of food as well as an
occupational agent of exposure. Inorganic species of arsenic exist when joined with other elements
including oxygen, chlorine, and sulfur, while organic species of arsenic are found when arsenic combines
with carbon and hydrogen. Relative to inorganic forms, organic forms of arsenic have been studied less
extensively but based on available evidence are largely thought to be of low or no toxicity and are
generally not implicated as determinants of adverse health outcomes (ATSDR 2007).
The arsenic identified in the data evaluation was not speciated; therefore, toxicity criteria were
conservatively identified and selected for inorganic arsenic for use in this baseline risk assessment.
4.3.1.2 INHALATION
No Tier 1 or Tier 2 toxicological criteria are available for inorganic arsenic. According to OEHHA, a
Tier 3 data source, the recommended exposure level for chronic inhalation of inorganic arsenic is 0.015
ug/m3 (OEHHA 2014). The chronic target organ groups included reproductive/developmental,
cardiovascular system, nervous system, lung and skin (OEHHA 2014). This value is derived from multiple
studies evaluating exposure of children to inorganic arsenic-containing drinking water, from which a
LOAEL of 0.23 µg/m3 was established (Tsai, Chou et al. 2003, Wasserman, Liu et al. 2004, OEHHA
2014). OEHHA applied a cumulative uncertainty factor of 30 to the data, including a factor of one to
adjust from subchronic to chronic exposure; therefore, the chronic reference concentration was used
to evaluate subchronic exposures (OEHHA 2014).
4.3.2.2 INHALATION
IRIS provides an inhalation unit risk of 4.3 x 10-3 (µg/m3)-1 for inorganic arsenic exposure (USEPA 1995).
This value was derived from multiple occupational studies of smelter employees exposed to inorganic
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arsenic (Enterline and Marsh 1982, Higgins, Welch et al. 1982, Brown and Chu 1983a, Brown and Chu
1983b, Lee-Feldstein 1983, USEPA 1995).
4.4.1.2 INHALATION
No Tier 1, Tier 2, or Tier 3 toxicological criteria were available for PCBs 1260 or 1254; therefore, PCB
1260 was evaluated for its carcinogenic potential and oral toxicity only.
4.4.2.2 INHALATION
IRIS recommends using the same high risk and high persistence cancer slope factor of 2.00 (mg/kg-day)-
1, applied to oral exposures, for the inhalation of PCB-contaminated aerosols and/or dusts (USEPA
1996). This converts into an inhalation unit risk of 5.7 x 10-4 µg/m3.
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4.5 LEAD
USEPA has not reached a consensus regarding toxicity criteria for inorganic lead; therefore, the 95%
UCL values for lead in applicable media were compared against appropriate screening levels per USEPA
guidance (USEPA 2019). A residential screening level of 400 mg/kg was identified as appropriate for
assessment of lead in soil and the USEPA Action Level of 15 µg/L was identified for assessment of lead
in water (USEPA 2019).
A summary of noncancer toxicological criteria for all COPCs is provided in Table 4-2.
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TABLE 4-2 NONCANCER TOXICOLOGICAL CRITERIA
CUMULATIVE
UNCERTAINT SUBCHRONIC TARGET ORGANS /
COPC VALUE UNIT VALUE TYPE SOURCE TIER Y FACTORS VALUE UNIT SOURCE SYSTEM
Reference Dose Thyroid / sperm
0.7 pg/kg-day (RfD) IRIS 1 30 0.7 pg/kg-day IRIS count and motility
Alimentary,
reproductive /
2,3,7,8-TCDD
development,
Reference endocrine,
Exposure Level hemotologic,
0.00004 µg/m3 (REL) OEHHA 3 100 0.00004 µg/m3 OEHHA respiratory
Hyperpigmentation,
Reference Dose keratosis, potential
0.0003 mg/kg-day (RfD) IRIS 1 3 0.0003 mg/kg-day IRIS vascular system
Cardiovascular,
Arsenic (inorganic)
reproductive /
Reference development,
Exposure Level nervous, respiratory,
0.015 µg/m2 (REL) OEHHA 3 30 0.015 µg/m2 OEHHA skin
Reference Dose
PCB 1260 0.00002 mg/kg-day (RfD) IRIS 1 300 0.00006 mg/kg-day IRIS Immune system
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5 EXPOSURE ASSESSMENT
The purpose of the exposure assessment is to predict the magnitude and frequency of potential human
exposure to each of the COPC for quantitative evaluation in the risk assessment. This exposure
assessment was based on the site conceptual site model (SCM), which characterized the sources, release,
and distribution of COPCs to receptors through exposure pathways.
Baseline Scenario (current conditions) – reflecting the baseline/current conditions on the Airbase,
this scenario includes evaluations of local residents, resident Airbase personnel and families, and
nonresident Airbase personnel under pre-remediation exposure conditions.
• Local Residents – Local residents, comprised of infants, children, and adults, may be exposed to
COPCs through consumption of contaminated food sources; dermal contact with surface soil and
sediment; incidental ingestion of surface soil, sediment, and groundwater; and inhalation of surface
soil, and sediment throughout their time living and working on the Airbase. Further, infants may be
exposed to COPCs through ingestion of breastmilk.
• Resident Airbase Personnel and Families – Similar to local residents, Airbase personnel and
residents, comprised of infants, children, and adults, may be exposed to COPCs through
consumption of contaminated food sources; dermal contact with surface soil and sediment;
incidental ingestion of surface soil, sediment, and groundwater; and inhalation of surface soil, and
sediment throughout their time living and working on the Airbase. Further, infants may be exposed
to COPCs through ingestion of breastmilk.
• Nonresident Airbase Personnel - Airbase personnel, comprised solely of adults, may potentially be
exposed to COPCs through dermal contact with surface soil and sediment; incidental ingestion of
surface soil and sediment; and inhalation of surface soil, and sediment throughout their time working
on the Airbase. Their exposure to contaminated food sources and ingestion of groundwater is
expected to be less than the resident Airbase personnel.
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5.3 EXPOSURE PATHWAYS
The potentially exposed populations and exposure pathways are summarized in Table 5-1 and
described below.
Ingestion of soil and sediment can result in exposure to human receptors. Adults and children who
come in close and regular contact with contaminated soils and sediments may ingest small amounts of
soil.
Direct dermal contact with COPCs present in sediments and soils can result in exposure to human
receptors. Direct dermal absorption represents an exposure pathway for adults and children who
come in close and regular contact with contaminated soils.
Inhalation of airborne particulates such as soil and dust provide an exposure route to human
receptors since the COPCs identified in the data evaluation are not predicted to be significantly
impacted by volatilization. Contaminated soils may become airborne due to wind erosion and/or
vehicular and construction-related disturbances, particularly in non- or minimally-vegetated conditions.
Inhalation of airborne substances containing COPCs, in particular fugitive airborne particulates,
represents an exposure pathway for dioxin via inhalation.
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Breast Milk Consumption of Breast Milk
Air Inhalation
Surface Soil Soil Ingestion
(0-1 ft BGS) Dermal Contact with Soil
Particulate Inhalation
Sediment Ingestion
Sediment
Dermal Contact with Sediment
Current and Future Local Resident or Resident
Airbase Personnel and Families Groundwater Groundwater Ingestion
– child (0-6 years),
– adolescent (7-18 years), and Consumption of Chicken
– adult (>18 years)
Consumption of Duck
Consumption of Chicken Eggs
Consumption of Duck Eggs
Local Diet
Consumption of Fish
Consumption of Snails
Consumption of Vegetables
Consumption of Rice
Air Inhalation
5.4.1.1 SOIL/SEDIMENT
Because the majority of soil and sediment data for the dioxins/furans were collected using an incremental
sampling protocol, the 95% UCL soil and sediment concentrations were calculated using either the
Student t 95% UCL of the arithmetic mean or the Chebyshev UCL, whichever was larger (ITRC 2012).
For the other COPCs, the 95% UCLs were estimated using the USEPA (2016) program ProUCL 5.1.
These 95% UCLs were used as the EPCs for the dermal contact with soil and sediment pathways as well
as the incidental ingestion of soil and sediment pathways in this assessment. For the baseline conditions,
the data from surface soil or sediment (<30 cm) was used to calculate the EPC. The soil and sediment
EPCs used for the PCDD/Fs for each DU are presented in Appendix A, Table A-2 through Table A-5.
The soil and sediment EPCs for the other COPCs are presented in Appendix, Table 5-8.
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5.4.1.2 AIR
EPCs in air for the particulate inhalation pathway were determined from 95% UCL soil
concentrations according to the following equation:
Where:
EPCair = Exposure point concentration in air (mg/m3)
PEF = Particulate emission factor for non-volatile chemicals (cubic meter per
kilogram [m3/kg])
The particulate emission factor (PEF) used (for non-volatile COPC) in the BRA for the current scenarios
was 1.36 x 109 m3/kg based on particulate emissions due to wind erosion. For volatile COPC in soil,
chemical-specific VFs were calculated in accordance with the USEPA Supplemental Soil Screening Level
Guidance Volatilization Factor Equation (USEPA 2002). This equation is a one-dimensional environmental
chemical transport model that incorporates chemical-specific parameters such as Henry's Law Constant,
organic soil binding coefficient, soil-air diffusion coefficient, and soil-water diffusion coefficient. The PEFs
used for each scenario are presented in Appendix A, Table A-9.
5.4.1.3 GROUNDWATER
For areas and COPCs with more than three groundwater samples, the 95% UCLs were estimated using
the USEPA (2016 (2016)) program ProUCL 5.1. For the PCDD/Fs, the groundwater EPCs are presented
in Appendix A, Table A-6 and for the other COPCs, the EPCs are presented in Appendix A, Table A-8.
5.4.1.4 DIET
For diet items other than fish and snails, the maximum concentration for each food item as presented
in Tuyet-Hahn et al. (2015) was used as the EPC. For fish and snail data from reports of onsite and
offsite data (USAID 2016; Hatfield and Office 33 2011), the 95% UCLs were estimated using the USEPA
(2016) program ProUCL 5.1 for data sets with more than three samples. These EPCs are presented in
Appendix A, Table A-7.
Where:
ADD = Average Daily Doses for non-carcinogens (milligram per kilogram per day,
mg/kg-day)
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LADD = Lifetime Average Daily Doses for carcinogens (mg/kg-day)
EPCsoil/sediment = Exposure point concentration for COPC in soil/sediment (mg/kg)
CF = Conversion factor (10-6 kg/mg)
EF = Exposure frequency (days/year)
ED = Exposure duration (years)
AF = Soil adherence factor (milligram per square centimeter per day [mg/cm2-day])
SA = Surface area of exposed skin (cm2)
ABS = Dermal absorption factor (unit less)
BW = Body weight (kg)
AT = Averaging time (days)
Where:
ADD = Average Daily Doses for non-carcinogens (mg/kg-day)
LADD = Lifetime Average Daily Doses for carcinogens (mg/kg-day)
EPCsoil/sediment = Exposure point concentration for COPC in soil or sediment (mg/kg)
CF = Conversion factor (10-6 kg/mg)
EF = Exposure frequency (days/year)
ED = Exposure duration (years)
IR = Soil ingestion rate (mg/day)
BW = Body weight (kg)
AT = Averaging time (days)
Where:
ADD = Average Daily Doses for non-carcinogens (mg/kg-day)
LADD = Lifetime Average Daily Doses for carcinogens (mg/kg-day)
EPCgroundwater = Exposure point concentration for COPC in groundwater (mg/L)
EF = Exposure frequency (days/year)
ED = Exposure duration (years)
IR = Groundwater ingestion rate (L/day)
BW = Body weight (kg)
AT = Averaging time (days)
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Dermal contact with groundwater was quantified according to the following equation:
Where:
ADD = Average Daily Doses for non-carcinogens (mg/kg-day)
LADD = Lifetime Average Daily Doses for carcinogens (mg/kg-day)
DAevent = Dermally Absorbed Dose per event (mg/cm2-event)
EV = Events per day (events/day)
EF = Exposure frequency (days/year)
ED = Exposure duration (years)
SA = Skin Surface Area (cm2)
BW = Body weight (kg)
AT = Averaging time (days)
DAevent is calculated differently for organic and inorganic compounds. Below are the equations used
for arsenic and PCDD/Fs, respectively:
𝐿𝐿
Arsenic 𝐷𝐷𝐷𝐷𝑒𝑒𝑒𝑒𝑒𝑒𝑒𝑒𝑒𝑒 = 𝐸𝐸𝐸𝐸𝐸𝐸𝑔𝑔𝑔𝑔𝑔𝑔𝑔𝑔𝑔𝑔𝑔𝑔𝑔𝑔𝑔𝑔𝑔𝑔𝑔𝑔𝑔𝑔 × 𝐾𝐾𝑝𝑝 × 𝐸𝐸𝐸𝐸 × (0.001 3 )
𝑐𝑐𝑐𝑐
𝐿𝐿 6×𝜏𝜏×𝐸𝐸𝐸𝐸
PCDD/Fs 𝐷𝐷𝐷𝐷𝑒𝑒𝑣𝑣𝑒𝑒𝑒𝑒𝑒𝑒 = 𝐸𝐸𝐸𝐸𝐸𝐸𝑔𝑔𝑔𝑔𝑔𝑔𝑔𝑔𝑔𝑔𝑔𝑔𝑔𝑔𝑔𝑔𝑔𝑔𝑔𝑔𝑔𝑔 × 2 × 𝐹𝐹𝐹𝐹 × 𝐾𝐾𝑝𝑝 × (0.001 )×�
𝑐𝑐𝑐𝑐3 𝜋𝜋
Where:
DAevent = Dermally Absorbed Dose per event (mg/cm2-event)
EPCsurface water = Exposure point concentration for COPC in surface water (mg/L)
ET = Exposure time (hrs/event)
Kp = Permeability constant (cm/hr)
FA = Fraction absorbed (0.5 for PCDD/Fs)
τ = Lag time for PCDD/F absorption (6.8 hrs)
𝑬𝑬𝑬𝑬𝑬𝑬𝒂𝒂𝒂𝒂𝒂𝒂 ×𝑪𝑪𝑪𝑪×𝑬𝑬𝑬𝑬×𝑬𝑬𝑬𝑬×𝑬𝑬𝑬𝑬
𝑬𝑬𝑬𝑬𝒏𝒏𝒏𝒏 �𝑬𝑬𝑬𝑬𝒄𝒄 =
𝑨𝑨𝑨𝑨
Where:
ECnc = TWA exposure concentration for non-carcinogenic chemicals (µg/m3)
ECc = TWA exposure concentration for carcinogenic chemicals (µg/m3)
EPCair = Exposure point concentration in air (μg/m3)
CF = Conversion factor of one (0.001 milligram per microgram)
ED = Exposure duration (years)
EF = Exposure frequency for inhalation (days/year)
ET = Exposure time (hours/day)
AT = Averaging time for carcinogens (number of hours in 70 years)
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Incidental surface water ingestion, during swimming or wading, was quantified according to the
following equation:
Where:
ADD = Average Daily Doses for non-carcinogens (mg/kg-day)
LADD = Lifetime Average Daily Doses for carcinogens (mg/kg-day)
EPCsurface water = Exposure point concentration for COPC in surface water (mg/L)
EF = Exposure frequency (days/year)
ET = Exposure time (hrs/day)
ED = Exposure duration (years)
IR = Surface water ingestion rate (L/hr)
BW = Body weight (kg)
AT = Averaging time (days)
Dermal contact with surface water, during swimming or wading, was quantified according to the
following equation:
Where:
ADD = Average Daily Doses for non-carcinogens (mg/kg-day)
LADD = Lifetime Average Daily Doses for carcinogens (mg/kg-day)
DAevent = Dermally Absorbed Dose per event (mg/cm2-event)
EV = Events per day (events/day)
EF = Exposure frequency (days/year)
ED = Exposure duration (years)
SA = Skin Surface Area (cm2)
BW = Body weight (kg)
AT = Averaging time (days)
DAevent is calculated differently for organic and inorganic compounds. Below are the equations used for
arsenic and PCDD/Fs, respectively:
𝐿𝐿
Arsenic 𝐷𝐷𝐷𝐷𝑒𝑒𝑒𝑒𝑒𝑒𝑒𝑒𝑒𝑒 = 𝐸𝐸𝐸𝐸𝐸𝐸𝑠𝑠𝑠𝑠𝑠𝑠𝑠𝑠𝑠𝑠𝑠𝑠𝑠𝑠𝑠𝑠𝑠𝑠𝑠𝑠𝑠𝑠𝑠𝑠 × 𝐾𝐾𝑝𝑝 × 𝐸𝐸𝐸𝐸 × (0.001 )
𝑐𝑐𝑐𝑐3
𝐿𝐿 6×𝜏𝜏×𝐸𝐸𝐸𝐸
PCDD/Fs 𝐷𝐷𝐷𝐷𝑒𝑒𝑒𝑒𝑒𝑒𝑒𝑒𝑒𝑒 = 𝐸𝐸𝐸𝐸𝐸𝐸𝑠𝑠𝑠𝑠𝑠𝑠𝑠𝑠𝑠𝑠𝑠𝑠𝑠𝑠𝑠𝑠𝑠𝑠𝑠𝑠𝑠𝑠𝑠𝑠 × 2 × 𝐹𝐹𝐹𝐹 × 𝐾𝐾𝑝𝑝 × (0.001 )× �
𝑐𝑐𝑐𝑐3 𝜋𝜋
Where:
DAevent = Dermally Absorbed Dose per event (mg/cm2-event)
EPCsurface water = Exposure point concentration for COPC in surface water (mg/L)
ET = Exposure Time (hrs/event)
Kp = Permeability constant (cm/hr)
FA = Fraction absorbed (0.5 for PCDD/Fs)
τ = Lag time for PCDD/F absorption (6.8 hrs)
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5.4.2.2 INDIRECT/DIETARY EXPOSURE
Dietary ingestion for each food item, such as local chicken, duck, eggs, fish, snails, vegetables, fruit,
or rice, was quantified according to the following equation:
Where:
ADD = Average Daily Doses for non-carcinogens (mg/kg-day)
LADD = Lifetime Average Daily Doses for carcinogens (mg/kg-day)
EPCDiet = Exposure point concentration for COPC in diet (mg/kg)
CF = Conversion factor (0.001 kg/g)
EF = Exposure frequency (days/year)
ED = Exposure duration (years)
IR = Dietary ingestion rate for the food item (gram per day [g/day])
FI = Fraction ingested (0 to 1, unit less)
BW = Body weight (kg)
AT = Averaging time (days)
Where:
ADD = Average Daily Doses for non-carcinogens (mg/kg-day)
LADD = Lifetime Average Daily Doses for carcinogens (mg/kg-day)
EPCmilk = Exposure point concentration for COPC in breastmilk (mg/L)
EF = Exposure frequency (days/year)
ED = Exposure duration (years)
IR = Dietary ingestion rate for breastmilk (L/day)
ABS = Oral absorption factor (unit less)
BW = Body weight (kg)
AT = Averaging time (days)
Exposure parameters were selected by age group for residential exposure scenarios due to differences
in intake and activity patterns between children, adolescents, and adults. Therefore, separate exposure
parameters were chosen for the following age groups as applicable to each exposure pathway: children
(1-6 years), adolescents (7-18 years), and adults (>18 years). Additionally, separate exposure parameters
were developed for infants (< 2 years) for the consumption of breast milk scenario. Exposure parameters
were also developed for nonresident Airbase personnel (>18 years). All exposure parameters were
consistent across all time periods (baseline conditions) where scenarios were applicable based on the
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time period-specific site conceptual models (SCMs). Exposure parameters were also the same for all
COCs, with the exception of chemical specific absorption factors.
Exposure parameters were selected or calculated using Vietnamese population-specific sources where
available. Where Vietnamese population-specific parameters were not available, exposure parameters
were selected using the USEPA’s Office of Solid Waste and Emergency Response (OSWER)
recommended default exposure factors for superfund site human health risk assessments or the USEPA
Exposure Factor’s Handbook.
Body weights representative of the Vietnamese population were determined for each age group using
the Lien et al. 1998 study which presented the average weight of Vietnamese males and females in several
age groups. The body weight of infants (< 2 years) was estimated by averaging the body weight of males
and females in the newborn and one-year old age groups (Lien 1998). Similarly, the body weights for
children, adolescents, and adults were calculated by averaging the male and female body weights for the
5-year, 10-year, and 20- to 50- year age groups, respectively (Lien 1998). Body weight values can be
found in Appendix A, Table A-9.
Skin surface areas (SAs) potentially in contact with contaminated soil or sediment for residential and
nonresident exposure scenarios were calculated using Vietnamese population-specific body weights
(BW), discussed above, USEPA defaults, and an equation expressing the relationship between body
weight and skin surface area presented in Burmaster (1998). Per the OSWER recommended default
exposure factors, resident SAs potentially in contact with soil for children is calculated as the weighted
average SA of the hands, head, forearms, lower legs, and feet while the weighted average SA of the
hands, head, forearm, and lower legs is used for adults. For worker scenarios, the skin SA potentially in
contact with soil is calculated as the weighted average SA of the hands, head, and forearms (USEPA
2014). The percentage of the total skin SA for each body part were obtained from the Exposure Factors
Handbook (EFH) Chapter 7: Dermal Exposure Factors (USEPA 2011). The percent of the total skin SA
for each body part was calculated as the average of the one to six year age groups for children, the
average of the six to 16 years age groups for adolescents, and the average of the male and female greater
than 21 years age group for adults. For each age group in the residential and nonresidential groups, the
overall percentage of the total SA potentially exposed to soil was calculated as the sum of the percentage
for each applicable body part (%SA).
The body weight adjusted skin SA was calculated using the Vietnamese population-specific BWs for each
age group and the equation relating body weight and skin surface area presented in Burmaster (1998).
The resulting skin SA for each exposure group was then multiplied by the % SA potentially in contact
with soil or sediment to obtain a SA specific to the Vietnamese populations for each exposure group.
Local residents and resident Airbase personnel were assumed to bath or shower using groundwater as
a drinking water source or swim in the nearby surface water bodies so the total skin surface area
calculated using the Burmaster (1998) equation was used. The calculated skin contact areas for each
exposure group can be found in Appendix A, Table A-9.
Local diet ingestion rates were determined using the Tuyet-Hanh et al. (2015) study which presented
daily consumption rates of meat, seafood, eggs, vegetables, and rice for adults in the Southeastern region
of Vietnam. Specifically, daily consumption rates were provided for free ranged chicken, free ranged
chicken eggs, freshwater fish, leafy vegetables, freshwater snail, and mixed rice which were selected for
their respective local diet consumption exposure scenarios for adults. For food groups where
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consumption rates were unavailable, conservative surrogate ingestion rates were used. The consumption
rate of free ranged chicken was used for the consumption of chicken and duck scenarios. The
consumption rate of free ranged chicken eggs was used for both the consumption of chicken eggs and
duck eggs scenarios. All adult ingestion rates were normalized by body weight for the children and
adolescent exposure groups using the Vietnamese population-specific body weights discussed above.
The selected consumption rates for each scenario can be seen in Appendix A, Table A-9.
Exposure duration was set for each residential age group such that the total residential exposure
duration summed to 26 years, per the recommended OSWER default exposure factors (USEPA 2014).
Therefore, the exposure duration was set to 5 years for children, 11 years for adolescents, and ten years
for adults for Airbase residents. The exposure duration for nonresident Airbase personnel was set to
25 years based on the OSWER default exposure duration for workers (USEPA 2014).
Exposure time for contact with groundwater while bathing or showering were set to the USEPA
(2011) default value of 17 minutes per day or 0.28 hrs/day for all age groups. Exposure times for contact
with surface water were set to the same values as those used in the evaluation of the Danang EVSA
(USAID 2016), which were two hours/day for the child and adolescent age groups and one hour/day for
the adult age group.
Exposure frequency was set to the OSWER default 350 days/year for all residential direct contact
exposure pathways and age groups except for local diet ingestion scenarios, where the exposure
frequency was set to 365 days/year due to annualized ingestion of local diet items (USEPA 2014). For
nonresident Airbase personnel, the default worker exposure frequency of 250 days/year was used.
Averaging time for each exposure scenario was selected depending on the endpoint (cancer or
noncancer) being evaluated. For noncancer endpoints, the averaging time was set equal to the exposure
duration and converted to the appropriate units of either days or hours. For cancer endpoints, the
averaging time was set to a lifetime of 70 years (USEPA 2014).
Soil adherence factors (SAFs) were selected from the OSWER default value for resident children
and applied to the Airbase resident children and adolescent scenarios. The default OSWER SAFs for
adult residents and workers were selected for the Airbase resident adult and nonresident Airbase
personnel scenarios, respectively (USEPA 2014).
Soil, sediment, groundwater, and surface water ingestion rates were selected from the
OSWER default values for resident drinking water ingestion and resident and outdoor worker soil
ingestion and applied to the groundwater ingestion and soil and sediment ingestion scenarios,
respectively. The OSWER resident adult drinking water ingestion rate default was selected for both the
adult Airbase resident and nonresident Airbase personnel groups. OSWER soil ingestion rates were also
conservatively applied to the sediment ingestion scenarios in addition to the soil ingestion scenarios.
The OSWER default resident child soil ingestion rate and drinking water ingestion rate was selected for
the Airbase resident child group for the soil and sediment ingestion and groundwater ingestion scenarios.
Adult resident drinking water and adult resident soil ingestion rates were selected for the adolescent
Airbase resident age group for the groundwater ingestion and soil and sediment ingestion scenarios,
respectively (USEPA 2014).
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5.4.3.3 OTHER EXPOSURE PARAMETERS
Other exposure parameters include breastmilk ingestion rate, absorption factors, and dermal
permeability constants.
The breastmilk ingestion rate selected for the consumption of breastmilk scenario was calculated
by averaging the breastmilk intake rate for all age groups between birth and 12 months of age in the
USEPA Exposure Factors Handbook Chapter 15 (USEPA 2011). The selected breastmilk ingestion rate
likely is an over prediction of the average breastmilk ingestion rate between the birth and two years of
age.
The chemical-specific oral and inhalation absorption factors for all the COPCs were
conservatively set equal to values of 1.0. Chemical-specific dermal absorption factors were selected
from USEPA Risk Assessment Guidance for Superfund Part E, Supplemental Guidance for Dermal Risk
Assessment (USEPA 2004). Dermal absorption factors of 0.03, 0.03, and 0.14 were selected for
PCDD/Fs, arsenic, and PCB 1260, respectively based on the USEPA recommended absorption factors
for 2,3,7,8-TCDD, arsenic, and Aroclors 1254/1242 and other PCBs (USEPA 2004).
The chemical-specific dermal permeability constants for arsenic and PCDD/Fs were set equal to
0.001 and 0.81 cm/hr, respectively. These chemical-specific values were selected from USEPA Risk
Assessment Guidance for Superfund Part E, Supplemental Guidance for Dermal Risk Assessment (USEPA
2004).
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6 RISK CHARACTERIZATION
The risk characterization provides a quantitative evaluation and qualitative discussion of the risks and
hazards posed by the COPCs in each environmental medium for each scenario. Both non-carcinogenic
and carcinogenic health effects are addressed. Non-carcinogenic health effects are characterized by
comparing estimated doses to the maximum acceptable doses, and carcinogenic health risks are
characterized with respect to cancer risks that typically trigger regulatory concern.
For ingestion and dermal contact exposures, the hazard quotient (HQ) is the ratio of the estimated
average daily dose (ADD) for a specific chemical to the maximally acceptable safe dose for that chemical
(i.e., the USEPA reference dose, or RfD).
For ingestion and dermal contact exposures, the hazard quotient is calculated as follows:
𝑨𝑨𝑨𝑨𝑨𝑨
𝑯𝑯𝑯𝑯 =
𝑹𝑹𝑹𝑹𝑹𝑹
Where:
ADD = Average daily dose (mg/kg-day)
RfD = Reference dose (mg/kg-day)
For inhalation exposures, the non-carcinogenic HQs are characterized as the ratio of the calculated
exposure concentration (ECnc) to the maximally acceptable concentration (i.e., the USEPA’s reference
concentration, or RfC).
𝑬𝑬𝑬𝑬𝒏𝒏𝒏𝒏
𝑯𝑯𝑯𝑯 =
𝑹𝑹𝑹𝑹𝑹𝑹
Where:
Because different chemicals may cause similar adverse health effects, it is appropriate to combine HQs
associated with different substances. This will be done through a Hazard Index (HI) approach. The HI is
the sum of HQs for substances that affect the same target organ or organ system (e.g., lung, kidney,
liver, etc.) or result in the same health endpoint (e.g., respiratory irritant). This will be calculated for
each target organ or organ system as follows:
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Information regarding the target organ effects of chemicals has been summarized in Section 4 of this
BRA. For each critical effect category, a total HI considering all exposure pathways will be determined
for each receptor. An HI of 1.0 or less will not likely result in adverse non-cancer health effects over a
lifetime of exposure. Chemicals with HIs of 1.0 or greater will be identified as chemicals of concern.
𝑨𝑨𝑨𝑨𝑨𝑨
𝑯𝑯𝑯𝑯 =
𝑻𝑻𝑻𝑻𝑻𝑻
Where:
ADD = Average daily dose (pg/kg-day)
TDI = Tolerable Daily Intake (pg/kg/day)
Hazard quotients representing single exposure routes are summed to express a hazard index for each
receptor. Similar to the noncancer hazard, if the cancer hazard for dioxin is greater than 1.0 it will be
identified as a chemical of concern.
For ingestion and dermal exposures, the increased lifetime cancer risk (ILCR) is based on the
lifetime average daily dose (LADD) and will be calculated as follows:
Where:
LADD = Lifetime average daily dose (mg/kg-day)
SF = Cancer slope factor (mg/kg-day)-1
For inhalation exposures, the increased lifetime cancer risks are calculated as follows:
Where:
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For each receptor, the risks due to exposure to carcinogens will be summed across each chemical and
pathway, regardless of the carcinogenic mode of action. For the residential receptor, risks for children
and adult risks will be summed to calculate lifetime exposures. Chemicals having a cancer risk less than
1 x 10-6 are considered not to be of concern while cancer risks above 1 x 10-4 are considered
unacceptable. For this Project, given the small to moderate number of potentially affected people, a
cancer risk threshold of
1 x 10-5 was chosen.
6.2.1 SOIL
6.2.1.1 PCDD/FS
6.2.1.1.1 LOCAL AND AIRBASE RESIDENTS
Noncancer hazard indices for local residents and Airbase residents’ exposure to soil under baseline
conditions are presented in Appendix, Table A-10 and demonstrate that all Areas with available data
had HIs greater than one. The overall Area HIs ranged from 1.3 in the Southeast Area and 6.2 in the
Northern Forest Area to 184 in the Southwest Area and 57 in the Pacer Ivy Area. All values reported
reflect HIs for children; all child receptor HIs exceeded those for adult receptors. Below is a summary
of the child HIs for those DUs within each area that were listed as having an Urban Residential or Forest
Land Use in Table 2-1:
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• SW Area: 0.3 (SW-04) – 134 (SW-01);
• PI Area: 0.1 (PI-07) – 57 (PI-02);
• NF Area: 0.1 (NF-03) – 2.0 (NF-04);
• NE Area: 0.1 (NE-01) – 6.3 (NE-02); and
• SE Area: 0.2 (SE-01) – 0.4 (SE-02).
Increased lifetime cancer risk for local residents’ and Airbase residents’ exposure to soil in all Areas and
DU is presented in Appendix A, Table A-10. All Areas and DUs yielded ILCRs greater than 1x10-6; two
Areas had ILCRs within the risk range of 1x10-6 to 1x10-4. The overall Area ILCRs ranged from 2x10-5
in the Southeast Area to 2x10-3 in the Southwest Area. Each Area included at least two DUs with ILCRs
within the risk range; the list below reflects the range of DU ILCRs within each Area whose land use is
listed in Table 2-1 as either Urban Residential or Forest Land.
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• ZI Area: 0.05 (ZI-12) – 5.6 (ZI-03);
• ZT Area: 0.007 (ZT-05) – 2.0 (ZT-02);
• SW Area: 0.03 (SW-04) – 14 (SW-01);
• PI Area: 0.01 (PI-07) – 6.0 (PI-02);
• NF Area: 0.01 (NF-03) – 0.2 (NF-04);
• NE Area: 0.007 (NE-01) – 0.7 (NE-02); and
• SE Area: 0.02 (SE-01) – 0.04 (SE-02).
Increased lifetime cancer risk for nonresident Airbase personnel exposure to soil in all Areas and DUs
under baseline conditions is presented in Appendix A, Table A-11. All Areas yielded ILCRs greater than
1x10-6; four Areas yielded ILCRs within the risk range of 1x10-6 to 1x10-4. The overall Area ILCRs ranged
from 5x10-6 in the Southeast Area to 6x10-4 in the Southwest Area. Each Area contained at least two
DU which had ILCRs within the risk threshold; the list below reflects the range of DU ILCRs within
each Area whose land use listed in Table 2-1 is Industrial.
ILCRs for local residents and Airbase residents’ exposure to soil under baseline conditions are presented
in Appendix A, Table A-12 and demonstrate that all Areas with available data yielded total, Arsenic-
specific, and Aroclor 1260-specific ILCRs greater than 1x10-6; five Areas had total and arsenic-specific
ILCRs within the risk range of 1x10-6 to 1x10-4. The Area total ILCRs ranged from 2x10-5 in the site
background to
1x10 in the Pacer Ivy Area. Arsenic-specific ILCRs ranged from 2x10 in the site background to 1x10-
-4 -5
4 in the Pacer Ivy Area, which also had an Aroclor 1260 ILCR of 4x10-6. If the site background ILCR for
arsenic is subtracted from the ILCRs for the other site areas, the ILCR for the ZT area is below
background and the ILCRs for the other areas range from 1x10-5 (Northeast Area) to 8x10-5 (Pacer Ivy
Area).
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6.2.1.2.2 NONRESIDENT AIRBASE PERSONNEL
Total noncancer HIs for nonresident Airbase personnel exposure to soil in all Areas with available data
under baseline conditions are presented in Appendix A, Table A-13. All Areas yielded total, arsenic-
specific, and Aroclor 1260-specific HIs below the threshold of one. Total HIs ranged from 0.03 in the
site background and 0.02 in the ZT Area to 0.3 in the Pacer Ivy Area. Arsenic-specific HIs ranged from
0.03 in the site background and 0.02 in the ZT Area to 0.2 in the Pacer Ivy Area; only one HI (0.1)
associated with Aroclor 1260 was calculated with available data for the Pacer Ivy Area. All values
reported were for adult receptors.
Total noncancer ILCRs for nonresident Airbase personnel exposure to soil in all Areas with available
data under baseline conditions are presented in Appendix A, Table A-13. All Areas yielded total and
arsenic-specific ILCRs within the risk range of 1x10-6 to 1x10-4; the PI Area yielded an Aroclor 1260-
specific ILCR of 1x10-6.
6.2.2 SEDIMENT
6.2.2.1 PCDD/FS
6.2.2.1.1 LOCAL AND AIRBASE RESIDENTS
Noncancer hazard indices for local residents and Airbase residents’ exposure to sediment under baseline
conditions are presented in Appendix A, Table A-14 and demonstrate that all Areas with available data
had HIs greater than one. The overall Area HIs ranged from 1.7 and 3.4 outside the Airbase to 44 in the
Pacer Ivy Area. Two Areas contained DUs with HIs below one; all other DUs reflected HIs above one.
The list below reflects the range of DU HIs within each Area. All values reported reflect HIs for children;
all child receptor HIs exceeded those for adult receptors.
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from 2x10-5 outside the Airbase to 6x10-4 in the Pacer Ivy Area. The ranges of DU ILCRs within each
Area are presented below.
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• NW Area: 5x10-6 (NW-02) – 3x10-5 (NW-04);
• NE Area: 2x10-6 (NE-10) – 9x10-5 (NE-07); and
• Outside Airbase: 6x10-6 (BHL-01) – 1x10-5 (G2L-01).
Increased lifetime cancer risks for local residents and Airbase residents’ exposure to arsenic and Aroclor
1260 in sediment under baseline conditions are presented in Appendix A, Table A-16 and demonstrate
that all Areas with available data yielded total and Arsenic-specific ILCRs within the risk range of 1x10-6
to 1x10-4. The Area total and arsenic-specific ILCRs ranged from 3x10-6 in the Northwest Area to 6x10-
5 in the Pacer Ivy Area. Only one ILCR (3x10-7) associated with Aroclor 1260 was calculated with
Increased lifetime cancer risks for nonresident Airbase personnel exposure to arsenic and Aroclor 1260
in sediment in all Areas with available data under baseline conditions are presented in Appendix A, Table
A-17. One Area had a total and arsenic-specific ILCR below the risk range or 1x10-6 to 1x10-4; all
remaining Areas yielded total and arsenic-specific ILCRs within the risk range. The Area total and
arsenic-specific ILCRs ranged from 8x10-7 in the Northwest Area to 2x10-5 in the Pacer Ivy Area. Only
one ILCR (7x10-8) associated with Aroclor 1260 was calculated with available data for the Pacer Ivy
Area.
6.2.3 GROUNDWATER
6.2.3.1 PCDD/FS
Noncancer hazard indices for local residents and Airbase residents’ exposure to groundwater under
baseline conditions are presented in Appendix A, Table A-18 and demonstrate that among Areas with
available data, two Areas yielded HIs greater than one. The overall Area HIs ranged from 0.1 in the ZI
and ZT Areas to 1.6 in the Pacer Ivy Area. All values reported reflect HIs for children; all child receptor
HIs exceeded those for adult receptors.
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Cancer hazard indices for local residents’ and Airbase residents’ exposure to groundwater in all Areas
with available data are presented in Appendix A, Table A-18 and demonstrate that all Areas with available
data yielded HIs below the threshold of one. The overall Area HIs ranged from 0.02 in the ZI and ZT
Areas to 0.5 in the Pacer Ivy Area. All values reported reflect HIs for child receptors.
Increased lifetime cancer risk for local residents’ and Airbase residents’ exposure to groundwater in all
Areas for which data were available under baseline conditions is presented in Appendix A, Table A-18.
All Areas yielded ILCRs between the risk range of 1x10-6 to 1x10-4. The Area ILCRs ranged from 3x10-
6 in the ZI and ZT Area to 8x10-5 in the Pacer Ivy Area.
While the maximum lead concentration in groundwater of 64.8 ug/L exceeds the USEPA MCL, this
concentration is still below the QVCN discharge criterion for lead of 100 ug/L from QVCN
40:2011/BTMNT National Technical Regulation on Industrial Wastewater (GVN/USAID 2016). In
addition, this groundwater concentration is based on an unfiltered sample and may not represent actual
potential drinking water exposures to lead. Based on both of these factors, the noncancer hazard
associated with lead in the groundwater is considered to be minimal.
Increased lifetime cancer risk for local residents’ and Airbase residents’ exposure to arsenic in
groundwater in all Areas for which data were available under baseline conditions is presented in
Appendix A, Table A-19. All Areas yielded ILCRs greater than the risk range of 1x10-6 to 1x10-6 except
for the ZT Area. Area ILCRs ranged from 1x10-5 for the ZT Area to 2x10-4 for all other Areas.
6.2.4 DIET
6.2.4.1 PCDD/FS
Noncancer hazard indices, cancer indices, and cancer risks were evaluated for only PCDD/Fs, as no
other COPC data were available from biota testing or in the peer-reviewed literature. Dietary sources
were evaluated only for local and Airbase residents. Data were evaluated site-wide, as available data
were not granular enough to establish dietary and consumption habits specific to the Areas or DU.
Sitewide noncancer hazard indices for exposure of local residents and resident Airbase personnel to
dietary items including chicken and chicken eggs, duck and duck eggs, fish, snails, vegetables, and rice are
presented in Appendix A, Table A-20. Infant ingestions to breast milk was also evaluated. The noncancer
hazard indices were above the threshold of one for all dietary sources except rice. The total dietary
noncancer HI, representing all dietary sources except breastmilk was 246; HIs ranged from 0.4 for rice
to 123 for fish. Infant ingestion of breastmilk yielded an HI of 75. All values reported reflect HIs for child
receptors.
Sitewide cancer hazard indices for exposure of local residents and resident Airbase personnel to dietary
items and breast milk are presented in Appendix A, Table A-20. The cancer hazard indices were above
the threshold of one for all dietary sources except rice. The total dietary cancer HI, representing all
dietary sources except breastmilk was 75; HIs ranged from 0.1 for rice to 37 for fish. Infant ingestion of
breastmilk yielded an HI of 23. All values reported reflect HIs for child receptors.
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Sitewide increased lifetime cancer risk for exposure of local residents and resident Airbase personnel
to dietary items and breast milk is presented in Appendix A, Table A-20. The ILCRs were greater than
the risk range of 1x10-6 to 1x10-4 for all dietary sources except rice. The total dietary ILCR, representing
all dietary sources except breastmilk was 8x10-3; ILCRs ranged from 1x10-5 for rice to 4x10-3 for fish.
Infant ingestion of breastmilk yielded an ILCR of 2x10-4.
Noncancer HIs for the local residents and the resident Airbase personnel are presented in Table 6-1.
The contributions of noncancer hazard for soils and sediment were weighted according to the area of
each Area and summed, and PCDD/Fs and COPC totals were summed to generate a sitewide total for
exposures. No scaling factors were applied to groundwater hazards by area; the contributions of
noncancer hazard in each Area were averaged and summed to generate a sitewide total for exposures
due to groundwater. All dietary items, including breastmilk, were summed to generate a sitewide total
for exposures due to diet. Sitewide, the noncancer hazard associated with PCDD/Fs (HI=312) is much
higher than that associated with the other COPCs (HI=2.0). In addition, sitewide, soil (HI=49) and diet
(HI=246) have the highest contributions to the overall HI (314). Relative to soil and diet, sediment
exposures contribute much less to the overall exposures at the site while groundwater exposures have
HIs that are below one, which are below the level of concern. None of the areas have an overall HI less
than one.
Cancer hazards for the local residents and the resident Airbase personnel are presented in Table 6-2.
The contributions of cancer hazard were weighted according to the area of each Area and summed to
generate a sitewide total for exposures. Sitewide, soil (HI=15) and diet (HI=75) contribute the most to
the overall cancer hazard (95) compared to sediment (5.6) and groundwater (0.2). Two areas have
overall cancer hazards below one, Southeast Area (0.4) and Bien Hung Lake (0.6).
Increased lifetime cancer risks (ILCRs) for the local residents and resident Airbase personnel are
presented in Table 6-3. The contributions of cancer risk were weighted according to the area of each
Area and summed, and PCDD/Fs and COPC totals were summed to generate a sitewide total for
exposures. Similar to noncancer hazard, the ILCR for PCDD/Fs (9x10-3) are much higher than those for
the other COPCs (2x10-4). Sitewide, the contributions of soil (7x10-4) and diet (8x10-3) dominate the
overall ILCR (9x10-3). Relative to soil and diet, the contribution of sediment (3x10-4) and groundwater
(2x10-4) contribute less to the overall ILCR. Only four of the areas have overall ILCRs within the
acceptable risk range of 10-6 to 10-4, Northern Forest Area, Southeast Area, Bien Hung Lake, and Gate
2 Lake.
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TABLE 6-1 NONCANCER HAZARD INDEX SUMMARY FOR LOCAL RESIDENTS AND RESIDENT AIRBASE PERSONNEL AND THEIR FAMILIES
TABLE 6-2 CANCER HAZARD INDEX SUMMARY FOR LOCAL RESIDENTS AND RESIDENT AIRBASE PERSONNEL AND THEIR FAMILIES
PCDD/FSA
SITE AREA
SOIL SEDIMENT GROUNDWATER DIET TOTAL
Z1 Area 8.7 9.2 2E-02 NA 18
ZT Area 14 NA 2E-02 NA 14
Southwest Area 56 NA 0.4 NA 56
Pacer Ivy Area 17 13 0.5 NA 31
Northwest Area 1.9 2.3 NA NA 4.2
Northern Forest Area 6.2 NA NA NA 6.2
Northeast Area 6.2 3.0 NA NA 9.2
Southeast Area 0.4 NA NA NA 0.4
Bien Hung Lake NA 0.5 NA NA 0.5
Gate 2 Lake NA 1.0 NA NA 1.0
SITEWIDE 15 5.6 0.2 75 95
a Bolded values indicate a hazard index above the threshold of one
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TABLE 6-3 INCREASED LIFETIME CANCER RISK SUMMARY FOR LOCAL RESIDENTS AND RESIDENT AIRBASE PERSONNEL AND THEIR FAMILIES
Z1 Area 4E-04 4E-04 3E-06 NA 8E-04 9E-05 5E-05 2E-04 3E-04 1E-03
ZT Area 6E-04 NA 3E-06 NA 6E-04 1E-05 NA 1E-05 3E-05 6E-04
Southwest Area 2E-03 NA 6E-05 NA 3E-03 8E-05 NA 2E-04 3E-04 3E-03
Pacer Ivy Area 8E-04 6E-04 8E-05 NA 1E-03 1E-04 6E-05 2E-04 4E-04 2E-03
Northwest Area NA 1E-04 NA NA 1E-04 NA 3E-06 NA 3E-06 1E-04
Northern Forest Area 8E-05 NA NA NA 8E-05 NA NA NA NA 8E-05
Northeast Area 3E-04 1E-04 NA NA 4E-04 3E-05 NA NA 3E-05 4E-04
Southeast Area 2E-05 NA NA NA 2E-05 NA NA NA NA 2E-05
Bien Hung Lake NA 2E-05 NA NA 2E-05 NA 3E-05 NA 3E-05 6E-05
Gate 2 Lake NA 5E-05 NA NA 5E-05 NA 2E-05 NA 2E-05 6E-05
SITEWIDE 6E-04 2E-04 4E-05 8E-03 B 9E-03 6E-05 2E-05 2E-04 2E-04 9E-03
a Bolded values indicate an increased lifetime cancer risk above 1 x 10-4; bolded italicized values indicate an increased lifetime cancer risk above 1 x 10-5
b Diet ILCR has been calculated separately
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6.2.5.2 NONRESIDENT AIRBASE PERSONNEL
Noncancer HIs for the nonresident Airbase personnel are presented in Table 6-4. The contributions of
noncancer hazard for soils and sediment were weighted according to the area of each Area and summed,
and PCDD/Fs and COPC totals were summed to generate a sitewide total for exposures. Similar to the
residential populations, the sitewide HI for PCDD/Fs (7) is much higher than the sitewide HI for the
other COPCs (0.2). Also, soil exposures (HI=5.1) contribute more to the overall noncancer hazard
compared to sediment exposures (HI=2.2). Three of the site areas have overall HIs less than one:
Northwest Area, Northern Forest Area, and Southeast Area.
Cancer hazards for the nonresident Airbase personnel are presented in Table 6-5. The contributions of
cancer hazard were weighted according to the area of each Area and summed to generate a sitewide
total for exposures. Sitewide, soil (HI=1.5) contributes more to the overall cancer hazard than sediment
(HI=0.6) for the nonresident Airbase personnel. Six areas have overall cancer hazards less than one,
Northwest Area, Northern Forest Area, Northeast Area, Southeast Area, Bien Hung Lake, and Gate 2
Lake.
ILCRs for the nonresident Airbase personnel are presented in Table 6-6. The contributions of cancer
risk were weighted according to the area of each Area and summed, and PCDD/Fs and COPC totals
were summed to generate a sitewide total for exposures. Similar to the residential scenario, PCDD/Fs
(2x10-4) have a higher ILCR than the other COPCs (2x10-5). In addition, sitewide, soil exposures (2x10-
4) contribute more to the total ILCR than sediment (7x10-5). Five areas have overall ILCRs within the
acceptable risk range, Northwest Area, Northern Forest Area, Southeast Area, Bien Hung Lake, and
Gate 2 Lake.
TABLE 6-4 NONCANCER HAZARD INDEX SUMMARY FOR NONRESIDENT AIRBASE PERSONNNEL
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TABLE 6-5 CANCER HAZARD INDEX SUMMARY FOR NONRESIDENT AIRBASE PERSONNEL
PCDD/FSA
SITE AREA
SOIL SEDIMENT TOTAL
Z1 Area 0.9 1.0 1.9
ZT Area 1.5 NA 1.5
Southwest Area 6.0 NA 6.0
Pacer Ivy Area 2 1.5 3
Northwest Area NA 0.2 0.2
Northern Forest Area 0.2 NA 0.2
Northeast Area 0.7 0.3 1.0
Southeast Area 4E-02 NA 4E-02
Bien Hung Lake NA 0.1 0.1
Gate 2 Lake NA 0.1 0.1
SITEWIDE 1.5 0.6 2.1
a Bolded values indicate a hazard index above the threshold of one
TABLE 6-6 INCREASED LIFETIME CANCER RISK SUMMARY FOR NONRESIDENT AIRBASE PERSONNEL
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6.3 UNCERTAINTY ANALYSIS
According to USEPA (1989) guidance, risk characterization should also present information important
to interpreting risks in order to place the risk estimates in proper perspective. There are numerous
areas of uncertainty in any risk assessment, and assumptions made in the absence of information are
often intentionally conservative and, therefore, tend to drive results toward overestimates of risk.
Uncertainties exist in each step, including the data collection and analysis, the estimation of potential
site exposures, and toxicity assessment.
• Most of the data used for the COPC screening included both more recent sampling data from 2016
as well as historical sampling data from previous reports. The use of multiple data sets can result in
significant variability in the environmental media concentrations used in the risk assessment.
• All of the environmental data used in the risk assessment are from multiple sources and there may
be differences in sampling and analysis methods that may affect the comparability of the data used.
• The concentration data for dietary items other than fish and snails were from a paper in the peer-
reviewed literature rather than a report prepared a contractor working at the site. Because of the
lack of detail available in the paper, there is some uncertainty with respect to sampling and analysis
methods for these data.
• Because there are no Tier 1 or Tier 2 toxicity criteria for carcinogenic effects for the PCDD/Fs,
there is uncertainty associated with the use of either a threshold or non-threshold toxicity criterion
for PCDD/Fs. To account for this uncertainty, both types of criteria were used to evaluate
carcinogenic effects.
• There is uncertainty associated with derivation of the WHO 2005 toxic equivalence factors (TEFs)
used to account for differences in the toxic effects of the various 2,3,7,8 PCDD/F congeners relative
to TCDD. However, for the PCDD/F congeners these TEFs were conservatively calculated based
on the upper bound assumptions regarding relative toxicity for each of the congeners with respect
to TCDD.
• For most of the DUs, the low sample sizes resulted in the use of the maximum concentration in
soil, sediment, or groundwater as the exposure point concentration for the baseline conditions
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scenario. This is conservative and may cause a general overestimation in the results of the risk
assessment.
• The contact rates (soil and sediment ingestion rates, soil and sediment adherence rates, and
tapwater ingestion rates) used to estimate hazards and risks for the local residents, resident Airbase
personnel and their families, and nonresident Airbase personnel are based on a mix of USEPA default
values and local Vietnamese values. Ideally there would have been available information for all
parameters to be based on local Vietnamese values.
• The exposure durations, exposure times, and exposure frequencies used to estimate the hazards
and risks for the local residents, resident Airbase personnel and their families, and nonresident
Airbase personnel are all based on a mix of USEPA default values and local Vietnamese values. Ideally
there would have been available information for all parameters to be based on local Vietnamese
values..
• While the noncancer HIs were greater than one for many of the DUs, target specific HIs were not
estimated and compared to the standard of one. This should not result in any significant effect on
the results of the risk assessment because of the major difference in the noncancer hazard for the
PCDD/Fs and the other COPCs.
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7 CONCLUSIONS
The main conclusions of the baseline risk assessment are as follows:
• Under baseline conditions, there are a number of DUs with noncancer and cancer hazards greater
than one and increased lifetime cancer risks greater than the acceptable Project risk value of 10-5 ,
with values that often exceeded 10-4, which indicates that remediation will be required for many of
these areas.
• Under baseline conditions, the noncancer hazards and cancer risks associated with PCDD/F
exposure are higher than those associated with exposure to the other COPCs.
• Under baseline conditions, soil and diet exposures are the predominant contributors to the overall
noncancer hazard, cancer hazard, and cancer risk for all areas and DUs at this site.
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Van den Berg, M., L. S. Birnbaum, M. Denison, M. De Vito, W. Farland, M. Feeley, H. Fiedler, H. Hakansson,
A. Hanberg, L. Haws, M. Rose, S. Safe, D. Schrenk, C. Tohyama, A. Tritscher, J. Tuomisto, M. Tysklind, N.
Walker and R. E. Peterson (2006). "The 2005 World Health Organization reevaluation of human and
Mammalian toxic equivalency factors for dioxins and dioxin-like compounds." Toxicol Sci 93(2): 223-241.
A–E SERVICES FOR DIOXIN REMEDIATION AT BIEN HOA AIRBASE AREA PROJECT | 55
FINAL TECHNICAL MEMORANDUM BASELINE RISK ASSESSMENT
VEA and MONRE (2012). A preliminary report on additional assessment on dioxin contamination at
new AO/Dioxin contaminated areas in Bien Hoa and Phu Cat Airbase.
VRTC (2013). Analysis Results Identifying the concentration of toxic substance of PCDD/PCDF and dl- PCB
in samples (Annex 1 contract HĐ-BQLDA/2012/30).
Wasserman, G. A., X. Liu, F. Parvez, H. Ahsan, P. Factor-Litvak, A. van Geen, V. Slavkovich, N. J. LoIacono,
Z. Cheng, I. Hussain, H. Momotaj and J. H. Graziano (2004). "Water arsenic exposure and children's
intellectual function in Araihazar, Bangladesh." Environ Health Perspect 112(13): 1329-1333.
Young, A. L. (2009). The History, Use, Disposition and Environmental Fate of Agent Orange, Springer
Science & Business Media.
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FINAL TECHNICAL MEMORANDUM BASELINE RISK ASSESSMENT
APPENDIX A
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TABLE A-1 SUMMARY OF DIOXIN/FURAN DATA SETS USED
Southwest Area 8 HR-GCMS Soil and sediment samples were collected in November of
2010 from the Pacer Ivy Area , the Southwest Corner of
Z1 Area 14 HR-GCMS the Airbase, the Z1 Area , and the northeastern , and
northern perimeters of the Airbase (Hatfield and Office 33
Northeastern Area 8 HR-GCMS 2011). Each soil sample consisted of a composite of 10-
subsamples collected at evenly-spaced sampling points
Northern Area 4 HR-GCMS within a 5x5 m square plot with a stainless steel soil corer,
Hatfield and Office 33 (2011)
spade, and/or chisel. Soil samples were collected at a depth
Sediment Pacer Ivy Area 7 HR-GCMS of 0-10 cm, with the exception of four soil depth profiles
conducted to a depth of 180 cm in pit excavations. Six soil
Z1 Area 3 HR-GCMS samples were collected from each pit at intervals of 0-30
cm, 30-60cm, 60-90cm, 90-120cm, 120-150cm, and 150-
Northeastern Area 3 HR-GCMS 180 (Hatfield and Office 33 2011).
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ENVIRONMENTAL NUMBER ANALYSIS
REPORT SITE AREA SAMPLING SUMMARY
MEDIA OF SAMPLES METHOD
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ENVIRONMENTAL NUMBER ANALYSIS
REPORT SITE AREA SAMPLING SUMMARY
MEDIA OF SAMPLES METHOD
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ENVIRONMENTAL NUMBER ANALYSIS
REPORT SITE AREA SAMPLING SUMMARY
MEDIA OF SAMPLES METHOD
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TABLE A-2 PCDD/F SURFACE SOIL EXPOSURE POINT CONCENTRATIONS BY DECISION UNIT IN PPT
ARITHMETIC CHEBYSHEV
95%
NUMBER 95% UPPER 95% UPPER PCDD/F EXPOSURE EXPOSURE POINT
STANDARD CONFIDENCE
DECISION UNIT MEAN OF MAXIMUM CONFIDENCE CONFIDENCE POINT CONCENTRATION
DEVIATION STUDENT T
SAMPLES LIMIT OF THE LIMIT OF THE CONCENTRATION TYPE
STATISTIC
MEAN MEAN
ZI AREA
Z1 Overall 564 1652 72 13300 1.7 889 1413 1413 Chebyshev
ZI-01 757 1066 2 1510 6.3 5514 4041 1510 Maximum
ZI-02 598 610 13 2090 1.8 900 1336 1336 Chebyshev
ZI-03 2944 5797 5 13300 2.1 8470 14244 8470 Arithmetic
ZI-04 94 88 6 259 2.0 166 250 250 Chebyshev
ZI-05 73 35 2 98 6.3 230 182 98 Maximum
ZI-06 259 261 9 757 1.9 421 639 639 Chebyshev
ZI-07 190 62 5 294 2.1 249 310 249 Arithmetic
ZI-08 59 53 4 107 2.4 122 176 107 Maximum
ZI-11 79 48 5 151 2.1 125 172 125 Arithmetic
ZI-12 7 NC 1 7.2 NC NC NC 7.2 Maximum
ZI-13 168 149 6 442 2.0 290 433 433 Chebyshev
ZI-16 844 1171 13 3210 1.8 1423 2260 2260 Chebyshev
ZI-17 14 NC 1 14 NC NC NC 13.6 Maximum
ZT AREA
ZT Overall 577.2 1125.9 9.0 3440.0 1.9 1275.1 2213.1 2213.1 Chebyshev
ZT-01 48.8 NC 1.0 48.8 NC NC NC 48.8 Maximum
ZT-02 1252.5 1511.5 4.0 3440.0 2.4 3031.1 4546.8 3031.1 Arithmetic
ZT-04 15.3 NC 1.0 15.3 NC NC NC 15.3 Maximum
ZT-05 10.5 NC 1.0 10.5 NC NC NC 10.5 Maximum
ZT-06 23.8 NC 1.0 23.8 NC NC NC 23.8 Maximum
ZT-07 86.4 NC 1.0 86.4 NC NC NC 86.4 Maximum
SOUTHWEST AREA
SW Overall 3182.8 6349.8 22.0 21800.0 1.7 5512.3 9083.8 9083.8 Chebyshev
SW-01 13485.0 9455.3 4.0 21800.0 2.4 24610.8 34092.3 21800.0 Maximum
SW-02 2681.3 3648.5 4.0 7880.0 2.4 6974.3 10632.9 6974.3 Arithmetic
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ARITHMETIC CHEBYSHEV
95%
NUMBER 95% UPPER 95% UPPER PCDD/F EXPOSURE EXPOSURE POINT
STANDARD CONFIDENCE
DECISION UNIT MEAN OF MAXIMUM CONFIDENCE CONFIDENCE POINT CONCENTRATION
DEVIATION STUDENT T
SAMPLES LIMIT OF THE LIMIT OF THE CONCENTRATION TYPE
STATISTIC
MEAN MEAN
SW-03 852.3 734.1 4.0 1880.0 2.4 1716.0 2452.2 1716.0 Arithmetic
SW-04 41.4 NC 1.0 41.4 NC NC NC 41.4 Maximum
SW-06 60.9 8.0 4.0 71.0 2.4 70.3 78.3 70.3 Arithmetic
SW-07 400.3 199.3 4.0 674.0 2.4 634.7 834.6 634.7 Arithmetic
SW-08 60.8 NC 1.0 60.8 NC NC NC 60.8 Maximum
PACER IVY AREA
PI Overall 1180.8 1919.2 26.0 9230.0 1.7 1823.7 2821.4 2821.4 Chebyshev
PI-01 183.5 NC 1.0 183.5 NC NC NC 183.5 Maximum
PI-02 9230.0 NC 1.0 9230.0 NC NC NC 9230.0 Maximum
PI-03 23.7 NC 1.0 23.7 NC NC NC 23.7 Maximum
PI-04 243.0 NC 1.0 243.0 NC NC NC 243.0 Maximum
PI-05 259.0 NC 1.0 259.0 NC NC NC 259.0 Maximum
PI-06 245.0 NC 1.0 245.0 NC NC NC 245.0 Maximum
PI-07 15.1 NC 1.0 15.1 NC NC NC 15.1 Maximum
PI-08 1753.3 1238.3 4.0 3040.0 2.4 3210.3 4452.1 3040.0 Maximum
PI-09 372.0 NC 1.0 372.0 NC NC NC 372.0 Maximum
PI-10 892.0 895.8 4.0 2220.0 2.4 1946.1 2844.4 2220.0 Maximum
PI-11 221.0 NC 1.0 221.0 NC NC NC 221.0 Maximum
PI-12 2167.5 656.6 4.0 2870.0 2.4 2940.1 3598.5 2870.0 Maximum
PI-13 152.1 151.4 4.0 299.0 2.4 330.2 482.0 299.0 Maximum
PI-14 48.1 NC 1.0 48.1 NC NC NC 48.1 Maximum
NORTHERN FOREST AREA
NF Overall 111.4 119.4 7.0 349.0 1.9 199.0 308.0 308.0 Chebyshev
NF-01 35.5 NC 1.0 35.5 NC NC NC 35.5 Maximum
NF-02 60.0 NC 1.0 60.0 NC NC NC 60.0 Maximum
NF-03 19.0 NC 1.0 19.0 NC NC NC 19.0 Maximum
NF-04 166.3 137.2 4.0 349.0 2.4 327.7 465.3 327.7 Arithmetic
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ARITHMETIC CHEBYSHEV
95%
NUMBER 95% UPPER 95% UPPER PCDD/F EXPOSURE EXPOSURE POINT
STANDARD CONFIDENCE
DECISION UNIT MEAN OF MAXIMUM CONFIDENCE CONFIDENCE POINT CONCENTRATION
DEVIATION STUDENT T
SAMPLES LIMIT OF THE LIMIT OF THE CONCENTRATION TYPE
STATISTIC
MEAN MEAN
NORTHEAST AREA
NE Overall 426.3 405.3 16.0 1040.0 1.8 603.9 867.9 867.9 Chebyshev
NE-01 10.6 NC 1.0 10.6 NC NC NC 10.6 Maximum
NE-02 834.3 218.4 4.0 1020.0 2.4 1091.2 1310.2 1020.0 Maximum
NE-03 34.7 NC 1.0 34.7 NC NC NC 34.7 Maximum
NE-04 550.8 214.8 4.0 706.0 2.4 803.5 1018.9 706.0 Maximum
NE-05 74.7 NC 1.0 74.7 NC NC NC 74.7 Maximum
SOUTHEAST AREA
SE Overall 50.7 19.5 2.0 64.5 NC NC NC 64.5 Maximum
SE-01 36.9 NC 1.0 36.9 NC NC NC 36.9 Maximum
SE-02 64.5 NC 1.0 64.5 NC NC NC 64.5 Maximum
NC: Not Calculated because the sample size is less than two
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TABLE A-3 PCDD/F ALL SOIL DEPTHS EXPOSURE POINT CONCENTRATIONS BY DECISION UNIT IN PPT
ARITHMETIC CHEBYSHEV
95%
NUMBER 95% UPPER 95% UPPER PCDD/F EXPOSURE EXPOSURE POINT
DECISION STANDARD CONFIDENCE
MEAN OF MAXIMUM CONFIDENCE CONFIDENCE POINT CONCENTRATION
UNIT DEVIATION STUDENT T
SAMPLES LIMIT OF THE LIMIT OF THE CONCENTRATION TYPE
STATISTIC
MEAN MEAN
ZI AREA
ZI-01 1510.0 0.0 2.0 1510.0 6.3 1510.0 1510.0 2238.0 Maximum
ZI-02 178.0 247.3 34.0 865.0 1.7 249.7 362.8 362.8 Chebyshev
ZI-03 80.3 157.3 16.0 512.1 1.8 149.2 251.7 251.7 Chebyshev
ZI-04 13.4 16.3 13.0 50.0 1.8 21.5 33.1 33.1 Chebyshev
ZI-05 21.2 23.7 3.0 48.2 2.9 61.1 80.8 48.2 Maximum
ZI-06 124.3 122.5 10.0 325.0 1.8 195.3 293.1 293.1 Chebyshev
ZI-07 152.9 132.9 13.0 438.0 1.8 218.6 313.6 313.6 Chebyshev
ZI-08 45.6 46.5 6.0 107.0 2.0 83.8 128.3 107.0 Maximum
ZI-11 68.4 50.6 6.0 151.0 2.0 110.0 158.5 110.0 Arithmetic
ZI-12 5.4 2.6 2.0 7.2 6.3 17.0 13.4 7.2 Maximum
ZI-13 59.2 39.7 6.0 103.2 2.0 91.8 129.8 91.8 Chebyshev
ZI-16 245.8 296.7 10.0 901.0 1.8 417.8 654.7 654.7 Chebyshev
ZI-17 4.2 4.6 7.0 13.6 1.9 7.6 11.8 11.8 Chebyshev
ZT AREA
ZT-01 40.4 25.5 5.0 64.7 2.1 64.8 90.2 64.7 Arithmetic
ZT-02 647.4 1094.8 9.0 3440.0 1.9 1326.0 2238.1 2238.1 Chebyshev
ZT-04 7.6 7.1 3.0 15.3 2.9 19.6 25.5 15.3 Maximum
ZT-05 4.6 5.2 3.0 10.5 2.9 13.3 17.5 10.5 Maximum
ZT-06 9.9 12.2 3.0 23.8 2.9 30.5 40.6 23.8 Maximum
ZT-07 34.3 38.7 5.0 86.4 2.1 71.2 109.8 71.2 Arithmetic
SOUTHWEST AREA
SW-01 15144.7 27421.7 17.0 111000.0 1.7 26756.1 44134.6 44134.6 Chebyshev
SW-02 1364.8 2569.7 9.0 7880.0 1.9 2957.7 5098.6 5098.6 Chebyshev
SW-03 619.5 650.0 12.0 1880.0 1.8 956.5 1437.4 1437.4 Chebyshev
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ARITHMETIC CHEBYSHEV
95%
NUMBER 95% UPPER 95% UPPER PCDD/F EXPOSURE EXPOSURE POINT
DECISION STANDARD CONFIDENCE
MEAN OF MAXIMUM CONFIDENCE CONFIDENCE POINT CONCENTRATION
UNIT DEVIATION STUDENT T
SAMPLES LIMIT OF THE LIMIT OF THE CONCENTRATION TYPE
STATISTIC
MEAN MEAN
SW-04 22.9 16.1 3.0 41.4 2.9 50.0 63.4 41.4 Maximum
SW-06 52.2 17.5 6.0 71.0 2.0 66.6 83.4 66.6 Arithmetic
SW-07 237.9 166.0 12.0 674.0 1.8 324.0 446.8 446.8 Chebyshev
SW-08 113.7 74.7 6.0 216.0 2.0 175.1 246.6 175.1 Arithmetic
PACER IVY AREA
PI-01 41.6 62.3 16.0 183.5 1.8 68.9 109.4 109.4 Chebyshev
PI-02 2711.7 3409.3 19.0 11400.0 1.7 4068.0 6120.9 6120.9 Chebyshev
PI-03 7.8 9.7 5.0 23.7 2.1 17.0 26.6 17.0 Arithmetic
PI-04 94.0 98.4 6.0 243.0 2.0 174.9 269.1 174.9 Arithmetic
PI-05 203.3 51.3 3.0 259.0 2.9 289.8 332.4 259.0 Maximum
PI-06 253.5 10.6 2.0 261.0 6.3 300.9 286.2 261.0 Maximum
PI-07 8.7 5.9 3.0 15.2 2.9 18.6 23.5 15.2 Maximum
PI-08 1274.1 1213.7 6.0 3040.0 2.0 2272.5 3433.9 2272.5 Arithmetic
PI-09 193.3 158.6 3.0 372.0 2.9 460.8 592.6 372.0 Maximum
PI-10 352.9 615.7 12.0 2220.0 1.8 672.1 1127.6 1127.6 Chebyshev
PI-11 96.7 107.7 3.0 221.0 2.9 278.2 367.7 221.0 Maximum
PI-12 1029.6 945.9 12.0 2870.0 1.8 1520.0 2219.9 2219.9 Chebyshev
PI-13 136.4 135.7 5.0 299.0 2.1 265.8 400.9 265.8 Arithmetic
PI-14 27.9 31.3 2.0 50.0 6.3 167.7 124.4 50.0 Maximum
NORTHERN FOREST AREA
NF-01 20.9 20.6 2.0 35.5 6.3 113.1 84.5 35.5 Maximum
NF-02 32.0 39.6 2.0 60.0 6.3 208.8 154.0 60.0 Maximum
NF-03 10.0 12.7 2.0 19.0 6.3 66.8 49.2 19.0 Maximum
NF-04 167.1 163.2 8.0 465.0 1.9 276.4 418.6 418.6 Chebyshev
NORTHEAST AREA
NE-01 7.2 4.8 2.0 10.6 6.3 28.7 22.0 10.6 Maximum
NE-02 680.3 393.3 5.0 1020.0 2.1 1055.2 1446.9 1020.0 Maximum
NE-03 27.8 10.0 2.0 34.8 6.3 72.3 58.5 34.8 Maximum
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ARITHMETIC CHEBYSHEV
95%
NUMBER 95% UPPER 95% UPPER PCDD/F EXPOSURE EXPOSURE POINT
DECISION STANDARD CONFIDENCE
MEAN OF MAXIMUM CONFIDENCE CONFIDENCE POINT CONCENTRATION
UNIT DEVIATION STUDENT T
SAMPLES LIMIT OF THE LIMIT OF THE CONCENTRATION TYPE
STATISTIC
MEAN MEAN
NE-04 511.6 205.6 5.0 706.0 2.1 707.6 912.4 706.0 Maximum
NE-05 57.8 23.9 2.0 74.7 6.3 164.5 131.5 74.7 Maximum
SOUTHEAST AREA
SE-01 35.7 1.7 2.0 36.9 6.3 43.3 40.9 36.9 Maximum
SE-02 48.2 23.1 2.0 64.5 6.3 151.4 119.4 64.5 Maximum
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TABLE A-4 PCDD/F SURFACE SEDIMENT EXPOSURE POINT CONCENTRATIONS BY DECISION UNIT IN PPT
ARITHMETIC CHEBYSHEV
95%
STANDAR NUMBER 95% UPPER 95% UPPER PCDD/F EXPOSURE EXPOSURE POINT
DECISION CONFIDENC
MEAN D OF MAXIMUM CONFIDENCE CONFIDENCE POINT CONCENTRATION
UNIT E STUDENT T
DEVIATION SAMPLES LIMIT OF THE LIMIT OF THE CONCENTRATION TYPE
STATISTIC
MEAN MEAN
ZI AREA
Z1 Overall 953.8 764.8 2.0 1494.6 6.3 4368.3 3311.1 1494.6 Maximum
ZI-09 413.0 NC 1.0 413.0 NC NC NC 413.0 Maximum
ZI-10 1494.6 NC 1.0 1494.6 NC NC NC 1494.6 Maximum
PACER IVY AREA
PI Overall 1006.6 1085.6 16.0 3370.0 1.8 1482.3 2189.6 2189.6 Chebyshev
PI-15 2038.3 1098.5 4.0 3370.0 2.4 3330.8 4432.3 3330.8 Arithmetic
PI-16 416.5 329.8 4.0 889.0 2.4 804.5 1135.2 804.5 Arithmetic
PI-17 516.3 551.0 4.0 1300.0 2.4 1164.7 1717.2 1164.7 Arithmetic
PI-18 1080.0 NC 1.0 1080.0 NC NC NC 1080.0 Maximum
PI-19 34.1 NC 1.0 34.1 NC NC NC 34.1 Maximum
PI-20 3080.0 NC 1.0 3080.0 NC NC NC 3080.0 Maximum
PI-21 26.6 NC 1.0 26.6 NC NC NC 26.6 Maximum
NORTHWEST AREA
NW Overall 139.0 158.1 11.0 477.0 1.8 225.4 346.7 346.7 Chebyshev
NW-01 96.8 NC 1.0 96.8 NC NC NC 96.8 Maximum
NW-02 72.4 NC 1.0 72.4 NC NC NC 72.4 Maximum
NW-03 140.2 176.9 4.0 385.0 2.4 348.4 525.8 348.4 Arithmetic
NW-04 198.3 198.2 4.0 477.0 2.4 431.5 630.3 431.5 Arithmetic
NORTHEAST AREA
NE Overall 212.2 281.7 19.0 1300.0 1.7 324.2 493.9 493.9 Chebyshev
NE-06 71.5 NC 1.0 71.5 NC NC NC 71.5 Maximum
NE-07 1300.0 NC 1.0 1300.0 NC NC NC 1300.0 Maximum
NE-08 166.5 80.7 4.0 223.0 2.4 261.4 342.4 261.4 Arithmetic
NE-09 448.0 NC 1.0 448.0 NC NC NC 448.0 Maximum
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ARITHMETIC CHEBYSHEV
95%
STANDAR NUMBER 95% UPPER 95% UPPER PCDD/F EXPOSURE EXPOSURE POINT
DECISION CONFIDENC
MEAN D OF MAXIMUM CONFIDENCE CONFIDENCE POINT CONCENTRATION
UNIT E STUDENT T
DEVIATION SAMPLES LIMIT OF THE LIMIT OF THE CONCENTRATION TYPE
STATISTIC
MEAN MEAN
NE-10 26.9 NC 1.0 26.9 NC NC NC 26.9 Maximum
NE-11 124.7 NC 1.0 124.7 NC NC NC 124.7 Maximum
NE-12 181.3 56.3 4.0 259.0 2.4 247.4 303.8 247.4 Arithmetic
NE-13 77.6 NC 1.0 77.6 NC NC NC 77.6 Maximum
NE-14 35.8 NC 1.0 35.8 NC NC NC 35.8 Maximum
NE-15 139.0 72.3 4.0 225.0 2.4 224.1 296.6 224.1 Arithmetic
OUTSIDE AIRBASE
BHL-01 83.0 NC 1.0 83.0 NC NC NC 83.0 Maximum
G2L-01 166.0 NC 1.0 166.0 NC NC NC 166.0 Maximum
NC: Not Calculated because the sample size is less than two
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TABLE A-5 PCDD/F ALL DEPTHS SEDIMENT EXPOSURE POINT CONCENTRATIONS BY DECISION UNIT IN PPT
ARITHMETIC CHEBYSHEV
95%
NUMBER 95% UPPER 95% UPPER PCDD/F EXPOSURE EXPOSURE POINT
DECISION STANDARD CONFIDENCE
MEAN OF MAXIMUM CONFIDENCE CONFIDENCE POINT CONCENTRATION
UNIT DEVIATION STUDENT T
SAMPLES LIMIT OF THE LIMIT OF THE CONCENTRATION TYPE
STATISTIC
MEAN MEAN
ZI AREA
ZI-09 372.3 98.5 3.0 444.0 2.9 538.4 620.2 444.0 Maximum
ZI-10 1106.1 747.1 3.0 1578.8 2.9 2365.5 2986.1 1578.8 Maximum
PACER IVY AREA
PI-15 1779.4 946.8 12.0 3370.0 1.8 2270.3 2970.8 2970.8 Chebyshev
PI-16 434.3 348.0 12.0 1120.0 1.8 614.7 872.2 872.2 Chebyshev
PI-17 355.4 356.9 12.0 1300.0 1.8 540.4 804.5 804.5 Chebyshev
PI-18 345.5 367.8 6.0 1080.0 2.0 648.1 1000.0 1000.0 Chebyshev
PI-19 23.2 15.8 3.0 40.1 2.9 49.8 63.0 40.1 Maximum
PI-20 4103.3 1190.6 3.0 5410.0 2.9 6110.4 7099.5 5410.0 Maximum
PI-21 38.0 27.2 3.0 69.1 2.9 83.9 106.5 69.1 Maximum
NORTHWEST AREA
NW-01 90.2 18.0 3.0 104.0 2.9 120.6 135.6 104.0 Maximum
NW-02 47.6 24.4 3.0 72.4 2.9 88.6 108.9 72.4 Maximum
NW-03 181.4 234.8 12.0 644.0 1.8 303.1 476.8 476.8 Chebyshev
NW-04 141.2 150.0 9.0 477.0 1.9 234.1 359.1 359.1 Chebyshev
NORTHEAST AREA
NE-06 63.6 16.4 3.0 74.5 2.9 91.2 104.7 74.5 Maximum
NE-07 706.4 625.0 3.0 1300.0 2.9 1760.1 2279.3 1300.0 Maximum
NE-08 154.1 76.1 12.0 265.0 1.8 193.6 249.9 249.9 Chebyshev
NE-09 332.7 116.0 3.0 448.0 2.9 528.2 624.6 448.0 Maximum
NE-10 36.5 11.3 3.0 49.0 2.9 55.6 65.0 49.0 Maximum
NE-11 221.8 127.9 3.0 366.8 2.9 437.5 543.8 366.8 Maximum
NE-12 139.4 78.3 6.0 259.0 2.0 203.8 278.7 203.8 Arithmetic
NE-13 77.1 12.9 3.0 89.7 2.9 98.8 109.6 89.7 Maximum
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FINAL TECHNICAL MEMORANDUM BASELINE RISK ASSESSMENT
ARITHMETIC CHEBYSHEV
95%
NUMBER 95% UPPER 95% UPPER PCDD/F EXPOSURE EXPOSURE POINT
DECISION STANDARD CONFIDENCE
MEAN OF MAXIMUM CONFIDENCE CONFIDENCE POINT CONCENTRATION
UNIT DEVIATION STUDENT T
SAMPLES LIMIT OF THE LIMIT OF THE CONCENTRATION TYPE
STATISTIC
MEAN MEAN
NE-14 36.6 2.3 3.0 39.2 2.9 40.5 42.4 39.2 Maximum
NE-15 98.6 84.6 6.0 226.0 2.0 168.2 249.2 168.2 Arithmetic
OUTSIDE AIRBASE
BHL-01 83.0 NC 1.0 83.0 NC NC NC 83.0 Maximum
G2L-01 122.1 53.7 4.0 166.0 2.4 185.3 239.1 166.0 Maximum
NC: Not Calculated because the sample size is less than two
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FINAL TECHNICAL MEMORANDUM BASELINE RISK ASSESSMENT
TABLE A-6 PCDD/F GROUNDWATER EXPOSURE POINT CONCENTRATIONS BY SITE AREA IN PG/L
NC: Not Calculated because the sample size is less than two
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TABLE A-8 OTHER COPC EXPOSURE POINT CONCENTRATIONS BY SITE AREA AND ENVIRONMENTAL MEDIA
ARITHMETIC CHEBYSHEV
95% COPC
NUMBER 95% UPPER 95% UPPER
ENVIRONMENTAL SITE STANDARD CONFIDENCE EXPOSURE EXPOSURE POINT
CHEMICAL MEAN OF MAXIMUM CONFIDENCE CONFIDENCE
MEDIUM AREA DEVIATION STUDENT T POINT CONC. TYPE
SAMPLES LIMIT OF THE LIMIT OF THE
STATISTIC CONC.
MEAN MEAN
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FINAL TECHNICAL MEMORANDUM BASELINE RISK ASSESSMENT
TABLE A-9 SUMMARY OF EXPOSURE PARAMETERS
BW EF ET ED SA AF PEF
EXPOSURE EXPOSURE AT IR
MEDIUM AGE GROUP AT A IR
PATHWAY GROUP UNITS UNITS
DAY/ MG/CM2-
KG VARIES B YEAR CM2 M3/KG
YEAR DAY
Child (1-6 yrs) 14.5 350 - 5 1825 days 200 mg/day - - -
Resident Adolescent (7-18 yrs) 22.8 350 - 11 4015 days 100 mg/day - - -
Soil Ingestion
Adult (>18 yrs) 49.1 350 - 10 3650 days 100 mg/day - - -
Nonresident Adult (>18 yrs) 49.1 250 - 25 9125 days 100 mg/day - - -
Child (1-6 yrs) 14.5 350 - 5 1825 days - - 2447 0.2 -
Dermal Resident Adolescent (7-18 yrs) 22.8 350 - 11 4015 days - - 3010 0.2 -
Soil Contact with
Adult (>18 yrs) 49.1 350 - 10 3650 days - - 3559 0.07 -
Soil
Nonresident Adult (>18 yrs) 49.1 250 - 25 9125 days - - 2584 0.12 -
Child (1-6 yrs) 14.5 350 24 5 43800 hours - - - - 1.36E09
Particulate Resident Adolescent (7-18 yrs) 22.8 350 24 11 96360 hours - - - - 1.36E09
Inhalation Adult (>18 yrs) 49.1 350 24 10 87600 hours - - - - 1.36E09
Nonresident Adult (>18 yrs) 49.1 250 8 25 219000 hours - - - - 1.36E09
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BW EF ET ED SA AF PEF
EXPOSURE EXPOSURE AT IR
MEDIUM AGE GROUP AT A IR
PATHWAY GROUP UNITS UNITS
DAY/ MG/CM2-
KG VARIES B YEAR CM2 M3/KG
YEAR DAY
Nonresident Adult (>18 yrs) 49.1 250 - 25 9125 days 2.5 L/day - - -
Child (1-6 yrs) 14.5 350 0.28 5 1825 days - - 6500 - -
Groundwater
(continued) Dermal -
Resident Adolescent (7-18 yrs) 22.8 350 0.28 11 4015 days - 8960 - -
Contact
Adult (>18 yrs) 49.1 350 0.28 10 3650 days - - 14800 - -
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FINAL TECHNICAL MEMORANDUM BASELINE RISK ASSESSMENT
BW EF ET ED SA AF PEF
EXPOSURE EXPOSURE AT IR
MEDIUM AGE GROUP AT A IR
PATHWAY GROUP UNITS UNITS
DAY/ MG/CM2-
KG VARIES B YEAR CM2 M3/KG
YEAR DAY
Adult (>18 yrs) 49.1 365 - 10 3650 days 15.3 g/day - - -
Child (1-6 yrs) 14.5 365 - 5 1825 days 49.8 g/day - - -
Consumption g/day
Resident Adolescent (7-18 yrs) 22.8 365 - 11 4015 days 78.0 - - -
Local Diet of Vegetables
Adult (>18 yrs) 49.1 365 - 10 3650 days 168 g/day - - -
(continued)
Child (1-6 yrs) 14.5 365 - 5 1825 days 91.4 g/day - - -
Consumption g/day
Resident Adolescent (7-18 yrs) 22.8 365 - 11 4015 days 143 - - -
of Rice
Adult (>18 yrs) 49.1 365 - 10 3650 days 309 g/day - - -
Consumption
Breast Milk Resident Infant (< 2 yrs) 5.33 365 - 2 730 days 647.5 mL/day - - -
of Breast Milk
a averaging time for noncancer endpoints; the cancer averaging time is 70 years.
b exposure time applicability and units depend on the exposure pathway, see equation in Section 5.4.2
AT = averaging time
BW = body weight
EF = exposure frequency
ET = exposure time
ED = exposure duration
IR = ingestion rate
PEF = particulate emission factor
SA = surface area
AF = adherence factor
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FINAL TECHNICAL MEMORANDUM BASELINE RISK ASSESSMENT
TABLE A-10 SOIL EXPOSURE RISK/HAZARD FROM PCDD/FS FOR LOCAL RESIDENTS AND RESIDENT
AIRBASE PERSONNEL AND THEIR FAMILIES
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FINAL TECHNICAL MEMORANDUM BASELINE RISK ASSESSMENT
CHILD NONCANCER CHILD CANCER INCREASED LIFETIME
DECISION UNIT
HAZARD INDEXA HAZARD INDEXA CANCER RISKB
PI-05 5 1.6 7E-05
PI-06 5 2 7E-05
PI-07 0.3 0.1 4E-06
PI-08 62 19 8E-04
PI-09 7.5 2.3 1E-04
PI-10 45 14 6E-04
PI-11 4.5 1.4 6E-05
PI-12 58 18 8E-04
PI-13 6.1 1.8 8E-05
PI-14 1.0 0.3 1E-05
NORTHERN FOREST AREA
NF Overall 6.2 1.9 8E-05
NF-01 0.7 0.2 1E-05
NF-02 1.2 0.4 2E-05
NF-03 0.4 0.1 5E-06
NF-04 6.6 2.0 9E-05
NORTHEAST AREA
NE Overall 20 6.2 3E-04
NE-01 0.2 0.1 3E-06
NE-02 21 6.3 3E-04
NE-03 0.7 0.2 9E-06
NE-04 14 4.4 2E-04
NE-05 1.5 0.5 2E-05
SOUTHEAST AREA
SE Overall 1.3 0.4 2E-05
SE-01 0.7 0.2 1E-05
SE-02 1.3 0.4 2E-05
a Bolded values indicate a hazard index above the threshold of one
b Bolded values indicate an increased lifetime cancer risk above 1 x 10-4; bolded italicized values indicate an increased lifetime cancer
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FINAL TECHNICAL MEMORANDUM BASELINE RISK ASSESSMENT
TABLE A-11 SOIL EXPOSURE RISK/HAZARD FROM PCDD/FS FOR NONRESIDENT AIRBASE PERSONNEL
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FINAL TECHNICAL MEMORANDUM BASELINE RISK ASSESSMENT
NONCANCER HAZARD CANCER HAZARD INCREASED LIFETIME CANCER
DECISION UNIT
INDEXA INDEXA RISKB
PI-05 0.6 0.2 2E-05
PI-06 0.5 0.2 2E-05
PI-07 3E-02 1E-02 1E-06
PI-08 6.6 2.0 2E-04
PI-09 0.8 0.2 3E-05
PI-10 4.8 1.5 2E-04
PI-11 0.5 0.1 2E-05
PI-12 6.2 1.9 2E-04
PI-13 0.7 0.2 2E-05
PI-14 0.1 3E-02 3E-06
NORTHERN FOREST AREA
NF Overall 7E-01 2E-01 2E-05
NF-01 8E-02 2E-02 3E-06
NF-02 1E-01 4E-02 4E-06
NF-03 4E-02 1E-02 1E-06
NF-04 0.7 0.2 2E-05
NORTHEAST AREA
NE Overall 2.2 0.7 7E-05
NE-01 2E-02 7E-03 7E-07
NE-02 2.2 0.7 7E-05
NE-03 0.1 2E-02 2E-06
NE-04 1.5 0.5 5E-05
NE-05 0.2 5E-02 5E-06
SOUTHEAST AREA
SE Overall 0.1 4E-02 5E-06
SE-01 0.1 2E-02 3E-06
SE-02 0.1 4E-02 5E-06
a Bolded values indicate a hazard index above the threshold of one
b Bolded values indicate an increased lifetime cancer risk above 1 x 10-4; bolded italicized values indicate an increased lifetime cancer
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FINAL TECHNICAL MEMORANDUM BASELINE RISK ASSESSMENT
TABLE A-12 SOIL EXPOSURE RISK/HAZARD FROM OTHER COPCS FOR LOCAL RESIDENTS AND RESIDENT
AIRBASE PERSONNEL AND THEIR FAMILIES
TABLE A-13 SOIL EXPOSURE RISK/HAZARD FROM OTHER COPCS FOR NONRESIDENT AIRBASE
PERSONNEL
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FINAL TECHNICAL MEMORANDUM BASELINE RISK ASSESSMENT
TABLE A-14 SEDIMENT EXPOSURE RISK/HAZARD FROM PCDD/FS FOR LOCAL RESIDENTS AND RESIDENT
AIRBASE PERSONNEL AND THEIR FAMILIES
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FINAL TECHNICAL MEMORANDUM BASELINE RISK ASSESSMENT
TABLE A-15 SEDIMENT EXPOSURE RISK/HAZARD FROM PCDD/FS FOR NONRESIDENT AIRBASE
PERSONNEL
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FINAL TECHNICAL MEMORANDUM BASELINE RISK ASSESSMENT
TABLE A-16 SEDIMENT EXPOSURE RISKS/HAZARD FROM OTHER COPCS FOR LOCAL RESIDENTS AND RESIDENT AIRBASE PERSONNEL AND
THEIR FAMILIES
TABLE A-17 SEDIMENT EXPOSURE RISK/HAZARD FROM COPCS FOR NONRESIDENT AIRBASE PERSONNEL
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FINAL TECHNICAL MEMORANDUM BASELINE RISK ASSESSMENT
TABLE A-18 GROUNDWATER EXPOSURE RISK/HAZARD FROM PCDD/FS FOR LOCAL RESIDENTS AND
RESIDENT AIRBASE PERSONNEL AND THEIR FAMILIES
TABLE A-19 GROUNDWATER EXPOSURE RISK/HAZARD FROM OTHER COPCS FOR LOCAL RESIDENTS
AND RESIDENT AIRBASE PERSONNEL AND THEIR FAMILIES
TABLE A-20 DIETARY EXPOSURE RISK/HAZARD FROM PCDD/F FOR LOCAL RESIDENTS AND RESIDENT
AIRBASE PERSONNEL AND THEIR FAMILIES
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FINAL TECHNICAL MEMORANDUM BASELINE RISK ASSESSMENT
ANNEX 8 – TECHNICAL MEMORANDA
DISCLAIMER THE VIEWS EXPRESSED IN THIS PUBLICATION DO NOT NECESSARILY REFLECT THE VIEWS OF THE UNITED
STATES AGENCY FOR INTERNATIONAL DEVELOPMENT OR THE UNITED STATES GOVERNMENT.
CONTENTS
CONTENTS I
LIST OF FIGURES I
LIST OF TABLES II
LIST OF ACRONYMS AND ABBREVIATIONS III
EXECUTIVE SUMMARY V
1 INTRODUCTION 1
2 TOXICITY ASSESSMENT 2
2.1 HIERARCHY FOR SELECTING TOXICOLOGICAL CRITERIA 2
2.2 PCDD/FS 2
2.2.1 CARCINOGENIC EFFECTS 3
2.2.2 NONCARCINOGENIC EFFECTS 3
2.3 ARSENIC 3
2.3.1 CARCINOGENIC EFFECTS 3
2.3.2 NONCARCINOGENIC EFFECTS 4
3 EXPOSURE ASSESSMENT 4
3.1 EXPOSURE PATHWAYS 4
3.2 SOURCE CONTAMINATION IN THE LTSA 4
3.3 GROUNDWATER AND SURFACE WATER TRANSPORT ASSUMPTIONS 4
3.4 GROUNDWATER TRANSPORT 5
3.5 SURFACE WATER TRANSPORT 5
3.6 ESTIMATION OF FISH CONCENTRATIONS 5
3.7 DOSE EQUATIONS 6
3.7.1 GROUNDWATER INGESTION 6
3.7.2 DERMAL CONTACT WITH GROUNDWATER 6
3.7.3 INCIDENTAL SURFACE WATER INGESTION 7
3.7.4 FISH CONSUMPTION 8
3.8 EXPOSURE PARAMETERS 8
3.8.1 VIETNAMESE POPULATION-SPECIFIC EXPOSURE PARAMETERS 9
3.8.2 USEPA DEFAULT EXPOSURE PARAMETERS 9
3.8.3 CHEMICAL-SPECIFIC EXPOSURE PARAMETERS 10
4 RISK CHARACTERIZATION 10
4.1 HAZARDS AND RISK FINDINGS 10
4.2 UNCERTAINTY ASSESSMENT 12
5 CONCLUSION 12
6 REFERENCES 12
LIST OF FIGURES
Figure 1. LTSA Location ................................................................................................................................................... 2
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LIST OF TABLES
Table 1. Summary of LTSA Exposure Parameters ................................................................................................... 14
Table 2. Summary of Noncancer Hazard from LTSA ............................................................................................. 15
Table 3. Summary of Cancer Hazard From LTSA ................................................................................................... 16
Table 4. Summary of Noncancer Hazard, Cancer Hazard, and Increased Lifetime Cancer Risk From
LTSA ................................................................................................................................................................................... 17
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LIST OF ACRONYMS AND ABBREVIATIONS
ADAFC Air Defense - Air Force Command
A&E Architect & Engineer
As Arsenic
ASTM American Society for Testing and Materials
BW Body weight
cm Centimeter
CLIN Contract Line Item Number
COC Contaminant of Concern
COPC Chemical of Potential Concern
d Day
DU Decision Unit
EA Environmental Assessment
EFH Exposure Factors Handbook
EPC Exposure Point Concentration
EVSA Excess Volume Stockpile Area
g gram
GVN Government of Vietnam
GWTF Groundwater transport factors
ha hectare
HDPE High-density polyethylene
HI Hazard index
HQ Hazard quotient
hr hour
ILCR Increased lifetime cancer risk
kg kilogram
km kilometer
L Liter
LTSA Long Term Storage Area
m meter
mm millimeter
MF Modifying factor
mg milligram
MND Ministry of National Defense
ng nanogram
Pb Lead
PCB Polychlorinated biphenyl
PCDD Polychlorinated dibenzodioxins
PCDF Polychlorinated dibenzofurans
pg picogram
ppt parts per trillion
RfC Reference Concentration
RfD Reference Dose
SCM Site Conceptual Model
SOW Statement of Work
SWTF Surface water transport factors
TCDD 2,3,7,8-Tetrachlorodibenzodioxin
TCDF 2,3,7,8-Tetrachlorodibenzofuran
TEF Toxic Equivalency Factor
TEQ Toxicity Equivalent
TM Technical Memorandum
UCL Upper confidence limit
ug microgram
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US United States
USAID United States Agency for International Development
USEPA United States Environmental Protection Agency
WHO World Health Organization
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EXECUTIVE SUMMARY
The Dioxin Remediation at Bien Hoa Airbase Area Project (Project) is managed by USAID and the
Government of Vietnam (GVN) Air Defense–Air Force Command (ADAFC). During Project Phase
1, USAID will initiate the construction of a Long-Term Storage Area (LTSA) to safely isolate on the
Airbase up to 300,000 cubic meters of excavated low concentration dioxin-contaminated soils and
sediments according to the Ministry of National Defense (MND) Decision No. 3869 /QD-BQP.
Excavation and storage will occur through multiple stages over the duration of the ten-year Project.
To assess the safety of the proposed LTSA design, USAID has evaluated the post remediation
human health risks, the noncancer hazard, cancer hazard, and increased lifetime cancer risk due to
potential future exposures of local residents, resident airbase personnel and families, and
nonresident airbase personnel to the planned LTSA. Because the LTSA will be capped and fenced,
the only potential complete exposure for this evaluation is the impact of leachate and runoff from
the LTSA to local groundwater and nearby surface water bodies. In addition, because the Baseline
Risk Assessment (USAID 2020) has identified polychlorinated dioxins/furans (PCDD/Fs) and arsenic
as the main contributors to hazards and risk from soil and sediment that may be placed in the
LTSA, only these Contaminants of Potential Concern (COPCs) were included in this evaluation.
• Prepare base with a minimum of 1.5 m separation from the projected high groundwater
elevation to the geotextile layer separating stored contaminated soil and sediment from the
prepared base
• Construct perimeter berm including galvanized gabion, high-density polyethylene (HDPE)
membrane and geo-composite drain on the berm top and berm slope, and concrete slope
protection
• Toe drain on the perimeter berm slope to provide drainage and protect the berm against
erosion
• Groundwater monitoring wells
• Security fencing
• Final cover to consist of:
o Non-woven geotextile fabric layer, 25 kN/m tensile strength
o HDPE double side rough geomembrane liner, 1.5 mm thick
o Geo-composite drains, 8 mm thick
o Soil barrier layer, 50 cm thick, sloped at 3%
o Vegetation cover and topsoil (organic) layer of 15 cm thick
o Automated irrigation system for vegetation cover
• Incidental Surface Water Ingestion and Dermal Contact with Surface Water:
COPCs present in the LTSA may leach or runoff into nearby surface water bodies and can
result in exposure to human receptors via incidental ingestion or dermal contact while
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swimming or wading during visits to the surface water bodies. Surface water may also be
directly impacted by contaminated groundwater. These exposure pathways are complete
for any persons swimming or wading in these surface water bodies from the Airbase,
including local residents and resident Airbase personnel and families.
• Fish Ingestion. Fish and aquatic biota will be exposed to the COPCs present in the LTSA
that are transported to surface water either through groundwater or direct transport to
surface water. These COPCs may bioaccumulate in fish that are then consumed by local
residents or resident Airbase personnel and their families. This exposure pathway is
complete for any persons living on the Airbase, including local residents and resident
Airbase personnel and families.
For the proposed LTSA design, USAID estimates that the post remediation noncancer hazard index
and the cancer hazard are well below 1, and the increased lifetime cancer risk is below 1x10-6 based
on best available estimates of groundwater and surface water concentrations at the site. While
limitations in availability of some site-specific data creates uncertainty in the precision of these
estimates, these findings conclude that PCDD/Fs and arsenic would have to be 100 fold more
mobile than estimated before the noncancer hazard would be unacceptable, 12,500 fold more
mobile before the cancer hazard would be unacceptable, and 50 to 5,000 fold more mobile before
the increased lifetime cancer risk is below an acceptable residential risk level of 1x10-6. As such,
these finding conclude that the proposed LTSA design will provide necessary protection to human
health from the low dioxin contaminated soil proposed to be stored in the LSTA (below
Vietnamese industrial land use standard).
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1 INTRODUCTION
The Dioxin Remediation at Bien Hoa Airbase Area Project (Project) is managed by USAID and the
Government of Vietnam (GVN) Air Defense–Air Force Command (ADAFC). During Project Phase
1, USAID will initiate the construction of a Long-Term Storage Area (LTSA) to safely isolate on the
Airbase up to 300,000 cubic meters of excavated low concentration dioxin-contaminated soils and
sediments according to the Ministry of National Defense (MND) Decision No. 3869 /QD-BQP.
Excavation and storage will occur through multiple stages over the duration of the ten-year Project.
To assess the safety of the proposed LTSA design, USAID has evaluated the post remediation
human health risks, the noncancer hazard, cancer hazard, and increased lifetime cancer risk due to
potential future exposures of local residents, resident airbase personnel and families, and
nonresident airbase personnel to the planned LTSA. Because the LTSA will be capped and fenced,
the only potential complete exposure for this evaluation is the impact of leachate and runoff from
the LTSA to local groundwater and nearby surface water bodies. In addition, because the Baseline
Risk Assessment (USAID 2020) has identified polychlorinated dioxins/furans (PCDD/Fs) and arsenic
as the main contributors to hazards and risk from soil and sediment that may be placed in the LTSA,
only these Contaminants of Potential Concern (COPCs) were included in this evaluation.
• Prepare base with a minimum of 1.5 m separation from the projected high groundwater
elevation to the geotextile layer separating stored contaminated soil and sediment from the
prepared base
• Construct perimeter berm including galvanized gabion, high-density polyethylene (HDPE)
membrane and geo-composite drain on the berm top and berm slope, and concrete slope
protection
• Toe drain on the perimeter berm slope to provide drainage and protect the berm against
erosion
• Groundwater monitoring wells
• Security fencing
• Final cover to consist of:
o Non-woven geotextile fabric layer, 25 kN/m tensile strength
o HDPE double side rough geomembrane liner, 1.5 mm thick
o Geo-composite drains, 8 mm thick
o Soil barrier layer, 50 cm thick, sloped at 3%
o Vegetation cover and topsoil (organic) layer of 15 cm thick
o Automated irrigation system for vegetation cover.
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FIGURE 1. LTSA LOCATION
2 TOXICITY ASSESSMENT
The purpose of the toxicity assessment is to identify the types of adverse effects a chemical may
cause and define the relationship between the dose of a constituent and the likelihood and
magnitude of an adverse effect. These relationships are represented mathematically as cancer slope
factors (SFs) or inhalation unit risks (IURs) for carcinogenic effects and as reference doses (RfDs) or
inhalation reference concentrations (RfCs) for non-carcinogenic effects. Noncancer toxicity criteria
were selected for chronic exposures.
2.2 PCDD/FS
The toxicities of individual PCDD/F congeners vary greatly, with TCDD recognized as one of
the most well-studied and toxic congeners (ATSDR 1998). As a result, the concept of toxic
equivalency was developed to relate the toxicity of PCDD/F congeners to the toxicity of TCDD
using a relative effect potency, in order to generate toxic equivalency factors (TEF) (Van den
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Berg, Birnbaum et al. 2006). The products of congener-specific concentrations and TEFs
represent the toxic equivalent (TEQ) concentrations of TCDD which are then summed to
generate a total TEQ value (Van den Berg, Birnbaum et al. 2006).
ORAL
No Tier 1 or 2 toxicological criteria was available for oral TCDD exposure based upon either a
non-threshold or threshold dose assumption. Therefore, a Tier 3, threshold-based tolerable daily
intake (TDI) of 2.3 pg/kg-day was used to evaluate potential carcinogenic effects of TCDD exposure
(JECFA 2002). The TDI was converted from a provisional tolerable monthly intake (PTMI) of 70
pg/kg-month by dividing the value by 30 (JECFA 2002).
A Tier 3 oral slope factor of 130,000 (mg/kg/day)-1 was also used to evaluate potential carcinogenic
effects of TCDD exposure; this value was derived by the California Office of Environmental Health
Hazard Assessment (OEHHA) based on the non-threshold dose assumption (OEHHA 2011).
ORAL
USEPA’s Integrated Risk Information System, IRIS, has established a chronic reference dose of 0.7
pg/kg-day for TCDD (USEPA 2012). This value is based upon developmental effects reported by two
epidemiological studies which assess human exposure to TCDD following an industrial accident in
Italy; the studies report increased levels of thyroid stimulating hormone and decreased sperm
motility and concentration (Baccarelli, Giacomini et al. 2008, Mocarelli, Gerthoux et al. 2008, USEPA
2012). A cumulative uncertainty factor of 30 was applied to the data, which did not include any
adjustment from sub-chronic to chronic exposures; therefore, the chronic reference dose was used
to evaluate sub-chronic exposures (USEPA 2012).
2.3 ARSENIC
Because arsenic was not speciated in the site soil and sediment data, the toxicity criteria were
conservatively identified and selected for inorganic arsenic for use in this evaluation.
ORAL
IRIS provides an oral cancer slop factor of 1.5 (mg/kg/day)-1 for inorganic arsenic exposure (USEPA
1995). Multiple epidemiological studies which observed skin cancer in humans following inorganic
arsenic exposure in drinking water were used to develop dose-response assessment (Tseng, Chu et
al. 1968, Tseng 1977, USEPA 1995).
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2.3.2 NONCARCINOGENIC EFFECTS
ORAL
IRIS provides a reference dose of 3 x 10-4 mg/kg/day for inorganic arsenic (USEPA 1995). This value
is derived from multiple epidemiological studies which observed hyperpigmentation, keratosis, and
possible vascular complications in humans following oral inorganic arsenic exposure (Tseng, Chu et
al. 1968, Tseng 1977, USEPA 1995). An uncertainty factor of 3 was applied to the data, which did not
include any adjustment from subchronic to chronic exposures; therefore, the chronic reference dose
was used to evaluate subchronic exposures (USEPA 1995).
3 EXPOSURE ASSESSMENT
• Incidental Surface Water Ingestion and Dermal Contact with Surface Water:
Dioxins/furans and arsenic present in the LTSA may leach or runoff into nearby surface water
bodies and can result in exposure to human receptors via incidental ingestion or dermal
contact while swimming or wading during visits to the surface water bodies. These exposure
pathways are complete for any persons swimming or wading in these surface water bodies from
the Airbase, including local residents and resident Airbase personnel and families.
• Fish Ingestion. Fish and aquatic biota will be exposed to the COPCs present in the LTSA
that are transported to surface water either through groundwater or direct transport to
surface water. These COPCs may bioaccumulate in fish that are then consumed by local
residents or resident Airbase personnel and their families. This exposure pathway is complete
for any persons living on the Airbase, including local residents and resident Airbase personnel
and families.
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Stockpile Area (EVSA) constructed as part of the Environmental Remediation of the Danang
Airport (CDM 2016). Based on the current design for the LTSA, the scenario from the EVSA
evaluation (CDM 2016) that best fits conditions at the LTSA after construction is Scenario 2A, i.e.
an assumed defect rate in the cover HDPE liner of one hole per hectare. These assumptions were
used to develop the groundwater and surface water transport factors.
where GWTF are groundwater transport factors for PCDD/Fs (pg/L per ng/kg) and arsenic (µg/L
per mg/kg) and SOILBien Hoa is the soil concentration of PCDD/Fs (ng/kg) and arsenic (mg/kg) at the
LTSA. This assessment used GWTF calculated for the EVSA in Danang as the site conditions are
similar.
The assumed GWTF for PCDD/F is 2.0 x 10-7 pg/L per ng/kg in terms of TEQ and for arsenic,
0.000124 µg/L per mg/kg. Using a PCDD/F TEQ concentration in LTSA soil of 1,200 ng/kg, the
estimated groundwater concentration in a downgradient well is 0.00024 pg/L. For arsenic, the
estimated groundwater concentration is 0.005 µg/L.
Because there is significant communication between groundwater and surface water at Bien Hoa,
surface water concentrations due to groundwater discharge were conservatively evaluated using
the same concentrations that were estimated here.
where SWTF are surface water transport factors for PCDD/Fs (pg/L per ng/kg) and arsenic (µg/L
per mg/kg) and SOILBien Hoa is the soil concentration of PCDD/Fs (ng/kg) and arsenic (mg/kg) at the
LTSA. This assessment used SWTF calculated for the EVSA in Danang as the site conditions are
similar.
The PCDD/F SWTF was estimated to be 1.4 x 10-7 pg/L per ng/kg in terms of TEQ. The arsenic
SWTF was estimated to be 0.00086 µg/L per mg/kg. Using a PCDD/F TEQ concentration in LTSA
soil of 1,200 ng/kg, the estimated surface water concentration is 0.00017 pg/L. For arsenic, using
the same soil EPC that was used for arsenic in the LTSA for the during remediation scenario of 40
mg/kg, the estimate surface water concentration is 0.034 µg/L.
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(mg/kg) by using the screening level bioconcentration factor approach used by the USEPA to derive
Ambient Water Quality Criteria based on the consumption of fish (USEPA 2002). This method
assumes that the concentration in fish is linearly related to the concentration in surface water using
the following equation:
where BCF are the generic bioconcentration factors for PCDD/Fs (L/kg) and arsenic (L/kg) and
SWBien Hoa is the surface water concentration of PCDD/Fs (mg/L) and arsenic (mg/L) due to
transport from the LTSA. The PCDD/F BCF used by the USEPA is 5,000 L/kg and the arsenic BCF
is 44 L/kg. These values for BCF only account for partitioning of chemical concentrations from
surface water into fish and are conservatively derived default values. In order to get a more refined
estimate of fish concentrations, site-specific and species-specific bioaccumulation factors would
need to be derived.
ADD = Average Daily Doses for non-carcinogens (milligram per kilogram per dose
[mg/kg-d])
LADD = Lifetime Average Daily Doses for carcinogens (mg/kg-d)
EPCgroundwater = Exposure point concentration for COPC in groundwater (mg/L)
EF = Exposure frequency (days/year)
ED = Exposure duration (years)
IR = Groundwater ingestion rate (L/day)
BW = Body weight (kilogram [kg])
AT = Averaging time (days)
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BW = Body weight (kilogram [kg])
AT = Averaging time (days)
The DAevent is calculated differently for organic and inorganic compounds. Below are the equations
used for arsenic and PCDD/Fs, respectively:
ARSENIC
𝑳𝑳
𝑫𝑫𝑫𝑫𝒆𝒆𝒆𝒆𝒆𝒆𝒆𝒆𝒆𝒆 = 𝑪𝑪𝒈𝒈𝒈𝒈𝒈𝒈𝒈𝒈𝒈𝒈𝒈𝒈𝒈𝒈𝒈𝒈𝒈𝒈𝒈𝒈𝒈𝒈 × 𝑲𝑲𝒑𝒑 × 𝑬𝑬𝑬𝑬 × (𝟎𝟎. 𝟎𝟎𝟎𝟎𝟎𝟎 )
𝒄𝒄𝒄𝒄𝟑𝟑
PCDD/FS
𝑳𝑳 𝟔𝟔 × 𝝉𝝉 × 𝑬𝑬𝑬𝑬
𝑫𝑫𝑫𝑫𝒆𝒆𝒆𝒆𝒆𝒆𝒆𝒆𝒆𝒆 = 𝑪𝑪𝒈𝒈𝒈𝒈𝒈𝒈𝒈𝒈𝒈𝒈𝒈𝒈𝒈𝒈𝒈𝒈𝒈𝒈𝒈𝒈𝒈𝒈 × 𝟐𝟐 × 𝑭𝑭𝑭𝑭 × 𝑲𝑲𝒑𝒑 × (𝟎𝟎. 𝟎𝟎𝟎𝟎𝟎𝟎 ) × �
𝒄𝒄𝒄𝒄𝟑𝟑 𝝅𝝅
The potential exists for each receptor to come into dermal contact with surface water during
swimming or wading. The doses associated with dermal contact were quantified according to the
following equation:
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DAevent = Dermally Absorbed Dose per event (mg/cm2-event)
EV = Events per day (events/day)
EF = Exposure frequency (days/year)
ED = Exposure duration (years)
SA = Skin Surface Area (cm2)
BW = Body weight (kilogram [kg])
AT = Averaging time (days)
The DAevent is calculated differently for organic and inorganic compounds. Below are the equations
used for arsenic and PCDD/Fs, respectively:
ARSENIC
𝑳𝑳
𝑫𝑫𝑫𝑫𝒆𝒆𝒆𝒆𝒆𝒆𝒏𝒏𝒏𝒏 = 𝑪𝑪𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔 × 𝑲𝑲𝒑𝒑 × 𝑬𝑬𝑬𝑬 × (𝟎𝟎. 𝟎𝟎𝟎𝟎𝟎𝟎 )
𝒄𝒄𝒄𝒄𝟑𝟑
PCDD/FS
𝑳𝑳 𝟔𝟔 × 𝝉𝝉 × 𝑬𝑬𝑬𝑬
𝑫𝑫𝑫𝑫𝒆𝒆𝒆𝒆𝒆𝒆𝒆𝒆𝒆𝒆 = 𝑪𝑪𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔 × 𝟐𝟐 × 𝑭𝑭𝑭𝑭 × 𝑲𝑲𝒑𝒑 × (𝟎𝟎. 𝟎𝟎𝟎𝟎𝟎𝟎 𝟑𝟑
)�
𝒄𝒄𝒄𝒄 𝝅𝝅
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were selected by age group for residential exposure scenarios due to differences in intake and
activity patterns between children, adolescents, and adults. Therefore, separate exposure
parameters were chosen for the following age groups as applicable to each exposure pathway:
children (1-6 years), adolescents (7-18 years), and adults (>18 years). Exposure parameters were
also the same for all COCs, with the exception of chemical specific absorption factors.
Exposure parameters were selected or calculated using Vietnamese population-specific sources
where available. Where Vietnamese population-specific parameters were not available, exposure
parameters were selected using the USEPA’s Office of Solid Waste and Emergency Response
(OSWER) recommended default exposure factors for Superfund site human health risk assessments
or the USEPA Exposure Factor’s Handbook.
BODY WEIGHT
Body weights representative of the Vietnamese population were determined for each age group
using the Lien et al. 1998 study, which presented the average weight of Vietnamese males and
females in several age groups. The body weight of infants (< 2 years) was estimated by averaging the
body weight of males and females in the newborn and 1 year age groups (Lien 1998). Similarly, the
body weights for children, adolescents, and adults were calculated by averaging the male and female
body weights for the 5 year, 10 year, and 20 to 50 year age groups, respectively (Lien 1998). Body
weight values can be found in Table 1.
EXPOSURE DURATION
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Exposure duration was set for each residential age group such that the total residential exposure
duration summed to 26 years, per the recommended OSWER default exposure factors (USEPA
2014). Therefore, the exposure duration was set to 5 years for children, 11 years for adolescents,
and 10 years for adults for airbase residents.
EXPOSURE TIME
For the LTSA, exposure times for contact with groundwater while bathing or showering were set to
the USEPA (2011) value of 17 minutes per day or 0.28 hrs/day for all age groups. Exposure times
for contact with surface water during swimming or wading were set to the same values as those
used in the evaluation of the Danang EVSA (CDM 2016), which were 2 hours/day for the child and
adolescent age groups and 1 hour/day for the adult age group.
EXPOSURE FREQUENCY
Exposure frequency was set to the OSWER default 350 days/year for the groundwater ingestion and
dermal contact exposure pathways for all age groups. For the groundwater as surface water and
surface water ingestion and dermal contact pathways, of 50 days/year for the child and adolescent
age groups and 25 days/year for the adult age group were used. For the fish consumption pathway,
the exposure frequency was set to 365 days/year because the fish consumption rate is presented in
terms of an annual basis (USEPA 2014).
AVERAGING TIME
Averaging time for each exposure scenario was selected depending on the endpoint (cancer or
noncancer) being evaluated. For noncancer endpoints, the averaging time was set equal to the
exposure duration and converted to the appropriate units of either days or hours. For cancer
endpoints, the averaging time was set to a lifetime of 70 years (USEPA 2014).
PERMEABILITY CONSTANTS
The chemical specific dermal permeability constants for arsenic and PCDD/Fs were set equal to
0.001 and 0.81 cm/hr, respectively. These chemical-specific values were selected from USEPA Risk
Assessment Guidance for Superfund Part E, Supplemental Guidance for Dermal Risk Assessment
(USEPA 2004).
4 RISK CHARACTERIZATION
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surface water, and surface water exposures to PCDD/Fs and arsenic for local residents and
resident airbase personnel and their families who may use groundwater or visit any surface water
bodies impacted by the LTSA. Table 4 also summarizes the noncancer and cancer hazard for the
most sensitive age group.
For groundwater exposures, the noncancer HI for both chemicals combined is 0.002 and the
cancer hazard for PCDD/F is 0.00007, which are well below the acceptable level of 1. The age
group with the highest noncancer HI and cancer HI for groundwater exposure is the adolescent age
group. The overall increased lifetime cancer risk for both chemicals combined is 1x10-8, which is
well below the acceptable residential risk of 1x10-6. In general, for groundwater, arsenic contributes
more to the overall noncancer HI while both have the same increased lifetime cancer risk.
Exposure through dermal contact with groundwater contributes more than incidental ingestion for
PCDD/Fs while groundwater ingestion contributes more for arsenic.
For groundwater as surface water exposures, the noncancer HI for both chemicals combined
is 0.003 and the cancer hazard for PCDD/Fs is 0.0007, which are well below the acceptable level of
1. All age groups had similar noncancer hazards and cancer hazards because the same adult fish
consumption rate was body-weight adjusted and used for all three age groups. The overall
increased lifetime cancer risk for both chemicals combined is 8x10-9, which is well below the
acceptable residential risk of 1x10-6. Fish ingestion is the exposure pathway that contributes most
to the overall noncancer hazard, cancer hazard, and increased lifetime cancer risk. In general, for
groundwater as surface water, PCDD/Fs contribute more to the overall noncancer HI than arsenic
while arsenic contributes more to the increased lifetime cancer risk than PCDD/Fs.
For surface water exposures, the noncancer HI for both chemicals combined is 0.005 and the
cancer hazard for PCDD/Fs is 0.0005, which are well below the acceptable level of 1. All age
groups had similar noncancer hazards and cancer hazards because the same adult fish consumption
rate was body-weight adjusted and used for all three age groups. The overall increased lifetime
cancer risk for both chemicals combined is 2x10-8, which is well below the acceptable residential
risk of 1x10-6. Fish ingestion is the exposure pathway that contributes most to the overall
noncancer hazard, cancer hazard, and increased lifetime cancer risk. In general, for groundwater as
surface water, PCDD/Fs contribute more to the overall noncancer HI than arsenic while arsenic
contributes more to the increased lifetime cancer risk than PCDD/Fs.
Overall, the noncancer hazard index for both PCDD/F and arsenic for groundwater, groundwater
as surface water, and surface water exposures combined is 0.007, the cancer hazard for PCDD/F is
0.0006, and the increased lifetime cancer risk for both chemicals is 3x10-8. Both the noncancer and
cancer hazards are well below the acceptable level of 1 and the increased lifetime cancer risk is well
below the acceptable residential risk of 1x10-6. The noncancer hazard, cancer hazard, and the
increased lifetime cancer risk are higher for groundwater as surface water and surface water
exposures compared to groundwater exposures. Exposures to arsenic contribute more to the
overall noncancer hazard and increased lifetime cancer risk than exposures to PCDD/Fs. Because
these noncancer hazard, cancer hazard, and increased lifetime cancer risk estimates are based on
estimates of groundwater and surface water concentration derived from the EVSA evaluation for
the Danang site and are not based on site-specific fate and transport data for the LTSA at the Bien
Hoa site and the fish concentrations due to surface water exposure are estimated using generic
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bioconcentration factors rather than site-specific and species-specific bioaccumulation data, there is
considerable uncertainty associated with these estimates. However, there is a substantial margin of
safety associated with these estimates. Given the results of this risk evaluation based on the EVSA
evaluation, PCDD/Fs and arsenic in the LTSA at the Bien Hoa site would have to 140 fold more
mobile before the noncancer hazard would be unacceptable, approximately 1,700 fold more mobile
before the cancer hazard would be unacceptable, and approximately 30 fold more mobile before
the increased lifetime cancer risk is within or above the acceptable residential risk level of 1x10-6.
Another major source of uncertainty associated with this evaluation is the use of the generic
bioconcentration factors to estimate the concentrations of the arsenic and PCDD/F in fish. While
these bioconcentration factors were derived to be conservative and for use in screening levels
assessments, the process of bioaccumulation of arsenic and PCDD/Fs in fish in Bien Hoa will be
dependent on both site-specific and species-specific factors.
5 CONCLUSION
For the LTSA, the noncancer hazard index and the cancer hazard are well below 1, and the
increased lifetime cancer risk is well below the residential target risk level of 1x10-6. While
limitations in availability of some site-specific data creates uncertainty in the precision of these
estimates, PCDD/Fs and arsenic in the LTSA at the Bien Hoa would have to 140 fold more
mobile before the noncancer hazard would be unacceptable, 1,700 fold more mobile before the
cancer hazard would be unacceptable, and 30 fold more mobile before the increased lifetime
cancer risk is above the acceptable residential risk level of 1x10-6. These finding conclude that
the proposed LTSA design provides necessary protection to human health from the low dioxin
contaminated soil proposed to be stored in the LSTA (below Vietnamese industrial land use
standard).
6 REFERENCES
ATSDR (1998). Toxicological Profile for Chlorinated Dibenzo-p-Dioxins. Agency for Toxic
Substances and Disease Registry, US Department of Health and Human Services.
Burmaster, D. E. (1998). "Lognormal distributions for skin area as a function of body weight." Risk
Anal 18(1): 27-32.
CDM (2016). Estimated Human Health and Ecological Risks Due to Arsenic and Dioxin in the
Excess Volume Stockpile Area at the Danang Airport, Vietnam.
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JECFA (2002). Polychlorinated dibenzodioxins, polychlorinated dibenzofurans, and
coplanar polychlorinated biphenyls, Joint FAO/WHO Expert Committee on Food
Additives WHO Food Additives Series 48.
Tseng, W. P. (1977). "Effects and dose-response relationships of skin cancer and blackfoot
disease with arsenic." Environ Health Perspect 19: 109-119.
Tseng, W. P., H. M. Chu, S. W. How, J. M. Fong, C. S. Lin and S. Yeh (1968). "Prevalence of skin
cancer in an endemic area of chronic arsenicism in Taiwan." J Natl Cancer Inst 40(3): 453-463.
USAID (Trigon Associates, llc, 2020). Technical Memorandum Baseline Risk Assessment.
USEPA (1989). Risk Assessment Guidance for Superfund (RAGS): Volume 1 – Human Health
Evaluation Manual (Part A), U.S. Environmental Protection Agency.
USEPA (1995). Arsenic, inorganic; CASRN 7440-38-2. Integrated Risk Information System, U.S.
Environmental Protection Agency.
USEPA (2002). National Recommended Water Quality Criteria: Human Health Criteria
Calculation Matrix, U.S. Environmental Protection Agency.
USEPA (2003). Human Health Toxicity Values in Superfund Risk Assessments. Washington,
D.C., U.S. Environmental Protection Agency.
USEPA (2004). Risk Assessment Guidance for Superfund (RAGS): Volume 1 – Human Health
Evaluation Manual (Part E), U.S. Environmental Protection Agency.
USEPA (2005). Guidelines for Carcinogen Risk Assessment, U.S. Environmental Protection
Agency.
USEPA (2014). Human Health Evaluation Manual, Supplemental Guidance: Update of Standard
Default Exposure Factors, U.S. Environmental Protection Agency.
USEPA (2016). ProUCL Version 5.1, U.S. Environmental Protection Agency. Office of Research and
Development.
Van den Berg, M., L. S. Birnbaum, M. Denison, M. De Vito, W. Farland, M. Feeley, H. Fiedler, H.
Hakansson, A. Hanberg, L. Haws, M. Rose, S. Safe, D. Schrenk, C. Tohyama, A. Tritscher, J.
Tuomisto, M. Tysklind, N. Walker and R. E. Peterson (2006). "The 2005 World Health
Organization reevaluation of human and Mammalian toxic equivalency factors for dioxins and
dioxin-like compounds." Toxicol Sci 93(2): 223-241.
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TABLE 1. SUMMARY OF LTSA EXPOSURE PARAMETERS
Skin
Skin adherence
BW EF ET ED contact
Exposure Exposure AT Ingestion IR factor (SAF)
Medium Age Group AT area
Pathway Group Units Rate (IR) Units
day/ hours/
kg years cm2 mg/cm2–day
year day
Child (1-6 yrs) 14.5 350 - 5 1825 days 0.78 L/day - -
Groundwater
Resident Adolescent (7-18 yrs) 22.8 350 - 11 4015 days 2.5 L/day - -
Ingestion
GROUND Adult (>18 yrs) 49.1 350 - 10 3650 days 2.5 L/day - -
WATER Child (1-6 yrs) 14.5 350 - 5 1825 days - L/day 6500 -
Dermal
Resident Adolescent (7-18 yrs) 22.8 350 - 11 4015 days - L/day 8960 -
Contact
Adult (>18 yrs) 49.1 350 - 10 3650 days - L/day 14800 -
Child (1-6 yrs) 14.5 50 2 5 1825 days 50 ml/hr - -
Incidental
Resident Adolescent (7-18 yrs) 22.8 50 2 11 4015 days 50 ml/hr - -
Ingestion
SURFACE Adult (>18 yrs) 49.1 25 1 10 3650 days 50 ml/hr - -
WATER Child (1-6 yrs) 14.5 50 2 5 1825 days - ml/hr 6500 -
Dermal
Resident Adolescent (7-18 yrs) 22.8 50 2 11 4015 days - ml/hr 8960 -
Contact
Adult (>18 yrs) 49.1 25 1 10 3650 days - ml/hr 14800 -
Child (1-6 yrs) 14.5 365 - 5 1825 days 19187 mg/day - -
Consumption
FISH Resident Adolescent (7-18 yrs) 22.8 365 - 11 4015 days 30059 mg/day - -
of Fish
Adult (>18 yrs) 49.1 365 - 10 3650 days 64900 mg/day - -
AT =averaging time
BW = body weight
EF = exposure frequency
ET = exposure time
ED = exposure duration
IR = fish consumption rate
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TABLE 2. SUMMARY OF NONCANCER HAZARD FROM LTSA
All
PCDD/Fs Arsenic
Chemicals
Exposure Group Endpoint
Incidental Dermal Fish Incidental Dermal Fish
Totalb Totalb Totalb
Ingestionb Contactb Ingestion Ingestionb Contactb Ingestion
Child Hazard Index 2E-05 2E-04 NA 2E-04 9E-04 2E-06 NA 9E-04 1E-03
GROUNDWATER Adolescent Hazard Index 4E-05 2E-04 NA 2E-04 2E-03 2E-06 NA 2E-03 2E-03
Adult Hazard Index 2E-05 2E-04 NA 2E-04 8E-04 1E-06 NA 8E-04 1E-03
Child Hazard Index 2E-07 4E-05 2E-03 2E-03 8E-06 1E-06 2E-03 2E-03 5E-05
GROUNDWATER AS
Adolescent Hazard Index 1E-07 4E-05 2E-03 2E-03 5E-06 9E-07 2E-03 2E-03 4E-05
SURFACE WATERA
Adult Hazard Index 5E-08 4E-05 2E-03 2E-03 2E-06 7E-07 2E-03 2E-03 4E-05
Child Hazard Index 1E-07 3E-05 1E-03 1E-03 5E-05 4E-06 3E-03 3E-03 9E-05
SURFACE WATER Adolescent Hazard Index 7E-08 3E-05 1E-03 1E-03 3E-05 3E-06 3E-03 3E-03 6E-05
Adult Hazard Index 3E-08 3E-05 1E-03 1E-03 2E-05 2E-06 3E-03 3E-03 5E-05
Child Hazard Index 2E-05 3E-04 1E-03 1E-03 9E-04 6E-06 3E-03 4E-03 1E-03
ALL PATHWAYS Adolescent Hazard Index 4E-05 2E-04 1E-03 1E-03 2E-03 5E-06 3E-03 5E-03 2E-03
Adult Hazard Index 2E-05 2E-04 1E-03 1E-03 8E-04 4E-06 3E-03 4E-03 1E-03
a Conservatively assumes groundwater directly discharges into surface water without dilution.
b Bolded values indicate a hazard index below the threshold of 1
1E = 1x10
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TABLE 3. SUMMARY OF CANCER HAZARD FROM LTSA
PCDD/Fs
Exposure Group Endpoint
Incidental Ingestionb Dermal Contactb Fish Ingestion Totalb
Child Hazard Index 5E-06 7E-05 NA 8E-05
GROUNDWATER Adolescent Hazard Index 1E-05 6E-05 NA 7E-05
Adult Hazard Index 5E-06 5E-05 NA 5E-05
Child Hazard Index 5E-08 1E-05 7E-04 7E-04
GROUNDWATER AS
Adolescent Hazard Index 3E-08 1E-05 7E-04 7E-04
SURFACE WATERA
Adult Hazard Index 1E-08 1E-05 7E-04 7E-04
Child Hazard Index 3E-08 9E-06 5E-04 5E-04
SURFACE WATER Adolescent Hazard Index 2E-08 8E-06 5E-04 5E-04
Adult Hazard Index 1E-08 9E-06 5E-04 5E-04
Child Hazard Index 5E-06 8E-05 5E-04 6E-04
ALL PATHWAYS Adolescent Hazard Index 1E-05 7E-05 5E-04 6E-04
Adult Hazard Index 5E-06 6E-05 5E-04 5E-04
aConservatively assumes groundwater directly discharges into surface water without dilution.
bBolded values indicate a hazard index below the threshold of 1
1E = 1 x 10
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TABLE 4. SUMMARY OF NONCANCER HAZARD, CANCER HAZARD, AND INCREASED LIFETIME CANCER RISK FROM LTSA
All
PCDD/Fs Arsenic
Chemicals
Exposure Group Endpoint
Incidental Dermal Fish Incidental Dermal Fish
Total Total Total
Ingestion Contact Ingestion Ingestion Contact Ingestion
Adolescent Hazard Indexb 4E-05 2E-04 NA 2E-04 2E-03 2E-06 NA 2E-03 2E-03
GROUNDWATER Adolescent Cancer Hazard Indexb 1E-05 6E-05 NA 7E-05 NA NA NA NA 7E-05
Increased Lifetime Cancer Riskc 2E-11 6E-09 NA 6E-09 6E-09 3E-10 NA 6E-09 1E-08
Child Hazard Indexb 2E-07 4E-05 2E-03 2E-03 8E-06 1E-06 1E-03 1E-03 5E-05
GROUNDWATER AS
Child Cancer Hazard Indexb 5E-08 1E-05 7E-04 7E-04 NA NA NA NA 1E-05
SURFACE WATERA
Increased Lifetime Cancer Riskc 1E-12 1E-09 2E-09 3E-09 2E-10 1E-10 4E-09 5E-09 2E-09
Child Hazard Indexb 1E-07 3E-05 2E-03 2E-03 5E-05 4E-06 3E-03 3E-03 9E-05
SURFACE WATER Child Cancer Hazard Indexb 3E-08 9E-06 5E-04 5E-04 NA NA NA NA 9E-06
Increased Lifetime Cancer Riskc 7E-13 9E-10 1E-09 2E-09 2E-09 5E-10 1E-08 2E-08 3E-09
Hazard Indexb 4E-05 2E-04 2E-03 2E-03 2E-03 5E-06 3E-03 5E-03 2E-03
ALL PATHWAYS Cancer Hazard Indexb 1E-05 7E-05 5E-04 6E-04 NA NA NA NA 8E-05
Increased Lifetime Cancer Riskc 2E-11 7E-09 1E-09 9E-09 7E-09 8E-10 1E-08 2E-08 2E-08
a Conservatively assumes groundwater directly discharges into surface water without dilution.
b Bolded values indicate a hazard index below the threshold of 1
c Bolded values indicate an increased lifetime cancer risk below 1 x 10-6
1E = 1x10
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ARCHITECT-ENGINEER SERVICES FOR DIOXIN REMEDIATION
AT BIEN HOA AIRBASE AREA PROJECT
JUNE 1, 2020
This publication was produced for review by the United States Agency for International Development
ARCHITECT–ENGINEER SERVICES FOR DIOXIN REMEDIATION
AT BIEN HOA AIRBASE AREA PROJECT
June 1, 2020
DISCLAIMER THE VIEWS EXPRESSED IN THIS PUBLICATION DO NOT NECESSARILY REFLECT THE VIEWS OF THE UNITED STATES
AGENCY FOR INTERNATIONAL DEVELOPMENT OR THE UNITED STATES GOVERNMENT.
CONTENTS
LIST OF ACRONYMS AND ABBREVIATIONS ................................................................................................. II
EXECUTIVE SUMMARY ........................................................................................................................................... 1
1 INTRODUCTION................................................................................................................................................ 2
2 BACKGROUND ................................................................................................................................................... 3
2.1 2016 BIEN HOA REMEDIAL TECHNOLOGIES EVALUATION.................................................... 3
2.2 TECHNOLOGY REVIEW AND ADVANCEMENTS SINCE RELEASE OF THE EA ................. 3
3 DEVELOPMENT OF ADDITIONAL SCREENING AND EVALUATION CRITERIA......................... 7
3.1 TREATMENT TECHNOLOGY SELECTION PROCESS................................................................... 7
3.2 STAGE 1: SCREENING CRITERIA ......................................................................................................... 7
3.3 STAGE 2: EVALUATION CRITERIA...................................................................................................... 8
4 SCREENING RESULTS........................................................................................................................................ 9
4.1 TCH ................................................................................................................................................................ 9
4.2 INCINERATION ......................................................................................................................................... 9
4.3 PLASMA ARC AND PYROLYSIS .......................................................................................................... 10
4.4 BASE CATALYZED DESORPTION ..................................................................................................... 10
4.5 SUPERCRITICAL AND SUBCRITICAL WATER TREATMENT ................................................... 10
4.6 GAS-PHASE CHEMICAL REDUCTION ............................................................................................. 11
4.7 MECHANO-CHEMICAL DESTRUCTION (MCD) .......................................................................... 11
5 STAKEHOLDER’S QUESTIONS/COMMENTS .......................................................................................... 12
6 CONCLUSIONS ................................................................................................................................................. 13
6.1 STAGE TWO EVALUATION OF TCH OPTIONS.......................................................................... 13
7 REFERENCE LISTING OF DATA AND INFORMATION ....................................................................... 14
APPENDICES
Appendix 1 Remedial Treatment Technologies Evaluation Criteria
Appendix 2 Evaluated Remedial Treatment Technologies (2016 EA)
Appendix 3 Output from Remedial Treatment Technologies Screening Tool
Appendix 4 Remedial Technologies Evaluation Tool
Appendix 5 Considerations in Applying Stage 2 Evaluation Criteria to TCH Options
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FINAL TM – TECHNOLOGY EVALUATION AND RECOMMENDED TREATMENT METHODS
LIST OF ACRONYMS AND ABBREVIATIONS
A&E Architect & Engineer
ARAR Applicable or Relevant and Appropriate Requirements
C Celsius
COC Contaminant of Concern
EA Environmental Assessment
GAC Granular Activated Carbon
GFH Granular Ferric Hydroxide
GVN Government of Vietnam
IPTD In Pile Thermal Desorption
kg Kilogram
m Meters
M Million
m3 Cubic Meters
MCD Mechano-Chemical Destruction
MCS Matrix Constituent Separator
MND Ministry of National Defense
MPPE Modified Polyphenylene Ether
NAPL Non-Aqueous Phase Liquids
NOX Nitrogen Oxide
POPS Persistent Organic Pollutants
ppt parts per trillion
QCVN National Technical Regulation
SVOC Semi-volatile Organic Compound
TCH Thermal Conductive Heating
TCVN Technical Committee of Vietnam (National Technical Standards)
TEQ Toxic Equivalents
TM Technical Memorandum
USAID United States Agency for International Development
USEPA United States Environmental Protection Agency
VOC Volatile Organic Compound
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EXECUTIVE SUMMARY
This Technical Memorandum (TM) presents the treatment technology recommended for the Dioxin
Remediation at Bien Hoa Airbase Area Project (Project) as agreed by Government of Vietnam (GVN)
stakeholders engaged with USAID in Project master planning.
The selection process was built on the technology evaluation conducted as part of the joint USAID-
Ministry of National Defense (MND) Environmental Assessment of Dioxin Contamination at Bien Hoa
Airbase dated May 3, 2016 (hereafter referred to as the “2016 EA”) (USAID 2016). The 2016 EA
evaluated 22 remedial technologies for treating contaminated soils from the Bien Hoa Airbase
(Airbase) area, screening them against three identified criteria. The 2016 EA screening identified three
remedial treatment technologies as viable alternatives, i.e., incineration, ex situ thermal conductive
heating (TCH), and mechano-chemical destruction (MCD).
Since publication of the EA in 2016, MND has conducted pilot tests at Bien Hoa Airbase evaluating
several treatment technologies, namely soil washing, a TCH-Matrix Constituent Separator (MCS)
technique, and a TCH technique involving hot air circulating steel tubes. The technology selection
process described in this TM utilized available results from these pilot tests as well information on
advancements in remedial treatment technologies since completion of the 2016 EA. Stakeholders
agreed that developments since completion of the 2016 EA provided no justification for adding new
remedial treatment technologies to the original list of 22 potential remedial technologies.
To re-evaluate the 22 potential remedial technologies, USAID and GVN stakeholders agreed on
criteria in seven major categories for assessing the technologies and a two-stage process to apply the
criteria. The first stage involved screening the technologies against nine criteria defined by the
stakeholders as “critical” to meeting Project objectives. It was agreed that only technologies meeting
all nine of these critical criteria would be considered further at a second evaluation stage. The second
stage involves assessing technologies that passed the first screening stage against the remaining
additional evaluation criteria using agreed upon weight factors.
Although three technologies were identified as viable in the 2016 EA assessment, only TCH was
determined to be viable as a result of the revised evaluation process since TCH was the only
technology that met all nine critical criteria. The MCD technology was eliminated from further
consideration, primarily due to a lack of proven treatment effectiveness over the range of dioxin
concentrations present at Bien Hoa and lack of GVN stakeholder acceptance. Although incineration
is a proven and mature technology, the high costs associated with the energy input requirements and
the lack of GVN stakeholder acceptance eliminated incineration from further consideration.
As with any remedial treatment technology, a number of TCH treatment techniques and
configurations could be utilized to meet Project requirements. Stakeholders agreed that USAID should
assess different TCH configurations submitted by offerors using the second stage evaluation criteria
as part of the USAID procurement process.
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1 INTRODUCTION
This TM: Technology Evaluation and Recommended Treatment Methods has been developed by the
A&E Bien Hoa Contractor for the US Agency for International Development (USAID) under Contract
No. AID-OAA-I-15-00053, Task Order No. 72044019F00001, in accordance with Section C–
Description/Specifications/ Statement of Work (SOW), Subsection C.5 Statement of Work,
Component 1 (CLIN 1), Task 1.2, Identify Approved Remedial Alternative for Soil Treatment.
The purpose of this TM is to summarize the process agreed with GVN stakeholders to evaluate
remedial technologies and recommend the technology or technologies that best addresses the dioxin
impacted soils in the Bien Hoa Airbase (Airbase) area. This document contains a review of previous
evaluations, identification of recent advancements in dioxin remediation, a description of the
stakeholder engagement that guided the evaluation process, and the results of agreed upon first stage
remedial technology screening.
Most technologies include multiple techniques and options for implementing the identified remedial
treatment technology. The goal of this TM is to identify treatment technologies that GVN stakeholders
found acceptable in meeting critical project criteria. It is not the intent of this document to identify
the best technique or equipment manufacturer to implement the identified technology or technologies.
The GVN mandated goal of remedial treatment at the Bien Hoa Airbase area is to effectively reduce
dioxin in the soils with concentrations equal to or greater than 1,200 parts per trillion (ppt) to a
concentration below 100 ppt. The 100 ppt remedial threshold was developed through consideration
of the Applicable or Relevant and Appropriate Requirements (ARARs) and equates to the lowest
allowable concentrations of dioxin in soils for the anticipated forestry land use on the Airbase, per
Vietnamese regulations (QCVN 45:2012/BTNMT). This threshold also maximizes the ability to use
treated material as fill or other material on the Airbase in formely contamined areas. Achieving lower
residual dioxin concentrations in treated material could allow even greater reuse on the Airbase.
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2 BACKGROUND
This section of the TM provides background on remedial technology evaluations performed as part of
previous efforts and USAID’s review of new information on potential treatment technologies.
1. Has the technology or strategy demonstrated dioxin destruction or containment on a scale larger
than a lab study, and from the range of concentrations measured in soils and sediments at the
Airbase to below the range of required MND-approved dioxin limits? (Required answer “Yes”)
2. Would full-scale costs be prohibitive or not competitive with other comparable technologies?
(Required answer “No”)
3. Is the technology or strategy expected to be acceptable to Vietnamese stakeholders? (Required
answer “Yes”)
Refer to Appendix 1 for the list of remedial treatment technologies that were evaluated in the 2016
EA.
The results of the 2016 EA screening identified three technologies that met all the screening criteria.
They include:
• Incineration,
• Ex situ Thermal Conductive Heating (TCH), and
• Mechano-chemical destruction (MCD).
In the 2016 EA, soil washing was originally eliminated from further consideration. At the time of
evaluation there was a lack of full-scale data to represent the maturity of the technology to treat the
range of dioxin concentrations found in the soil at the Airbase, and available data indicated that the
technology is not effective on soils that contain high fractions of silts and clays common in the Airbase
area. The discussion below summarizes additional data gathering efforts to further evaluate this
technology.
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than 100 ppt. The results confirmed the technology’s sensitivity to variations in grain size, and the
provided costs did not include treatment of filter cake or additional treatment of coarse fraction that
is above the 100 ppt treatment threshold. These pilot test results confirm the original conclusion of
the 2016 EA to eliminate soil washing from further consideration as a primary treatment technology.
Following extraction, photolysis, entailing UV light and use of a photolytic catalyst (titanium dioxide)
have been employed to oxidize dioxins on extracted soil particles. Oxidation improved with increasing
numbers of particles, suggesting improved contact with the catalyst, but decreased as the number of
particles continued to increase, suggesting that penetration of UV light was limited.
While offering promise, this technology is still not matured or scalable to large-scale soil treatment
and further confirms conclusions in the 2016 EA to eliminate soil washing techniques from further
consideration.
Ex situ TCH was identified in the 2016 EA as one of the three technologies to be considered for
implementation at the Bien Hoa Airbase. This technology was used successfully during the USAID–
GVN Environmental Remediation at the Danang Airport Project. There are numerous different
techniques and configurations for implementing TCH. The intent of this evaluation is not to single out
a single TCH technique to recommend for implementation. The discussions below are intended to
summarize the additional efforts to further evaluate the applicability of TCH.
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was conducted on three discrete 20 kg soil samples. MCS was also successfully utilized on a large-scale
(24,000 tons) dioxin-contaminated (average 8,600 ppt) soil/dredged coral project at the Johnston Atoll
US Air Force Base in the Pacific Ocean. Dioxin concentrations averaged 8,600 ppt. Definitive cost data
was not available. Vendor estimates in 2015 indicate costs below $500 per ton (Cooke 2015), while
more recent information (Thermodyne 2018) suggests that the cost could be closer to $650 per ton.
HAEMERS TECHNOLOGIES
The Center for Technology Environmental Treatment (CTET), the GAET Corporation, and Haemers
Technologies SA (Haemers) established a joint operation to test the effectiveness of Haemers’ TCH
method on dioxin-contaminated soils at Bien Hoa Airbase. In the Haemers’ process, the soil is heated
by circulating hot air through stainless steel tubes placed horizontally in the soil. The soil temperature
is raised to a level at which contaminants vaporize. Vapors containing volatilized contaminants are
recovered through a soil vapor extraction network. During the pilot test at Bien Hoa, kerosene was
used to fuel the heating system. The vapors were thermally oxidized. The pilot test activities began in
2019 but were interrupted by COVID-19. When results are available, they will be reviewed to further
evaluate the applicability of this method for implementation at Bien Hoa.
MCS and Haemers technologies are considered remedial treatment techniques under the umbrella of
TCH technology. While no definite results from this pilot test are available to date, there is no reason
to suspect that results from this pilot would change the recommendation to further consider TCH as
a viable alternative for dioxin treatment at Bien Hoa.
TCH SUMMARY
This TM does not recommend any of these techniques over other TCH techniques, at this time.
Rather, these latest results confirm the viability of TCH for Bien Hoa. Additionally, in situ TCH remains
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under the umbrella of TCH technologies to consider in the future. In situ configurations were
eliminated from further consideration in the 2016 EA due to the large areas with shallow depths to
be treated, creating prohibitively excessive heat loss. This TM recommends that in situ remain an
option under the TCH technologies, since the overall technology has proven to be effective at dioxin
reduction. If conditions arise at Bien Hoa that suit in situ treatment, it is recommended the approach
be considered further.
2.2.3 FLUE GAS CONTROL TECHNOLOGY
In addition to continued development of technologies for the treatment of dioxin-impacted soil, much
research and development has focused on controlling dioxin emissions for existing soil treatment
technologies such as incineration. While the formation of dioxins in flue gas can be controlled, in part,
through manipulation of process temperature, residence time, turbulence within the combustion
chamber and flue, additional control technologies can further protect against dioxins in emissions.
Some of the flue gas control technologies available include:
The use of electron irradiation has been tested for incinerator flue gas. Flue gases were subjected to
irradiation via an electron-beam that forms hydroxyl radicals through interaction on flue gas macro
components. Significant decomposition for all PCDD isomers was observed. The technology
reportedly can reduce process dioxins by up to 99% (Hirota and Kojima, 2005). Decomposition
products include only organic acids. Low energy consumption was required. The technology is simple
to install with incinerators.
Following the review of advancements in remedial treatment technologies and on-site pilot testing, no
remedial treatment technologies were added to the list of 22 potential remedial technologies cited in
the 2016 EA, but the results of these data gathering efforts have been incorporated in the screening
activities discussed in Section 3.
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3 DEVELOPMENT OF ADDITIONAL SCREENING AND
EVALUATION CRITERIA
Building on the joint GVN-USAID 2016 EA and the subsequent USAID review of new research and
advancements outlined in Section 2, this section outlines the subsequent treatment technology
selection process developed by USAID with GVN stakeholders participating in the Dioxin Remediation
of the Bien Hoa Airbase Area Project Masterplan Roadmap meetings.
Initially the USAID A&E Contractor developed a list of 13 criteria in seven major categories, in addition
to the original three criteria used in the 2016 EA for technology evaluation. USAID shared these
proposed criteria with GVN stakeholders participating in the Masterplan Roadmap Meeting No. 2 on
November 18, 2019. After presentation of the proposed criteria, the A&E Contractor facilitated a
group discussion with the stakeholders to identify additional criteria, refine the criteria, and develop a
procedure to use the criteria to evaluate technology alternatives. USAID summarized the resulting
proposed 22 criteria in a Meeting No. 2 summary shared with stakeholders after the meeting.
Following discussions with ADAFC, USAID proposed in the summary to apply these criteria in a two-
stage process.
General
• Overall protection of human health and environment (1A)
• Ability to comply with Project Applicable or Relevant and Appropriate Requirements (ARARs)
agreed by GVN stakeholders (1B)
Effectiveness
• Effectiveness in treating relevant range of dioxin concentrations (2B)
• Treatment of dioxin must satisfy QCVN and TCVN (2D)
• By-products must be completely treated/destroyed (2E)
Implementability
• Scalability for estimated volumes of soil and sediment (3A)
• Meets timeline for treating estimated volumes of soil and sediment (3B)
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Cost
• Within budget (5B)
Acceptance
• GVN stakeholder acceptance (7A)
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4 SCREENING RESULTS
The USAID Bien Hoa A&E Contractor assessed the 22 remedial technologies originally identified in
the 2016 EA against the nine Stage 1 screening criteria listed in Section 3.2. The technologies are listed
in Appendix 2, along with a brief description of each. TCH was the only technology that was
determined to meet all nine critical Stage 1 screening criteria. This finding eliminated the need to
advance to the second stage of the technology evaluation process. Instead, the remaining criteria may
be considered during USAID procurement to distinguish among different applications of TCH.
An assessment for each of the remaining technologies on why they failed the screening process is
included in the Appendix 3 results table. Many of the technologies failed more than half of the criteria,
indicating they should not be considered further. However, there were five technologies that met all
but two of the screening criteria. All five of these technologies were rejected for projected costs and
lack of GVN stakeholder acceptance. Since these technologies meet the treatment criteria, further
discussion of the process details, advantages, and disadvantages of each is provided below. For
comparison TCH technology is described first. Mechano-chemical destruction is discussed based on
its initial promise as an effective treatment technology, however during this review it was found to
only met four of the nine screening criteria.
4.1 TCH
TCH can be used to either cause desorption of dioxin or to thermally degrade it. Desorption is
accomplished by heating contaminated soils to approximately 335 ͦC. During the TCH process, soils
and sediments are directly heated for a sufficient duration to extract and potentially destroy target
constituents of concern (COC). Any extracted dioxin mass can then be removed from off-gas,
condensate, and leachate by conventional treatment technologies. A TCH system may be designed to
induce high temperature for the destruction of COCs or lower temperatures for the desorption of
COCs only (followed by destruction along the treatment train). A wide variety of energy sources may
be used to power the system.
One example of the successful use of TCH is the ex situ In Pile Thermal Desorption (IPTD) system
used at the Da Nang Airport remediation project (USAID 2015a, USAID 2015b, USAID 2015c) where
soils were placed in an insulated and capped pile, and heated.
In the 2016 EA, costs for the Ex Situ TCH Alternative were estimated to be $539 million (M) for a
contaminated soil volume of 408,500 cubic meters (m3). Based on a soil density of 1.5 tonne/m3, this
equates to a treatment cost of approximately $880 per tonne. In 2018, USAID commissioned an
independent evaluation of USAID’s Environmental Remediation at Danang Airport that found the
treatment cost for IPTD to be $669 per tonne, and $1,137 per m3, respectively (USAID 2018).
4.2 INCINERATION
Although incineration technology is mature and established, it is not anticipated to be cost effective
(due to high energy and capital equipment costs). Among the potential treatment technologies using
applied heat for treatment, incineration is projected to bear more upfront capital costs, compared to
other technologies such as TCH. In order for incineration to volatilize and destroy dioxins, high
temperatures (ranging from approximately 870 to 1,200°C) are required. In comparison, TCH
requires soil to be heated to a target temperature of 335°C. The requirement for significant additional
heat alone suggests that more robust equipment and energy input would be necessary for incineration
to be effective. The resulting costs of this type of operation are expected to be greater than those
associated with TCH technologies. In the 2016 EA, costs for the Incineration/Ex Situ Thermal
Treatment Alternative were estimated to be $666 M for a contaminated soil volume of 408,500 m3.
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Based on a soil density of 1.5 tonne/m3, this equates to a treatment cost of approximately $1,087 per
tonne. In 2018, the costs for on-site incineration were found to range from $649 – 4,967 per tonne
(USAID 2018). Additionally, GVN concerns associated with the potential for heavy metals in the fly
ash cause this technology to fail the GVN Acceptance criteria.
Another significant factor with the potential to adversely affect the supercritical/subcritical water
treatment processes is high organic loading, which can slow the treatment process throughput. Much
of the soil to be treated will likely contain roots, stumps, and other organic debris, since the treatment
areas will be cleared but not grubbed prior to excavation. This material would certainly introduce a
high organic loading to the treatment train. As a preparation step, mechanical separation may be
required for the organic debris, which in turn would require separate treatment as an additional waste
stream.
As such, both supercritical and subcritical water treatment would require significant pre- and post-
treatment processes, which would introduce significant effort and cost. Therefore, this technology
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was not retained because of high expected costs relative to other treatment technologies. The
excessive costs also result in an unfavorable assessment by the GVN stakeholders.
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5 STAKEHOLDER’S QUESTIONS/COMMENTS
The results of the screening assessment were presented to the stakeholders at Roadmap Meeting
No. 3. The conclusion that TCH was the only viable technology raised several questions about the
technology associated with experiences with the TCH technique implemented for Environmental
Remediation at the Danang Airport Project.
Table 5-1 summarizes all questions and comments by the stakeholders as well as USAID’s
answers/explanations.
# QUESTIONS/COMMENTS ANSWERS/EXPLANATION
1 TCH in Da Nang generated huge amount These are not problems inherent to TCH technology but
of spent GAC and contaminated resulted from the manner in which TCH was applied at
concrete, how USAID addresses this issue Danang. Based on the lessons learned from Danang, USAID
in Bien Hoa if still recommend using TCH will address these and other concerns in the selection of
particular approaches to TCH application for Bien Hoa using
agreed Stage 2 selection criteria. For example, proposals that
use use alternate vapor control technology such as thermal
oxidizer that avoids use of excess spent GAC, while increasing
energy costs, may be evaluated as preferable. Regarding
contaminated concrete, dioxins are anticipated to be on or
slightly beneath the surface such that removal and disposal of
surficial concrete could significantly minimize this waste
stream as to be confirmed through concrete analysis.
2 TCH in Da Nang create several Using Stage 2 selection criteria, proposals that address non-
exceedances, how USAID addresses this uniform heating and corresponding non-uniform dioxin
issue in Bien Hoa if still recommend using reduction and improve cover design and variability in heating
TCH layers within piles would be preferred to improve
performance and avoid exceedances.
3 Is it possible to combine TCH with other Some rejected treatment technologies could be theoretically
rejected technology to advance the combined with TCH to additionally treat waste streams. For
benefits and save cost? example, batch treatment using plasma arc pyrolysis
specifically for the treatment of drainage fluids could provide
effective treatment and waste reduction. However, cost and
other Stage 2 criteria will be used to evaluate such proposed
applications of a modified TCH treatment system.
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6 CONCLUSIONS
TCH is the agreed remedial treatment technology selected for treatment of the Bien Hoa Airbase
area dioxin-impacted soils, based on the stakeholder-approved screening criteria. Since this technology
was the only one to meet all critical screening criteria, the second stage of the evaluation process was
not implemented for technology comparison purposes. However, the TCH technology was rated and
scored with the evaluation criteria and weight factors assigned by the stakeholders at the Roadmap
No. 2 Meeting. This score is included in Appendix 4 and can be assessed for comparison purposes if
other technologies are identified in the future as meeting all screening criteria.
With any remedial treatment technology, there are a number of configurations that can be utilized to
meet the remedial outcome. TCH options that should be considered during the procurement phase
are presented below, though the list is not intended to be exhaustive.
Stakeholders agreed that USAID should assess different TCH configurations submitted by offerors
using the second stage evaluation criteria as part of the USAID procurement process. The USAID
Bien Hoa A&E Contractor provides some recommendations on how some of these criteria should
be considered along with lessons learned from the TCH application in Danang in Appendix 5.
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7 REFERENCE LISTING OF DATA AND INFORMATION
BEM. 2007. Mitigating the Impact of Dioxin-contaminated "Hot Spots" in Vietnam – Assessment of
Alternative Remediation Technologies and Work Plan for a Future Feasibility Study for Da Nang
Airport. Report number 07-GSA34CNEF, December, 40 pp.
Cooke, R. J., Man-West Environmental Group Ltd. 2015. Independent Expert Evaluation of Three
Pilot/Laboratory Scale Technology Demonstrations on Dioxin Contaminated Soil Destruction from
the Bien Hoa Airbase in Vietnam. March.
Hirota K, Kojima T. 2005. Decomposition behavior of PCDD/F isomers in incinerator gases under
electron-beam irradiation. Bull Chem Soc Jpn.; 78: 1685-90.
GVN/USAID (CDM International, Inc. and Hatfield Consultants). 2016. Environmental Assessment of
Dioxin Contamination at Bien Hoa Airbase. May 3, 2016.
Ministry of National Defence. 2019. Decision No. 3869/QD-BQP on Approval of the Investment
project and the plan for selection of the “Dioxin Remediation in Bien Hoa Airbase – Phase 1” Project
with non-refundable Official Development Assistance from the United States of America, September
6, 2019
Shimizu Corporation. 2019. Soil Washing Pilot Test Evaluation Report, Dioxin Remediation at Bien
Hoa Airbase Area Project. November 15, 2019.
Thermodyne Technologies Inc. 2018. The MCSTM Technology: An Innovative, Flexible Ex Situ Agent
Orange / Dioxin Contaminated Soil Remediation Solution. 2018.
UNDP. 2009b. Technology Review for Dioxin Contaminated Soils and Sludge, Vietnam. Version 2,
February, 151 pp.
USAID. 2015a. Initial Environmental Examination Amendment #1: Environmental and Gender
Assessments for Dioxin Remediation at Bien Hoa Airport. Asia 15-040. Hanoi, Vietnam: U.S. Agency
for International Development in Vietnam. Hanoi, Vietnam.
USAID. 2015b. Environmental Scoping Statement. Environmental Assessment at Bien Hoa Airbase.
Hanoi, Vietnam: U.S. Agency for International Development in Vietnam. Hanoi, Vietnam.
USAID. 2015c. IPTD® Final Report – Phase I. In Pile Thermal Desorption® (IPTD®) Services, Da
Nang Airport, Vietnam Contract No. Aid-486-C-13-00001. October 20. Hanoi, Vietnam: U.S. Agency
for International Development in Vietnam. Hanoi, Vietnam.
USAID. 2016. Environmental Assessment of Dioxin Contamination at Bien Hoa Airbase. Hanoi,
Vietnam: U.S. Agency for International Development in Vietnam. Hanoi, Vietnam.USEPA. 1998a. Cost
and Performance Report – Incineration at the Baird and McGuire Superfund Site, Holbrook,
Massachusetts.
USAID (Intera, LLC) 2018. Performance Evaluation of USAID’s Dioxin Remediation at Danang Airport.
October.
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USEPA. 1998b. Cost and Performance Report – Incineration at the Times Beach Superfund Site, Times
Beach, Missouri. USEPA. 2005. Using Non-Thermal Plasma to Control Air Pollutants. Accessed at:
http://www3.epa.gov/ttncatc1/dir1/fnonthrm.pdf
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APPENDICES
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APPENDIX 1. REMEDIAL TECHNOLOGIES SCREENING AND EVALUATION CRITERIA
Criteria in black text were authored by the A&E Contractor. Nhà thầu
Criteria in blue text were developed with stakeholders during the Masterplan Roadmap Meeting No. 2. Nhóm 1 Nhóm 2 Nhóm 3 Nhóm 4 Stakeholder
TV&TK
Group 1 Group 2 Group 3 Group 4 Average
A&E
Normalized
Contractor
to 100%
Ưu tiên đề
xuất Ưu tiên Ưu tiên Ưu tiên Ưu tiên Ưu tiên
Tiêu chí (Trọng số) (Trọng số) (Trọng số) (Trọng số) (Trọng số) (Trọng số)
Criteria Proposed Priority Priority Priority Priority Priority
Priority (Weight (Weight (Weight (Weight (Weight
(Weight Factor) Factor) Factor) Factor) Factor)
Factor)
Tổng thể
General
1.A. Bảo vệ toàn diện sức khỏe con người và môi trường Có/Không Có/Không Có/Không Có/Không Có/Không Có/Không
1.A. Overall Protection of Human Health and Environment Yes/No Yes/No Yes/No Yes/No Yes/No Yes/No
1.B. Tuân thủ ARARs Có/Không Có/Không Có/Không Có/Không Có/Không Có/Không
1.B. Compliance with ARARs Yes/No Yes/No Yes/No Yes/No Yes/No Yes/No
Có/Không
2.B. Phạm vi xử lý nồng độ dioxin 5% Có/Không Có/Không Có/Không Có/Không
Yes/No
2.B. Range of Dioxin Concentrations Yes/No Yes/No Yes/No Yes/No
3.A. Quy mô đáp ứng khối lượng đất và trầm tích dự kiến Có/Không Có/Không Có/Không Có/Không Có/Không Có/Không
3.A. Scalability for Estimated Volumes of Soil/Sediment Yes/No Yes/No Yes/No Yes/No Yes/No Yes/No
3.B. Thời gian xử lý khối lượng đất và trầm tích dự kiến Có/Không Có/Không Có/Không Có/Không Có/Không Có/Không
3.B. Timeline for Treating Estimated Volumes of Soil/Sediment Yes/No Yes/No Yes/No Yes/No Yes/No Yes/No
3.C. Khả năng hoạt động trong mùa khô và mưa 15% 8% 5% 5% 5% 7%
3.C. Ability to Operate in Dry and Rainy Seasons and tropical storms
3D. Tính nhạy cảm đối với lý tính của đất và trầm tích
3D. Sensitivity to physical properties of soil and sediment 1% 5% 5% 5% 4%
3E. Cần xem lại sự có sẵn của nguồn cung cấp đủ điện/năng lượng
3E. Should consider the availability of sufficient power/energy supply 2% 0% 0% 5% 2%
3F. Công nghệ xử lý cần được thương mại hóa cho chất ô nhiễm hữu cơ khó phân hủy và
đã được thử nghiệm tại hiện trường 6% 5% 5% 5% 5%
3F. Treatment technology should be commercialized for POPS or have been tested on site
4.A. Giảm thiểu tiêu thụ nguồn nguyên nhiên liệu 15% 10% 5% 4% 10% 9%
4.A. Minimization of Consumption of Resources
Chi phí
Cost
5.A. Dự kiến chi phí khả dĩ 15% 10% 10% 15% 10% 11%
5.A. Estimate of Probable Cost
6.A. Giảm thiểu phát thải tồn dư 15% 6% 13% 5% 10% 10%
6.A. Minimization of Byproducts
6.B. Nhu cầu quan trắc lâu dài hoặc kiểm soát thể chế sau hoạt động 10% 2% 5% 10% 5% 8%
6.B. Need for LTM or ICs following Implementation
Chấp thuận
Acceptance
7.A. Chấp thuận của bên liên quan thuộc CPVN Có/Không Có/Không Có/Không
5% 5% 7%
7.A. GVN Stakeholder Acceptance Yes/No Yes/No Yes/No
TỔNG
100% 100% 100% 100% 100% 100%
TOTAL
A–E SERVICES FOR DIOXIN REMEDIATION AT BIEN HOA AIRBASE AREA PROJECT | 1
FINAL TM – TECHNOLOGY EVALUATION AND RECOMMENDED TREATMENT METHODS
APPENDIX 2. EVALUATED REMEDIAL TREATMENT TECHNOLOGIES (2016 EA)
TREATMENT BASIC DESCRIPTION
TECHNOLOGY
Uses high temperatures (870 to 1,200 degrees Celsius (°C) to volatilize dioxin from
INCINERATION
contaminated soil and sediment, and then oxidize it in the gaseous phase.
THERMAL CONDUCTIVE Use thermal energy to volatilize and desorb dioxins from contaminated materials, and in
HEATING (TCH) some cases, induce chemical reactions that degrade dioxin.
Creates a thermal plasma field by applying a large electric current through an oxygen-
PLASMA ARC AND deficient gas. Depending on the type of system and the temperature reached, this
PYROLYSIS technology can be used to pyrolyze waste material, producing a slag and gaseous end
products.
MECHANO-CHEMICAL Employs mechanical energy to initiate chemical reactions. Soil crystal damage caused by
the vibration leads to the formation of highly-reactive free radicals, which react with
DESTRUCTION (MCD)
organic molecules in the vicinity.
BASE CATALYZED A dechlorination process wherein dioxin is desorbed from contaminated soil and
DESORPTION dewatered sediments using heat (approximately 326 to 500°C) and sodium bicarbonate.
SUPERCRITICAL AND Water in a supercritical state (above 374°C and 22 megapascals) can be used to facilitate
SUBCRITICAL WATER oxidation of organics, and subcritical water (pressurized into a liquid above 100°C) can
TREATMENT be used to extract dioxin from soils and sediments.
During this process, materials are heated above 1,590°C, which degrades organic
VITRIFICATION contaminants via pyrolysis and dechlorination reactions, or locks them into a vitreous
and crystalline matrix with no leachability.
Some versions work by segregating smaller diameter particles with higher organic
SOIL WASHING / fractions (e.g., silts and clays), which are more likely to contain dioxins and other organic
LIQUEFIED GAS contaminants, from larger particles with lesser organic fractions (e.g., sands and gravels).
EXTRACTION Other variations use the addition of a solvents such as ethanol to extract of dioxin from
contaminated soil and sediments for separate treatment.
Mixes hydrogen gas with chlorinated organic compounds, such as PCBs, at temperatures
GAS-PHASE CHEMICAL above 850°C and low pressure and results in decomposition into primarily methane and
REDUCTION hydrogen chloride with minor amounts of other low molecular-weight hydrocarbons,
including benzene.
IN SITU
In-place biological degradation by micro-organisms over time.
BIOREMEDIATION
EX SITU CHEMICAL Uses chemical oxidation or reduction processes not described elsewhere in this table,
REDUCTION / especially those used more typically for remediation which includes: potassium
OXIDATION permanganate, persulfate, hydrogen peroxide (i.e. Fenton’s reagent), and ozone.
ADVANCED Aqueous-phase oxidation techniques utilizing ultraviolet (UV) light, photolytic catalysts
OXIDATION such as TiO2, and/or varying oxidants (e.g. peroxide, ozone).
BIOLOGICAL /
Aqueous-phase slurry reactors where partial oxidation was followed by bioremediation.
CHEMICAL HYBRIDS
Solvate electron solution (typically generated via dissolution of alkali or alkaline earth
SOLVATED ELECTRON metals in anhydrous ammonia at room temperature and elevated pressure) is then placed
TECHNOLOGY in a cell with soil or sediment where it acts as a dehalogenating agent, degrading
contaminants into metal salts and simple hydrocarbon compounds.
COPPER-MEDIATED Copper is used to catalyze treatment of dioxin-contaminated solutions via hydrogenation
DESTRUCTION and dichlorination after pre-treatment with thermal desorption.
Low-toxicity organic solvent (e.g. isooctane, hexane, cyclohexane) is sprayed on the soils
IN SITU PHOTOLYSIS and sediments. As the solvent volatilizes, dioxin molecules are migrated upwards, where
they can be photodegraded by ultraviolet rays from the sun.
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FINAL TM – TECHNOLOGY EVALUATION AND RECOMMENDED TREATMENT METHODS
TREATMENT BASIC DESCRIPTION
TECHNOLOGY
Utilizes microwave-based heating to reach temperatures under 100°C to generate steam
STEAM DISTILLATION and remove organics from soils.
RADIOLYTIC Relies on high-energy electron beams and gamma rays to ionize soil, using surfactants and
DEGRADATION water.
HYDROTHERMAL Involves dissolution of contaminated material in sodium hydroxide and methanol solution
TREATMENT at 300°C for 20 minutes.
Note:
Basic descriptions summarized from 2016 Environmental Assessment
A–E SERVICES FOR DIOXIN REMEDIATION AT BIEN HOA AIRBASE AREA PROJECT | 3
FINAL TM – TECHNOLOGY EVALUATION AND RECOMMENDED TREATMENT METHODS
APPENDIX 3. OUTPUT FROM REMEDIAL TREATMENT TECHNOLOGIES SCREENING
A–E SERVICES FOR DIOXIN REMEDIATION AT BIEN HOA AIRBASE AREA PROJECT | 4
FINAL TM – TECHNOLOGY EVALUATION AND RECOMMENDED TREATMENT METHODS
SCREENING CRITERIA • Retain
TREATMENT
TECHNOLOGY X Reject FINDINGS AND
FOR DIOXINS IN
SOIL/SEDIMENT
GENERAL (1A AND 1B) EFFECTIVENESS (2B) IMPLEMENTABILITY (3A AND 3B) COST (5B) ACCEPTANCE (7A) RATIONALE
? ADVANTAGE/DISADVANTAGES ? ADVANTAGE/DISADVANTAGES ? ADVANTAGE/DISADVANTAGES ? ADVANTAGE/DISADVANTAGES ? ADVANTAGE/DISADVANTAGES
- For excavated soils, exposure - Ex sit treatment within insulated - Scalable for large volumes of soil, but As presented in the 2016 EA, the - Stakeholders likely to accept based Proven and very effective
pathways to soil/sediment will be structure would improve control over limited by available electric power IPTD of the base soil volume of on similar successful application ad Da technology for application to
eliminated TCH process - Estimate 14 years for this alternative. 408,500 m3 was estimated to cost Nang, large volumes of high-
• - Capable of meeting dioxin limits for • - >95% destruction efficiency in piles • - Individual pile could handle 50,000 m3 • $539M. Based on a soil density of 1.5 • concentration dioxin-
THERMAL soil/sediment with relatively low contaminants in at a time tonne/m3, this equates to an impacted soilProven and very
CONDUCTIVE - Risks associated with generation of exhaust vapors estimated unit cost of $880 per • effective
HEATING (TCH) liquid condensate waste - Will generate solid and liquid waste tonne. Estimated to be $539M to t technology for application to
- Risks associated with exhaust from streams requiring treatment and disposal $640M total a
vapor treatment system - $669 per tonne or $1,137 per m3 large volume of high-
(USAID 2018) concentration
dioxin-impacted soil
- Not applicable for soils - For liquid waste treatment, reported - PAP system cannot process soil, -Likely to be expensive for full-scale Stakeholders won't accept for soil Not applicable for full-scale
- Likely capable of meeting ARARs for to be clean burning with most toxic only liquids treatment treatment treatment of dioxin-impacted
• liquid waste only • constituents having been destroyed • - Not cost competative soil
- Requires scubber for HCL in X X X
PLASMA ARC discharge
PYROLYSIS (PAP)
(for liquid waste)
COPPER-MEDIATED - Potential exposure risk from - Copper found to catalyze the d - Not proven for full-scale soil - Developing technolgy with full scale Stakeholders unlikely to accept Not demonstrated for full-
DESTRUCTION byproduct PCDD/Fs dechlorination/ hydrogenation of application (UNDP 2009a and UNDP costs not yet developed developing technology not proven for scale application for the
- Potentially capable of meeting ARARs octaCDD and octaCDF at low 2009b) field-scale application treatment of dioxin-impacted
(for small scale treatment) ttemperatures soil
X X - Reaction leads to mixtures of X X X X
PCDD/PCDF congeners, or potentially
to below limits of detection
A–E SERVICES FOR DIOXIN REMEDIATION AT BIEN HOA AIRBASE AREA PROJECT | 5
FINAL TM – TECHNOLOGY EVALUATION AND RECOMMENDED TREATMENT METHODS
SCREENING CRITERIA • Retain
TREATMENT
TECHNOLOGY X Reject FINDINGS AND
FOR DIOXINS IN
SOIL/SEDIMENT
GENERAL (1A AND 1B) EFFECTIVENESS (2B) IMPLEMENTABILITY (3A AND 3B) COST (5B) ACCEPTANCE (7A) RATIONALE
? ADVANTAGE/DISADVANTAGES ? ADVANTAGE/DISADVANTAGES ? ADVANTAGE/DISADVANTAGES ? ADVANTAGE/DISADVANTAGES ? ADVANTAGE/DISADVANTAGES
SUPERCRITICAL - For excavated soils, exposure - Extremely efficient solvent for organic - Not currently scalable for large - Costs increased from heating of - Stakeholders unllikely to accept a Not demonstrated for full-
AND SUBCRITICAL pathways to soil/sediment would be pollutants such as dioxins treatment volumes water to subcritical/supercritical technology that has not been proven scale application for the
WATER eliminated - At 300oC (subcritical water) shown to Process moderately fast conditions for applicaton to full-scale treatment of dioxin-impacted
TREATMENT - Capable of meeting dioxin limits for extract up to 95% dioxins from soils - Requires temperatures slightly to - Based on only theoretical or soil
soil/sediment Removal rates vary among soil types moderately higher than for TCH laboratory testing, costs for full-scale
- Risks associated with dioxin-impacted - Supercritical water likely to be even applicaton unknown
solvent extract more effective (98%-99.97% DREs - Energy (cost) requirements reduced
Potential to meet ARARs reported), and results in hydroxyl if organic matter present (1%-20%)in
• • radical formation (super critical water • soils
oxidation [SCWO] (see ex-situ - Higher percentage organic matter
chemical oxidation/reduction would suggest incineration as more
technology), improving viability of this economic
technology - Specific costs were not identified,
- Does not require addition of toxic X but the amount of pre- and post- X X
solvents and associated potential processing required to conduct this
byproducts, except potentially for extraction and treatment in a liquid
supercritical application with hydroxyl for the anticipated quantity of
radical formation contaminated material would be very
Potential for PCDD/F byproducts significant.
- High expected costs relative to other
treatment technologies.
PHYSICAL DECHLORINATION METHODS
IN SITU - Reliance upon photolysis (UV - Effective for moderate to low dioxin No full-scale applications identified - Costs would increase with this Community unlikely to accept Not demonstrated for full-
PHOTOLYSIS radiation) alone is unlikely to concentrations - Photolysis is not fast, which can lead technology based on requirement to potential for increasingly toxic dioxin scale application for the
significantly reduce exposure risks - Even when photolysis combined with to increasingly toxic intermediates process soil in multiple thin layers, thus intermediates (e.g., 2,3,7,8-TCDD) treatment of dioxin-impacted
from dioxin-impacted soil solvent desorption, DRE of 40-85% - Implementabe for shallow layers of increasing time frame for treatment soil
- Addition of solvents or surfactants reported in soil soil, but depth of treatment limited - Solvent costs high for full-scale soil
will improve reduction in exposure - Photolysis of solvent wash water - only effective in top 5-6 mm of soil, extraction/photolysis
risk reported removal of 90% to 99.8% TEQ. thus requiring solvent extraction to
- Risks associated with generation and - Photolysis only effective for shallow bring dioxins to surface
handling of solvent wash solution soil, and resulting dechlorination can - Full scale application requires large
X X result in intermediate, more highly X areas to spread out dioxin impacted X X X
toxic congeners (e.g., 2,3,7,8-TCDD) soil and solvents
-Sunlight based photolysis can take up
to 30 days per treated soil layer
RADIOLYTIC - For soil treated, exposure risks likely - Effective for moderate to low dioxin -Has been applied at bench scale (e.g., Costs comparable with incineration Community unlikely to accept Not demonstrated for full-
DEGRADATION to be significantly reduced, pending concentrations Love Canal) potential for increasingly toxic dioxin scale application for the
confirmation sampling - DRE of 92% - 99% - As with photolysis, destruction is intermediates (e.g., 2,3,7,8-TCDD) treatment of dioxin-impacted
- One study reported 92% DRE 100 ppb relatively slow soil
TCDD
- Penetrates and treats deeper into soil
as compared with photolysis, but still
X X only effective for relatively shallow soil X X X X
layers
- Potential generation of increasingly
toxic dioxins (e.g., 2,3,7,8-TDD)
resulting from dechlorination
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FINAL TM – TECHNOLOGY EVALUATION AND RECOMMENDED TREATMENT METHODS
SCREENING CRITERIA • Retain
TREATMENT
TECHNOLOGY FOR X Reject FINDINGS AND
DIOXINS IN
SOIL/SEDIMENT
GENERAL (1A AND 1B) EFFECTIVENESS (2B) IMPLEMENTABILITY (3A AND 3B) COST (5B) ACCEPTANCE (7A) RATIONALE
? ADVANTAGE/DISADVANTAGES ? ADVANTAGE/DISADVANTAGES ? ADVANTAGE/DISADVANTAGES ? ADVANTAGE/DISADVANTAGES ? ADVANTAGE/DISADVANTAGES
CHEMICAL DECHLORINATION METHODS
BASE CATALYZED - Exposure risks largely removed from - Applicable to moderate Applied at bench scale - Uses less expensive chemicals as - Stakeholders unlikely to accept based Not demonstrated for full-
DESORPTION/ treated soil concentrations of dioxins - Currently not scalable for large compared with other chemical-based on limited field scale testing scale application for the
DECOMPOSITION - Potential exposure risk increase from - Destruction and removal efficiencies treatment volumes (data from bench processes - Not acceptable to GVN during treatment of dioxin-
(BCD) dioxin volatilization during treatment, higher than 99.5% have been achieved in testing) - Further development and discussions conducted as part of impacted soil
which is mitigated through subsequent bench testing on soil/sediment Process is robust and reasonably fast optmization of technololgy could development of the EA for the Danang
• fluids treatment • - Results in significant volatization of • result in cost decrease Airpor remediation project
- For moderately impacted soil, likely dioxins from soils during process that - Waste associated with excess alkali
capable to meet ARARs require solvent extraction from and caron would require menagement
condensate and subsequent treatment X (landfilling, recylcing, and/or reuse), X X
- Significant waste associated with which would increase costs beyond
excess alkali and carbon those reported by others
- $2,320–5,205 per tonne
MECHANO-CHEMICAL - Based on studies with this - Bench tests with milling have shown - More testing needed for full-scale - Developing technollogy that could Stakeholders unlikley to accept Not demonstrated for full-
DESTRUCTION (MCD) technology, exposure risk to impacted 99% DRE for dioxins in soil applicatrion be cost effective technololgy not proven at field scale scale application for the
soils/sediment may be mitigated - Only trace tetra through hepta- Process is reasonably fast Use of less expensive chemicals treatment of dioxin-
however, results varied with dioxin in- CDD/F degradation products observed - Room temperature applicaton impacted soil
feed concentration - Does not require addition of toxic • • eliminates heating costs
- Capable of achieving dioxin limits for chemicals, does not result in toxic
treated soil/sediment (small scale byproducts
X treatment), though perhaps not X - 2012 study from the Airbase indicated X X
consistently that DRE was sensitive to in-feed soil
dioxin concentrations. Claim of 99.99%
DRE not consistent.
CHEMICAL OXIDATION/REDUCTION TECHNIQUES
EX SITU CHEMICAL - For treated soil/sediment, exposure - Applicable to moderate to low dioxin - Scalable for large volumes of dioxin- - Reagent costs for treatment of large Stakeholders unlikely to accept While demonstrated for
REDUCTION / risks largely eliminated depending on concentrations impacted soil volumes of soil likely to be high potential for byproduct production full-scale application to
OXIDATION extent of treatment - more effective for less chlorinated - Chemical oxidation while theoretically - Non-specific nature of chemical from incomplete oxidation in treated dioxin-impacted soils, DRE
- Exposure risks remain for soils that dioxins (e.g., 2,3,7,8-TCDD), but less rapid, is slowed in presence of dissolved reagents results in high costs due to soils being considered as backfill is low and unlikely to meet
achieve only partial dioxane reduction effective for more highly chlorinated organic carbon, carbonates, and other reagent scavengers ARARs
(i.e., through hydroxyl radical dioxins (e.g., OCDD) oxidant scavangers
production) - In bench testing, DRE for dioxins in - Approaches optimizing contact with
Unlikely to meet ARARs soil ranged from 5% - 85% dioxins in soils are most implementable
- Insufficient reagent dosage can result (i.e., ozone sparging, calcium peroxide
in creation of chlorinated byproducts soil blending)
- Ozone (gas phase) treatment of soils - depth limitations for applicability (e.g,
X X can be more effective as compared with X 15 feet for typical soil blending) X X X
liquid-phase reagents
- Field application using alternative
reagent (calcium peroxide),
demonstrated 64% reduction in dioxins
(liquid-phase with soil blending for
optimal contact)
ADVANCED Limited application to soils suggests - Use of Fenton's reagent and UV light - Not scaleable for treatment of large - Effectiveness of advanced oxidation Stakeholders unlikely to accept use for Not applicable for full-scale
OXIDATION unlikely use for reducing exposure suggested for dioxins volumes of soil may reduce overall reagent costs as soil treatment treatment of dioxin-
(primarily for water risks in soil - Most effective for water treatment, - Most applicable for water treatment, compared with ex-situ chemical impacted soil
treatment) but soil treatment using thin layers and but can be implemented for soil oxidaton
sunlight have been tested (only 25% treatment (thin layers exposed to - UV light reduced oxidant dosage
dioxine DRE) sunlight) requirement through additional
- Applicable to moderate to low dioxin hydroxyl radical formation
concentrations - Chemical reagents non-specific
X X 95% 2,3,7,8-PCDD/Fs (except OCDD) X X increasing costs due to reagent X X
degradation reported (bench scale) scavengers
- Less effective for more highly - Soil treatment would require
chlorinated dioxins (e.g., OCDD) significant processing of soils which
Potential for PCDD/F byproducts would significantly increase costs
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FINAL TM – TECHNOLOGY EVALUATION AND RECOMMENDED TREATMENT METHODS
SCREENING CRITERIA • Retain
TREATMENT
TECHNOLOGY FOR X Reject FINDINGS AND
DIOXINS IN
SOIL/SEDIMENT
GENERAL (1A AND 1B) EFFECTIVENESS (2B) IMPLEMENTABILITY (3A AND 3B) COST (5B) ACCEPTANCE (7A) RATIONALE
? ADVANTAGE/DISADVANTAGES ? ADVANTAGE/DISADVANTAGES ? ADVANTAGE/DISADVANTAGES ? ADVANTAGE/DISADVANTAGES ? ADVANTAGE/DISADVANTAGES
SOLVATED ELECTRON - For soils treated, likely to result in
Not applicable for high concentration Not currently scalable for large scale - Treatment costs expected to be - Stakeholders unlikely to accept Not demonstrated for full-
TECHNOLOGY significant exposure risk reduction dioxin-impacted soil treatment high, particularly considering low potential for byproduct production scale application for the
- Exposure risks remain for soils that Aggressive technololgy likely to result in Processing of soil for this technology volume throughput from incomplete oxidation in treated treatment of dioxin-
achieve only partial dioxane degradation significant DRE formoderately-impacted likely to require extended time frame soils being considered as backfill impacted soil
- Use of anhydrous ammonia poses soils treated
significant concerns for health and Potential for chlorinated byproduct
X safety X production X X X X
Treatment residue from use of ammonia
useage, required disposal
GAS-PHASE CHEMICAL Exposure risk to impacted soil likey to - Non-uniform treatment, particularly Scalable for full-scale treatment - Non-homogeneous treatment and - Stakeholders likely to reject based While can be applied full-
REDUCTION remain based on non-uniform in heterogeneous soils, can significantly Difficult to control system to maintain repeated applications can extend time on non-homogeneous treatment scale, this technology is
treatment of soil reduce effectiveness (poor contact anaerobic conditions (e.g., for reductive and costs potential difficult to control during
Short term exposure risk potential between injected donor and dioxins) dechlorination) implementation so as to
from PCDD/Fs bydrpoducts or long Difficult to implement in situ, but may meet ARARs
term from incomplete reduction be more controlable ex situ
Strong likelyhood of not meeting Incompletely treated soils cannot be
ARARs reused
- High reagent quantities likely, low
• • • throughput, and high degree of
complexity. Vijgen (2009b) estimated
costs to treat chlorinated pesticides at
$1,317 per ton (for utilities, based on
2004 U.S. utility costs) and $222 (for
labor) per ton, or approximately X X X
$1,539 per ton, or $1,026 per m3
(assuming 1.5 tons per m3), exclusive
of the Contractor’s overhead and
profit, and capital and decommissioning
costs.
Not expected to be cost competitive
with other options.
BIOREMEDIATION
IN SITU - Exposure risks from dioxins in soil - Not demonstrated for applicabiity to - Not practical for use with large - Risk that bioavailable fraction of -Stakeholders unlikely to accept based - Limited effectiveness for
BIOREMEDIATION likely to remain based on limited existing dioxin concentrations at the volumes of highly dioxin-impacted soils dioxins is replenished over time, on limited effectiveness, potential for soils where dioxins are
bioavailability of strongly sorbed Airbase - May be more practical for moderate requiring repeated soil remediation, toxic byproducts, and unacceptability tightly bound to clay/silts
dioxins to soil - Effectiveness likely limited to dioxin-impacted soils of smaller volume, thus significantly increasing costs for reuse and organic matter
- Potential increase exposure risks bioavailable portion of dioxins, with particularl higher permeability soils with (bioavailability)
associated with degradation daughter much of the strongly sorbed dioxin low organic matter content
products that are less chlorinated, but mass on soil undegraded - Biormediation tends to be a slower
more highly toxic - Anaerobic degradation (reductive process as compared with more •
- Slow rates of degradation present dechlorination) most likely pathway for aggressive technologies
short term exposure risks to bioavailable fraction - May not result in soil acceptable for
byproducts - May be more effective for low organic reuse
X - Available field testing suggests limited X matter TCDD-contaminated soils with X X X
likelihood of meeting ARARs high permeability
- Degradation likely to result in less
chlorinated, but more toxic dioxins
(e.g., TCDD)
- Bench and field trials report 0 to 50%
DRE
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FINAL TM – TECHNOLOGY EVALUATION AND RECOMMENDED TREATMENT METHODS
SCREENING CRITERIA • Retain
TREATMENT
TECHNOLOGY FOR X Reject FINDINGS AND
DIOXINS IN
SOIL/SEDIMENT
GENERAL (1A AND 1B) EFFECTIVENESS (2B) IMPLEMENTABILITY (3A AND 3B) COST (5B) ACCEPTANCE (7A) RATIONALE
? ADVANTAGE/DISADVANTAGES ? ADVANTAGE/DISADVANTAGES ? ADVANTAGE/DISADVANTAGES ? ADVANTAGE/DISADVANTAGES ? ADVANTAGE/DISADVANTAGES
PHYTOREMEDIATION - Exposure risks from dioxin-impacted - Suggesed to be effective in desorbing -Limited applicability for soil at depth - Potential to mobilize dioxins could Unlikely to be accepted based on - Ineffective for dioxins in
(AND soils likely to remain PCDD/Fs from soil as result of release Not practical for use with large volumes result in increased costs associated limited applicability, effectiveness, the soil at depth, and does not
PHYTOEXTRACTION) - Increased exposure risks associated of dioxin-binding compounds of highly dioxin-impacted soils with groundwater remediation potential for the mobilization of result in destruction of
with dioxins that become mobilized - Effectiveness limited for mobilized May be more practical for moderate - Limited effectivness in soil could dioxins in groundwater, and dioxins, but uptake and
into groundwater PCDD/Fs that are not taken up into dioxin-impacted soils of smaller volume result in repeated stages of unacceptability for reuse accumulation in plant
- Increased risk from exposure to plant, but are mobilized in groundwater Phytoextraction/phytoremediation tends phytoextraction, or may require matter
plants in which dioxin uptake does not - No evidence that dioxins are to be a slower process as compared selecting an alternative technology
result in degradation degraded in plants, so much as with more aggressive technologies which would increase overall costs
- Poor management of plant waste, accumulated May not result in soil acceptable for
X could reimpact the environment with X - Plants likely to stimulate soil X reuse X X X
dioxins microorganisms to degrade dioxins
Unlikely to meet ARARs - Limited data avaialble to provide basis
of effectivness
BIOLOGICAL / - Exposure risks from dioxins in soil - Applicable for moderate to low - Not practical for use with large - Costs likely to be high, particularly if -Stakeholders unlikely to accept based Not demonstrated for full-
CHEMICAL HYBRIDS likely to remain concentrations of dioxin-impacted soil volumes of highly dioxin-impacted soil repeated treatments are required for on limited effectiveness, potential for scale application for the
- chemical approach most effective on - Slow treatment, particularly if poor more complete DRE toxic byproducts, and unacceptability treatment of dioxin-
less chlorinated PCDD/Fs, but data contact with heterogeneous soils for reuse impacted soil
suggest limited DRE (see chemical requiring repeated treatment
reduction/oxidation technology) - May not result in soil acceptable for
- chemical approach can result in reuse
chlorinated byproducts
- biological element limited
effectiveness except for bioavailable
dioxins; however, most dioxins are
tightly bound to soil
X X - Testing at Airbase (UNDP project by X X X X
HPC-Envirotec) with persulfate
indicated ineffective technology
requiring multiple persulfate additions
(Cooke 2015). One of 5 tests showed
90% DRE.
MYCOREMEDIATION - Limited data available to support - Not applicable to high dioxin - Not practical for use with large - Costs likely to increase from -Stakeholders unlikely to accept based Not demonstrated for full-
(fungi) reduction exposure risks from dioxin- concentrations given reported DRE of volumes of highly dioxin-impacted soil inneffective soil treatment requiring on limited effectiveness, potential for scale application for the
impacted soils 50% (BEM 2007) - May be more practical for smaller reapplication or selection of toxic byproducts, and unacceptability treatment of dioxin-
- Limited evidence that is capable of - Much interest mycoremediation (e.g., volumes of moderate to low alternative technology for reuse impacted soil
meeting ARARs use of white root fungi) that may offer concentration dioxin-impacted soils - Pilot testing reported high costs
fortuitous degradation of PCDD/Fs - Mycoremediation likely to be slow as ($250 per cubic meter soil) (UNDP
X X Limited data available on effectivness X compared with more aggressive X 2009a, UNDP 2009b, BEM 2007) X X
technologies
- May not result in soil acceptable for
reuse
Notes:
CDD/F - chlorinated dibenzo-p-dioxins/chlorinated dibenzofurans DCDD - 2,7-dichlorodibenzo-p-dioxin
DRE - destruction/removal efficiency
m3 – cubic meters
M - million
OCDD - 1,2,3,4,6,7,8,9-Octachloro dibenzo-p-dioxin dibenzofurans
RE - removal efficiency
TCDD -2,3,7,8- tetrachlorodibenzodioxin TCH - thermal conductive heating
TEQ - toxic equivalency quantity
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FINAL TM – TECHNOLOGY EVALUATION AND RECOMMENDED TREATMENT METHODS
APPENDIX 4. REMEDIAL TREATMENT TECHNOLOGIES EVALUATION TOOL
ADJUSTED
STAKEHOLDER
AVERAGE
TIÊU CHÍ TCH
ƯU TIÊN (TRỌNG
CRITERIA
SỐ)
PRIORITY
(WEIGHT FACTOR)
RANK SCORE RANK SCORE
Tính hiệu quả
Effectiveness
Chi phí
Cost
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FINAL TM – TECHNOLOGY EVALUATION AND RECOMMENDED TREATMENT METHODS
6.B. Nhu cầu quan trắc lâu dài hoặc kiểm soát thể
chế sau hoạt động 8% 3 0.24
6.B. Need for LTM or ICs following Implementation
6C. Rủi ro cháy nổ trong quá trình xử lý
5% 3 0.16
6C. Risk of expolosion during treatment
Chấp thuận
Acceptance
TỔNG
100% 2.45
TOTAL
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APPENDIX 5. CONSIDERATIONS IN APPLYING STAGE 2 EVALUATION CRITERIA TO TCH OPTIONS
Considering lessons learned from the Danang project promise will inform final selection of a TCH
approach for the treatment of dioxin impacted soil at Bien Hoa. Below are a few lessons learned from
implementing TCH at Danang, as noted by stakeholders of the project.
Schedule time for pilot test prior to going full scale to help confirm
Time can be included in the schedule for
assumptions about risks. If unable to schedule time for pilot test, then design
pilot tests
system for worst case scenarios.
Remedial Treatment
Oxidizer was not used because approval was not granted to use the oxidation
Assumed oxidizer would be used in unit to treat emissions due to the uncertainty of energy supply system
treatment Lack of oxidation and generation of other organics in the vapor (e.g. benzene)
resulted in greater volumes of spent GAC being generated
Treatment pile to be protected from the Roof, cover, HDPE liner for the pile to keep the rainwater out during the
rain rainy season.
Assumed wouldn't have high High benzene in the vapor systems, required additional granulated activated
benzene/VOCs in vapor stream. carbon (GAC) - required to find local vendor to provide.
GAC was never changed due to dioxin concentrations, but rather due to
Change carbon due to dioxin
benzene concentrations. Need to plan for this.
Assumed granular activated carbon
GAC could not be destroyed in Vietnam - Waste materials were sent to
(GAC) would be destroyed in the cement
Switzerland and France for incineration
kiln in Vietnam
Additional lessons learned from the experiences with the Danang Airport project include:
• Power limitations practically limit the amount of material that can be treated at a time. Assuming
similar electrical infrastructure as with the Danang project, treatment piles would be limited to
approximately 50,000 m3.
• Non-uniform heating within a pile (in the case of In-Pile Thermal Desorption [IPTD]) was improved
through better cover design (to limit rainwater infiltration) over the piles (as related to heating
challenges during monsoon rains). This non-uniform heating was overcome through boosting
temperatures in the upper and lower portions of the approximately 6 m thick piles. An alternative
development is the use of horizontal TCH heater installation that simplified construction, saves on
materials, and improves heating.
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• Additional developments are currently being advanced to treat liquid waste that drains from the piles
• The merits of possible bench-scale and field pilot studies for various TCH techniques will be assessed
in the coming phases of the project.
The following key components of treatment should incorporate lessons learned from the Danang
remediation project, the application of which are believed to be critical for successful remediation at Bien
Hoa Airbase.
REMEDIATION THROUGHPUT
Evaluation of any thermal approach should include the ability to achieve the required project production
or “throughput”. Volume estimates of soil and sediment containing dioxin concentrations >1200 ppt at
Bien Hoa Airbase exceed 150,000 m3 (2016 EA). Completion of remediation activities discussed in the
Master Planning process is ten years, including: planning, design, construction, operation, and restoration.
Timelines for active treatment activities will likely be less than 5 years. Target throughput goals for
treatment activities must accommodate these schedules.
An ex situ thermal treatment approach requires construction of insulated piles or containers to place and
treat soil in batches. While many ex situ high-temperature treatment systems have used relatively small
metal treatment containers (less than 20 m3), constructed piles as large as 45,000 m3 have been used (Da
Nang). The optimal combination of piles and/or containers will need to be determined for Bien Hoa. In
addition to reliability and safety, many factors—including size, number, treatment duration, and
demobilization—will require analysis.
Calculation of throughput for each pile or container is equal to the volume of soil per batch, divided by
the total time per batch. The total time includes loading the soil into the treatment pile or container,
warming it to the target temperature for the required treatment duration, cool down period, and removal
of treated material. The total time per batch can range from weeks to months, depending on batch size,
construction, and type of heating system. While there are advantages and disadvantages to each approach,
the evaluation must determine an adequate number of piles or containers required to meet the overall
Bien Hoa project timelines.
PROCESS OPTIONS
Process options to consider when evaluating thermal treatment options include pile and/or container
construction, operating vacuum, operating temperature, and power supply. Aside from achieving project
throughput goals, variations in construction of piles and/or containers can impact safety, energy efficiency,
operational reliability, ease of loading and unloading soils, and re-use.
For example, while the large-pile approach used at Da Nang achieved dioxin destruction goals (mass
reduction and throughput), it generated many lessons learned that can be applied when evaluating
approaches for Bien Hoa, including the following:
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• Construction of multiple smaller piles;
• Enhancements to pile insulation, water proofing, and vapor control; and
• Selection of building materials to minimize additional waste streams.
Another process variation for consideration in thermal treatment includes operation at higher vacuums,
resulting in desorption at lower temperature (e.g. MCS) versus higher “in-pile/container” temperatures,
resulting in more dioxin destruction via hydrolysis and oxidation.
When considering a technology using multiple smaller piles/containers, a thorough evaluation of how to
simultaneously maintain temperature, vacuum, and vapor treatment is critical.
VAPOR TREATMENT
The vapor phase effluent from the treated soil must be controlled and treated. The two primary vapor
treatment techniques are GAC and thermal oxidation. GAC is a non-destructive adsorption-based
treatment process that removes the target COCs from the vapor (e.g., VOCs, SVOCs, and dioxin) by
adsorbing them onto the carbon treatment medium. This process results in creation of a solid waste
(spent GAC) that can either be thermally regenerated or disposed of in an approved landfill. The amount
of spent GAC created is a function of the mass removed and their respective adsorption isotherms. The
use of GAC was considered in costing assumption in the 2016 EA. Selection of a vapor treatment
technology is a critical step that should be considered when evaluating the energy source used for
pile/container heating.
Potential sources of VOCs and SVOCs in the soil at the Airbase include mineral spirits, possibly mixed
with Agent Orange and aviation fuel used at the Airbase. Other naturally occurring organics (such as
organic acids present in tropical soils) may be released during the heating process and adsorb to the GAC.
The mass of these naturally occurring organics can be several orders of magnitude higher than the target
COCs and can significantly increase the amount of spent GAC. Quantifying the anticipated mass of all
organics (COCs and naturally occurring) in the soils targeted for treatment is essential for projecting the
amount of spent GAC. Currently there is not an approved regeneration facility or approved landfill for
disposal of spent GAC with dioxins in Vietnam. Spent GAC from the Danang project was taken to
Switzerland and other waste to France.
Thermal oxidation is a robust vapor treatment process that has proven effective for destruction of dioxin
and other anticipated organic COCs (VOCs and SVOCs). The target temperature for dioxin destruction
is typically 1,100°C and can be achieved with a petroleum-based fuel (liquid or gas). While thermal
oxidation should not be significantly impacted by the presence of naturally occurring organics, it is energy
intensive. Thermal requirements and the need for continuous fuel supply should be considered during
alternatives evaluation. Permitting requirements for operating thermal oxidizers must also be considered.
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• pile/container construction materials
• vapors
• liquids
• treated soils
Following thermal treatment at Da Nang, concrete blocks used for constructing the pile had residual
dioxin impacts requiring special handling and disposal. Selection of materials used to construct piles or
containers should include an evaluation of how to minimize dioxin adsorption. Landfilling options should
also be evaluated.
During thermal treatment, steam and vapors will be extracted from the pile(s) or container(s) to minimize
fugitive emissions. Technology choices for handling and treatment of these vapors and liquids will affect
the type and amount of waste generated and requiring treatment and/or disposal.
Cooling vapors and removing condensate may require using heat exchangers and vapor/liquid separators.
These processes can generate the following waste streams which would require management:
• GAC: Liquid-phase and vapor-phase GAC could be generated depending on alternative, and would
require offsite destruction, regeneration, or disposal.
• Granular ferric hydroxide (GFH): If required, arsenic removal media would also require offsite
disposal.
• Macro porous polymer extraction (MPPE) media: Based on experience at the Da Nang Airport
remediation project, MPPE media may need to be disposed following use.
• Non-aqueous phase liquids (NAPL): It is expected that NAPL would be concentrated at both the
oil-water separator and via MPPE treatment. NAPL would require offsite management and disposal,
likely at an incinerator permitted to handle dioxin-laden waste.
• Thermal oxidizer effluent: Operation of a thermal oxidizer will also require permitting and
monitoring for constituents such as nitrous oxides (NOx).
After thermal treatment, soils and sediments are cooled and sampled. Re-use options for this material will
be based on sampling results, geotechnical properties, and potential on-base fill areas. As significant time
may have passed between excavation of material and completion of treatment, the original excavation
sites may have already been filled. Sequencing and identification of potential fill areas with anticipated
treatment throughput will be critical for processing 150,000 m3 of soil. Planning should include evaluation
of both geotechnical and future vegetative growth properties. Treated soil may need to be amended prior
to placement, which will require both schedule and process area considerations. In addition to final
placement of the treated soils and sediments, planning should include final disposition of all residual waste
materials.
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DIOXIN REMEDIATION AT BIEN HOA
AIRBASE AREA PROJECT
DISCLAIMER
THE VIEWS EXPRESSED IN THIS PUBLICATION DO NOT NECESSARILY REFLECT THE VIEWS OF THE UNITED STATES AGENCY FOR
INTERNATIONAL DEVELOPMENT OR THE UNITED STATES GOVERNMENT.
CONTENTS
1 INTRODUCTION....................................................................................................................................................... 1
2 APPROACH .................................................................................................................................................................. 2
2.1 DISPOSITION CATEGORIES ......................................................................................................................... 2
2.2 MATERIAL TYPES .............................................................................................................................................. 3
3 RESIDUAL CONTAMINATION ACTION LEVELS ........................................................................................... 4
3.1 DIOXIN ................................................................................................................................................................ 4
3.2 ARSENIC .............................................................................................................................................................. 4
3.3 MATERIAL DISPOSITION PLANS ................................................................................................................ 4
3.4 REQUIRED DISPOSITION PROCEDURES................................................................................................. 5
3.1 DIOXIN
• For wipe sampled material/equipment, if dioxin levels are less than 25 nanograms
tetrachlorodibenzo‐p‐dioxin (TCDD) per square meter (ng TCCD/m2) (National Research
Council [NRC] 1988), the material/equipment is acceptable for unrestricted reuse and if dioxin
levels are less than 125 ng TCDD/m2 (Michaud 1994), but greater than 25 ng TCDD/m2, the
material/equipment is acceptable for offsite disposal as scrap. If dioxin levels are greater than 125
ng TCDD/m2, the material/equipment will be treated as hazardous waste.
• For solid, granular samples, if dioxin levels are less than 1,200 picograms toxic equivalent per
gram (pg TEQ/g) or parts per trillion (ppt) (QCVN 45:2012/BTNMT), then the
material/equipment will be acceptable for industrial reuse or offsite disposal [Note that TCVN
8183:2009 was replaced by QCVN 45:2012/BTNMT]. For solid, granular samples with dioxin
levels equal to or greater than 1,200 pg TEQ/g or ppt, the material will be handled as hazardous
waste. It is important to note that the GVN’s National Technical Regulation on Hazardous Waste
Thresholds (QCVN 07:2009/BTNMT) identifies a material as being hazardous for dioxin if the
concentration exceeds 100,000 ppt. It should be noted that materials from the Project with
dioxin concentrations between 1,200 ppt and 100,000 ppt will be conservatively managed as
hazardous waste, even though they are not technically classified as hazardous per GVN
regulations. Therefore, the proposed Project approach is conservative by nearly two orders of
magnitude.
3.2 ARSENIC
• For solid, granular samples, if arsenic levels are less than 25 mg/kg (QCVN 03-MT:2015/BTNMT),
then the material/equipment will be acceptable for unrestricted industrial reuse or offsite disposal.
• If arsenic levels exceed 25 mg/kg, but leachable arsenic is less than 2 mg/L (QCVN 07:2009/
BTNMT), then the material/equipment will be acceptable for restricted industrial reuse or offsite
disposal.
• If neither condition is met, the material will be handled as hazardous waste.
It should be noted that because of the limited capacity of hazardous waste disposal facilities in Vietnam,
USAID may require contractors to export materials identified as Project “hazardous waste.” USAID will
require any such waste exports to follow the MONRE-managed Basel Convention procedures.
APRIL 2, 2020
This publication was produced for review by the United States Agency for International Development.
ARCHITECT-ENGINEER SERVICES FOR DIOXIN REMEDIATION
AT BIEN HOA AIRBASE AREA PROJECT
PREPARED BY
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DISCLAIMER
THE VIEWS EXPRESSED IN THIS PUBLICATION DO NOT NECESSARILY REFLECT THE VIEWS OF THE UNITED STATES AGENCY
FOR INTERNATIONAL DEVELOPMENT OR THE UNITED STATES GOVERNMENT.
CONTENTS
CONTENTS i
UPDATES ii
PREAMBLE 1
ACRONYMS & ABBREVIATIONS 1
000 April 2, 2020 All Project Acronyms & Abbreviations USAID COR
151. DDL Development Data Library DDL Thư viện Dữ liệu USAID
Decontamination and
152. DDP DDP Kế hoạch Khử nhiễm và tháo dỡ
Demolition Plan
dichloro diphenyl
153. DDT DDT dichloro diphenyl trichloroethane
trichloroethane
154. DE destruction efficiency DE hiệu suất phân hủy
effective diffusivity of the Độ khuếch tán hiệu dụng của hóa
155. De absorbing chemical in the De chất hấp thụ trong lớp biểu bì (cm2
epidermis (cm2/hr) / giờ)
Dermal Exposure Assessment: Đánh giá phơi nhiễm da: Nguyên
156. DEA Principles and Applications DEA tắc và áp dụng (Hoa Kỳ EPA,
(U.S. EPA, 1992a) 1992a)
Development Experience
157. DEC DEC Kho Lưu trữ trực tuyến (USAID)
Clearinghouse (USAID)
158. Decon decontamination Decon khử nhiễm
159. DEP dioxin exposure prevention DEP ngăn ngừa phơi nhiễm dioxin
destruction and removal
160. DER DER hiệu suất phân hủy, thải tách
efficiency
Department of Foreign Affairs
161. DFA CĐN Cục Đối ngoại (BQP)
(MND)
162. DFTO direct flame thermal oxidizer DFTO oxy hóa nhiệt, đốt trực tiếp
Phân tích Thiếu hụt dữ liệu, Phân
163. DGA Data Gap Analysis DGA
tích Lỗ hổng dữ liệu
164. DFW Definable Feature of Work DFW Hạng mục công việc cụ thể
165. DGM digital geophysical mapping DGM liên kết kênh số địa vật lý
166. DGR Dangerous Goods Regulations DGR Quy định Hàng hóa nguy hiểm
2,3,7,8-tetrachlorodibenzo-p- Chất 2,3,7,8-tetrachlorodibenzo-p-
167. dioxin dioxin
dioxin dioxin
168. DMP Data Management Plan DMP Kế hoạch Quản lý dữ liệu
chất lỏng ngoài pha nước dạng
169. DNAPL dense nonaqueous-phase liquid DNAPL đặc, NAPL đặc
170. DO Development Objective DO Mục tiêu phát triển
171. DOC Department of Construction SXD Sở Xây dựng (Việt Nam)
United States Department of
172. DOD DOD Bộ Quốc phòng Hoa Kỳ
Defense
Department of Defense
173. DODI DODI Chỉ thị Bộ Quốc phòng
Instruction
174. DOE U.S. Department of Energy DOE Bộ Năng lượng Hoa Kỳ