20201228-Final Masterplan en

DIOXIN REMEDIATION AT BIEN HOA
AIRBASE AREA PROJECT
FINAL MASTERPLAN – VOLUME 1

(MAIN IMPLEMENTATION ACTIVITIES)
DECEMBER 28, 2020

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.

(MAIN IMPLEMENTATION ACTIVITIES)
US AGENCY FOR INTERNATIONAL DEVELOPMENT

CONTRACT NUMBER: AID-OAA-I-15-00053
ORDER NUMBER: 72044019F00001
SEPTEMBER 10, 2020
PREPARED BY
TRIGON ASSOCIATES, LLC
1515 POYDRAS ST. SUITE 2200
NEW ORLEANS, LA 70112
USA
DISCLAIMER
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.
Special acknowledgement to:
• 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
DIOXIN REMEDIATION AT BIEN HOA AIRBASE AREA PROJECT

FINAL MASTERPLAN – VOLUME 1 | i
CONTENTS
ACKNOWLEDGEMENT ........................................................................................................... I
CONTENTS ................................................................................................................................. II
RECORD OF REVISIONS ....................................................................................................... VII
LIST OF ACRONYMS AND ABBREVIATIONS .............................................................. VIII
EXECUTIVE SUMMARY.......................................................................................................... IX
MASTERPLAN IX
POST-PROJECT XIII
1 INTRODUCTION................................................................................................................ 1
1.1 PROJECT OBJECTIVES 1
1.2 PROJECT ROLES AND RESPONSIBILITIES 1
1.3 MASTERPLAN PURPOSE AND SCOPE 6
1.4 MASTERPLAN DEVELOPMENT 7
1.5 CRITICAL SUCCESS FACTORS 7
2 PROJECT BACKGROUND ............................................................................................... 9
2.1 KEY PLANNING AND APPROVAL DOCUMENTS 9
2.2 APPLICABLE DIOXIN REGULATIONS 10
2.3 DIOXIN CONTAMINATION AT BIEN HOA AIRBASE AREA 11
2.4 PROJECT ACTION LEVELS 14
2.5 POST-REMEDIATION PREVIEW 17
3 STAKEHOLDER ENGAGEMENT ................................................................................... 20
3.1 ENGAGEMENT DURING MASTERPLAN DEVELOPMENT 20
3.2 ENGAGEMENT DURING MASTERPLAN IMPLEMENTATION 22
4 MASTERPLAN CONTENT SUMMARY ........................................................................ 24
4.1 IMPLEMENTATION SUMMARY 24
4.2 CONSTITUENTS OF CONCERN 28
4.3 REMEDIAL ACTIONS AND KEY DESIGN PARAMETERS 28
4.4 SITE CONCEPTUAL MODEL 33
4.5 RISK IDENTIFICATION AND MANAGEMENT FOR PROJECT IMPLEMENTATION 36
4.6 RECONTAMINATION PREVENTION AND CONTROL 38
4.7 PROJECT FUNDING 38
5 REMEDIAL ACTIONS ....................................................................................................... 42
5.1 RISK REDUCTION MEASURES IMPLEMENTED TO DATE 42
5.2 EXCAVATION DESIGN AND TRANSPORT OF CONTAMINATED SOILS AND
SEDIMENTS 44
5.3 LONG-TERM STORAGE – CONSTRUCTION AND OPERATION OF LTSA 46
5.4 TREATMENT PLANT DESIGN – CONSTRUCTION AND OPERATION 50
5.5 RECONTAMINATION CONTROLS 57
5.6 LAND USE CONTROLS 63
5.7 COMMON PROJECT WORK STAGES 64
5.8 ACTIVITIES 70
5.9 ALTERNATIVE SOLUTIONS 105
6 IMPLEMENTATION EFFORTS, SCHEDULE, AND ESTIMATED CAPITAL
COSTS ................................................................................................................................ 109

FINAL MASTERPLAN – VOLUME 1 | ii
6.1 PROJECT WORK BREAKDOWN STRUCTURE (WBS) 109
6.2 PROJECT SCHEDULE 112
6.3 ESTIMATED CAPITAL COSTS 115
7 MAPS OUTLINING DECISION UNITS AND REMEDIAL ELEMENTS ............... 118
APPENDIX A – PROJECT SUMMARY CHARTS ............................................................ 158
APPENDIX B – PROJECT SCHEDULE .............................................................................. 169
APPENDIX C – PROJECT RISK AND MITIGATION.................................................... 173
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)

FINAL MASTERPLAN – VOLUME 1 | iii
TABLES
Table 1-1 Masterplan Implementation Stakeholders ................................................................................. 3
Table 2-1 Bien Hoa Airbase Area Dioxin Allowable Limits ................................................................. 10
Table 2-2 Total Estimated Contamination Volume to be Remediated 1 ........................................... 14
Table 2-3 Annual Remediation Work........................................................................................................ 17
Table 4-1 Masterplan Schedule.................................................................................................................... 24
Table 4-2 MND Contributions and Critical Milestones ........................................................................ 27
Table 4-3 Long-Term Storage Area (LTSA) Design Requirements .................................................... 29
Table 4-4 Summary of Site Conceptual Model ........................................................................................ 34
Table 4-5 Remedial Actions ......................................................................................................................... 37
Table 5-1 Material Disposition Categories ............................................................................................... 69
Table 5-2 Remediation Volumes Schedule ............................................................................................... 70
Table 5-3 Phase 1 – Remediation Activities Timeline ............................................................................ 72
Table 5-4 Phase 1 Excavation & Hauling Work by Decision Unit ...................................................... 73
Table 5-5 IM1 Contaminated Volumes...................................................................................................... 76
Table 5-6 Phase 1 Excavation & Hauling Work by Decision Unit – IM1 .......................................... 76
Table 5-7 IM2 Contaminated Volumes...................................................................................................... 78
Table 5-8 Phase 1 Excavation & Hauling Work by Decision Unit – IM2 .......................................... 78
Table 5-9 Phase 1 Excavation & Hauling work by Decision Unit – Annual 1 .................................. 82
Table 5-10 Phase 1 Excavation & Hauling Work by Decision Unit – Annual 2............................... 84
Table 5-13 TCH Treatment Plant Footprint (Area) .............................................................................. 90
Table 5-14 Remediation Support Activities Timeline ............................................................................ 92
Table 5-15 Phase 2 – Remediation Activities Timeline ......................................................................... 92
Table 5-16 Phase 2 Excavation & Hauling Work by Decision Unit .................................................... 93
Table 5-17 Phase 2 Excavation & Hauling work by Decision Unit – Annual 1 ................................ 97
Table 5-19 Phase 2 Excavation & Hauling Work by Decision Unit – Annual 3............................. 101
Table 5-20 Phase 2 Excavation & Hauling Work by Decision Unit – Annual 4............................. 103
Table 5-21 Remediation Support Activities Timeline – Phase 2 ....................................................... 105
Table 6-1 Project WBS................................................................................................................................ 110
Table 6-2 Capital Cost Summary .............................................................................................................. 116
Table 6-3 Capital Cost Expenditures Distribution ............................................................................... 116
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

FINAL MASTERPLAN – VOLUME 1 | iv
Figure 4-2 Northeast Area Showing Topography, Post-Project Dioxin Concentrations and Land
Use .................................................................................................................................................. 39
Figure 4-3 Revised Decision Units Proposed for Northeast Area ..................................................... 40
Figure 4-4 Reclasification of PI-20 and Expansion of PI-17 Pond ........................................................ 41
Figure 5-1 Project XD2 – Completed Volume ...................................................................................... 43
Figure 5-2 Excavation Process ..................................................................................................................... 45
Figure 5-3 Preliminary LTSA Drainage Diversion ................................................................................... 47
Figure 5-4 Preliminary LTSA Layout and Conceptual Design .............................................................. 48
Figure 5-5 Preliminary LTSA Layout and Conceptual Design Renderings ........................................ 49
Figure 5-6 Preliminary LTSA Layout and Conceptual Design - Cross Section ................................ 50
Figure 5-7 TCH Treatment Plant Location .............................................................................................. 52
Figure 5-8 TCH Treatment Work Stages................................................................................................. 54
Figure 5-9 TCH Treatment Operations.................................................................................................... 56
Figure 5-10 TCH Demobilization Process................................................................................................ 57
Figure 5-11 Water Monitoring Locations ................................................................................................. 59
Figure 5-12 Weather and Air Monitoring Locations.............................................................................. 60
Figure 5-13 Groundwater Monitoring Locations .................................................................................... 61
Figure 5-14 Site Restoration Process ........................................................................................................ 63
Figure 5-15 Project Access Gate 3 ............................................................................................................. 65
Figure 5-16 Pacer Ivy Security Area Layout ............................................................................................. 66
Figure 5-17 Remedial Measures – Phase 1 & 2 ........................................................................................ 71
Figure 5-18 Phase 1 Remediation Work Areas ....................................................................................... 75
Figure 5-19 First Interim Measures ............................................................................................................ 77
Figure 5-20 Second Interim Measures ....................................................................................................... 79
Figure 5-21 Civil Works Phase 1 ................................................................................................................ 81
Figure 5-22 Civil Works Phase 1 – Annual 1 ........................................................................................... 83
Figure 5-26 TCH Treatment Plant ............................................................................................................. 91
Figure 5-27 Phase 2 Remediation Work Areas ....................................................................................... 94
Figure 5-28 Civil Works Phase 2 ................................................................................................................ 96
Figure 5-30 Civil Works Phase 2 – Annual 2 ......................................................................................... 100
Figure 5-33 Existing Land Fills (XD1 & XD2) ........................................................................................ 106
Figure 5-34 Alternative Packaging TCH Treatment Plant................................................................... 108
Figure 6-1 Seven Levels of Hierarchy in WBS ....................................................................................... 109
Figure 6-2 Project Schedule (Phase 1) ..................................................................................................... 113
Figure 6-3 Project Schedule (Phase 2) ..................................................................................................... 114
Figure 6-4 Masterplan Cost Elements...................................................................................................... 115
Figure 6-5 Cumulative Capital Cost and Cash Flow ............................................................................ 117
Figure 7-1 Historical (1968) Overlay Bien Hoa Airbase Area (Larger/Detailed Image) .............. 120
Figure 7-2 Bien Hoa Airbase Overview (Larger/Detailed Image) ..................................................... 121
Figure 7-3 Proposed Land Use Based on EA/EIA (Larger/Detailed Image) .................................... 122
Figure 7-4 Proposed Project Action Levels for Masterplan Development (Larger/Detailed
Image) ........................................................................................................................................... 123
Figure 7-5 Remedial Measures – Phase 1 & 2 (Larger/Detailed Image) ........................................... 124

FINAL MASTERPLAN – VOLUME 1 | v
Figure 7-6 Phase 1 Remediation Work Areas (Larger/Detailed Image) .......................................... 125
Figure 7-7 First Interim Measures (Larger/Detailed Image) ............................................................... 126
Figure 7-8 Pacer Ivy Security Area Layout (Larger/Detailed Image) ................................................ 127
Figure 7-9 Second Interim Measures (Larger/Detailed Image) .......................................................... 128
Figure 7-10 TCH Treatment Plant Location (Larger/Detailed Image) ............................................. 129
Figure 7-11 TCH Treatment Plant (Larger/Detailed Image) .............................................................. 130
Figure 7-12 Alternative Packaging TCH Treatment Plant (Larger/Detailed Image) ..................... 131
Figure 7-13 Civil Works Phase 1 (Larger/Detailed Image) ................................................................. 132
Figure 7-14 Civil Works Phase 1 – Annual 1 (Larger/Detailed Image)............................................ 133
Figure 7-18 Phase 2 Remediation Work Areas (Larger/Detailed Image)........................................ 137
Figure 7-19 Civil Works Phase 2 (Larger/Detailed Image) ................................................................. 138
Figure 7-24 UXO Clearance (Larger/Detailed Image) ......................................................................... 143
Figure 7-25 2009 Topographic View (Larger/Detailed Image)........................................................... 144
Figure 7-26 Additional Characterization (Larger/Detailed Image).................................................... 145
Figure 7-27 Northeast Area Showing Topography, Post-Project Dioxin Concentrations, and
Land Use (Larger/Detailed Image) ......................................................................................... 146
Figure 7-28 Surface Water (Larger/Detailed Image) ............................................................................ 147
Figure 7-29 Water Monitoring Locations (Larger/Detailed Image) .................................................. 148
Figure 7-30 Weather and Air Monitoring Locations (Larger/Detailed Image) .............................. 149
Figure 7-31 Groundwater Monitoring (Larger/Detailed Image)........................................................ 150
Figure 7-32 Groundwater Table Contours - Dekonta Report, 2014 (Larger/Detailed Image) . 151
Figure 7-33 Drainage System Structures (Larger/Detailed Image) ................................................... 152
Figure 7-34 Hauling Roads (Larger/Detailed Image)............................................................................. 153
Figure 7-35 Existing Landfills (Larger/Detailed Image) ......................................................................... 154
Figure 7-36 Surface Dioxin Concentration (Larger/Detailed Image) ............................................... 155
Figure 7-37 Surface Dioxin Concentration Post-Phase 1 (Larger/Detailed Image) ...................... 156
Figure 7-38 Post-Remediation Surface Dioxin Concentration (Larger/Detailed Image) ............. 157

FINAL MASTERPLAN – VOLUME 1 | vi
RECORD OF REVISIONS
REVISION DATE PAGES SUMMARY OF REVISIONS APPROVAL
000 May 4, 2020 All Initial development/submittal of Draft MND and USAID
Implementation Masterplan COR
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
Updated Executive Summary and MND and USAID

004 September 10, 2020 Selected Introduction COR

FINAL MASTERPLAN – VOLUME 1 | vii
LIST OF ACRONYMS AND ABBREVIATIONS
% percent m3 cubic meter
°C degrees Celsius Masterplan
Implementation Masterplan
°F degrees Fahrenheit MEL Monitoring, Evaluation, and Learning
A&E Architect & Engineer MND Ministry of National Defence
ADAFC Air Defence-Air Force Command MOF Ministry of Finance
ADS Automated Directives System MOI Memorandum of Intent
Airbase Bien Hoa Airbase MONRE Ministry of Natural Resources and
AMST Academy of Military Science and Environment
Technology MOPI Ministry of Planning and Investment
ARARs Applicable or Relevant and Appropriate MOST Ministry of Science and Technology
Requirements MSD Military Science Department
BCY Bank Cubic Yards NACCET National Action Centre for Toxic
CC Chemical Command Chemicals and Environmental Treatment
CFR Code of Federal Regulations NE Northeast
CLIN Contract Line Item Number NW Northwest
CM Construction Management O&M Operations and Maintenance
COC Chemical(s) of Concern PI Pacer Ivy
COP Chief of Party PCB polychlorinated biphenyl
CTET Center for Technology and ppt parts per trillion
Environmental Treatment Project Dioxin Remediation at Bien Hoa Airbase
DGA Data Gap Analysis Area Project
DoD Department of Defense QAPP Quality Assurance Project Plan
DONRE Dong Nai Department of Natural QCVN Vietnamese National Technical Regulation
Resources and Environment SAP Sampling and Analysis Plan
DU Decision Unit SCM Site Conceptual Model
EA Environmental Assessment SME Subject Matter Expert
EIA Environmental Impact Assessment SW Southwest
EMP Environmental Management Plan SVOC Semi-Volatile Organic Compound
EMMP Environmental Mitigation and Monitoring SWEMMP Site-Wide Environmental Mitigation and
Plan Monitoring Plan
FS Feasibility Study SWPPP Stormwater Pollution Prevention Plan
ft2 square feet TCH Thermal Conductive Heating
G2L Gate 2 Lake TCVN Vietnamese Technical Standard
GHG Greenhouse Gas TEQ Toxic Equivalents
GVN Government of Vietnam TM Technical Memorandum
ha hectare UCDDA Uncontaminated Construction Debris
HASP Health and Safety Plan Disposal Area
HCSA High Concentration Storage Area UNDP United Nations Development Programme
HCTS High Concentration Temporary Storage U.S. United States
ID Identification USAID United States Agency for International
IM Interim Measure Development
IPTD In Pile Thermal Desorption USEPA United States Environmental Protection
LCSA Low Concentration Storage Area Agency
LCY Loose Cubic Yards UXO Unexploded Ordnance
LSGA Limited Scope Grant Agreement VOC Volatile Organic Compound
LTSA Long-Term Storage Area VRTC Vietnam Russia Tropical Center
m2 square meter WBS Work Breakdown Structure

FINAL MASTERPLAN – VOLUME 1 | viii
EXECUTIVE SUMMARY
In a Memorandum of Intent signed on January 23, 2018, the U.S. Agency for International Development
(USAID) and Vietnamese Military Science Department confirmed “their mutual desire to cooperate
on efforts to remediate dioxin contamination at the Bien Hoa Airbase area, Vietnam.”
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:
• EXCAVATION AND TRANSPORT OF CONTAMINATED SOIL AND SEDIMENT – soils and

sediment with dioxin concentrations greater than the cleanup action level for each decision unit
will be excavated. For further details see Section 5.2;
• LONG-TERM STORAGE OF SOIL AND SEDIMENT WITH “LOW” DIOXIN

CONCENTRATIONS GREATER THAN THE CLEAN UP LEVEL BUT LESS THAN 1,200

FINAL MASTERPLAN – VOLUME 1 | ix
PPT TEQ – this excavated material will be isolated (stored) in the long-term storage area (LTSA).
The LTSA will be constructed north of the runway. For details on its design see Section 5.3;
• TREATMENT OF SOIL AND SEDIMENT WITH “HIGH” DIOXIN CONCENTRATIONS

ABOVE 1,200 PPT TEQ – soils and sediment with dioxin concentrations at or above 1,200 ppt
TEQ will undergo thermal treatment to a residual dioxin concentration of 100 ppt TEQ or less.
TCH was selected as the preferred remedial treatment technology as described in Section 4.3.
There will be one TCH Treatment plant constructed in the Z1 area throughout the life of the
Project. For further details on its construction, operation, and demobilization see Section 5.4;
• RECONTAMINATION CONTROLS TO PREVENT SOIL AND SEDIMENT EROSION WILL

BE IMPLEMENTED FOR EACH ACTIVITY – erosion and sediment controls and site restoration
will be conducted to prevent recontamination. For further details see Section 5.5; and
• 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.
REMEDIATION ACTIVITY PACKAGING

The remediation activities are organized into six (6) packages to implement the remedial actions: First
Interim Measures (IM1), Second Interim Measures (IM2), Civil Work Phase 1, TCH Treatment Plant
(Design, build and Operation), Civil Work Phase 2, and TCH Treatment Plant (Operation and
Demobilization). An implementation summary that describes each activity package is provided in
Section 4.1. The activity details, remediation volumes, and maps are provided in Section 5.8. The
Project schedule for these activities is shown in the below Summary Table 1.
SUMMARY TABLE 1 MASTERPLAN SCHEDULE

PHASE 1 PHASE 2
ACTIVITY
2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030
Interim Measures 1 (IM1)
Interim Measures 2 (IM2)
Civil Works Phase 1

TCH Treatment Plant
(Design, Build & Operation)
Remediation Support
Civil Works Phase 2

TCH Treatment Plant
(Operation & Demobilization)
ANNUAL REMEDIATION WORK

The amount of remediation work to be completed each year is provided in Summary Table 2 by task,
volume of low and high dioxin concentration material, and decision units (DUs). In the Z1 Area, an
example of a DU is Z1-02. Most DUs are further divided into Sub-DUs with a letter appended to the
DU, such as Z1-02A. Remedial actions are determined at the DU and/or sub-DU level.

FINAL MASTERPLAN – VOLUME 1 | x
SUMMARY TABLE 2 ANNUAL REMEDIATION WORK
VOLUME (M3)
YEAR TASK LOW HIGH TOTAL DECISION UNITS
PI-08, PI-10, PI-13A', G2L, MND-A42, SW-01, SW-02,
2021 Dig & Haul 46,142 21,907 68,049 SW-03
Dig & Haul 55,644 55,644 SW-07, NF-04
2022
Reload to LTSA 26,505 26,505 LCSA Stockpile
NE-07, NE-8, NE-09, NE-11, NE-12, NE-15, NW-03,
2023 Dig & Haul 32,257 1,106 33,363 NW-04
Dig & Haul 8,934 26,527 35,461 DONRE-A1, DONRE-A2, PI-12, PI-15, ZT-02
Reload to
2024 Treatment - 23,013 23,013 HCSA, HCTS Stockpile
MND-A42, DONRE-A1, DONRE-A2, PI-08, PI-10, PI-12,
Treatment - 49,540 49,540 PI-15, ZT-02, SW-01, SW-02, SW-03, NE-07
Dig & Haul 1,780 51,630 PI-02B, PI-02C, PI-13A’’
2025
Treatment - 49,850 49,850 PI-02B, PI-02C
Dig & Haul 5,028 57,242
2026
Treatment - 52,214 52,214 PI-02A, PI-02B
Dig & Haul 14,071 63,814
2027
Treatment - 49,743 49,743 PI-17, PI-18, PI-20, Z1-01
Dig & Haul 13,954 63,238 Z1-01, Z1-02, Z1-03, Z1-06, XD-2
2028
Treatment - 49,284 49,284 Z1-01, XD-2
Dig & Haul 23,942 58,547 Z1-07, Z1-09, Z1-10, Z1-16, XD-2
2029
Treatment - 34,605 34,605 Z1-10, XD-2
2030 Demobilization - - -
REMEDIATION SUPPORT ACTIVITIES

Throughout Project implementation, Remediation Support Activities will be performed to facilitate
the effective completion of the main activities and achieve the Project objectives. These remediation
support activities will include construction oversight, topographic surveying, site-wide hydrology
study, additional soil/sediment site characterization, baseline sampling, treated soil/sediment re-use
approach, material disposition, and Ministry of National Defence (MND) contributions, such as
providing for access and utility infrastructure for the Project. A critical support activity, to be provided
by MND, is unexploded ordnance (UXO) clearance since this is a dependency, required to be
completed, for all other activities to begin. Additional site characterization will work to confirm the
depth and boundaries of dioxin contamination, where uncertainties exist, to help ensure that final
remediation activity designs most effectively meet Project objectives. It should be noted that additional
site characterization efforts may result in changes in the volumes of soils currently estimated for
excavation and treatment. Any changes will target more complete removal of dioxin from the Bien
Hoa Airbase area.
WORK BREAKDOWN STRUCTURE AND CAPITAL COST

The overall capital cost estimate for the Project is $450.3 Million; this capital cost includes primary
assumptions, risks, sensitivities, contingencies and escalation that are presented in Section 6 along with
an annual capital cost distribution and S-curve for the Masterplan implementation. The Project Work
Breakdown Structure (WBS), description of cost elements as they relate to the remediation activities,
implementation schedule, and costs are also provided in Section 6. In addition, Project Summary
Charts including excavation volumes, dependencies, constraints, and estimated cost/schedule are
provided in Appendix A. The summary chart for the entire Project follows.

FINAL MASTERPLAN – VOLUME 1 | xi
ACTIVITIES DEPENDENCIES MND MILESTONES
REMEDIATION REMEDIATION SUPPORT NO. ACTIVITY TIMELINE
PHASE • UXO Clearance
ACTIVITIES ACTIVITIES
• Design Approval 1 UXO Clearance Complete by Mar 2021
Phase 1 1. Interim Measures 1 6. Project Management 2 Utility Supply
2. Interim Measures 2 7. UXO Clearance • Utilities
• LTSA Construction Water Supply Infrastructure Complete by Jun 2022
3. Civil Works 8. Topographic Surveying
Phase 1 9. Site-wide Hydrology Study, Upgrade • Treatment Plant Construction Power Supply Infrastructure Complete by Jun 2022
4. Utilities (Power and Monitoring 3 Design Approval
and Water) Supply 10. Additional Soil/Sediment Treatment Plant
infrastructure -
MND 11.
Site Characterization
EMMP Baseline Sampling and Monitoring
CONSTRAINTS – 10% Design Complete by Jun 2021
5. TCH Treatment 12. Roads (Hauling Roads Review – Detailed Design Complete by Aug 2022
and Recommendations) • Funding/Budget Civil Works (Annual)
Plant (Design,
Build, Operation) 13. Project Material Disposition Approach • Off-Airbase Relocation – Phase 1 Apr (annual – 2022 to 2025)
14. Placement of Treated Soil Approach • Weather – Dry Season Loading/Unloading
– Phase 2 Complete by Apr 2025
15. Other Measures (Awareness and Signage) • Working Hours Schedule
4 Sampling Quality Assurance / Oversight
• Market
Ambient Air & Water
• Available Equipment (Baseline & Monitoring) Aug 2020 – Dec 2030
Phase 2 1. Civil Works Phase 2 3. Project Management
2. TCH Treatment 4. Topographic Surveying • Traffic Management Additional Site Characterization Aug 2020 – Sep 2022
Plant (Operation, 5. Site-wide Hydrology Study, Upgrade Treatment Plant Operations Aug 2023 – Jan 2030
Demobilization) and Monitoring
6. EMMP Baseline Sampling and Monitoring
7. Roads (Hauling Roads Review and ESTIMATED CAPITAL COST/SCHEDULE
Recommendations) USD $
ACTIVITY (M) 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030
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

FINAL MASTERPLAN – VOLUME 1 | xii
PROJECT FUNDING
Masterplan implementation faces potential funding risks and constraints given that the total estimated
Project capital cost is well above the initial $183 million USAID total estimated contribution. The
Masterplan utilizes three strategies to manage associated risks to meeting Project objectives:
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.

FINAL MASTERPLAN – VOLUME 1 | xiii
1 INTRODUCTION
This Implementation Masterplan (Masterplan) was developed under Architect-Engineer (A&E) Services
for Dioxin Remediation at Bien Hoa Airbase Area Project (Project) by Trigon Associates, LLC (A&E
Bien Hoa Contractor), in accordance with Section C Description/Specifications/Statement of Work,
Subsection C.1.12, Prepare Masterplan, under Component 1 (Contract Line Item Number 1 or
CLIN 1) of Contract No. AID-OAA-I-15-00053, Task Order No. 72044019F00001.
1.1 PROJECT OBJECTIVES

In a Memorandum of Intent signed on January 23, 2018, the U.S. Agency for International Development
(USAID) and Vietnamese Military Science Department confirmed “their mutual desire to cooperate
on efforts to remediate dioxin contamination at the Bien Hoa Airbase area, Vietnam.”
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.
1.2 PROJECT ROLES AND RESPONSIBILITIES

This section summarizes the roles and responsibilities of stakeholders to be involved with Masterplan
implementation. The main GVN stakeholders with responsibilities for implementing the Project are
listed below:
• 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.

FINAL MASTERPLAN – VOLUME 1 | 1
FIGURE 1-1 BIEN HOA AIRBASE OVERVIEW

The Project stakeholders hold a variety of roles, which include approvals, development, funding, and
oversight. Table 1-1 provides a summary matrix of the stakeholder roles.
TABLE 1-1 MASTERPLAN IMPLEMENTATION STAKEHOLDERS

ROLES
DEVELOPMENT
TECHNICAL
OVERSIGHT
FUNDING
SUPPORT
PROJECT
OWNER
STAKEHOLDER
Government of Vietnam (GVN)

GVN National Steering Committee 701
Ministry of National Defence (MND)
Ministry of Natural Resources and the Environment (MONRE)
Provincial Government
United States Agency for International Development (USAID)
The following subsections provide detailed descriptions of the GVN and USAID implementing parties.
1.2.1 GOVERNMENT OF VIETNAM (GVN)

The GVN implementing parties are primarily GVN National Steering Committee 701, MND, MONRE,
and the Provincial Government. These parties and others participated in the Roadmap meetings to
develop the Masterplan. Less visible GVN implementing parties include:
• 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.
1.2.1.1 NATIONAL STEERING COMMITTEE 701

GVN established Office 701, National Steering Committee on the Settlement of Post-war Unexploded
Ordnance and Toxic Chemical Consequences, to oversee and coordinate all dioxin-related matters.
USAID communicates with Office 701 to coordinate Project meetings and events (internal and public)
with GVN project management stakeholders. Office 701 will communicate requests for meetings and
engagement with GVN stakeholders to discuss progress towards USAID/Project objectives,
opportunities for technical innovation, public relations opportunities/challenges, and to gain
understanding of GVN strategy for on-Airbase and off-Airbase remediation activities.
1.2.1.2 MINISTRY OF NATIONAL DEFENCE (MND)

MND is the government agency tasked by the Prime Minister to jointly administer this Project with
USAID. Because the dioxin contamination is on an airbase, project ownership and management have
been delegated to ADAFC; however, ADAFC must comply with MND’s internal policies and
regulations. This includes review by other organizations within MND. The implementing parties and
consulting organizations under MND include the following:
• Military Science Department;

• ADAFC, Division 370, and Regiment 935; and

• ADAFC Technical consultants (AMST, Chemical Command and Vietnam–Russia Tropical Centre).
1.2.1.2.1 MILITARY SCIENCE DEPARTMENT (MSD)

MSD is a signatory, with USAID, to the Project’s 2018 Memorandum of Intent (MOI) and has the
primary role of coordinator for GVN contributions from other ministries to project implementation
through their role as leading Office 701. In addition, MSD leads coordination and technical reviews
within MND of ADAFC requests and submittals.
1.2.1.2.2 AIR DEFENCE AIR FORCE COMMAND (ADAFC)/PROJECT OWNER

As the Project Owner, ADAFC communicates Project strategy, provides updates on Project status
and issues/risks, and provides guidance to the GVN and other implementing parties as needed. ADAFC
will provide regular communication on the status of the Masterplan and supporting components, co-
host Masterplan Roadmap meetings with USAID, be responsible for GVN Project management, and
provide Project technical oversight. ADAFC is a signatory, with USAID, to the Project’s Limited Scope
Grant Agreement (LSGA) and, on behalf of the GVN, is expected to contribute significant resources
towards the Project, such as utility infrastructure and unexploded ordnance (UXO) clearance.
• 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
– VIETNAM-RUSSIA TROPICAL CENTRE (VRTC) – provides technical support to GVN

regarding remedial actions and is tasked with environmental monitoring and oversight.
1.2.1.3 MINISTRY OF NATURAL RESOURCES AND THE ENVIRONMENT (MONRE)

MONRE is the GVN environmental authority. MONRE provides necessary guidance and feedback on
remediation approaches and guidance on regulatory and permitting issues. MONRE establishes GVN
environmental quality regulations and reviews and approves project EIAs including the Bien Hoa EIA.

1.2.1.4 PROVINCIAL GOVERNMENT
The implementing parties under the Provincial Government include the Dong Nai Provincial People’s
Committee, Bien Hoa City People’s Committee and DONRE. All provide local insight and have key
responsibilities in implementing off-site Project activities and local community outreach.
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.
1.2.2 UNITED STATES AGENCY FOR INTERNATIONAL DEVELOPMENT (USAID)

USAID is the signatory, on behalf of the U.S. Government, to the Project MOI and LSGA and as such
will manage/coordinate all activities and funding. The LSGA will be an obligating mechanism through
which USAID Vietnam can manage sub-obligations to various implementation mechanisms. Although
some contract mechanisms are global, all have been and will be awarded by the Vietnam Mission.
There is an Environmental Remediation Unit within the Vietnam Mission from which a contract officer
representative will be assigned to each contracted activity of the Project who will manage all aspects
of implementation including the Implementing Contractors and coordination with GVN stakeholders.
1.2.2.1 IMPLEMENTING CONTRACTOR(S)

Implementing Contractors will be engaged by USAID to accomplish specific remediation activities. The
Implementing Contractors will be responsible for developing and/or implementing activity-specific
workplans as well as annexes to the site-wide Project plans (see Annexes). Oversight will be
conducted by USAID, all applicable GVN stakeholders and the A&E Bien Hoa Contractor.
1.2.2.2 A&E BIEN HOA CONTRACTOR

The A&E Bien Hoa Contractor staff and subcontractors are responsible for supporting USAID in
achieving Project goals and objectives through effective relationships and communications. The A&E
Bien Hoa Contractor is responsible for the development of all site-wide plans and this Masterplan to
provide guidance for all Project contractors. The A&E Bien Hoa Contractor is responsible for
engineering design, construction management implementation support, and related Project support
services.
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.

1.3 MASTERPLAN PURPOSE AND SCOPE
The Masterplan presents remedial alternatives and an implementation approach, including a detailed
schedule and estimated costs. It is the basis for Project procurement and implementation.
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;
• Applicable or Relevant and Appropriate Requirements (ARARs);
• Applicable cleanup levels, reuse, and waste characterization criteria;
• Roles and responsibilities of all parties implementing the Masterplan;
• Implementation activities, schedule, and estimated cost, including interim and long-term remedial
measures; and
• Maps outlining where remedial elements are located.

1.4 MASTERPLAN DEVELOPMENT
course of 10 months, from September 2019 to June 2020 to engage GVN stakeholders as shown in
Figure 1-2. The purpose of the Roadmap meetings was to gain consensus from stakeholders on key
decision points, meet established implementation schedules, and ensure appropriate incorporation of
stakeholder input. Project action levels (thresholds to determine whether soil or sediment must be
treated) for remediation, including the identification of thermal conductive heating (TCH) as the
selected dioxin treatment technology for the Project, are identified and described in Section 2.4 and
Section 4.3. Additional detail regarding the Masterplan Roadmap meetings is provided in Section 3.1.
FIGURE 1-2 PROJECT ROADMAP MEETINGS
1.5 CRITICAL SUCCESS FACTORS

The Masterplan will guide the remediation of dioxin contamination at the Bien Hoa Airbase Area and
has been developed to address the following critical success factors:
• Accomplish Project goals and objectives while striving for “Zero Injuries;”
• Reduce risk to humans and the environment;
• Remediate, in accordance with the ARARs, contaminated soil and sediment;
• Maintain Sufficient funding
• Halt off-Airbase migration of dioxin contamination;

• Prevent recontamination of remediated areas;
• Provide economic benefits for Vietnam and the local community;
• Ensure Project stakeholder expectations are met; and
• Incorporate lessons learned from other successful remediation sites.

2 PROJECT BACKGROUND
The U.S. Government and the GVN have established a strong working relationship to overcome the
legacies of the American-Vietnam War. The U.S. military stored Agent Orange at several facilities,
including the Bien Hoa Airbase, which have become hotspots of lingering contamination. Agent
Orange is an herbicide that contains dioxin as a production byproduct, and dioxin contamination has
been identified in soils and sediments in and around areas where this chemical was handled or stored.
Studies have found the Bien Hoa Airbase Area to be the largest of three major dioxin contamination
hotspots in Vietnam (approximately 500,000 m3). The others were Danang (162,500 m3 remediated
in 2012–2018 through treatment and isolation by USAID) and Phu Cat Airports (11,000 m3
remediated in 2012 through isolation by the United Nations Development Programme (UNDP)–
Global Environmental Finance).
2.1 KEY PLANNING AND APPROVAL DOCUMENTS

The following key documents and decisions form the basis for the Project. Additional historical
information can be found in Volume 2, Section 8.
• GVN/USAID Environmental Assessment 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);
• MSD/USAID Memorandum of Intent on Dioxin Remediation at Bien Hoa Airbase Area, signed in
early 2018, describes roles, collaboration mechanisms, as well as the intentions of each participant
during implementation.
• ADAFC/USAID Limited Scope Grant Agreement for the Project, signed in mid-2018, specifies the
Project purpose, USAID financial contribution, Project completion date, and formalizes the joint
project implementation relationship between USAID and ADAFC.
• MND/ADAFC “Project Pre-Feasibility Report for Dioxin Remediation at Bien Hoa Airbase Area
Phase I”, prepared in 2018 by the New Technology Institute/Academy of Military Science and
Technology (AMST) provides the initial description of the work needed to perform remediation
of dioxin contamination at the Bien Hoa Airbase Area;
• USAID Dioxin Remediation at Bien Hoa Airbase Area Project – Project Appraisal Document,
prepared in 2019, defines the initial scope of the Project and available funding;
• MND/ADAFC Report of Environmental Impact Assessment (EIA) for the Dioxin Remediation at
Bien Hoa Airbase Area Project, prepared 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. It also provides
the initial Environmental Management Plan (EMP);
• Ministry of Natural Resources and the Environment (MONRE) Decision Document No. 702/QD-
BTNMT, Approval of Environmental Impact Assessment Report – The Dioxin Remediation and
Bien Hoa Airbase Area Project, prepared in 2019, approves the EIA, highlights the key
environmental protection requirements, and requires development of an EMP;
• GVN Prime Minister Decision No. 425/QD-TTg on Approval of the Investment Policy for the
Project of “Dioxin Pollution Remediation at Bien Hoa Airbase Area – Phase 1,” signed in 2019,

established the investment policy and set MND as the lead ministry to coordinate within GVN
and with USAID; and
• 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, prepared in 2019, approves
the Project and establishes key benchmarks for remediation activities.
2.2 APPLICABLE DIOXIN REGULATIONS

Project planning and execution must follow a path that consistently protects human health and the
environment. This requires establishment of a comprehensive understanding of ARARs and strategies
to apply the requirements throughout the course of the Project. As is required by industry standards
and best practices, the A&E Bien Hoa Contractor developed tabulated ARARs, which are introduced
in Volume 2, Section 10 and provided in Volume 2, Annex 5.
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;
TABLE 2-1 BIEN HOA AIRBASE AREA DIOXIN ALLOWABLE LIMITS

ALLOWABLE LIMIT OF DIOXIN CONTAMINATION
LAND AND USE TYPE
(ppt TEQ DRY WEIGHT)
Forest Land and Land for Perennial Trees 100
Urban Residential Land 300
Commercial Land 1,200
Industrial Land 1,200
Notes:
ppt – parts per trillion
TEQ – Toxicity Equivalents to 2,3,7,8-tetrachlorodibenzodioxin (2,3,7,8-TCDD)
• 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;

• National Standard TCVN 10843:2015, Ambient Air Quality - Maximum Dioxin Concentration in
Ambient Air, will be considered along with baseline data on levels of dioxin in ambient air to
establish Project action levels outside of active excavation, handling, and treatment areas; and
• 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.
2.3 DIOXIN CONTAMINATION AT BIEN HOA AIRBASE AREA

The EA provides a comprehensive assessment of dioxin contamination on the Airbase, although
additional site characterization is underway to support Masterplan implementation. The total volume
of dioxin-contaminated soils and sediments was estimated in the EA to be in the range of 408,500 m3
(baseline estimated volume) to 495,300 m3 (with contingency). The baseline estimate includes a
projected depth of contamination in areas where the extent was not physically measured as part of
the EA effort. The contingency accounts for the uncertainty in the projected depth and the lateral
extent in unbounded areas. Approximately 95 percent (%) of the dioxin contamination is located on
the Airbase, primarily in the Pacer Ivy (40%), Z1 (30%), and Southwest (10%) areas. The contamination
in the Z1 area is largely contained in two landfills which were constructed by MND (75% of Z1 volume)
in 2010 and 2016. Airbase areas were previously shown in Figure 1-1, while surface dioxin
concentrations are shown in Figure 2-1 by area, DU, and sub-DU.
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:
• DONRE-A1 (adjacent to PI-12): An area of 8,560 m2 of contaminated soils (reported with a

maximum of 1,751 ppt TEQ), occupied by 75 households (residences) in Bửu Long Ward, referred
to by DONRE as “Residential Area 5.” Estimated volume of 6,560 m3 (before contingency) plus
an additional 5,840 m3 in uncontaminated overburden soils;

FIGURE 2-1 SURFACE DIOXIN CONCENTRATION

• DONRE-A2: An area of approximately 1,630 m2 of contaminated soils (reported with a maximum
of 4,023 ppt TEQ in soils) on open land located to the southeast of Pacer Ivy Area near the access
road to the Trấn Biên Temple. Estimated volume of 760 m3 contaminated soils (before
contingency);
• MND-A42: An area of approximately 320 m2 of contaminated sediments (reported with a

maximum of 4,023 ppt TEQ) on open land that is located to the south of the Airbase outside of
Gate 1. Estimated volume of 190 m3 contaminated soil (before contingency); and
• G2L-1: An area of approximately 5,810 m2 of contaminated sediments in Gate 2 Lake (reported

with a maximum of 166 ppt TEQ) which excludes the areal extent of the Tax Department building
currently under construction in a portion of the original Gate 2 Lake footprint. Estimated volume
of 870 m3 contaminated sediment (before contingency). Dong Nai Province has not provided
information on the fate of the excluded 230 m3 in the tax building footprint.
Additional changes since the EA include the following:
• 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.

TABLE 2-2 TOTAL ESTIMATED CONTAMINATION VOLUME TO BE REMEDIATED 1
TOTAL VOLUME (m³)
AREAS
SOIL SEDIMENT GRAND TOTAL
DONRE-A1 6,920 - 6,920

DONRE-A2 830 - 830
MND-A42 230 - 230
Gate 2 Lake - 1,370 1,370
Northeast - 26,610 26,610
Northern Forest 35,270 - 35,270
Northwest - 6,750 6,750
Pacer Ivy 152,700 36,830 189,530
Southwest 53,890 - 53,890
ZI 136,380 16,660 153,040
ZT (taxiway) 12,560 - 12,560
Grand Total 2 398,770 88,210 486,990
Notes:
1
– Estimate volume includes contingency
2
– Totals may differ slightly from a sum of the areas in this table due to rounding
m³ – Cubic Meters
MND – Ministry of National Defence
DONRE - Dong Nai Department of Natural Resources and Environment
2.4 PROJECT ACTION LEVELS

During the Masterplan Roadmap meetings, consensus was reached with GVN stakeholders on the
ARARs discussed in Section 2.2. The ARARs were used to identify the Project action levels
(thresholds) that directed remediation activities such as the following:
• 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

FIGURE 2-2 PROPOSED LAND USE BASED ON EA/EIA

FIGURE 2-3 PROPOSED PROJECT ACTION LEVELS FOR MASTERPLAN DEVELOPMENT

• TREATMENT TECHNOLOGY EVALUATION CRITERIA – as discussed in Section 4.3.2,
evaluation criteria were identified in seven categories covering general regulatory compliance,
effectiveness of dioxin treatment, implementability, sustainability, cost, residual risk, and
stakeholder/community acceptance. Nine criteria were determined to be mandatory “Stage One”
thresholds (i.e., “Yes/No” or “Retain/Reject”) that must be met for a technology to be suitable
for this Project. One of these is the Project Treatment Threshold for remediating dioxin-
contaminated soils/sediments – treat contaminated material to ≤100 ppt TEQ. Thermal
conductive heating (TCH) was the only technology to successfully meet all Stage One criteria.
The remaining Stage Two “weight factor” evaluation criteria will be considered during USAID’s
procurement process to evaluate the TCH treatment proposals.
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.
TABLE 2-3 ANNUAL REMEDIATION WORK

VOLUME (M3)
YEAR TASK LOW HIGH TOTAL DECISION UNITS
PI-08, PI-10, PI-13A', G2L, MND-A42, SW-01, SW-02,
2021 Dig & Haul 46,142 21,907 68,049 SW-03
Dig & Haul 55,644 55,644 SW-07, NF-04
2022
Reload to LTSA 26,505 26,505 LCSA Stockpile
NE-07, NE-8, NE-09, NE-11, NE-12, NE-15, NW-03,
2023 Dig & Haul 32,257 1,106 33,363 NW-04
Dig & Haul 8,934 26,527 35,461 DONRE-A1, DONRE-A2, PI-12, PI-15, ZT-02
Reload to
2024 Treatment - 23,013 23,013 HCSA, HCTS Stockpile
MND-A42, DONRE-A1, DONRE-A2, PI-08, PI-10, PI-12,
Treatment - 49,540 49,540 PI-15, ZT-02, SW-01, SW-02, SW-03, NE-07
Dig & Haul 1,780 51,630 PI-02B, PI-02C, PI-13A’’
2025
Treatment - 49,850 49,850 PI-02B, PI-02C
Dig & Haul 5,028 57,242
2026
Treatment - 52,214 52,214 PI-02A, PI-02B
Dig & Haul 14,071 63,814
2027
Treatment - 49,743 49,743 PI-17, PI-18, PI-20, Z1-01
Dig & Haul 13,954 63,238 Z1-01, Z1-02, Z1-03, Z1-06, XD-2
2028
Treatment - 49,284 49,284 Z1-01, XD-2
Dig & Haul 23,942 58,547 Z1-07, Z1-09, Z1-10, Z1-16, XD-2
2029
Treatment - 34,605 34,605 Z1-10, XD-2
2030 Demobilization - - -
2.5 POST-REMEDIATION PREVIEW

Implementation of remediation activities, based on the Project Action Levels, will result in changes to
the existing surface dioxin concentrations at the Airbase Area that were presented in Figure 2-1. As
a preview of what will be accomplished by the Project, Figure 2-4 shows surface dioxin concentrations
after implementing Phase 1 in 2025, and Figure 2-5 shows surface dioxin concentrations after Project
completion in 2030.

FIGURE 2-4 SURFACE DIOXIN CONCENTRATION POST-PHASE 1

FIGURE 2-5 POST-REMEDIATION SURFACE DIOXIN CONCENTRATION

3 STAKEHOLDER ENGAGEMENT
Intrinsic to the Masterplan process are contributions from Project stakeholders which have been a
critical factor in the success of the Masterplan development and, therefore, must continue during
Project implementation. The following Subsections provide a summary of engagement during the
Masterplan development and an overview of engagement during its implementation.
3.1 ENGAGEMENT DURING MASTERPLAN DEVELOPMENT

course of 10 months from September 2019 to June 2020 to engage GVN stakeholders to benefit
Project design and implementation. As shown in Figure 3-1, the various participants cover a wide
range of mostly technical agencies. Project stakeholders include additional organizations to the
implementing parties described in Section 4. Additional Project stakeholders include the Ministry of
Science and Technology (MOST), Military Science Department (MSD), Chemical Command, i.e., the
parent organization of CTET, and the National Action Centre for Toxic Chemicals and Environmental
Treatment (NACCET)
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.
FIGURE 3-1 MASTERPLAN PROJECT STAKEHOLDERS

FIGURE 3-2 ROADMAP TO MASTERPLAN DEVELOPMENT
3.1.1 ROADMAP MEETING 1

Roadmap Meeting 1 was held on September 6, 2019. The purpose of the meeting was to kick off the
remediation project and coordinate initial actions. Discussion topics included an introduction and
background to the Project, USAID-GVN past efforts, overview of the Masterplan, and overview of
the Project Roadmap and future meeting topics.
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.

Roadmap Meeting 2 was held on November 18 and 19, 2019. Discussion topics included previous
meeting recap and update on major activities since the last meeting, Site Conceptual Model (SCM),
ARARs, Data Gaps Analysis (DGA), Site-Wide Health & Safety Plan (HASP), Sampling & Analysis Plan–
Quality Assurance Project Plan (SAP/QAPP), introduction to Risk, Remedial Standards, and Remedial
Treatment Technologies Selection Criteria.
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.

Roadmap Meeting 3 was held on February 28 and 29, 2020. Discussion topics included previous
meeting recap, update on major activities since the last meeting, review of ARAR comments received,
LTSA Technologies Selection and Design, Site Wide HASP, Medical Monitoring, and Treatment
Technology Selection. Ahead of the meeting, the A&E Bien Hoa Contractor consolidated Stakeholder
feedback from Roadmap Meeting 2 and 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.
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.
3.1.4 ROADMAP MEETING 4/5

Roadmap Meeting 4 was delayed due to COVID-19 and was combined with Meeting 5. Meeting 4/5
was held on June 25 and 26, 2020. Discussion topics included previous meeting recap and update on
major activities since the last meeting, presentation of the Masterplan (including work phasing and
scheduling), reflections on the road itself and recognized contributors, and discussed initial steps and
schedule to implement the Final Masterplan.
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.
3.2 ENGAGEMENT DURING MASTERPLAN IMPLEMENTATION
3.2.1 AGENCY ENGAGEMENT

As Project Owners, ADAFC and USAID have regular monthly project management meetings. Under
the Project Risk Identification and Management plan, there will be quarterly internal USAID review
meetings and semi-annual review meetings with USAID, ADAFC, and other GVN Stakeholders.
Environmental monitoring results will be shared regularly. In addition, there will be periodic ad hoc
meetings to address technical issues or facilitate implementation. It is anticipated that there will be a
technical workshop in 2022 with USAID and GVN stakeholders to facilitate the TCH treatment design
review.
3.2.2 COMMUNITY OUTREACH

Because of the structure of civil society in Vietnam, direct engagement with local communities is
primarily conducted by governmental agencies and is represented by the balloon titled
“Communication and Community Outreach” in Figure 3-1. While civil society was not directly
represented in the Roadmap meetings, the need for communication and engagement with the local
community is a required element of Project implementation acknowledged by all participants. Dong
Nai PPC and DONRE have already been engaged with the local community through the ongoing

relocation process to move residents out of contaminated off-Airbase areas that need to be
remediated.
Community outreach as well as press releases and events are being considered to mark the following
Project milestones:
• First year remediation activities (December 2020);
• Start of TCH Contractor’s construction activities (November 2022);
• Start of TCH operation (November 2023);
• Mid-project (approximately November 2025);
• Start of demobilization (November 2029); and
• Project completion (December 2030).

4 MASTERPLAN CONTENT SUMMARY
Section 4 presents the implementation summary of the Masterplan, constituents of concern, site
conceptual model, remedial actions and key design parameters, risk identification and management,
recontamination prevention and control, and project funding.
4.1 IMPLEMENTATION SUMMARY

The Masterplan details activities to accomplish and support the remediation of approximately 500,000
cubic meters (m3) of contaminated soils in roughly a 10-year period. Remedial actions include
excavation and transport, long-term storage, treatment, site restoration, recontamination controls,
and land use controls. There are additional remediation support activities necessary to complete the
remedial actions and achieve the Project objectives. Most critical of these support activities is
unexploded ordnance (UXO) clearance. All other activities are dependent on this critical path item
(i.e., must start and finish on time to ensure that other activities remain on schedule). Other
remediation support activities will address topographic surveying, site-wide hydrology, additional
soil/sediment site characterization, baseline sampling, treated soil/sediment, material disposition, and
MND contributions (detailed in the following subsections). To ensure the accuracy and quality of data
collected during such efforts, a Site-Wide SAP/QAPP has been developed (Annex 2). Further to
ensure health and safety throughout the Project, a Site-Wide HASP has been developed (Annex 3).
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.
TABLE 4-1 MASTERPLAN SCHEDULE

ACTIVITY 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030
Interim Measures 1
(IM1)
Interim Measures 2
(IM2)
Civil Works Phase 1
TCH Treatment Plant

(Design, Build &
Operation)
Remediation Support
Civil Works Phase 2
TCH Treatment Plant

(Operation &
Demobilization)
4.1.1 PHASE 1
Phase 1 (2019 through 2025) includes the following projects:
• FIRST INTERIM MEASURES (IM1) – Design/build procurement that is one of several

construction activities to support the overall Project implementation, began in December 2019

and will occur in the Pacer Ivy (PI) area of the Airbase. Details regarding the tasks to be performed
under the IM1 contract include the following:
– 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;
– Construction of a high concentration temporary storage (HCTS) area;
– 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).

DONRE. 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 (threshold to determine whether excavated soil or sediment must be
treated) will be hauled and placed at the TCH Treatment Plant. Site restoration after
excavation of each area is complete;
– 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.
• UTILITIES (POWER & WATER) SUPPLY INFRASTRUCTURE – MND is responsible for

constructing power and water utility supply infrastructure improvements at the Airbase to
support Project activities, including the TCH Treatment Plant in the Z1 area.
• 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;
• Roads (hauling roads review and recommendations);
• Project material disposition approach;
• Placement of treated soil approach; and
• Other Measures (awareness and signage).

MND CONTRIBUTIONS – Pursuant to its involvement in the Project, MND is committed to provide
direct contributions to the Project. This includes project management on behalf of GVN, design review
and approvals, oversight monitoring, and other activities. There are two MND contributions to the
Project where the timing of completion is critical to achieve overall success of the project. The first
is performing UXO clearance, and the second is providing utility infrastructure for the Project efforts,
particularly for the TCH Treatment Plant. Table 4-2 provides the timeline for completion of critical
MND contributions to support the Project.
TABLE 4-2 MND CONTRIBUTIONS AND CRITICAL MILESTONES

NO. ACTIVITY TIMELINE
1 UXO Clearance Complete by Mar 2021
2 Utility Supply
– Water Supply Infrastructure Complete by Jun 2022
– Power Supply Infrastructure Complete by Jun 2022
3 Design Approval
– Treatment Plant
10% Design Complete by Jun 2021
Detail Design Complete by Aug 2022
– Civil Works (Annual)
Phase 1 Apr (annual – 2022 to 2025)
Phase 2 Complete by Apr 2025
4 Sampling Quality Assurance / Oversight
– Ambient Air & Water (Baseline & Monitoring) Aug 2020 – Dec 2030
– Additional Site Characterization Aug 2020 – Sep 2022
– Treatment Plant Operations Aug 2023 – Jan 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.

• TCH TREATMENT PLANT (OPERATION & DEMOBILIZATION) – is the procurement
package to address treatment of soils or sediment excavated in Phase 2. It will continue operation
of the treatment plant. The TCH contractor will operate 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.
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.
4.2 CONSTITUENTS OF CONCERN

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. Agent Blue, which
contained two organic arsenic compounds as active ingredients, was also used at the Airbase during
the war. While arsenic occurs naturally, sampling for the EA demonstrated an association between
elevated arsenic concentrations in soil and sediment and areas where herbicides were stored and
handled. Agent Orange did not contain arsenic. Thus, a second Project object is to not adversely affect
risks from arsenic, whether naturally occurring or not, when remediating dioxin-contaminated soils
and sediments.
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.
4.3 REMEDIAL ACTIONS AND KEY DESIGN PARAMETERS

The main Project objective is to remediate dioxin contamination at the Bien Hoa Airbase area (both
on and off the Airbase) through treatment (destruction of dioxin) and isolation (block dioxin exposure
to humans and the environment through construction of containment structures). As discussed in
Section 3, USAID and ADAFC co-hosted Masterplan Roadmap meetings to engage GVN stakeholders
and gain consensus from stakeholders on key decision points. The following is the result of that joint
process.
4.3.1 ISOLATION – LONG-TERM STORAGE AREA

During Roadmap Meeting 3, GVN stakeholders discussed the proposed location of the LTSA and its
conceptual design. USAID and MND will provide review and acceptance of the technical design. There
was consensus that the location north of the runway was suitable and that the existing drainage
channel through the area should be re-routed to the west. This would allow for one structure rather

than two on either side of the existing channel and would minimize the impact of any potential erosion.
The consensus design requirements in terms of size, structural stability, environmental risk mitigation,
and operational affordability are summarized in Table 4-3. The only issue that required further action
was to perform a risk assessment on whether the design, without a bottom liner but separated from
groundwater, was protective of human health and the environment.
TABLE 4-3 LONG-TERM STORAGE AREA (LTSA) DESIGN REQUIREMENTS
DESIGN ELEMENT REQUIREMENT
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
Structural Stability  Final cover with low-profile slopes

 Fill thickness depends on total area
 Prevent groundwater seepage
Environmental Risk  Divert surface water

Mitigation  Control the risk of groundwater contamination
 Monitor groundwater during implementation
 Risk assessment on design concept
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.
4.3.2 TREATMENT – SELECTION OF TCH

This section summarizes the process agreed to with GVN stakeholders for evaluating remedial
technologies and to recommend the technology or technologies that best addresses the dioxin
impacted soils in the Bien Hoa Airbase (Airbase) area. Most technologies include multiple techniques
and options for implementing the identified remedial treatment technology. It is not the intent to
identify the best technique or equipment manufacturer to implement the identified technology or
technologies. Instead, the goal is to identify treatment technologies that GVN stakeholders considered
and identify the one found acceptable in meeting critical Project criteria.
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.

Achieving lower residual dioxin concentrations in treated material could allow even greater reuse on
the Airbase.
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.
4.3.2.1 STAGE ONE EVALUATION CRITERIA

The 22 remedial technologies were evaluated against nine (9) “Stage One” screening criteria
determined through stakeholder engagement in Roadmap Meeting 3. The nine (9) screening criteria
were determined to be critical and failure against any criterion excludes a technology from further
consideration. These Stage One evaluation criteria, by category, are as follows, with an identifying
category (number) and criteria (letter) label in parentheses:
GENERAL
• Overall protection of human health and environment (1A); and
• Ability to comply with Project ARARs agreed by GVN stakeholders (1B).
EFFECTIVENESS – Technology must be able to treat the volume of dioxin-contaminated materials to

100 ppt TEQ within the overall Project timeline of ten years with a proven full-scale track record in
terms of reducing dioxin mass and consistent results.
• Effectiveness in treating relevant range of dioxin concentrations (2B);
• Treatment of dioxin must satisfy QCVN and TCVN (2D); and
• By-products must be completely treated/destroyed (2E).
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,

be able to treat all types of soil and sediment and powered by available resources (after reasonable
infrastructure improvements).
• Demonstrated scalability for estimated volumes of soil and sediment (3A); and
• Meets timeline for treating estimated volumes of soil and sediment (3B).
COST – Must be within the established Project budget.

• Within budget (5B).
ACCEPTANCE – Technology must be accepted by the community and GVN stakeholders.

• GVN stakeholder acceptance (7A).
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.
4.3.2.2 TCH TECHNOLOGY

As with any remedial treatment technology, a number of TCH treatment techniques and
configurations could be utilized to meet Project requirements. TCH can be used to either cause
desorption of dioxin or to thermally degrade it. Desorption is accomplished by heating contaminated
soils to approximately 300 degrees Celsius (°C). During the TCH process, soils and sediments are
directly heated for a sufficient duration to extract and potentially destroy target constituents of
concern. Any extracted dioxin mass can then be removed from off-gas, condensate, and leachate by
conventional treatment technologies. TCH technology may be designed to induce high temperature
for destruction or lower temperatures for desorption only (followed by destruction along the
treatment process). A wide variety of energy sources may be used to power the system (e.g., heating
oil or fuel, electricity).
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:

• Ex situ or in situ applications;
• Large constructed ex situ pile(s) or smaller container treatment approach(es);
• Standard vapor extraction or higher vacuum;
• High-temperature in-pile destruction or lower-temperature desorption, followed by off-gas

treatment;
• Vapor treatment via thermal oxidizer or granular activated carbon (GAC);
• Various primary power sources, including fuel (kerosene/diesel) or electric; and/or
• Various leachate/condensate treatment options.
4.3.2.3 STAGE TWO EVALUATION CRITERIA

Stakeholders agreed that USAID should assess different TCH configurations submitted by offerors
using the “Stage Two” evaluation criteria as part of USAID’s procurement process to evaluate TCH
treatment proposals. These Stage Two evaluation criteria, by category, are:
EFFECTIVENESS
• Reducing dioxin mass (2A); and
• Consistent results per technology (2C).
IMPLEMENTABILITY
• Ability to efficiently treat material in dry and rainy seasons and tropical storms (3C);
• Sensitivity to physical properties of soil and sediment (3D);
• Availability of sufficient power/energy supply (3E);
• Technology commercialized for persistent organic pollutants or have been tested on site (3F);
and
• Ability to control the technology and easy to operate (3G).
SUSTAINABILITY – consideration of life cycle costs to operate and manage wastes
• Minimization of consumption of resources (4A).
COST
• Estimate of probable cost (5A).
RESIDUAL RISKS – acceptability of residual risks
• Minimization of byproducts (6A);

• Need for long-term maintenance following implementation (6B); and
• Risk of explosion during treatment (6C).
ACCEPTANCE
• Community acceptance (7B).
Further information is provided on the design, construction, and operation of the TCH Treatment
Plant in Section 5.4.
4.3.3 REMEDIAL ACTIONS SUMMARY

In addition to the primary remediation activities of isolation and treatment, there are other actions
needed such as excavation and storage, recontamination controls, and land use. The ultimate objective
of the remedial actions is to reduce risk to humans and the environment caused by dioxin
contamination by halting off-Airbase migration of contaminated media, preventing recontamination of
remediated areas, treating highly contaminated soil and sediment, and minimizing land use controls.
Table 4-5 presents an overview of the Project’s remedial actions with descriptions of individual
activities for each remedial action and how those activities are protective of human health and the
environment. The implementation details are provided in Section 5 and the scheduling and cost is
provided in Section 6.
4.4 SITE CONCEPTUAL MODEL

The Project SCM is a tool for understanding how dioxin (and other considerations) have changed
over time in the past and will do so in the future. It will continue to be updated with information and
experience gained during Masterplan implementation. The SCM describes the Bien Hoa Airbase Area
site definition and setting, sources of contamination and distribution, migration pathways and
exposure routes, and sensitive receptors. It is presented in a narrative format below, illustrated in
Figure 4-1, and summarized in Table 4-4. Additional information is provided in Volume 2, Section 9.1
and Annex 6.

FIGURE 4-1 PROJECT SITE CONCEPTUAL MODEL
TABLE 4-4 SUMMARY OF SITE CONCEPTUAL MODEL

KEY SITE DEFINITION AND SIGNIFICANT DIOXIN IDENTIFIED DIOXIN POTENTIAL
SETTING CHARACTERISTICS MIGRATION PATHWAYS EXPOSURE ROUTES RECEPTORS
Pacer Ivy and Z1 areas are significant Stormwater Runoff Dietary Exposure / Off-Airbase Adults and
secondary sources Ingestion Children (particularly
near Pacer Ivy)
Multiple drainage pathways from Surface Water Flow Inhalation of Fugitive

Pacer Ivy to residential areas Airborne Particulates On-Airbase Personnel
On-Airbase Residents
Off-Airbase contamination is mostly Wind Erosion and Deposition Dermal Absorption
adjacent to Pacer Ivy Terrestrial Animals
Some contaminated areas disturbed Excavation and Movement of Soil / Sediment Aquatic Animals
since the EA (e.g., XD2 project) Materials Ingestion
Notes:
Bold indicates the pathway of greatest potential concern under existing conditions.
• 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;

– When released to the environment, dioxin compounds became associated with the organic
fractions of Airbase soils and sediment because they are extremely hydrophobic;
– 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.
• Release and Transport Mechanisms
– Dioxin contamination migration pathways exist;
– 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;
– Stormwater runoff is a significant dioxin migration pathway, in particular along drainage

channels from the Pacer Ivy Area to adjacent off-Airbase land areas and, the pathway to the
gateway pond and other off-Airbase water bodies in addition to the Dong Nai River;
– 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
– Exposure routes are identified as dietary exposure/ingestion, inhalation of fugitive airborne

particulate (dust), dermal absorption (direct contact), and soil/sediment ingestion; and
– Dietary exposure/ingestion of contaminated food sources is a significant exposure route.
• Receptors
– Sensitive receptors are identified as off-Airbase adults/children, on-Airbase personnel, on-

Airbase residents, terrestrial animals, and aquatic animals; and
– Off-Airbase adults/children who reside in proximity to the Pacer Ivy Area are particularly at
risk for exposure.

4.5 RISK IDENTIFICATION AND MANAGEMENT FOR PROJECT IMPLEMENTATION
A Risk Identification and Management Plan (Annex 1) was developed 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 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).

TABLE 4-5 REMEDIAL ACTIONS
EXCAVATION LONG-TERM TREATMENT - THERMAL CONDUCTIVE HEATING RECONTAMINATION CONTROLS LAND USE
AND TRANSPORT STORAGE TREATMENT CONTROL OF CONTROL OF SWPPP MONITORING CONTROLS
OF SOIL OFF-GASSING DEWATERING (BACKGROUND,
BASELINE, COMPLIANCE)
Action Physically remove all Storage of low- Destruction of Collection, Collection, Prevent migration Environmental monitoring Restore all
soil or sediment level contaminated contaminants treatment or treatment or of contaminants of all processes to baseline, remediated DUs
that exceeds soil/sediment in high-level other control of other control of during excavation background and compliance to most stringent
Project action levels contaminated TCH off-gas liquids generated and treatment criteria land use on
soil/sediment during during treatment Airbase – forestry
treatment (maximum 100 ppt
TEQ)
Result Eliminates source Eliminates source Permanently Eliminates Eliminates source Monitoring will be Monitoring will be used to Eliminates or
from source area, from environment, eliminates source to air to surface water, used to shut down shut down process if reduces the
eliminates pathway eliminates pathway source from all contamination, soil, or sediment, process if criteria criteria are exceeded, constraints on
to humans or to all receptors environment eliminates eliminates are exceeded, eliminates pathway to future
ecological receptors over long-term receptors pathway to pathway to eliminates pathway human and ecological development of
inhalation for all human and to human and receptors the Airbase area.
receptors aquatic receptors aquatic receptors
Notes:
DUs – decision units
ppt – parts per trillion
SCM – Site Conceptual Model
SWPPP – Stormwater Pollution Prevention Plan
TCH – thermal conductive heating
TEQ – toxic equivalents of 2,3,7,8–TCDD

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. It is designed to be easily understood, used and communicated to stakeholders. The Project
Risk Register provides guidance and support to the A&E Bien Hoa Contractor, USAID and GVN
Stakeholder decision-makers for effective management of Project risks; it does not make decisions for
them.
4.6 RECONTAMINATION PREVENTION AND CONTROL

There is one risk that is low at Project completion but may increase over time. That is the risk of
recontamination of remediated areas if surrounding land use allows higher dioxin concentrations. This
situation is most pronounced when a sediment area (maximum 150 ppt TEQ) is downstream of
industrial land (maximum 1,200 ppt TEQ). As shown in the map in Figure 4-2, the conditions for
potential recontamination would exist in the Northeast area post-Project completion. From top left,
the four panels show the Northeast decision units overlain on a 1) 1968 map, 2) 2009 topography, 3)
surface concentrations post-Project completion, and 4) land use. There is an area of surface
contamination with dioxin concentrations between 450 ppt and less than 1,200 ppt TEQ. While
meeting the industrial land use in this area, the surface contamination is on high ground and could
erode over time into the stream and migrate south into remediated ponds or potentially off Airbase
adjacent to residential areas. Since this area is large (greater than ten hectares), the planned solution
is to conduct additional site characterization in Northeast using redefined decision units with a smaller
grid size to more accurately target areas for remediation. The initial plan for decision units with smaller
grid sizes was presented at the Masterplan Roadmap Meeting 4/5 and is shown in Figure 4-3. Additional
information on recontamination is provided in Section 5.5.
4.7 PROJECT FUNDING

Masterplan implementation faces potential funding risks and constraints given that the total estimated
Project capital cost is well above the initial $183 million USAID total estimated contribution. The
Masterplan utilizes three strategies to manage associated risks to meeting Project objectives:
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

FIGURE 4-2 NORTHEAST AREA SHOWING TOPOGRAPHY, POST-PROJECT DIOXIN CONCENTRATIONS AND LAND USE

FIGURE 4-3 REVISED DECISION UNITS PROPOSED FOR NORTHEAST AREA

FIGURE 4-4 RECLASIFICATION OF PI-20 AND EXPANSION OF PI-17 POND

5 REMEDIAL ACTIONS
This section identifies and describes the Project’s remedial measures or remediation activities that
will be carried out to address the dioxin contamination in the Airbase area. In addition, it also identifies
and describes remediation support activities necessary to facilitate efficient Project implementation.
The main remedial actions include the following:
• EXCAVATION AND TRANSPORT OF CONTAMINATED SOIL AND SEDIMENT – soils

and sediment with dioxin concentrations greater than the cleanup action level for each decision
unit will be excavated and hauled (ultimately) to the LTSA or TCH Treatment Plant. Excavated
material with dioxin less than 1,200 ppt TEQ will be excavated, hauled, and isolated in the LTSA.
Excavated material with dioxin at or above 1,200 ppt TEQ will be hauled to the TCH Treatment
Plant;
• LONG-TERM STORAGE OF SOIL AND SEDIMENT WITH “LOW” DIOXIN

CONCENTRATIONS GREATER THAN THE CLEAN UP LEVEL BUT LESS THAN 1,200
PPT TEQ – this excavated material will be isolated (stored) in the LTSA. The preliminary
conceptual design of the LTSA is a multi-celled landfill with a leachate collection system and cover
layers comprised of grass, a geocomposite drainage layer, geomembrane liner, and geotextile
fabric layer;
• TREATMENT OF SOIL AND SEDIMENT WITH “HIGH” DIOXIN CONCENTRATIONS

ABOVE 1,200 PPT TEQ – soils and sediment with dioxin concentrations at or above 1,200 ppt
TEQ will undergo thermal treatment to a residual dioxin concentration of 100 ppt TEQ or less.
TCH was selected as the preferred remedial treatment technology as described in Section 4.3.
Although TCH technologies can either be implemented in-situ or ex-situ, an ex-situ system was
used as the basis for developing phasing and costs;
• RECONTAMINATION CONTROLS TO PREVENT SOIL AND SEDIMENT EROSION WILL

BE IMPLEMENTED FOR EACH ACTIVITY – erosion and sediment controls and site
restoration will be conducted to prevent recontamination; and
• 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.
5.1 RISK REDUCTION MEASURES IMPLEMENTED TO DATE

Prior to this Project, GVN, MND, Office 33, the UNDP, and other organizations have implemented
several risk reduction measures on and off the Bien Hoa Airbase to eliminate or mitigate dioxin
migration pathways or exposure routes. Additionally, USAID, DONRE, and the City of Bien Hoa are
implementing additional risk reduction measures. These include:
• 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;

• Project XD2, implemented by the CC from 2015 to 2016, included excavation of approximately
51,520 m3 of dioxin-contaminated soils in the Southwest and Z1 area of the Airbase and isolated
in the XD2 Landfill (located adjacent to and on the east side of the XD1 Landfill) in the new DU
called Z1-XD2. The volume of dioxin-contaminated soils removed during Project XD2 in relation
to the total volume of soil and sediment to be remediated during the Project (486,990 m3) is
shown in Figure 5-1;
FIGURE 5-1 PROJECT XD2 – COMPLETED VOLUME
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;
• MND/ADAFC Infrastructure Development and Dioxin Pre-remediation at Bien Hoa Airbase

project initiated in 2016 focused on moving troop basing operations away from dioxin-
contaminated areas to prevent direct exposure risks and develop the infrastructure for this
Project; and
• 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.

5.2 EXCAVATION DESIGN AND TRANSPORT OF CONTAMINATED SOILS AND
SEDIMENTS
5.2.1 EXCAVATION DESIGN

The basis for excavation design (depth and lateral extent/boundary) under IM2 and Civil Works
Phase 1 and Phase 2 is the data collected during the EA, DONRE data for several off-Airbase areas,
and any additional site characterization data collected in select cases when the depth or boundary of
the dioxin contamination is not known from the EA or DONRE data (see Figure 7-26). The pre-
excavation data will be used to fully specify the depth and lateral extent for the excavation design.
This design approach obviates the need to collect any samples post excavation; thus, making the
process more efficient and cost-effective.
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.
5.2.2 EXCAVATION AND TRANSPORT

The following discussion describe the process for excavation and transport of soils and sediments,
including site preparations, excavation measures, and transport. A summary of the excavation process,
which is described further in the paragraphs that follow, is shown in Figure 5-2.
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;

FIGURE 5-2 EXCAVATION PROCESS
• 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;

• Plant roots, aquatic animals, etc. in sediment areas will be handled the same as contaminated
sediment to moved to the LTSA or TCH Treatment Plant;
• The excavation will primarily occur during the dry seasons using equipment and vehicles such as
bulldozers, crawler excavators, and conveyor belts;
• Dioxin-contaminated locations at higher elevations will generally be excavated before those at

lower elevations in order to prevent dioxin recontamination. If lower areas are excavated prior
to higher areas, erosion control measures will be put in place;
• 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 LONG-TERM STORAGE – CONSTRUCTION AND OPERATION OF LTSA

Long term storage is the remedial action for contaminated soils and sediments for which dioxin
contamination is above the cleanup action level for the DU but below 1,200 ppt TEQ.
5.3.1 DESIGN
The characteristics for the selected LTSA location are as follows:
• Comprised of approximately 9.2 hectares;
• 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.

UXO clearance at the LTSA along with topographic survey, hydrological and geotechnical investigation
were conducted. The basis of design was completed in May 2020 and the detail design is in its final
stage. The drainage diversion of the LTSA is shown in Figure 5-3. The preliminary layout and
conceptual design are shown in Figure 5-4. An image of the three-dimensional render is shown in
Figure 5-5, and the cross section is provided in Figure 5-6.
FIGURE 5-3 PRELIMINARY LTSA DRAINAGE DIVERSION

FIGURE 5-4 PRELIMINARY LTSA LAYOUT AND CONCEPTUAL DESIGN

FIGURE 5-5 PRELIMINARY LTSA LAYOUT AND CONCEPTUAL DESIGN RENDERINGS

FIGURE 5-6 PRELIMINARY LTSA LAYOUT AND CONCEPTUAL DESIGN - CROSS SECTION
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;
• Remove grass growing on the surface of the isolation area; and
• Periodically water and maintain vegetation on the surface.
Post-Project, MND will be responsible for ongoing operation and maintenance of the LTSA and needs
to commit dedicated funding to accomplish this.
5.4 TREATMENT PLANT DESIGN – CONSTRUCTION AND OPERATION

Section 4.3 provides an overview of the selection of TCH as the recommended remedial treatment
technology for dioxin-impacted soils with concentrations greater than 1,200 ppt TEQ. This subsection
summarizes the design, construction, and operation of the TCH Treatment Plant that is planned to be
located in the Z1 Area. The location and the main components, such as treatment plant to process
the soil and sediment, pre and post storage areas, and the liquid-vapor treatment plant to handle the

off gas are shown in Figure 5-7. The construction and operation will consider the following factors
that will be established during the planning, engineering and design of the system:

FIGURE 5-7 TCH TREATMENT PLANT LOCATION

• Minimum target design temperature of 335°C (635 degrees Fahrenheit [°F]);
• Capacity for up to approximately 55,000 m3 of contaminated material per annual batch;
• The minimum cumulative design capacity in Phase 1 is 150,000 m3;
• 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;
• Sealed insulation cover to prevent waste gas from escaping; and
• Temperature monitoring points to track heating progress.
Siting for the TCH Treatment Plant is based on the following criteria:
• An area without dioxin-contaminated soil or sediment in order to avoid delays in construction

efforts due to mitigation of contaminated soil or sediment;
• 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
5.4.1 ACTIVITY WORK STAGES

The five primary work stages include site readiness, detail design, excavation, equipment acquisition
and installation, and treatment. These tasks are followed by two post-treatment phases focusing on
material reuse, and demobilization. These work stages are shown in Figure 5-8, and a brief description
of each work stages is provided below.

FIGURE 5-8 TCH TREATMENT WORK STAGES
Engineering and Detail Design
Site Readiness
Excavation
Equipment Acquisition and Installation
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 4: EQUIPMENT ACQUISITION AND INSTALLATION – While the site is being

prepared and excavation of low concentration material is in process, proposed equipment and
facilities will be procured, transported, constructed, and tested to ensure the TCH Treatment
Plant is ready to receive contaminated soil for processing;

• STAGE 5: TREATMENT – Treatment will be performed in batches and under vacuum. It is
anticipated there will be six annual batches of up to approximately 55,000 m3 of contaminated
material per batch and a minimum cumulative design capacity of 150,000 m3 for Phase 1. The TCH
Treatment Plant includes liquid–vapor treatment of condensate, leachate, and extracted vapors;
• 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
• STAGE 7: DEMOBILIZATION – Following completion of treatment activities and removal of all

treated material, the equipment and any materials formerly in contact with contaminated materials
will be decontaminated, or, alternatively, characterized as hazardous or non-hazardous waste
based on volumetric and wipe testing, depending on material type. Once decontamination is
ensured, equipment and temporary facilities will be removed, and the labor force will demobilize.
5.4.2 TREATMENT OPERATIONS

The TCH treatment operations are shown in Figure 5-9. It is anticipated that the duration for each
batch to be excavated, moved, loaded, treated, and unloaded will be approximately one year.
Excavation, loading, and unloading will occur in the dry season. In order to treat the projected volumes
within the Project period, treatment will occur sometimes during the rainy season.
The following steps describe what occurs during TCH treatment:
• 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.

FIGURE 5-9 TCH TREATMENT OPERATIONS
5.4.3 TCH DEMOBILIZATION

The treated material is intended for reuse within the Airbase property and will be reused based on
land use criteria and in a way that eliminates unwanted migration of contaminants. Specific plans for
reuse have not been identified at this time. However, a detail material use plan for the Project will be
developed with focus on the following two options:

• As post-excavation fill, dependent on the land use; and/or
• 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.
FIGURE 5-10 TCH DEMOBILIZATION PROCESS
5.5 RECONTAMINATION CONTROLS
5.5.1 ENVIRONMENTAL MITIGATION AND MONITORING

EMMPs serve as tools for translating the applicable EA conditions and Environmental Impact
Assessment (EIA) environmental mitigation measures into specific implementable and verifiable
actions.
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.
A SWEMMP (Annex 4) was developed to document environmental mitigation measures and

monitoring actions implemented site-wide during Project to minimize the potential for these negative
environmental impacts. Activity-level EMMPs and/or contract specifications will be developed to
provide needed detail to mitigate and monitor for activity-specific, potential environmental impacts.
All Implementing Contractors are required to comply with the applicable activity-level EMMP and
contract specifications. The SWEMMP establishes:

• Site-wide monitoring locations to evaluate changes from baseline conditions and/or Project
impacts are shown in Figure 5-11, Figure 5-12 and Figure 5-13;
• Monitoring to establish baseline surface water quality, air quality, groundwater quality, and ambient
noise/vibration conditions;
• Minimum mitigation measures to be implemented during the Project to address negative

environmental impacts;
• 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.

FIGURE 5-11 WATER MONITORING LOCATIONS

FIGURE 5-12 WEATHER AND AIR MONITORING LOCATIONS

FIGURE 5-13 GROUNDWATER MONITORING LOCATIONS

5.5.2 EROSION AND SEDIMENT CONTROLS
Erosion and sediment controls must be implemented during Project remedial activities, including
construction and excavation activities. These controls consist primarily of structural systems and/or
barriers that prevent recontamination by minimizing surface erosion, scouring, and sedimentation
from stormwater runoff. The minimum erosion and sediment controls, as described in the Site-Wide
Stormwater Pollution Prevention Plan (SWPPP) which is an annex to the SWEMMP (Annex 4), that
must be implemented (at minimum) during Project remedial construction and excavation activities
include the following:
• 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;
• Manage soil/sediment stockpiles and land-clearing debris piles;
• Minimize dust by applying water or other dust suppression techniques to exposed soils;
• Minimize steep slope disturbances (defined as 15% or greater in grade);
• 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.

5.5.3 SITE RESTORATION
Site restoration will occur immediately after excavation to prevent erosion and the buildup of standing
water. Clean, uncontaminated soil will be brought onsite to backfill the excavation locations and
restore the site. In order to minimize standing water in excavated holes, holes will be filled immediately
after the excavation. The site restoration process is displayed in Figure 5-14.
FIGURE 5-14 SITE RESTORATION PROCESS
5.6 LAND USE CONTROLS

Following excavation and site restoration, the Bien Hoa Airbase, ADAFC and the City of Bien Hoa
will have the opportunity to re-evaluate land use opportunities for restored sites.
In addition to allowable dioxin levels, stakeholders will base future land use decisions on the following:

• Airbase operational requirements, such as airfield operations, on-Airbase personnel, and barracks;
• Airbase site constraints, such as flight line clearances, explosive ordnance, and explosive safe
standoff requirements; and
• Community reuse requirements, such as housing, open space, and manufacturing.
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 COMMON PROJECT WORK STAGES

The remedial action activities have common project work stages, common to all, which are required
to execute the remediation; these stages include planning, construction, post-construction (warranty)
and others.
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.
5.7.1.1 SITE SECURITY

For the health, safety, and welfare of the general public and project personnel, all contaminated sites
must be secured prior to and during excavation activities. Security entails physical hardening
(installation of fencing, barriers, vehicle gates), with the goal of preventing access by the general public
and providing security personnel to monitor and limit access to the site. The Pacer Ivy Area has been
the first area to be secured with fencing and personnel from MND’s Regiment 935 in 2019.
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.

FIGURE 5-15 PROJECT ACCESS GATE 3
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.

FIGURE 5-16 PACER IVY SECURITY AREA LAYOUT

5.7.1.2 UXO CLEARANCE
UXO clearance is a key activity that triggers the start of all other Project activities. It is one of the
Project implementation constraints, meaning that no activity on the project can begin without
certifying that UXO clearance for specific area has been completed and is safe for other Project
activities to begin. The UXO clearance certificate is issued by the UXO clearance contractor on behalf
of MND. Through coordination with ADAFC and Regiment 935, the Military Engineer Unit of Dong
Nai Province will implement clearance and collection for removal of UXO and treatment of chemicals
during the Project preparation phase for the entire Project area. A map showing the areas where
UXO has been cleared and areas that still require clearance is presented in Figure 7-24. All explosive
materials will be collected and disposed of in accordance with MND’s regulations.
5.7.1.3 ADDITIONAL SITE INVESTIGATIONS

In order to resolve critical site data gaps, site investigations are required to further refine the
engineering and design process. Volume 2, Section 9.1, provides an overview of the critical data gaps
and the site investigation prioritization process. The findings of the additional site investigation will be
incorporated into design reports, technical specifications, drawings, and supporting documents that
comprise procurement packages to be issued from USAID.
5.7.1.4 ENGINEERING AND DESIGN

Based on site data and planning activities, a complete design and technical specification package will be
prepared for use in procurement tasks; the design and technical specification package are part of the
contract/tender documents which interested parties will use to develop bids for submittal to USAID.
Design documents will incorporate siting, utility, facility and infrastructure requirements needed to
achieve successful construction of the project. Design efforts will include the development, for each
activity, of a HASP, EMMP, SAP, QAPP, and SWPPP. These documents will be based on site-wide plans
developed in the earlier stages of the overall Project.
5.7.1.5 GVN APPROVAL

As part of the design process, the A-E Contractor and USAID will coordinate with MND and ADAFC
for consent on design documents at various stages of the design. Prior to progressing to the
procurement phase, coordination and approval of the design documents will be documented as
necessary.
5.7.1.6 PROCUREMENT/BID AND AWARD

Following the completion of the engineering and design stage and approval of the design documents,
a procurement package for each activity will be developed. The procurement process includes draft
and final statements of work, prospective bidder site walks, and preparation of detailed cost estimates.
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.

5.7.2.1 SITE PREPARATION
Site preparation consists of vegetation clearance and disposal as well as establishing erosion control
and recontamination prevention measures.
• 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.
5.7.2.2 FACILITY CONSTRUCTION

Following installation of site preparation and erosion control measures, all facilities and support
facilities will be constructed. These will include temporary staging areas, utilities, roadway
infrastructure, operation office space and decontamination.
5.7.2.3 OVERSIGHT/CONSTRUCTION MANAGEMENT/EMMP

Oversight and construction management are the day-to-day construction quality assurance oversight
and record-keeping efforts required to ensure that the selected Implementing Contractors meet the
statement of work and contractual requirements. Additionally, oversight efforts will include ensuring
compliance by the Implementing Contractors with the site-wide SAP/QAPP, the site-wide HASP,
blood dioxin serum monitoring, the SWEMMP, and activity-level EMMPs.
5.7.2.4 ENGINEERING SERVICES DURING PROCUREMENT AND CONSTRUCTION

Unforeseen conditions and/or circumstances may require additional design and procurement activities
during construction. The engineering services will serve as the basis for potential modification of
construction contracts to achieve the completion of the remedial action.
5.7.3 POST CONSTRUCTION (WARRANTY PHASE AND MATERIAL DISPOSITION )

Upon construction completion, processes will be in place for inspection and follow-up so that
Implementing Contractor warranties remain valid. Also included in this phase is material reuse/waste
disposal and demobilization.
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.

As shown in Table 5-1, three disposition categories are established in which remaining material will be
evaluated against when the Project activities or tasks are nearing completion. These categories are as
follows:
• 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.
TABLE 5-1 MATERIAL DISPOSITION CATEGORIES
LEVEL OF RESIDUAL DIOXIN OR ARSENIC

MATERIAL TYPE
LOW MEDIUM HIGH
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.

5.8 ACTIVITIES
The Activities required to execute the remedial actions and meet the overall Project objectives are
described below by phase and then activity. Each phase in this section includes a description of what
activities will be accomplished and the estimated volumes that will be remediated annually. A summary
of the annual and total volumes excavated, stored, and treated is provided in Table 5-2. Specific project
work stages and elements (described in Section 5.7) are detailed in Section 6. Appendix A provides
summaries of each activity in addition to the descriptions below.
TABLE 5-2 REMEDIATION VOLUMES SCHEDULE

Excavate Store Treat
ACTIVITY 2021 2022 2023 2024 2025 2026 2027 2028 2029
(m3) (m3) (m3)
Phase 1 244,150 144,760 99,390 68,050 55,640 33,360 35,460 51,630
Phase 2 242,840 57,000 185,850 57,240 63,810 63,240 58,550
Total 486,990 201,760 285,240 68,050 55,640 33,360 35,460 51,630 57,240 63,810 63,240 58,550
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.

FIGURE 5-17 REMEDIAL MEASURES – PHASE 1 & 2

5.8.1 PHASE 1
Phase 1 activities address highly contaminated DUs within the Pacer Ivy and Southwest Areas. Phase 1
will also remediate contamination in several off-Airbase areas. The activities and timeline are shown
in Table 5-3.
TABLE 5-3 PHASE 1 – REMEDIATION ACTIVITIES TIMELINE

TENTATIVE DATES
PHASE 1 REMEDIATION ACTIVITY (ACTIVITY – DECISION UNITS)
START FINISH
1. Interim Measure 1 (IM1) – PI-8, PI-10, PI-13 Dec-2019 Jun-2022
2. Interim Measure 2 (IM2) – G3 Access/LTSA/HCTS, G2L, A42, SW-1/2/3/7, Fence A1/2 Mar-2020 Jun-2023
3. Civil Works Phase 1 Aug-2020 Dec-2025
3.1. Annual 1 – NF-04; Reload LC @ G2L, PI-08/10/13A' Nov-2021 Nov-2022
3.2. Annual 2 – NE-07/08/09/11/12/15, NW-03/04 Nov-2022 Nov-2023
3.3. Annual 3 – A1/A2, PI-12/15, ZT-02; Reload HC @ A42, NE-07, PI-08/10, SW- Nov-2023 Nov-2024
01/02/03
3.4. Annual 4 – PI-02B, 02C, 13A'' Nov-2024 Nov-2025
4. Utilities (Power and Water) Supply Infrastructure – MND Mar-2021 Sep-2022
5. TCH Treatment Plant (Design, Build and Operation) Aug-2020 Dec-2025
5.1. Design Oct-2021 Oct-2022
5.2. Construction Oct-2022 Oct-2023
5.3. Operation Oct-2023 Dec-2025
Table 5-4 provides the Phase 1 excavation and hauling activities by decision unit, including Civil Works
Phase 1.

TABLE 5-4 PHASE 1 EXCAVATION & HAULING WORK BY DECISION UNIT
CONCENTRATION
ACTIVITY OR ANNUAL (m3)
DU TOTAL (m3) NOTES
WORK ORDER
LOW HIGH
Total 66,520 21,910 88,430

Dig and haul to SW-02
Reload to LTSA in Civil Works
G2L-01 1,370 - 1,370 Annual 1
Dig and haul to LCSA, HCSA,
MND-A42 - 230 230
or HCTS based on material
concentration
PI-08 13,190 3,100 16,290
IM1 & IM2 Reload high concentration
PI-10 10,910 4,710 15,620
material to TCH Treatment
Plant in Civil Works Annual 3
PI-13A' 1,040 - 1,040
Dig and haul to LTSA or HCTS
SW-01 370 320 700 based on material
concentration
SW-02 6,600 990 7,590
Reload high concentration
SW-03 12,660 12,560 25,220
material to TCH Treatment
SW-07 20,380 - 20,380 Plant in Civil Works Annual 3
Includes reload
Total 35,270 - 61,770 (35,270 without)
Annual 1: Reload IM1 &
LCSA and
IM2 LC to LTSA, Dig and Reload to LTSA
G2L in SW-02 - - 26,505
haul
Dig and haul to LTSA directly
NF-04 35,270 - 35,270
Total 32,260 1,110 33,360
NE-07 1,440 1,110 2,540
NE-08 10,540 - 10,540

Dig and haul to LTSA or TCH
NE-09 6,540 - 6,540 Treatment Plant based on
material concentration
Annual 2: Dig and haul
NE-11 4,970 - 4,970
Reload high material
NE-12 710 - 710 concentration to TCH
Treatment Plant in Civil
NE-15 1,310 - 1,310
Works Annual 3
NW-03 6,150 - 6,150
NW-04 600 - 600

Includes reload
Total 8,930 26,530 58,470 (35,460 without)
HCSA and Reload to TCH Treatment
HCTS - - 23,013 Plant
Annual 3: Reload IM1 & DONRE-A1 - 6,920 6,920

IM2 to TCH Treatment
Plant, dig and haul off- DONRE-A2 560 270 830
Airbase Dig and haul to LTSA or TCH
Treatment Plant based on
PI-12 6,280 4,600 10,880
PI-15 2,090 2,180 4,270
ZT-02 - 12,560 12,560

CONCENTRATION
DU TOTAL (m3) NOTES
WORK ORDER
LOW HIGH
Total 1,780 49,850 51,630
PI-02 B - 75% - 33,710 33,710

Annual 4: Dig and haul Dig and haul to LTSA or TCH
PI-02 C - 16,140 16,140
PI-13 A'' 1,780 - 1,780
Notes:
Volume figures (amounts) are rounded to the nearest ten
Figure 5-18 shows the areas in which remediation activities will be implemented under Phase 1 of the
Project.

FIGURE 5-18 PHASE 1 REMEDIATION WORK AREAS

5.8.1.1 INTERIM MEASURES 1 (IM1)
IM1 is a design/build construction package currently being implemented as part of Phase 1 for Dioxin
Remediation at Bien Hoa Airbase Area. The goal of IM1 is to address significant potential human health
and ecological risks from dioxin contamination that may be considered for implementation in advance
of completion of Project remediation and containment activities. Significant human health and
ecological risks to dioxin are those via exposure routes documented as ingestion (dioxin-contaminated
food items and incidental ingestion of soils), inhalation (dioxin-contaminated dust or airborne
particulate), and direct dermal contact with dioxin contaminated soils or sediments.
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.
TABLE 5-5 IM1 CONTAMINATED VOLUMES

CONCENTRATION (m³) MAXIMUM
DU EXCAVATION TOTAL (m³)
LOW HIGH DEPTH (cm)
Total 25,140 7,810 32,950
PI-08 13,190 3,100 90 16,290
PI-10 10,910 4,710 60 15,620
PI-13A’ 1,040 - 30 1,040

Notes:
cm – centimeter
DU – Decision Unit
m3 – cubic meter
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
Total 25,140 7,810 32,950
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:
IM1 work areas are shown in Figure 5-19.

FIGURE 5-19 FIRST INTERIM MEASURES

5.8.1.2 INTERIM MEASURES 2 (IM2)
The IM2 project includes the design and construction of the following:
• 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 5-7 IM2 CONTAMINATED VOLUMES

CONCENTRATION (m³) MAXIMUM
DU EXCAVATION TOTAL (m³)
LOW HIGH DEPTH (cm)
Total 41,380 14,100 55,480
G2L-01 1,370 - 15 1,370
MND-A42 - 230 60 230
SW-01 370 320 60 700
SW-02 6,600 990 60 7,590
SW-03 12,660 12,560 155 25,220
SW-07 20,380 - 30 20,380
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
ANNUAL DU NOTES
LOW HIGH (m3)
WORK ORDER
Total
41,380 14,100 55,480
G2L-01 1,370 - 1,370

MND-A42 - 230 230 Dig and haul to LTSA or HCTS based
IM2 on material concentration
SW-01 370 320 700
Reload high concentration material to
SW-02 6,600 990 7,590 TCH Treatment Plant in Civil Works
Annual 3
SW-03 12,660 12,560 25,220
SW-07 20,380 - 20,380
Notes:
Remediation work areas under IM2 including the location of the LTSA is shown in Figure 5-20.

FIGURE 5-20 SECOND INTERIM MEASURES

5.8.1.3 CIVIL WORKS PHASE 1
Civil Works Phase 1 will include excavation, hauling, and reloading of approximately 293,700 m³ of
contaminated soil and sediment in the Pacer Ivy, Southwest, Northeast, ZT, and off-Airbase areas.
This project will reload (transfer) approximately 26,500 m³ of low concentration materials from the
IM1 and IM2 storage areas to the LTSA. Additionally, the project will reload (transfer) approximately
23,000 m³ of highly contaminated materials from IM1 and IM2 temporary storage areas to the TCH
Treatment Plant. During construction, approximately 1,100 m3 of high concentration material at
Northeast area will be temporarily stored for further transfer to the TCH Treatment Plant.
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;
• Reduce risk of re-contamination, i.e., excavate higher areas first;
• Areas available for potential reuse; and
• Avoidance of impact to airbase operations.
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.

FIGURE 5-21 CIVIL WORKS PHASE 1

A summary of this activity, by annual work order, follows:
• 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
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.

FIGURE 5-22 CIVIL WORKS PHASE 1 – ANNUAL 1

• Annual 2
– 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.
CONCENTRATION
DU TOTAL (m3) NOTES
WORK ORDER
LOW HIGH
Total 32,260 1,110 33,370
NE-07 1,440 1,110 2,550
NE-08 10,540 - 10,540

Dig and haul to LTSA or
NE-09 6,540 - 6,540 HCTS based on material
concentration
Annual 2: Dig and haul
NE-11 4,970 - 4,970
Reload high material
NE-12 710 - 710 concentration to TCH
Treatment Plant in Civil
NE-15 1,310 - 1,310 Works Annual 3
NW-03 6,150 - 6,150
NW-04 600 - 600

Notes:
the Project.


• Annual 3
– 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.
ANNUAL DU NOTES
LOW HIGH (m3)
WORK ORDER
Total 8,930 26,530 58,470

HCSA - - 7,810 Reload to TCH Treatment plant
Annual 3: Reload HCTS - - 15,200 Reload to TCH Treatment plant
HCSA and
HCTS to TCH DONRE-A1 - 6,920 6,920
Treatment Plant, DONRE-A2 560 270 830 Dig and haul to LTSA or TCH
dig and haul
PI-12 6,280 4,600 10,880 Treatment Plant based on material
concentration
PI-15 2,090 2,180 4,270
ZT-02 - 12,560 12,560
Notes:
the Project.


• Annual 4
– 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;
– Demobilization and site restoration at temporary storage area (PI-13);
– The remaining low concentration materials from PI-13A’’ (previously underneath the HCTS)
will be excavated and hauled to the LTSA.
CONCENTRATION
DU TOTAL (m3) NOTES
WORK ORDER
LOW HIGH
Total 1,780 49,850 51,630
PI-02 B - 75% - 33,710 33,710

PI-02 C - 16,140 16,140
PI-13 A'' 1,780 - 1,780
Notes:
the Project.


5.8.1.4 TCH TREATMENT PLANT
The Project includes construction of infrastructure to treat up to 55,000 m³ of high concentration soil
and sediment (above 1,200 ppt TEQ) per year and 285,200 m3 overall. The TCH Treatment Plant will
be the only treatment facility constructed and during Phase 1 will treat approximately 99,400 m³ of
high concentration material from the Pacer Ivy, Southwest, Northeast, ZT, North forest and off-
Airbase areas identified by DONRE. The exact technology will be determined as part of the
procurement process.
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.
TABLE 5-13 TCH TREATMENT PLANT FOOTPRINT (AREA)

ELEMENT AREA (m²)
TCH Pile 8,000

Vapor and Water Treatment 1,950
Support Facility
Operating office, decontamination, warehouse /storage 4,800
Soil - Before Treatment 18,075
Soil - After Treatment 15,000
Power Station 500
Internal circulation, exterior storage, material collection, auxiliary construction TBD
Notes:
m2 – square meters
TBD – To be determined
TCH – Thermal Conductive Heating
A map showing the main components of the TCH Treatment Plant is presented in Figure 5-26.

FIGURE 5-26 TCH TREATMENT PLANT

5.8.1.5 REMEDIATION SUPPORT ACTIVITIES
Throughout the Remediation Activities, Remediation Support Activities are performed to maintain the
facilitate the effective completion of the main activities. This includes tasks that can be done within
the first year, and continued as necessary, to raise awareness of the existing risks of dioxin
contaminated soil and sediment. They can include an education program, new and/or improved signage
on and off the Airbase, particularly around water bodies with contaminated sediment, such as the
Pacer Ivy drainage channel, and fenced off Project areas.
Table 5-14 identifies and provides the timeline for the remediation support activities.
TABLE 5-14 REMEDIATION SUPPORT ACTIVITIES TIMELINE

TENTATIVE DATES
PHASE 1 REMEDIATION SUPPORT ACTIVITIES
START FINISH
6. Project Management Jan-2019 Dec-2025
7. UXO Clearance Aug-2020 Mar-2021
8. Topographic Surveying Dec-2020 Jul-2021
9. Site-wide Hydrology Study, Upgrade and Monitoring Mar-2021 Dec-2025
10. Additional Soil/Sediment Site Characterization May-2020 Sep-2022
11. EMMP Baseline Sampling and Monitoring Aug-2020 Dec-2025
12. Roads (Hauling Roads Review and Recommendations) Aug-2019 Nov-2021
13. Project Material Disposition Approach Jun-2020 Aug-2020
14. Placement of Treated Soil Approach Jun-2020 Aug-2020
15. Other Measures (Awareness and Signage) Dec-2020 Dec-2025
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 5-15 PHASE 2 – REMEDIATION ACTIVITIES TIMELINE

PHASE 2 REMEDIATION ACTIVITIES TENTATIVE DATES
(ACTIVITY – DECISION UNITS) START FINISH
1. Civil Works Phase 2 Aug-2023 Dec-2030
1.1. Annual 1 – PI-02A, PI-02B 25% Jan-2026 Dec-2026
1.2. Annual 2 – PI-17, PI-18, PI-20, Z1-01 50% Jan-2027 Dec-2027
1.3. Annual 3 – Z1-01 50%, Z1-02, Z1-03, Z1-06, Z1-XD2 35% Jan-2028 Jan-2029
1.4. Annual 4 – Z1-07, Z1-09, Z1-10, Z1-16 Z1-XD2 65% Jan-2029 Jan-2030
2. TCH Treatment Plant (Operation, Demobilization) May-2024 Dec-2030
Table 5-16 provides the Phase 2 excavation and hauling work by decision unit, including Civil Works
Phase 2.

TABLE 5-16 PHASE 2 EXCAVATION & HAULING WORK BY DECISION UNIT
CONCENTRATION
ANNUAL - ACTION DU (m3) TOTAL (m3) NOTES
LOW HIGH
Total 5,030 52,220 57,250
Annual 1: Dig and haul PI-02 A 5,030 40,980 46,010 Dig and haul to LTSA or TCH
PI-02 B - 25% - 11,240 11,240
Total 14,070 49,740 63,810
PI-17 8,360 1,330 9,690

PI-18 5,710 1,790 7,500
PI-20 - 15,370 15,370
Z1-01 – 50% - 31,250 31,250
Total 13,950 49,280 63,230
Z1-01 - 50% - 31,250 31,250
Z1-02 4,270 - 4,270

Z1-03 6,950 - 6,950
Z1-06 2,730 - 2,730
Z1-XD2 -
35% - 18,030 18,030
Total 23,950 34,610 58,560
Z1-07 8,250 - 8,250
Z1-09 14,200 - 14,200

Z1-10 1,340 1,120 2,460
Z1-16 160 - 160
Z1-XD2 -
65% - 33,490 33,490
Notes:
Figure 5-27 shows the areas in which remediation activities will be implemented under Phase 2 of the
Project.

FIGURE 5-27 PHASE 2 REMEDIATION WORK AREAS

5.8.2.1 CIVIL WORKS PHASE 2
Civil Works Phase 2 will provide for the excavation and hauling of approximately 242,800 m³ of
contaminated soil and sediment in the Z1 and PI areas. High concentration contaminate materials will
be hauled to the TCH Treatment Plant. Low concentration materials will be hauled to the LTSA.
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.

FIGURE 5-28 CIVIL WORKS PHASE 2

A summary of this activity, by annual work order, follows:
• 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.
CONCENTRATION
LOW HIGH
Total 5,030 52,210 57,240
Annual 1: Dig and haul Dig and haul to LTSA or

PI-02 A 5,030 40,980 46,010 TCH Treatment Plant based
on material concentration
PI-02 B - 25% - 11,240 11,240
Notes:
the Project.


• Annual 2
– 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.
CONCENTRATION
LOW HIGH
Total 14,070 49,740 63,810
PI-17 8,360 1,330 9,690

PI-18 5,710 1,790 7,510
PI-20 - 15,370 15,370
Z1-01 – 50% - 31,250 31,250

Notes:
the Project.


• Annual 3
– 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.
CONCENTRATION
LOW HIGH
Total 13,950 49,280 63,240
Z1-01 - 50% - 31,250 31,250
Z1-02 4,270 - 4,270

Z1-03 6,950 - 6,950
Z1-06 2,730 - 2,730
Z1-XD2 -
35% - 18,030 18,030
Notes:
the Project.


• Annual 4
– 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.
CONCENTRATION
LOW HIGH
Total 23,940 34,610 58,550
Z1-07 8,250 - 8,250
Z1-09 14,200 - 14,200

Z1-10 1,340 1,120 2,460
Z1-16 160 - 160
Z1-XD2 -
65% - 33,490 33,490
Notes:
the Project.


5.8.2.2 TCH TREATMENT PLANT
TCH Treatment Plant operations that began under Phase 1 will continue in Phase 2 and will treat
approximately 185,850 m³ of high concentration soils and sediments from the Pacer Ivy and Z1 areas.
This includes the cycle of filling during the dry season, then treating during the rainy season, and
unloading to a post-treatment storage area at the beginning of the next dry season. Material will then
be reused for either excavation fill or for construction fill. At the end of operations, the TCH
Treatment Plant will be dismantled, demobilized, and restored.
5.8.2.3 REMEDIATION SUPPORT ACTIVITIES

Throughout the Remediation Activities, Remediation Support Activities are performed to maintain the
facilitate the effective completion of the main activities. Table 5-21 provides the timeline for the
remediation support activities.
TABLE 5-21 REMEDIATION SUPPORT ACTIVITIES TIMELINE – PHASE 2

TENTATIVE DATES
PHASE 2 REMEDIATION SUPPORT ACTIVITIES
START FINISH
3. Project Management Jan-2026 Dec-2030
4. Topographic Surveying Aug-2023 Aug-2026
5. Site-wide Hydrology Study, Upgrade and Monitoring Aug-2023 Dec-2030
6. EMMP Baseline Sampling and Monitoring Jan-2024 Dec-2030
7. Roads (Hauling Roads Review and Recommendations) Jan-2025 Jan-2026
5.9 ALTERNATIVE SOLUTIONS

A Project of this size and duration will necessarily require adaptive management during
implementation. As part of the Masterplan development, a Project Risk Identification and Management
Plan was developed and is summarized in Section 4.5. There are alternative implementation solutions
which are environmentally safe and, which could contribute to cost-effective completion without
compromising ARARs. These alternatives add flexibility in achieving the Project objectives. In addition,
working toward a reduction in total capital costs and/or leveling annual funding needs could reduce
the likelihood of Project delays—therefore helping to ensure Project success. Two potential
alternative solutions are summarized below. Similar alternative solutions should be continually re-
assessed and considered throughout Project implementation.
5.9.1 Z1-01 AND Z1-XD2 LANDFILLS

One opportunity to reduce or delay Project costs is to leave the XD1 (Z1-01) and XD2 (Z1-XD2)
landfills in place until the final years of the Project. These two landfills contain approximately 62,510
m3 and 51,520 m3, respectively, of dioxin-contaminated material that is safely isolated from humans
and the environment. The location of these landfills is shown in Figure 5-33.

FIGURE 5-33 EXISTING LAND FILLS (XD1 & XD2)

5.9.2 ALTERNATIVE ACTIVITY PACKAGING AND DELIVERY
Packaging and delivery of activities are critical to the successful completion of the Project. Alternative
packaging can increase efficiency in, both, capital cost and schedule. The environmental remediation
industry in Vietnam is in its infancy, which means that there are few local companies capable of
performing the limited available work. This results in a heavy reliance on overseas firms and experts,
often with high associated costs. Developing focused statements of work for upcoming construction
packages can eliminate non-essential tasks while maintaining mandatory tasks for a given contractor.
Moving non-essential tasks from remediation contracts would allow the work to be performed by
local construction companies in one or more procurement package(s) and likely at a lower cost. This
will also have the benefit of maximizing engagement by local companies who will then gain familiarity
and experience to increasingly support or eventually implement environmental remediation projects
in Vietnam.
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.

FIGURE 5-34 ALTERNATIVE PACKAGING TCH TREATMENT PLANT

6 IMPLEMENTATION EFFORTS, SCHEDULE, AND ESTIMATED
CAPITAL COSTS
Section 6 of the Masterplan addresses the implementation efforts to achieve the project goals to treat
or isolate approximately 487,000 m3 of contaminated soil and sediment. The implementation efforts
are presented within a WBS which organizes the overall effort into groups of manageable, executable
tasks. Section 6.1 contains detailed description of the WBS while Section 6.2 provides the WBS
schedule and Section 6.3 provides a summary of estimated costs.
6.1 PROJECT WORK BREAKDOWN STRUCTURE (WBS)

A WBS, in project management and systems engineering, is a deliverable-oriented breakdown of a
project into smaller components. The WBS for the implementation of the Masterplan is broken down
into seven levels of hierarchy as illustrated in Figure 6-1and outlined in Table 6-1.
FIGURE 6-1 SEVEN LEVELS OF HIERARCHY IN WBS
Level 1: Dioxin Remediation at Bien

Project Hoa Airbase Area Project
Level 2: Phase 1 Phase 2

Phase
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
Level 6: Planning Design Procurement Construction

Post
Work Stage Construction
Level 7: Design Design Site

Excavation Inspection etc.
Task submitals reviews mobilization

The Project WBS is provided in Table 6-1 with some examples.
TABLE 6-1 PROJECT WBS

LEVEL TITLE DESCRIPTION
1 Project Dioxin Remediation at Bien Hoa Airbase Area Project
2 Phase Phase 1 or Phase 2

3 Activity Type Remediation Remediation Support
IM1 Project Management
IM2 UXO Clearance
Civil Works Phase 1 Topographic Surveying
Site-wide Hydrology Study, Upgrade and
Civil Works Phase 2
Monitoring
Additional Soil/Sediment Site
TCH Treatment Plant
Characterization
Utility Infrastructure
EMMP Baseline Sampling and Monitoring
4 Activity (Water and Power)
Roads (Hauling Roads Review and
Recommendation)
Project Material Disposition Approach
Placement of Treated Soil Approach
Other Measures (Awareness and Signage)
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
6.1.1 LEVEL 1 - PROJECT

Level 1 is an overall view from start to finish of the Dioxin Remediation at Bien Hoa Airbase Area
Project. It captures all types of activities, sub-activities, stages, tasks and sub-tasks that are planned to
be implemented in the various phases over the duration of this Project.

6.1.2 LEVEL 2 - PHASE
Level 2 is indicative of the Project timeframe in which certain priorities are to be met. It allows for
the logical sequencing of critical Project activities and tasks to be given an utmost implementation
priority in terms of resources and schedule. The Masterplan activities and tasks are grouped into the
following two Phases:
• 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.
6.1.3 LEVEL 3 - ACTIVITY TYPE

Level 3 is indicative of the Activity types. It outlines the type of remediation activities and the
remediation support activities:
• 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.
6.1.4 LEVEL 4 - ACTIVITY

Level 4 - Activity consists of specific remediation measures or remediation support measures that will
be implemented to accomplish the objectives of the Project.
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

several activities and tasks. It is anticipated that the LTSA will be ready to accept excavated material
in 2021. The design, procurement and construction of the TCH Treatment Plant are expected to begin
in 2021 and will be ready for treatment of highly contaminated material in 2023. Once completed, the
TCH Treatment Plant will be continuously operated through the reminder of Phase 1 and most of
Phase 2. On an annual basis, the TCH Treatment Plant will be unloaded early in the dry season,
concurrent to excavation site preparations. Demobilization of the TCH Treatment Plant is projected
to begin in early 2030 and is completed well into end 2030.
6.1.5 LEVEL 5 - SUB-ACTIVITY

Within each Project activity there are, at times, main components that are unique to a specific location
or type of work that require focused tracking and delivery efforts. These components are represented
in Level 5 of the Project WBS and identified as sub-activities. Example of such activities are the five
components of IM2 as outlined earlier. These components (sub-activities) are LTSA, dig and haul of
SW DUs, access roads, temporary storage area for highly contaminated soils and fencing off several
locations off the Airbase.
6.1.6 LEVEL 6 - WORK STAGE

Activity work stages are the various steps activities and sub-activities progress through during their
delivery. These steps may include planning, engineering, design, procurement, construction, operation,
demobilization, project close-out and post-constructions. In the Project WBS, these steps are referred
to as work stages and are tracked at Level 6.
6.1.7 LEVEL 7 - TASK

Level 7, the lowest hierarchy level in the Project WBS, is where specific activities’ tasks and sub-task
are tracked.
6.2 PROJECT SCHEDULE

The successful implementation and delivery of the activities identified in the Masterplan depends on
the effective management and the accuracy of information available to facilitate the decision-making
process. This dictates that the proper tools and systems are being used. The Project schedule has
been designed and built to house and track all activities down to the sub-task level. This means that
activities are monitored closely to insure their progression in accordance with Masterplan strategy.
Each level of the WBS provides the accurate schedule and cost data and reflects impacts of delays that
some activities and tasks have on the overall Project.
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.

FIGURE 6-2 PROJECT SCHEDULE (PHASE 1)

FIGURE 6-3 PROJECT SCHEDULE (PHASE 2)

6.3 ESTIMATED CAPITAL COSTS
Section 6.3 provides a description of how the overall capital cost estimate was developed and the
elements of this cost, including contingencies and escalation. This section also highlights the primary
assumptions, risks and sensitivities used while developing the capital cost estimate. An annual capital
cost distribution and a cumulative curve (also known as an “S-curve”) for the Masterplan
implementation is presented at the end of the section.
6.3.1 BASIS OF ESTIMATE

The Masterplan capital cost estimate was generated using unit rates derived from limited cost data
and therefore will be monitored and updated during implementation. As more information becomes
available on the details of the various activities and tasks, the level of accuracy for the Project capital
cost will increase. The Masterplan capital cost elements include the planning, engineering, project
management, design, procurement, construction, construction management, engineering services
during construction and post construction, with the construction cost element being the highest in
value. Therefore, the construction cost was used as a basis to develop the overall Masterplan
implementation capital costs where all other elements costs are a function of the construction cost.
A schematic illustrating the various Masterplan cost elements and how the overall cost was developed
is shown in Figure 6-4.
FIGURE 6-4 MASTERPLAN COST ELEMENTS
A. Construction Cost including contingency
B. Other Cost Elements are calculated as a percentage (indicated

below) of the Construction Cost, depending on the size and
complexity of the activity/sub-activity:
- Project Management (approximately 5% - 10%)

- Planning (approximately 1% – 3%)
- Design and Engineering (approximately 2% - 5%)
- Procurement (approximately 1% - 3%)
- Construction Management (approximately 3% - 5%)
- Engineering Services During Construction (approximately 1% - 4%)
- Post Construction/ Warranty (approximately 1% - 2%)
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.

An escalation factor was applied using the Building Cost Index methodology. This escalation rate was
derived and factored in on an assumed implementation mid-point of May 2023 for Phase 1 and June
2028 for Phase 2.
A contingency rate of 10% was added on the construction cost to improve the estimate accuracy to
accommodate implementation maturation.
6.3.2 ESTIMATE CAPITAL COST AND CASH FLOW

The Masterplan implementation capital cost is estimated to be approximately $450.3 million with
Phase 1 estimated at approximately $232.2 million and Phase 2 estimated at approximately $218.1
million. Table 6-2 provides a summary of total capital cost by activity.
TABLE 6-2 CAPITAL COST SUMMARY

CAPITAL COST
ACTIVITIES
USD $ (M)
Phase 1
IM1 15.7
IM2 20.0
Civil Works Phase 1 68.0
TCH Treatment (Design, Build and Operation) 81.5
Remediation Support Activities 47.0
Sub-Total 232.2
Phase 2
Civil Works Phase 2 61.2
TCH Treatment (Operation and Demobilization) 137.5
Remediation Support Activities 19.3
Sub-Total 218.1
Total 450.3
Notes:
M – Million USD $
Capital Cost figures (amounts) are rounded to the nearest ten
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.
TABLE 6-3 CAPITAL COST EXPENDITURES DISTRIBUTION

USD $
ACTIVITY 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030
(M)
Phase 1
Remediation 185.1 0.4 8.6 22.2 31.2 36.0 44.8 42.0
Activities
Phase 1
Remediation 47.0 7.4 10.8 10.4 8.5 3.3 3.3 3.3
Support Activities
Phase 2
Remediation 198.8 0.2 2.1 1.1 49.5 45.3 46.3 43.2 11.1
Activities
Phase 2
Remediation 19.3 0.4 0.4 0.5 3.6 3.6 3.6 3.6 3.6
Support Activities
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

FIGURE 6-5 CUMULATIVE CAPITAL COST AND CASH FLOW
CAPITAL COST & CASHFLOW
60.0 500.0
450.0
50.0
400.0
Cumulative (USD $ Million)

350.0
Annual (USD $ Million)
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
Annual Capital Cost Cumulative Capital Cost

7 MAPS OUTLINING DECISION UNITS AND REMEDIAL
ELEMENTS
In addition to the figures presented throughout the document, the following reference figures are
presented in this section:
• Figure 7-1 Historical (1968) Overlay Bien Hoa Airbase Area (Larger/Detailed Image);
• Figure 7-2 Bien Hoa Airbase Overview (Larger/Detailed Image);
• Figure 7-3 Proposed Land Use Based on EA/EIA (Larger/Detailed Image);
• Figure 7-4 Proposed Project Action Levels for Masterplan Development (Larger/Detailed Image);
• Figure 7-5 Remedial Measures – Phase 1 & 2 (Larger/Detailed Image);
• Figure 7-6 Phase 1 Remediation Work Areas (Larger/Detailed Image) ;
• Figure 7-7 First Interim Measures (Larger/Detailed Image);
• Figure 7-8 Pacer Ivy Security Area Layout (Larger/Detailed Image);
• Figure 7-9 Second Interim Measures (Larger/Detailed Image);
• Figure 7-10 TCH Treatment Plant Location (Larger/Detailed Image);
• Figure 7-11 TCH Treatment Plant (Larger/Detailed Image);
• Figure 7-12 Alternative Packaging TCH Treatment Plant (Larger/Detailed Image);
• Figure 7-13 Civil Works Phase 1 (Larger/Detailed Image);
• Figure 7-14 Civil Works Phase 1 – Annual 1 (Larger/Detailed Image);
• Figure 7-18 Phase 2 Remediation Work Areas (Larger/Detailed Image);
• Figure 7-19 Civil Works Phase 2 (Larger/Detailed Image);

• Figure 7-24 UXO Clearance (Larger/Detailed Image);
• Figure 7-25 2009 Topographic View (Larger/Detailed Image);
• Figure 7-26 Additional Characterization (Larger/Detailed Image);
• Figure 7-27 Northeast Area Showing Topography, Post-Project Dioxin Concentrations, and Land
Use (Larger/Detailed Image);
• Figure 7-28 Surface Water (Larger/Detailed Image);
• Figure 7-29 Water Monitoring Locations (Larger/Detailed Image);
• Figure 7-30 Weather and Air Monitoring Locations (Larger/Detailed Image);
• Figure 7-31 Groundwater Monitoring (Larger/Detailed Image);
• Figure 7-32 Groundwater Table Contours - Dekonta Report, 2014 (Larger/Detailed Image);
• Figure 7-33 Drainage System Structures (Larger/Detailed Image);
• Figure 7-34 Hauling Roads (Larger/Detailed Image);
• Figure 7-35 Existing Landfills (Larger/Detailed Image);
• Figure 7-36 Surface Dioxin Concentration (Larger/Detailed Image);
• Figure 7-37 Surface Dioxin Concentration Post-Phase 1 (Larger/Detailed Image); and
• Figure 7-38 Post-Remediation Surface Dioxin Concentration (Larger/Detailed Image).

FIGURE 7-1 HISTORICAL (1968) OVERLAY BIEN HOA AIRBASE AREA (LARGER/DETAILED IMAGE)

FIGURE 7-2 BIEN HOA AIRBASE OVERVIEW (LARGER/DETAILED IMAGE)

FIGURE 7-3 PROPOSED LAND USE BASED ON EA/EIA (LARGER/DETAILED IMAGE)

FIGURE 7-4 PROPOSED PROJECT ACTION LEVELS FOR MASTERPLAN DEVELOPMENT (LARGER/DETAILED IMAGE)

FIGURE 7-5 REMEDIAL MEASURES – PHASE 1 & 2 (LARGER/DETAILED IMAGE)

FIGURE 7-6 PHASE 1 REMEDIATION WORK AREAS (LARGER/DETAILED IMAGE)

FIGURE 7-7 FIRST INTERIM MEASURES (LARGER/DETAILED IMAGE)

FIGURE 7-8 PACER IVY SECURITY AREA LAYOUT (LARGER/DETAILED IMAGE)

FIGURE 7-9 SECOND INTERIM MEASURES (LARGER/DETAILED IMAGE)

FIGURE 7-10 TCH TREATMENT PLANT LOCATION (LARGER/DETAILED IMAGE)

FIGURE 7-11 TCH TREATMENT PLANT (LARGER/DETAILED IMAGE)

FIGURE 7-12 ALTERNATIVE PACKAGING TCH TREATMENT PLANT (LARGER/DETAILED IMAGE)

FIGURE 7-13 CIVIL WORKS PHASE 1 (LARGER/DETAILED IMAGE)

FIGURE 7-14 CIVIL WORKS PHASE 1 – ANNUAL 1 (LARGER/DETAILED IMAGE)




FIGURE 7-18 PHASE 2 REMEDIATION WORK AREAS (LARGER/DETAILED IMAGE)

FIGURE 7-19 CIVIL WORKS PHASE 2 (LARGER/DETAILED IMAGE)





FIGURE 7-24 UXO CLEARANCE (LARGER/DETAILED IMAGE)

FIGURE 7-25 2009 TOPOGRAPHIC VIEW (LARGER/DETAILED IMAGE)

FIGURE 7-26 ADDITIONAL CHARACTERIZATION (LARGER/DETAILED IMAGE)

FIGURE 7-27 NORTHEAST AREA SHOWING TOPOGRAPHY, POST-PROJECT DIOXIN CONCENTRATIONS, AND LAND USE (LARGER/DETAILED IMAGE)

FIGURE 7-28 SURFACE WATER (LARGER/DETAILED IMAGE)

FIGURE 7-29 WATER MONITORING LOCATIONS (LARGER/DETAILED IMAGE)

FIGURE 7-30 WEATHER AND AIR MONITORING LOCATIONS (LARGER/DETAILED IMAGE)

FIGURE 7-31 GROUNDWATER MONITORING (LARGER/DETAILED IMAGE)

FIGURE 7-32 GROUNDWATER TABLE CONTOURS - DEKONTA REPORT, 2014 (LARGER/DETAILED IMAGE)

FIGURE 7-33 DRAINAGE SYSTEM STRUCTURES (LARGER/DETAILED IMAGE)

FIGURE 7-34 HAULING ROADS (LARGER/DETAILED IMAGE)

FIGURE 7-35 EXISTING LANDFILLS (LARGER/DETAILED IMAGE)

FIGURE 7-36 SURFACE DIOXIN CONCENTRATION (LARGER/DETAILED IMAGE)

FIGURE 7-37 SURFACE DIOXIN CONCENTRATION POST-PHASE 1 (LARGER/DETAILED IMAGE)

FIGURE 7-38 POST-REMEDIATION SURFACE DIOXIN CONCENTRATION (LARGER/DETAILED IMAGE)

APPENDIX A – PROJECT SUMMARY CHARTS

APPENDIX B – PROJECT SCHEDULE

APPENDIX C – PROJECT RISK AND MITIGATION

HIGH RISKS AND MITIGATION ACTIONS
RISK STATEMENT INHERENT RISK LEVEL RISK CONTROLS AND MITIGATION ACTION TASKS
RISK ID
(DESCRIPTION) (HIGH, MODERATE, OR LOW) (IN PROJECT MANAGEMENT SOFTWARE)
Some soil and sediment decision units do not > Conduct additional data collection to develop excavation design and determine
have a defined bottom to contamination; soil and sediment quantities.
1 therefore, the scope of remedial measures may High > Closely monitor IM1 confirmation sampling of excavated sediment quantities
be underestimated. during the construction Phase.
Treatment Technology approval by GVN may be
difficult to obtain in a timely manner, therefore > As an approval risk this is a single point of failure.
2 completion of Masterplan and its implementation High > Map the Treatment Technology Approval tasks and dates.
could be delayed. > Identify key Treatment Technology Approval steps in the process.
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

RISK ID
Certain highly complex US regulatory
requirements may not be practicable in Vietnam
(e.g., unavailability of hazardous waste disposal > Consider practicability when determining applicability of regulations/requirements.
10 services, lacking regulatory authority to High > Determine the activities likely to be affected and identify communication and
authorize actions) and therefore delay (stop) training needs.
some Project progress.
> A consistent and aligned project message should be designed and implemented
Consistent and aligned Project messaging is through all contacts with stakeholders.
critical for external communication with > Address monthly with USAID.
11 stakeholder otherwise confusion and High > Explore how social media could be used as a means to help deliver a consistent
miscommunication can occur; therefore, message that is aligned with USAID objectives.
resulting in disruption of project activities and > Meetings with stakeholders should be organized and executed to assure the
loss of project participant reputations. aligned message is delivered consistently.
USAID procurement process is lengthy > Add high level scheduling of USAID procurement to the Project schedule.
(minimum of one year); therefore, certain > Address monthly with USAID.
12 services may not be obtained in time to meet High > Take steps as far in advance as possible to identify the necessary expertise.
project needs. > Establish procurement dates as far in advance as possible.
Significant pressure exists to advance
implementation as much as possible, even before > Whenever possible exercise restraint in moving to implementation activities prior
planning activates are complete; therefore, key to completing all necessary planning activities.
13 components of future phases may not be High > Identify the benefits, costs, and risks of the proposed change.
adequately developed and there will be less > Document the decision, update the risk register, communicate the decision and
integration when phasing activities (loss of risks, and update affected plans.
efficiency).
Documented risk control and mitigation tasks > Insert risk control and mitigation action tasks into the project management
will benefit Risk Owners; therefore, without software (P6).
14 documented tasks risks would not be properly High > Allow risk owners access on at least a read-only basis so that tasks can be
controlled and cause negative effects on project properly monitored and executed as scheduled.
activities. > Discuss during Risk Owner Calls.
> Reference to the EMMP
There are multiple discharge points from the > Communication - internal/external
Airbase for surface water/stormwater > Fugitive emissions: stormwater
15 (particularly from Pacer Ivy); therefore, High > Document identifiable discharge points
discharges may result in public concerns and > Develop Stormwater Management Plan
questions. > Monitor stormwater discharge
> Implement corrective actions as needed
Design, construction and post-construction costs
uncertainties exist; therefore, budgets may be > Review EA costs for completeness and current values and incorporate knowledge
16 exceeded. High into procurement cost estimates
> Use normally established and routinely exercised budget management practices to
Example: IM1 Contract (design/build) has a cost monitor and track control of this risk.
estimate for excavation 36% higher than the

RISK ID
estimate in the EA due to additional excavation > Include high-level control practices in the Project schedule and activity schedules
and moving of soils beyond the amount that was
cost-estimated in the EA. Project may exceed
anticipated funding Example:
> Determine reality of cost differential through clear understanding of project
construction and post-construction cost drivers
> Closely monitor project cost
> Identify where double handling of excavated material can be minimized
> Identify means to save money on fixed price contracts through clearly defined and
detailed scopes
> Identify local contractors with potentially lower cost profiles
> Seek additional information from DONRE.
> Determine what and when additional data is needed.
DONRE has not granted access to > Identify who should obtain the needed data, including whether it can be done
verify/characterize off-Airbase contamination. before land handover.
17 There is uncertainty in the volumes and if greater High > Determine how and when procurement of the needed data collection services are
than anticipated this could delay remedial to be obtained on a timely basis.
activities and increase costs. > Gain early access to sample.
> Incorporate data gathered into activities of all applicable project life-cycle phases.
> Regular communication with ADAFC is needed on the importance and status of
Unexploded Ordnance (UXO) clearance is a UXO clearance
critical path item with many dependent activities > Identify UXO Subject Matter Experts to assist in implementing the UXO
that are affected by delays (site investigations, clearance oversight plan.
18 design work, etc.). Additionally, UXO found after High > Arrange for qualified persons to monitor UXO search and identification work to
initial screening will delay project activities until assure compliance with requirements.
removed. > Establish agreement 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 to next dry
season (~ 7 months later). Excavation and > Identify likely rainy season scenarios in applicable planning documents
treatment present much higher risks when they > Include rainy season aspect in planning in construction plans and activity designs
19 occur in the rainy season; therefore, the lack of High > Identify single points of failure in the construction schedule
timeliness for procurement, approvals, > Monitor single points of failure in schedule and proactively mitigate whenever
excavations, and other activities can have possible
significant negative implications when they shift
excavation and/or treatment into the rainy
season. there are ripple effects of things not
getting done in the rainy.

ANNEX 1 – RISK IDENTIFICATION AND MANAGEMENT PLAN

FINAL BIEN HOA PROJECT RISK

IDENTIFICATION AND MANAGEMENT
PLAN
MARCH 18, 2020

This publication was produced for review by the United States Agency for International Development
FINAL BIEN HOA PROJECT RISK

IDENTIFICATION AND ANAGEMENT
PLAN

MARCH 18, 2020
PREPARED BY
USA
DIOXIN REMEDIATION AT BIEN HOA AIRBASE AREA PROJECT | i

FINAL PROJECT RISK IDENTIFICATION AND MANAGEMENT PLAN
CONTENTS
RECORD OF REVISIONS ............................................................................................................................................... II
LIST OF ACRONYMS AND ABBREVIATIONS....................................................................................................... III
EXECUTIVE SUMMARY .................................................................................................................................................. 1
PLAN IMPLEMENTATION ....................................................................................................................................... 2
ROLES AND RESPONSIBILITIES FOR PROJECT RISK PLAN IMPLEMENTATION ................................ 2
QUARTERLY AND SEMI-ANNUAL PROJECT RISK REVIEWS BY USAID AND GVN
STAKEHOLDERS ............................................................................................................................................... 3
CAPACITY BUILDING IN PROJECT RISK MANAGEMENT FOR GVN STAKEHOLDERS .................. 3
1 PURPOSE AND INTRODUCTION .............................................................................................................. 4
2 IMPLEMENTATION OF THE PROJECT RISK IDENTIFICATION AND MANAGEMENT PLAN5
2.1 PROJECT RISK MANAGEMENT GENERAL ROLES AND RESPONSIBILITIES ................................ 6
2.2 PROJECT RISK IDENTIFICATION AND MANAGEMENT PLAN REVIEWS.................................... 7
2.3 CAPACITY BUILDING IN PROJECT RISK IDENTIFICATION AND MANAGEMENT FOR
GVN STAKEHOLDERS .................................................................................................................................... 8
2.4 QUARTERLY AND SEMI-ANNUAL REVIEW AGENDAS ..................................................................... 8
3 THE PROJECT RISK REGISTER ..................................................................................................................... 9
3.1 RISK IDENTIFICATION ................................................................................................................................... 9
3.2 RISK ASSESSMENT, RATING AND RANKING ...................................................................................... 10
3.3 HIGH RISK CONTROLS AND MITIGATION ACTIONS.................................................................... 11
3.4 PROCESS STEPS TO POPULATE THE PROJECT RISK REGISTER MATRIX.................................. 12
3.5 RISK ELEVATION PROCESS ........................................................................................................................ 13
3.6 POTENTIAL OPPORTUNITIES ................................................................................................................... 14
3.7 PROJECT RISK IDENTIFICATION AND MANAGEMENT PLAN METRICS .................................. 14
APPENDIX A: PROJECT RISK IDENTIFICATION AND MANAGEMENT PLAN RISK REGISTER
MATRIX ............................................................................................................................................................................. 15
APPENDIX B: SCHEDULE FOR THE QUARTERLY AND SEMI-ANNUAL REVIEWS OF THE
PROJECT RISK IDENTIFICATION AND MANAGEMENT PLAN AND RISK REGISTER.......................... 31
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

RECORD OF REVISIONS
PAG SUMMARY OF
REVISION DATE APPROVAL
ES REVISIONS
000 December 6, 2019 All Initial Draft USAID COR
001 March 18, 2020 All Revised Draft USAID COR
002 August 10, 2020 All Final USAID COR
DIOXIN REMEDIATION AT BIEN HOA AIRBASE AREA PROJECT | ii

ADAFC Air Defence - Air Force Command
A&ECOPCOR Architect & Engineer Chief of Party Contracting Officer’s Representative
DOCSONRE Development Outreach Communication Specialist Department of Natural Resources and the Environment
ERU Environmental Remediation Unit
GVN Government of Vietnam
LSECS Lead Safety and Environmental Compliance Specialist
MND Ministry of National Defense
MONRE Ministry of Natural Resources and the Environment
PAD Project Appraisal Document
ppt parts per trillion
SME Subject Matter Expert
SWEMMP Site-wide Environmental Mitigation and Monitoring Plan
TBD To Be Determined
US United States
USAID United States Agency for International Development
UXO Unexploded Ordnance
DIOXIN REMEDIATION AT BIEN HOA AIRBASE AREA PROJECT | iii

EXECUTIVE SUMMARY
This Final Project Risk Identification and Management Plan (the Project Risk Plan) details a process to
identify and manage project risks for the Dioxin Remediation at Bien Hoa Airbase Area (the Project)
throughout implementation. The risk identification, assessment, planning and management methods
established in this plan, although in many ways very different from, are consistent with and aligned with
United States Agency for International Development (USAID) processes for risk management as indicated
in several USAID risk assessment documents, including: US Agency for International Development Risk
Appetite Statement – June 2018; Developing a Risk Management Plan; and Risk Assessment Guidelines, A
Mandatory Reference for ADS Chapter 545.
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.
A–E SERVICES FOR DIOXIN REMEDIATION AT BIEN HOA AIRBASE AREA PROJECT | 1
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)
ROLES AND RESPONSIBILITIES FOR PROJECT RISK PLAN IMPLEMENTATION

Table 1 below shows a partial list of general roles and responsibilities for Project Risk Plan activities.
Additional responsibilities for Risk Owners are listed in the Project Risk Register in Appendix A.
Responsibilities may be modified as the project progresses through the various life cycle phases.
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
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.
CAPACITY BUILDING IN PROJECT RISK MANAGEMENT FOR GVN STAKEHOLDERS

Importantly, when the Quarterly and Semi-Annual Reviews are conducted as described above, 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.
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.
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:
• Keep it simple and systematic, using matrices, tables, and diagrams.

• Avoid imprecise and vague unclear terms.
• Only high risks have control and mitigation actions.
• Moderate and low risks are monitored, reviewed quarterly and updated as needed.
• Project Risks will be routinely reviewed and updated.
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
All of these methods of handling risk require certain basic steps:

• Risk Identification • Risk Control
• Risk Assessment • Risk Ownership
• Risk Prioritization • Risk Monitoring
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
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.
2 IMPLEMENTATION OF THE PROJECT RISK IDENTIFICATION

AND MANAGEMENT PLAN
Implementing this Risk Identification and Management Plan will involve all project participan broadly across
ts and will be managed throughout all phases of the project. Project Risk Plan implementation is guided
by the Project Risk Register which is the catalogue for all Project Risks identified, managed and tracked
across the phases of the project. The Project Risk Register includes a prioritization method for rating and
ranking Project Risks. The A&E Contractor will intermittently review project activities during all phases
of the project to identify and prioritize risks that emerge or change throughout each project phase.
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.
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).
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
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
4th Quarter Project Risk Plan and Risk
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
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 QUARTERLY AND SEMI-ANNUAL REVIEW AGENDAS

The A&E Contractor will conduct internal reviews during A&E Quarterly and Semi-Annual Review
Preparation meetings consistent with the schedule in Table 3 prior to the Quarterly and Semi-Annual
USAID and GVN Stakeholder reviews. The Quarterly Internal Review and the Semi-Annual Review with
GVN Stakeholders will be facilitated by the A&E Contractor Team. The A&E will develop agendas similar
to what is suggested below for each Quarterly and Semi-Annual Review.
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)
An Opportunity for GVN Risk Management Capacity Building

• Review of Updated PPT Summary of Project Risk Management Progress
o Review of High Risks (Red) and Summary of Moderate and Low Risks
• Summary of Risks Added and Removed and Elevated or Lowered to Yellow or Green
• Facilitated Review of Project Activities and Phase to Identify New Project Risks
o Rating and Ranking of New Risks
o Identification of Risk Control and Mitigation Actions
o Assignment of Risk Owners
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.
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:
Risk Identification and Risk Description

Risk Assessment, Rating, and Ranking
High Risk Control and Mitigation Actions
Responsible Organization and Risk Owners
The main Project Risk Management segments have subcomponents that are described in detail in this
section and the Project Risk Register matrix in Appendix A. The Risk Register Matrix is the first tab of
the MSExcel® workbook. Additional tabs have supporting tools and information, including the:
• 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.
3.1 RISK IDENTIFICATION

The Risk Identification segment specifies the Risk Category and Risk Source. Then the risk is described
in a Risk Statement designed in a particular way with particular words to provide clarity and promote
understanding of the risk. The Risk Statement is a very important part of Risk Assessment as it identifies
the particular circumstance or condition of concern that is a result of the project being executed or
managed and the potential consequences of that circumstance or condition.
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
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.
Treatment Technology approval by GVN may be difficult to obtain in a

2 External Approvals timely manner, therefore completion of Masterplan and its implementation
could be delayed.
Masterplan approval is required for implementation; therefore delay in

3 External Approvals
approval will delay (or stop) procurement and implementation.
3.2 RISK ASSESSMENT, RATING AND RANKING

A simple risk-based assessment and prioritization method using binary proxy indicators is used to rate
and rank the 36 risks identified during the Risk Brainstorming Session, through consultation with A&E
Bien Hoa Contractor Team personnel, and during the Masterplan Roadmap Meeting #2.
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.
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 5: RISK ASSESSMENT

(2)
Risk Assessment
Rating, Ranking and Risk Level
Likelihood X Severity = Risk Level
Determination of Severity
The Negative Effect on Project Activities in Life Cycle Phases Inherent
Risk
Severity of Risk
Post- Rating
Likelihood Impact Score Level
Construction Score
Rating Plan Design Procurement Construction (High,
(d) (Max 10) Moderate,
(a) (b) (c) (e) (Max 30)
or Low)
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.
TABLE 6: RISK RATING AND PRIORITIZATION METHOD

Risk Assessment Risk Rating and Prioritization Method
Matrix
Score Likelihood Segment Severity Score
3 Likely to Occur a Negative Impact on Planning Yes=2;
Phase Activities No=0
2 Just as Likely Not to Occur as to Occur b Negative Impact on Design Phase Yes=2;
Activities No=0
1 Unlikely to Occur c Negative Impact on Procurement Yes=2;
d Negative Impact on Construction Yes=2;
Range Risk Level e Negative Impact on Post- Yes=2;
Construction Activities No=0
21-30 High No Impact on Any Phase 1
10-20 Medium Severity Score = a + b + c + d + e
< 10 Low Likelihood Score X Severity Score = Risk Rating Score
3.3 HIGH RISK CONTROLS AND MITIGATION ACTIONS

The High Risk Control and Mitigation section includes the preliminary high-level (limited detail) actions
needed to control and mitigate the High risks. Table 7 shows the High-level Risk Control and Mitigation
Actions suggested for the risks identified in Table 6 above. The “Residual Risk Level” shows what the level
of risk will be after the controls and mitigation actions are implemented.
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.
3.4 PROCESS STEPS TO POPULATE THE PROJECT RISK REGISTER MATRIX

The steps to populate the Project Risk Register Matrix is provided in Table 8 along with the proposed
responsible parties. The steps are designed without too much detail, so they can be easily modified. The
“Responsible Parties” can be modified as necessary according to the needs of the A&E Bien Hoa
Contractor Project Team.
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.
3.5 RISK ELEVATION PROCESS

A critical step in the process involves determining if a risk needs to be elevated - either in its rating,
needed attention from others involved in the project, or to a higher level of decision maker and risk
manager. Thus, a means to determine if a risk needs to be elevated by a “risk elevation trigger” needs to
be developed. A “risk trigger” is an event or a change in circumstances that will cause the risk to increase
and indicates that additional resources or actions are needed to maintain control or mitigate the
heightened level of risk. These determinations may be made by the Risk Owners but should always be
made with consultation of the A&E Contractor. A simple but effective means to facilitate elevation and
record and monitor this action is shown in Table 9.
TABLE 9: RISK ELEVATION TEMPLATE

Bien Hoa Dioxin Project Risk Elevation and Communication Template
Person and Company Generating Risk Risk Elevated TO: (Person, Organization, Location)
Elevation:
Risk Category Risk Source Date

Risk Risk Rating
Risk Description Explanation for Elevation Describe What Help is Needed and When
ID# and Level
The reasons for Risk Elevation are typically related to resource demands, changing priorities, or synergy
or conflict with other project work activities. Risk elevation is frequently necessary as risks can change
due to many internal and external factors and influences. This Project Risk Identification and Management
Plan integrates Risk Elevation as part of its process.
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.
TABLE 10: POTENTIAL OPPORTUNITIES

Estimate
Assigned Recommended Opportunity
Result of Cost to Feasibility Importance
Opportunity Description to for Action and Capture
Analysis Capture of Capture to GVN
Analysis Schedule Owner
Opportunity
Using the Quarterly and
Semi-Annual Reviews as
venues to Build Capacity
of GVN Stakeholder in
Dioxin Remediation
Project Risk
Identification and
Management.
Use of local contractors
and local labor presents
opportunity for cost
savings.
3.7 PROJECT RISK IDENTIFICATION AND MANAGEMENT PLAN METRICS

Project Risk Management Metrics will be developed once the current risks are reviewed by the A&E
Contractor, USAID and GVN Stakeholders, and the next steps in Project Risk Plan Implementation are
taken. The metrics will be used to monitor Project risk controls and mitigation actions and Project Risk
Management performance. The Project Risk Register has a simple template that will be used to organize
metrics for selection as shown here in Table 11.
TABLE 11: PROJECT KEY RISK METRIX

Existing Data or Effect on Project
Metric
Measure Requires New
Description
Data? Cost Schedule Performance
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.
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.
APPENDIX A
(3)
(2) Action Plans
(4)
(When)
Risk Owner
Monitoring
Residual and
Severity
of
(Max Bi-weekly
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
APPENDIX A
(3)
(2) Action Plans
(4)
(When)
Risk Owner
Monitoring
Residual and
Severity
of
(Max Bi-weekly
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
APPENDIX A
(3)
(2) Action Plans
(4)
(When)
Risk Owner
Monitoring
Residual and
Severity
of
(Max Bi-weekly
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
APPENDIX A
(3)
(2) Action Plans
(4)
(When)
Risk Owner
Monitoring
Residual and
Severity
of
(Max Bi-weekly
10) Risk Owner
Actions
Calls and
Other
Reviews.
participant organized and executed
reputations. to assure the aligned
message is delivered
consistently.
> Add high level

scheduling of USAID
USAID Monitory
procurement to the
procurement monthly and
Project schedule.
process is lengthy Review
> Address monthly with
(minimum of one during
USAID. COR
year); therefore Likely to Quarterly
12 External Management 10 30 High > Take steps as far in 20 USAID and A&E Contractor
certain services Occur Internal and
advance as possible to Chief of Party
may not be Simi-Annual
identify the necessary
obtained in time Reviews with
expertise.
to meet project GVN
> Establish procurement
needs. Stakeholders
dates as far in advance as
possible.
> Whenever possible
Significant
exercise restraint in
pressure exists to
moving to
advance
implementation activities Monitory
implementation as
prior to completing all monthly and
much as possible,
necessary planning Review
even before
activities. during
planning activates
Likely to > Identify the benefits, Quarterly
14 Internal Management are complete; 10 30 High 20 USAID COR
Occur costs, and risks of the Internal and
therefore key
proposed change. Simi-Annual
components of
> Document the Reviews with
future phases may
decision, update the risk GVN
not be adequately
register, communicate Stakeholders
developed and
the decision and risks,
there will be less
and update affected
integration when
plans.
APPENDIX A
(3)
(2) Action Plans
(4)
(When)
Risk Owner
Monitoring
Residual and
Severity
of
(Max Bi-weekly
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
APPENDIX A
(3)
(2) Action Plans
(4)
(When)
Risk Owner
Monitoring
Residual and
Severity
of
(Max Bi-weekly
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
APPENDIX A
(3)
(2) Action Plans
(4)
(When)
Risk Owner
Monitoring
Residual and
Severity
of
(Max Bi-weekly
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.
APPENDIX A
(3)
(2) Action Plans
(4)
(When)
Risk Owner
Monitoring
Residual and
Severity
of
(Max Bi-weekly
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
APPENDIX A
(3)
(2) Action Plans
(4)
(When)
Risk Owner
Monitoring
Residual and
Severity
of
(Max Bi-weekly
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.
APPENDIX A
(3)
(2) Action Plans
(4)
(When)
Risk Owner
Monitoring
Residual and
Severity
of
(Max Bi-weekly
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.
APPENDIX A
(3)
(2) Action Plans
(4)
(When)
Risk Owner
Monitoring
Residual and
Severity
of
(Max Bi-weekly
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.
APPENDIX A
(3)
(2) Action Plans
(4)
(When)
Risk Owner
Monitoring
Residual and
Severity
of
(Max Bi-weekly
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.
APPENDIX A
(3)
(2) Action Plans
(4)
(When)
Risk Owner
Monitoring
Residual and
Severity
of
(Max Bi-weekly
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
APPENDIX A
(3)
(2) Action Plans
(4)
(When)
Risk Owner
Monitoring
Residual and
Severity
of
(Max Bi-weekly
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
APPENDIX A
(3)
(2) Action Plans
(4)
(When)
Risk Owner
Monitoring
Residual and
Severity
of
(Max Bi-weekly
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.
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
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
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 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
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
Review risks, adjust risk mitigation actions, change risk owners.
4th Quarter Project Risk Plan and Risk Register 1/2 Day with A&E Contractor
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 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
ANNEX 2 – SITE-WIDE SAMPLING AND ANALYSIS PLAN (SAP) /
QUALITY ASSURANCE PROJECT PLAN (QAPP)

SITE-WIDE SAMPLING & ANALYSIS PLAN –

QUALITY ASSURANCE PROJECT PLAN
JULY 17, 2020

DISCLAIMER
SITE-WIDE SAMPLING & ANALYSIS PLAN –


JULY 17, 2020
PREPARED BY
USA
DISCLAIMER
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

SITE-WIDE SAMPLING & ANALYSIS PLAN–QUALITY ASSURANCE PROJECT PLAN | i
14.1.4 INVESTIGATION-DERIVED WASTE 57
14.1.4.1 INVESTIGATION-DERIVED WASTE MANAGEMENT 58
14.1.4.2 INVESTIGATION-DERIVED WASTE SAMPLING 58
14.2 GROUNDWATER MONITORING WELL INSTALLATION 59
14.2.1 GROUNDWATER ELEVATION MEASUREMENTS 60
14.2.2 HYDRAULIC CONDUCTIVITY TESTING 60
14.3 SAMPLING TASKS 61
14.3.1 SOIL SAMPLES 61
14.3.2 GROUNDWATER SAMPLES 61
14.3.3 AIR SAMPLES 61
14.4 ANALYSIS TASKS 61
14.5 QUALITY CONTROL SAMPLES 62
14.6 SECONDARY DATA 62
14.7 DATA MANAGEMENT TASKS 62
14.8 DOCUMENTATION AND RECORDS 63
14.9 PROJECT SCHEDULE 63
WORKSHEET #15 PROJECT ACTION LIMITS AND LABORATORY -SPECIFIC
DETECTION/QUANTITATION LIMITS 77
WORKSHEET #17 SAMPLING DESIGN AND RATIONALE 80
WORKSHEET #18 SAMPLING LOCATIONS AND METHODS 81
WORKSHEETS #19 AND #30 SAMPLE CONTAINERS, PERSERVATION, AND HOLD
TIMES 82
WORKSHEET #20 FIELD QUALITY CONTROL SUMMARY 85
WORKSHEET #21 FIELD SOPS 86
WORKSHEET #22 FIELD EQUIPMENT CALIBRATION, MAINTENANCE, TESTING,
AND INSPECTION 88
WORKSHEET #23 ANALYTICAL SOPS 90
WORKSHEET #24 ANALYTICAL INSTRUMENT CALIBRATION 94
WORKSHEET #25 ANALYTICAL INSTRUMENT AND EQUIPMENT
MAINTENANCE, TESTING, AND INSPECTION 114
WORKSHEETS #26 & #27 SAMPLE HANDLING, CUSTODY, AND DISPOSAL 118
27.1 SAMPLE IDENTIFICATION 119
WORKSHEET #28 ANALYTICAL QUALITY CONTROL AND CORRECTIVE
ACTION 121
WORKSHEET #29 PROJECT DOCUMENTS AND RECORDS 159
WORKSHEET #31, #32, AND #33 ASSESSMENTS AND CORRECTIVE ACTIONS 161
31.1 LABORATORY VERIFICATION 163
32.1 FIELD SAMPLING AUDIT 165
32.2 FIELD DOCUMENT REVIEW 165
32.3 LABORATORY ASSESSMENT 165
32.4 CORRECTIVE ACTION PROCEDURES 165

SITE-WIDE SAMPLING & ANALYSIS PLAN–QUALITY ASSURANCE PROJECT PLAN | ii
WORKSHEET #34 DATA VERIFICATION AND VALIDATION INPUTS 167
WORKSHEET #35 DATA VERIFICATION PROCEDURES 169
WORKSHEET #36 DATA VALIDATION PROCEDURES 172
WORKSHEET #37 DATA USABILITY ASSESSMENT 173
REFERENCES 175
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

SITE-WIDE SAMPLING & ANALYSIS PLAN–QUALITY ASSURANCE PROJECT PLAN | iii
Table 22-1. Field Equipment Calibration, Maintence, Testing, and Inspection.................................................. 88
Table 23-1 Analytical SOP References ....................................................................................................................... 90
Table 24-1. Analytical Instrument Calibration .......................................................................................................... 94
Table 25-1. Analytical instrument and equipment maintenance, Testing, and Inspection ........................... 114
Table 26-1 Sample Handling System ........................................................................................................................ 118
Table 28-1 Laboratory qc samples tables for vocs by 6260C, Soil ................................................................... 121
Table 28-2. Laboratory QC Samples Tables For VOCs By 6260C, Water ................................................... 123
Table 28-3. Laboratory QC Samples Tables for SVOCS By 6270D, Soil ....................................................... 125
Table 28-4. Laboratory EC Samples Tables for SVOCs By 6270D, Water.................................................... 127
Table 28-5. Laboratory QC Samples Tables for PCBs By 6082A, Soil ............................................................ 129
Table 28-6. Laboratory QC Samples Tables for PCBs By 6082A, Water ...................................................... 131
Table 28-7. Laboratory QC Samples Tables for Herbicides by 6151A, Soil .................................................. 133
Table 28-8. Laboratory QC Samples Tables for Herbicides by 6151A, Water ............................................ 134
Table 28-9. Laboratory QC Samples Tables for Arsenic Speciation by USEPA 1632, Soild ...................... 135
Table 28-10. Laboratory QC Samples Tables for Arsenic Speciation by USEPA 1632, Water................. 136
Table 28-11. Laboratory QC Samples Tables for Anions By USEPA 600.0, Soil .......................................... 137
Table 28-12. Laboratory QC Samples Tables for Anions by USEPA 600.0, Water ..................................... 138
Table 28-13. Laboratory QC Samples Tables for Dioxins/Furans by USEPA 1613B, Soil .......................... 139
Table 28-14. Laboratory QC Samples Tables for Dioxins/Furans By USEPA 1613B, Water .................... 141
Table 28-15. Laboratory QC Samples Tables for Ferrous Iron By 5M 3500................................................. 143
Table 28-16. Laboratory QC Samples Tables for Metals By USEPA 200.8, Water...................................... 144
Table 28-17. Laboratory QC Samples Tables For Metals By 6010C, Soil ...................................................... 146
Table 28-18. Laboratory QC Samples Tables for Metals By 6010C, Water.................................................. 148
Table 28-19. Laboratory QC Samples for Metals HG By 7471A/B, Soil ......................................................... 150
Table 28-20. Laboratory QC Samples Tables for Metals HG BY 7470A, Water ......................................... 151
Table 28-21. Laboratory QC Samples Tables ........................................................................................................ 152
Table 28-22. Laboratory QC Samples Tables for Total organic Carbon, Water ......................................... 154
Table 28-23. Laboratory QC Samples Tables For Total Organic Carbon, Water ....................................... 155
Table 28-24. Laboratory QC Samples Tables for PH By 9045DC, Soild ........................................................ 156
Table 28-25. Laboratory QC Samples Tables for Dixins By USEPA 6290, Water and Soil ....................... 157
Table 29-1. Project Documents and Records........................................................................................................ 159
Table 31-1. Planned Project Assessments .............................................................................................................. 161
Table 32-1. Assessment Findings and Corrective Action Responses .............................................................. 164
Table 33-1. Planned Project Assessments .............................................................................................................. 166
Table 34-1 Verification (Step 1) Process................................................................................................................. 167
Table 35-1. Validation (Step 11A and 11B) Process ............................................................................................. 170
Table 36-1. Analytical Data Validation (Step 11A and 11B) ............................................................................... 172
FIGURES
Figure 5-1 Project Organization Chart ....................................................................................................................... 11

SITE-WIDE SAMPLING & ANALYSIS PLAN–QUALITY ASSURANCE PROJECT PLAN | iv
% percent CSknown known concentration of the spike
%D percent difference added
%R percent recovery CVAA Cold Vapor Atomic Absorption
< less than DCOP Deputy Chief of Party
> greater than DDT dichlorodiphenyl trichloroethane
± plus or minus DFTPP decafluorotriphenylphosphine
≤ less than or equal to DO dissolved oxygen
≥ greater than or equal to DoD Department of Defense
°C degree Celsius DoD QSM v5.0 Department of Defense Quality
µg/L microgram per liter Systems Manual, Version 5.0
µg/m3 microgram per cubic meter DONRE Dong Nai Department of Natural
95% UCL 95th percentile upper confidence Resources and Environment
limit DOT Department of Transportation
A&E Architect and Engineering DPT direct push technology
ABS Dermal Absorption Factor DQI data quality indicator
ABSGI Gastrointestinal absorption factor DQO data quality objective
ADAFC Air Defense Air Force Command DU Decision Unit
ADD Average Daily Dose EA Environmental Assessment
AF Soil adherence factor EB Equipment Blank
AMU Atomic Mass Unit EC Exposure Concentration
ARAR applicable or relevant and ECc Exposure Concentrations for
appropriate requirement carcinogenic chemicals
AT Averaging time ECD Electron Capture Detector
BFB 4-bromofluorobenzene ECnc Exposure Concentrations for
BGS below ground surface non-carcinogenic chemicals
BRA Baseline Human Health Risk ED Exposure Duration
Assessment EDD electronic data deliverable
BTV background threshold value EDL Estimated Detection Limit
BW Body Weight EF Exposure Frequency
CA corrective action ELAP Environmental Laboratory
CAS Number Chemical Abstract Service Accreditation Program
registration number EPC Exposure Point Concentration
CCB continuing calibration blank EPCair Exposure point concentration in
CCV continuing calibration verification air
CD measured concentration of the EPCDiet Exposure point concentration for
duplicate result COPC in diet
CF Conversion Factor EPCGW Exposure point concentration for
CFIA Canadian Food Inspection Agency chemicals of potential concern in
CFR Code of Federal Regulations groundwater
CLP Contract Laboratory Program EPCsoil Exposure point concentration for
cm centimeter chemicals of potential concern in
cm2 square centimeter soil
COC chain of custody ES Environmental Sampling
COD coefficient of determination ET Exposure Time
COP Chief of Party EU European Union
COPC chemical(s) of potential concern FB Field Blank
COR Contracting Officer’s FID flame ionization detector
Representative FM Field Management
CPR cardiopulmonary resuscitation FO Field Operations
CR measured concentration of the ft foot/feet
original sample result g/day gram per day
CR Cancer Risk G2L Gate 2 Lake
CS measured concentration of the GC gas chromatograph
spiked sample result

SITE-WIDE SAMPLING & ANALYSIS PLAN–QUALITY ASSURANCE PROJECT PLAN | v
GC/MS gas chromatograph/mass mg/µg milligram per microgram
spectrometer mg/cm2-day milligram per square centimeter
GEF Global Environmental Finance per day
GP groundwater profile mg/kg milligram per kilogram
GPS Global Positioning System mg/kg-d milligram per kilogram per dose
GRO gasoline range organics mg/L milligram per liter
GVN Government of Vietnam mg/m3 milligram per cubic meter
ha hectare ml milliliter
HASP Health and Safety Plan MND Ministry of National Defense
HAZWOPER Hazardous Waste Operations and MPC measurement performance
Emergency Response criteria
HCl hydrogen chloride MS matrix spike
HI hazard index MSD matrix spike duplicate
HQ Hazard Quotient MSO Military Science Office
HSA hollow stem auger MW monitoring well
IC ion chromatograph N/A not applicable
ICAL initial calibration ND Non Detect
ICP-AES inductively coupled plasma-atomic NELAP National Environmental
emission spectroscopy Laboratory Accreditation
ICP-MS inductively coupled plasma-mass Program
spectrometry NFA No Further Action
ICSAB Interference Check Standard AB NO3 nitrate
ICV initial calibration verification NO2 nitrate
ID identifier OAF Oral Absorption Factor
IDQTF Intergovernmental Data Quality OCDD Octachlorodibenzo-p-dioxin
Task Force OCDF Octachlorodibenzo-p-furan
IDW investigation-derived waste OPR ongoing precision and recovery
IR Soil Ingestion Rate ORP oxidation-reduction potential
IRIS Integrated Risk Information PA preliminary assessment
System PAL Project action limit
IS internal standard PCB polychlorinated biphenyl
ISO International Organization for PDS Post Digestion Spike
Standardization PEF Particulate emission factor for
IUR Inhalation Unit Risk non-volatile chemicals
kg kilogram pg/g picogram per gram
kg/mg kilogram per milligram pH measure of acidity or basicity of
km kilometer an aqueous solution
km2 square kilometer PID photoionization detector
L/day liter per day PM Project Manager
l/s liter per second PO4 Phosphate
LADD Lifetime Average Daily Dose PPE Personal Protective Equipment
LCS laboratory control sample ppq parts per quadrillion
LCSD laboratory control sample PPRTV Provisional Peer Reviewed
duplicate Toxicity Value
LLC low level check ppt parts per trillion
LOQ limit of quantitation pg/l picogram per liter
LTSA Long-Term Storage Area PQO project quality objective
m meter PVC polyvinyl chloride
m2 square meter QA quality assurance
m3 cubic meter QC quality control
m3/h cubic meter per hour RAGS Risk Assessment Guidance for
m3/kg cubic meter per kilogram Superfund
MCL maximum contaminant level RCRA Resource Conservation and
MDL Method Detection Limit Recovery Act
mg milligram RF Response Factor

SITE-WIDE SAMPLING & ANALYSIS PLAN–QUALITY ASSURANCE PROJECT PLAN | vi
RfC Reference Concentration SW-846 Test Methods for Evaluating Solid
RfD Reference Dose Waste, Physical/Chemical
RfDABS Dermal reference dose Methods
(absorbed) TAL Target analyte list
RfDO Oral reference dose TAT turnaround time
(administered) TBD to be determined
RI remedial investigation TCDD 2,3,7,8-tetrachlorodibenzo-p-
RK Record Keeping dioxin
RL Reporting Limit TCDF tetrachlorodibenzofuran
RPD relative percent difference TEQ Toxicity Equivalent
RRF relative response factor TOC Total Organic Carbon
RSD relative standard deviation TWA Time-Weighted Average
RSK Robert S. Kerr U.S. United States
RSL regional screening level UFP–QAPP Uniform Federal Policy-Quality
RT retention time Assurance Project Plan
SA Surface area of exposed skin UNDP United Nations Development
SAP–QAPP Sampling and Analysis Plan- Programme
Quality Assurance Project Plan USAID United States Agency for
SB soil boring International Development
SCM Site Conceptual Model USEPA United States Environmental
SDG sample delivery group Protection Agency
SF Slope Factor UST underground storage tank
SFABS Dermal slope factor (absorbed UXO unexploded ordnance
SFO Oral slope factor (administered) VF volatilization factor for volatile
SHASP Supplemental Health and Safety chemicals
Plan VISL Vapor Intrusion Screening Level
SI site investigation VOA Volatile Organic Analysis
SM standard method VOC volatile organic compound
SO4 Sulfate VPHA Vietnam Public Health Association
SOP standard operating procedure VRTC Vietnam-Russia Tropical Centre
SVOA Semi Volatile Organic Analysis
SVOC Semi Volatile Organic Compound

SITE-WIDE SAMPLING & ANALYSIS PLAN–QUALITY ASSURANCE PROJECT PLAN | vii
WORKSHEETS #1 AND #2 TITLE AND APPROVAL PAGE
Review and Approved By:
USAID Contracting Officer’s Representative Signature/Date
A&E Bien Hoa Contractor Chief of Party Signature/Date

SITE-WIDE SAMPLING & ANALYSIS PLAN–QUALITY ASSURANCE PROJECT PLAN | 1
1.0 INTRODUCTION
USAID/Vietnam’s Architect–Engineer Services for Dioxin Remediation at Bien Hoa Airbase Area
Contractor (A&E Bien Hoa Contractor) developed this Site-Wide Sampling and Analysis Plan–Quality
Assurance Project Plan (SAP–QAPP) in accordance with the Uniform Federal Policy–Quality Assurance
Project Plan (UFP–QAPP) guidance of the United States Environmental Protection Agency (USEPA). This
Site-Wide SAP–QAPP addresses all data collection for the Dioxin Remediation at Bien Hoa Airbase Area
Project (the Project), located in Bien Hoa, Vietnam. The purpose of the Site-Wide SAP–QAPP is to be
the comprehensive, site-specific planning and guidance document to govern the field sampling, field
analysis, and environmental laboratory analysis for the Project. This document will guide all project
contractors in conducting field sampling and laboratory analysis to ensure these efforts meet common
data quality objectives (DQOs) for each task. Anticipated field sampling activities will include but not be
limited to:
1.0.1 SITE EVALUATION/DESIGN

• Collection of soil, sediment, surface and groundwater, air and waste material samples and testing of
their chemical and physical properties as required to define/support:
− Establishment of background conditions - of air, sediment, and surface water prior to site
investigation and construction at the site and Bien Hoa Airbase (Airbase) boundaries as applicable;
− Refine nature and extent of contamination;
− Support of Human Health and Ecological Risk Assessment;
− Evaluation of Storage Area Siting; and
− Decontamination of collection equipment and personnel as applicable.
• Collection of chemical and geotechnical data required to support engineering design of:
− Removal Actions;
− Non-treatment construction – haul roads, staging areas, storage facilities; and
− Treatment Facilities – to include but not be limited to dewatering, treatment off-gassing,
disposal/reuse of materials after treatment.
1.0.2 SITE REMEDIATION/IMPLEMENTATION

Collection of soil, sediment, surface and groundwater, air, and waste material samples and testing of their
chemical and physical properties as required to:
• Confirm achievement of dioxin cleanup action levels after First Interim Measure (IM1) excavation of
soil/sediments;
• Confirm achievement of the dioxin treatment goal following treatment of soil/sediments;
• Confirm no increase in health or environmental risk from arsenic due to project activities;
• Determine any needed modifications to the designed treatment processes or disposal methods for
treatment waste streams;
• Determine any needed modification to designed treatment of water discharged from soil de-watering
and/or site stormwater run-off;

• Determine actions necessary to protect human health and the environment on site during
implementation of all remediation activities; and
• Confirm achievement of effective decontamination of equipment during demobilization.
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’.
1.0.4 HISTORICAL OPERATIONS

Data collected during the Dioxin Remediation at Bien Hoa Airbase Area will be reassessed throughout
the project and will build upon the historical investigations conducted across the Airbase. The following
summarizes the operational history of the Airbase with respect to dioxin and provides a summary of
historical investigations.
During the United States (U.S.)-Vietnam War, over 80 million liters of herbicides were sprayed over South
Vietnam in a code-named mission called Operation Ranch Hand (Cecil 1986). Bien Hoa Airbase was the
largest and most active Ranch Hand site in Vietnam. These herbicide mixtures were predominantly used
to defoliate forests and crops, and many of them contained 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD)
as a contaminant by-product. The Airbase is recognized as a dioxin hotspot due to high TCDD
concentrations remaining decades after the large volumes of Agent Orange and other herbicides were
stored, handled, and spilled at the Airbase during the U.S.-Vietnam War (Dwernychuk et al. 2002;
Dwernychuk 2005).
Three large storage tanks were used for herbicide storage at the Airbase; one each for Agent Orange,
Agent White, and Agent Blue. According to U.S. military data, the Airbase was used to store and handle
98,000 45-gallon (170-liter) barrels of Agent Orange, 45,000 barrels of Agent White, and 16,000 barrels
of Agent Blue (U.S. Department of Defense [DoD] 2007). Agent Blue did not contain dioxin but organic
arsenic was in the formulation. Additional herbicide formulations that were also used at the Airbase
included Agents Purple, Pink, Green and others. The Pacer Ivy mission was launched on September 15,

1971 to consolidate, re-drum, and ship all remaining Agent Orange herbicide and Ranch Hand herbicides
in South Vietnam to Johnston Atoll in the central Pacific Ocean (U.S. Agency for International
Development [USAID] 2016).
1.0.5 HISTORICAL INVESTIGATIONS

Several sampling programs have been conducted within and around the Airbase since 1990 to determine
concentrations exceeding national and international dioxin limits. The known major dioxin source areas
on the Airbase were identified as follows:
• Z1 Area: Located in the southern area of the Airbase, Z1 was the main storage area for Agent Orange,
Blue, and White herbicides at the Airbase and initially contained the most heavily contaminated
materials at the Airbase. A landfill (referred to as the Z1 Landfill) was constructed at the Airbase in
2009 to contain the contaminated soils from the area where the storage tanks were located (USAID
2016). Project XD1 implemented by the Chemical Command from 2005 to 2010 completed
excavation and containment of approximately 100,000 cubic meters (m3) across 4.3 hectares (ha) of
dioxin-contaminated soils at the Z1 area of the Airbase. Project XD2 implemented by the Chemical
Command from 2015 to 2016 excavated approximately 51,500 m3 of dioxin-contaminated soils at the
southern area and the south Z1 area of the Airbase and placed in the landfill at the Z1 area of the
Airbase (Ministry of National Defense 2019).
• Southwest Area: Located west of the Z1 Area along residential areas abutting the boundary of the
Airbase, dioxin contamination was discovered in this area during studies in 2008 and 2010. The area
was suspected to be used as an herbicide storage area during the Pacer Ivy mission at the Airbase
(Hatfield and Vietnam-Russia Tropical Centre [VRTC] 2009; Hatfield and Office 33 2011; USAID
2016).
• Pacer Ivy Area: Located on the western end of the Airbase, the Pacer Ivy Area is close to the current
runway. During the Pacer Ivy mission, this area was used to store, re-drum, and package 11,000
containers of Agent Orange for shipping to Johnston Atoll in the central Pacific Ocean. Under the
United Nations Development Programme (UNDP) Global Environmental Finance (GEF) Dioxin
Project in 2013, a series of drainage ditches were constructed around the perimeter of the Pacer Ivy
Area to restrict flow into this area and outside of the Airbase. In addition, a ban on aquaculture in the
area was also implemented (USAID 2016).
In addition to the known major source areas, elevated dioxin concentrations have also been found in lake
sediments in the Northwest Area, Northeast Area, and outside the Airbase (G2L, BHL, and in the drainage
canal west of the Pacer Ivy Area). Whole fish, as well as fish fat and muscle tissue samples analyzed from
lakes and waterways within and outside of the Airbase have exceeded acceptable limits (Hatfield and Office
33 2009, 2011). Dioxin has also been recorded in blood serum and breast milk in the human population
in Bien Hoa, 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). These previous
studies identified the potential for contamination of local Bien Hoa residents, and confirmed the main
exposure pathway was through consumption of fish and other aquatic organisms on the Airbase (Durant
et al. 2014; USAID 2016).
1.0.6 DONRE OFF AIRBASE SAMPLING

In the Environmental Assessment (EA), it is noted that the Dong Nai Department of Natural Resources
and Environment (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 (USAID 2016).
DONRE has reportedly implemented dioxin monitoring in several City of Bien Hoa wards surrounding
Bien Hoa Airbase since 2009, including since the EA, and the monitoring has shown migration of dioxin
from on-Airbase to off-Airbase areas. 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 Dong Nai River; from Z1 Area of the Airbase toward the Tang Phong Ward; and from the
southern end of the Airbase to G2L.
DONRE communicated the identification of three of these off-Airbase areas with elevated dioxin
concentration in soils and sediments in recent meetings with USAID and the A&E Bien Hoa Contractor.
These three off-Airbase areas are:
1. An area of approximately 36,824 square meters (m2) of contaminated soils (reported with a maximum
of 4,992 parts per trillion [ppt] dioxin in soils), excluding the area of the Airbase, occupied by 75
households (residences) in Buu Long Ward, referred to by DONRE as “Residential Area 5”;
2. 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. An area of approximately 5,903 m2 of contaminated G2L sediments (reported with a maximum of 166
ppt in sediments from the EA sampling program), now excluding the areal extent of the Tax
Department building currently under construction in the original G2L footprint.
The first area identified by the DONRE monitoring encompasses, but expands, the areal extent of Pacer
Ivy Area Decision Unit (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 across the Airfield boundary. The third area
was already designated as an off-Airbase DU, i.e., G2L in the EA, but the area identified by the DONRE
monitoring now excludes the areal extent of the Tax Department building currently under construction.
A fourth 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. This fourth area
is:
1. An area of approximately 155 m2 of contaminated sediments (reported with a maximum of 4,023 ppt
dioxin) on open land that is located to the south of the Southern Area.
It should be noted that CDM Smith conducted an assessment of the DONRE sampling program (CDM
Smith 2018) 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
2018). 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, quality control (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 2018). 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 and quality control (QA)/QC and general requirements of a dioxins/furans data
package. Overall, non‐compliances were identified; however, the laboratory staff were observed to be
following good recordkeeping and document organization practices and nearly all the non‐compliances,
including deficiencies in support infrastructure, could be mitigated with additional capital investments
(CDM Smith 2018).

Project Name/Number Dioxin Remediation at Bien Hoa Airbase Area
Decision Units DUs of the Dioxin Remediation of the Bien Hoa Airbase Area C
Contractor Name Trigon Associates, LLC (Trigon)
Contract Number AID-OAA-I-15-00053, Order Number 72044019F00001
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.
4. This Site-Wide SAP–QAPP is a: Document to provide detailed information on the

execution of the field program for the Dioxin
Remediation at Bien Hoa Airbase Area Project.
Annexes to this document will be developed for
specific tasks as applicable to include task-specific
procedures not included in this Site-Wide SAP–
QAPP and site-specific locations.
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.
6. List dates and titles of any SAP– Not applicable

QAPP documents written for
previous site work that are relevant
to the current investigation:

Air Defence – Air Force Command (ADAFC)
7. List of Stakeholders: US Agency for International Development (USAID)
Government of Vietnam (GVN)
Dong Nai Peoples Committee
Ministry of National Defence (MND) 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)
MND Depart of Foreign Affairs
Department of Army Security Protection
Chemical Command (CC) / National Action Center
on Toxic Chemicals and Environmental Treatment
(NACCET)
Vietnam – Russia Tropical Center (VRTC)
Academy of Military Science and Technology (AMST)
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:

WORKSHEETS #3 AND #5 PROJECT ORGANIZATION AND SITE-WIDE SAP-QAPP
DISTRIBUTION
Table 3-1 of this worksheet identifies key project personnel for the lead organization and regulating authorities that will receive a complete copy
of the Site-Wide SAP–QAPP, including future updates, change pages, and/or addenda.
TABLE 3-1. DISTRIBUTION LIST
Name of QAP Title/Role Organization Telephone E-mail Address or Mailing
Recipients Number (Optional) Address
Tony Kolb COR / Unit Chief, Environmental Remediation Unit USAID C. +84 (96) 2002758 [email protected]
Andrew Sayers- Chief of Party / Remediation Specialist Trigon T. +1 504.585.5767
[email protected]
Fay A&E Bien Hoa Contractor Associates C. +84 (84) 9360544
Deputy Chief of Party Trigon T. +1 347.295.9113
Suzan Samara [email protected]
A&E Bien Hoa Contractor Associates C. +84 (36) 7731624
Lead Local Engineer Trigon
Tri Hoang C. +84 (91) 3465795 [email protected]
A&E Bien Hoa Contractor Associates
Trigon
Quang Mai Construction Manager C. +84 (90) 3511779 [email protected]
Associates
Lead Design & Engineering Manager Trigon
Lisbeth Nagrath T. +1 504.274.8466 [email protected]
Lead Safety and Environmental Compliance Specialist Trigon
Thang Vu C. +84 (91) 8077753 [email protected]
Notes: A&E – Architect and Engineering COR – Contracting Officer’s Representative
ADAFC – Air Defence – Air Force Command USAID – United States Agency for International
CO – Contracting Officer

The chart on the following page details the organizational structure of the project and includes the lead
organization and the A&E Bien Hoa Contractor. This structure shows reporting relationships between
the entities involved in the project.

FIGURE 5-1 PROJECT ORGANIZATION CHART

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WORKSHEETS #4, #7, AND #8 PERSONNEL QUALIFICATIONS AND SIGN-OFF SHEET
This worksheet identifies key Project personnel, their responsibilities and qualifications, and specialized training/certifications required by the
Project. Table 4-1 documents that all key Project personnel performing work have read the applicable sections of this Site-Wide SAP–QAPP and
will perform the tasks as described.
TABLE 4-1. PROJECT PERSONNEL SIGN-OFF SHEET
Name Title Organization Telephone Number Signature/E-mail Receipt Date Reviewed
Anthony C. +84 (96) 2002758
Unit Chief, Environmental Remediation Unit USAID [email protected]
(Tony) Kolb
Andrew
Chief of Party / Remediation Specialist T. +1 504.585.5767
Sayers-Fay, Ph. Trigon Associates [email protected]
A&E Bien Hoa Contractor C. +84 (84) 9360544
D.
Tri Mingh Lead Local Engineer
Trigon Associates C. +84 (91) 3465795 [email protected]
Hoang A&E Bien Hoa Contractor
Thang Vu Lead Safety and Environmental Compliance Specialist Trigon Associates C. +84 (91) 8077753 [email protected]
Peter Project Chemist
Cardno +1 434-295-4446 [email protected]
Chapman A&E Bien Hoa Contractor
Quality Manager
Kit Adsetts Cardno +1 916-949-6687 [email protected]
A&E Bien Hoa Contractor
Notes: SAP–QAPP – Sampling and Analysis Plan-Quality Assurance Project Plan
USAID – United States Agency for International Development.

Table 7-1 identifies the responsibilities of each Project role. In addition, the education and experience qualifications are described for the assigned
personnel.
TABLE 7-1. PERSONNEL RESPONSIBILITIES AND QUALIFICATIONS
Education and
Organizational Experience
Name Title/Role Affiliation Responsibilities Qualifications
Chief of Party / • Responsible for QA/QC of deliverables BS, PhD Ag and Env
Andrew Sayers- Trigon
Remediation Specialist • Manages day-to-day operations Chemistry and over 17 years
Fay Associates
A&E Bien Hoa Contractor • Oversight of all remediation activities of experience
Tri Hoang Lead Local Engineer Trigon • Lead engineering and technical contact with GVN officials and BS, Civ Eng and over 23 years
A&E Bien Hoa Contractor Associates Vietnamese contractors of experience
• Responsible for engineering deliverables
• Responsible for translation review of engineering documents
Thang Vu Lead Safety and • Responsible for implementation of the Site-Wide SAP–QAPP
Environmental Compliance Trigon • Health and Safety oversight of all Project field work BS, Environmental Eng. and
Specialist Associates • Responsible for implementation of the Site-Wide HASP and over 12 years of experience
A&E Bien Hoa Contractor contract-specific SHASPs
• Responsible for defining analytical requirements
• Responsible for resolution of laboratory QC issues with
Project Chemist Project Manager B.Sc., CEAC, and 34 years of
Peter Chapman Cardno
A&E Bien Hoa Contractor • Provides program-level QA/QC guidance to installation points experience
of contact, Project Manager, and project team
• Reviews validation reports before release to the project team
• Responsible for defining field elements and developing the Site-
Wide SAP–QAPP
• Monitors field, laboratory, and validation activities to ensure
Quality Manager BS Eng, PE, and 21 years of
Kit Adsetts Cardno compliance with Site-Wide SAP–QAPP requirements
A&E Bien Hoa Contractor experience
• Identifies non-conformances through QA/QC review
activities/audits and recommends corrective action
• Prepares reports for submittal
Notes:
QA/QC – Quality Assurance / Quality Control
SAP – Sampling and Analysis Plan
SAP–QAPP – Sampling and Analysis Plan-Quality Assurance Project Plan
USAID – United States Agency for International Development

Table 8-1 documents specialized training or course certification required on this Project.
TABLE 8-1. SPECIAL PERSONNEL TRAINING REQUIREMENTS
Specialized Training Personnel Titles/ Location of Training
Project Title or Description of Training Training Personnel/Groups Organizational Records/
Function Course Provider Date Receiving Training Affiliation Certificates
40-hour HAZWOPER, or
All personnel that will be
Environmental equivalent, and site-specific Qualified Field staff,
Varies by staff performing intrusive field
Field Work personal protection vendor subcontractors
work on-site
equipment (PPE) Training
3-Day On-Site Personnel that will be
Environmental Qualified Field staff,
HAZWOPER Training, or Varies by staff infrequently conducting non-
Field Work vendor subcontractors
equivalent intrusive field work
Personnel that will be
8-Hour HAZWOPER
Environmental Qualified performing intrusive field Field staff,
Refresher Training, or Varies by staff
Field Work vendor work on-site and are re- subcontractors
equivalent
certifying Current training
8-Hour HAZWOPER records are maintained
Environmental Qualified At least one staff member on
Supervisor Training, or Varies by staff Field staff in the home office for
Field Work vendor each field team
equivalent each employee and on-
Ongoing training and site during field work.
Environmental monitoring to ensure field All personnel that will be
Contractor Ongoing Field staff
Field Work activities are performed in performing field work
accordance with the SOPs
At least two field personnel
Environmental CPR/Adult Standard First Qualified
Varies by staff that will be on-site Field staff
Field Work Aid Vendor
performing field work
Federal Information
Systems Security All personnel designated to
Data Management Contractor Ongoing Field staff
Awareness Training upload data
Certificate
Notes:
CPR – Cardiopulmonary Resuscitation
HAZWOPER – Hazardous Waste Operations and Emergency Response
SOP – Standard Operating Procedure

WORKSHEET #6 COMMUNICATION PATHWAYS
Table 6-1 identifies the communication pathways between Project personnel.
TABLE 6-1. PROJECT COMMUNICATION PATHWAYS
Communication Drivers Organization/Title Name/E-mail Phone Number Procedure
USAID Contracting 02439351231 E-mail/phone communication with COP and
Manage contract Suzanne Johnson
Officer COR.
USAID Primary Point of C. +84 (96) 2002758
Contact Anthony (Tony) Kalb E-mail/phone communication with COP,
USAID COR
Manage and oversee the [email protected] Project Director and stakeholders.
Project technical direction
All communications from A&E Bien Hoa
Contractor with USAID must go through the
COP. As directed by COP, communications
with USAID can also go through the DCOP.
Leads the Architect- COP / Remediation
All deliverables to USAID are submitted
Engineer (A&E) Services for Specialist Andrew Sayers-Fay, Ph. D. T. +1 504.585.5767
through the COP. Responsible for Project
Dioxin Remediation at Bien A&E Bien Hoa [email protected] C. +84 (84) 9360544
document management (including of
Hoa Airbase Area Activity Contractor
deliverables, meeting minutes, technical
documents, etc.).
Email/phone communication with A&E Bien

Hoa Contractor team.
Deliverables to USAID are submitted for
Leads the operations of the
review by the DCOP and submittal by the
A&E Services for Dioxin
COP. Responsible for Project document
Remediation at Bien Hoa DCOP
Suzan Samara T. +1 347.295.9113 management (including of deliverables, meeting
Airbase Area Activity and A&E Bien Hoa
[email protected] C. +84 (36) 7731624 minutes, technical documents, etc.).
can act as COP for Contractor
responsibilities described
above
Hoa Contractor team and COP.

Leads the engineering A&E Lead Local Engineer Tri Hoang C. +84 (91) 3465795 All engineering technical deliverables to USAID
Services for Dioxin A&E Bien Hoa [email protected] are submitted for review by the Lead Local
Remediation at Bien Hoa Contractor Engineer and submittal by the COP. Lead
Airbase Area Activity engineering and technical contact with GVN
officials and Vietnamese contractors.
Responsible for translation review of
engineering documents.

Hoa Contractor team and COP.
Ensure the health and safety of the field team
Lead Safety and
and keep COP apprised of environmental
Environmental
Manage Health, Safety and Thang Vu compliance progress and any safety issues.
Compliance Specialist C. +84 (91) 8077753
Environmental [email protected]
A&E Bien Hoa
Contractor
Hoa Contractor team and PM, and COP.
Ensure that field team and COP apprised of
field progress and any issues. Coordinate
Quang Mai access to site through COP.
Manage Site Activities Construction Manager C. +84 (90) 3511779
[email protected]
Hoa Contractor team and PM, and COP.
Lead Safety and Environmental Compliance
Quality Manager
Field and Analytical Kit Adsetts / Specialist (or designee) will e-mail or fax daily
A&E Bien Hoa C. +1 916-949-6687
Corrective Actions [email protected] field progress reports to COP and Quality
Contractor
Manager.
Project Chemist will e-mail or fax analytical
Release of Analytical Data Project Chemist data as requested by COP or Lead Safety and
Peter Chapman
and Site-Wide SAP–QAPP A&E Bien Hoa T. +1 434-295-4446 Environmental Compliance Specialist. Site-
[email protected]
Amendments Contractor Wide SAP–QAPP changes to be e-mailed to
COP.
QA/QC issues with project field samples will
be reported by Laboratory PM to the Project
Reporting Laboratory Data
Data Validation Chemist TBD Chemist within 2 business days. If corrective
Quality Issues
measures are required, Project Chemist will
notify the Quality Manager and COP.

be reported by Laboratory PM to Project
Reporting Laboratory Data
Analytical Laboratory TBD Chemist within 2 business days. If corrective
Quality Issues
be reported by Laboratory PM to Project
Reporting Laboratory Data Geotechnical
TBD Chemist within 2 business days. If corrective
Quality Issues Laboratory
Notes:
COP – Chief of Party
COR – Contracting Officer’s Representative
DCOP – Deputy Chief of Party
HASP – Health and Safety Plan
QA/QC – Quality Assurance / Quality Control
PM – Project Manager

WORKSHEET #9 PROJECT PLANNING SESSION SUMMARY
Project Name/Number: Task order 72044019F00001
Operable Units: Dioxin Remediation at Bien Hoa Airbase Area
Projected Date(s) of Sampling:
Site Location: Bien Hoa Airbase, Bien Hoa, Vietnam
Project Manager:
USAID CO – Michael Capobianco [CO at the time, now it is Suzanne Johnson]
Trigon Chief of Party – Sal Mansour [COP at the time, now it is Andrew Sayers-Fay]
Date of Session:
The project team conducted a kick-off meeting on April 22, 2019 to discuss general activity details,
including team introduction, project execution strategy, and schedule. Meeting attendees were as follows:
TABLE 9-1. PROJECT SCOPING SESSION PARTICIPANTS
E-mail Address or
Name of Meeting Attendee Title/Role Organization Mailing Address
Michael Greene Mission Director USAID [email protected]
Michael Capobianco CO USAID [email protected]
[email protected]
Anthony (Tony) Kolb COR USAID
Nguyen Manh Phuc Alternate COR USAID [email protected]
Contracting
Karittha (Apple) Jenchiewchan USAID [email protected]
Specialist
Remediation
Eileen Fanelli USAID [email protected]
Advisor
Remediation
Nguyen Manh Cuong USAID [email protected]
Specialist
Trigon
Sal Mansour Chief of Party [email protected]
Associates
Trigon
Lisa Cookmeyer Project Director [email protected]
Associates
Karla Bonner Project Director Cardno [email protected]
Ken Swain Planning Lead Cardno [email protected]
Contracts Cardno
Kristen Blandford [email protected]
Specialist
Notes:
COR – Contracting Officer’s Representative

Kick-off Meeting Purpose:
The following topics were addressed during the kick-off meeting:
• Introduction
• Project Team
• Execution Strategy
• Schedule

WORKSHEET #10 SITE CONCEPTUAL MODEL
A detailed Site Conceptual Model (SCM) has been developed by USAID for the Project and is submitted
under separate cover (Trigon 2019). The SCM will be revised as new data is collected.

WORKSHEET #11 PROJECT/DATA QUALITY OBJECTIVES
The DQO process is a series of planning steps designed to ensure that the type, quantity, and quality of
environmental data used in decision-making are appropriate for the intended purpose.
The DQO process specifies project decisions, the data quality required to support those decisions, specific
data types needed, data collection requirements, and analytical techniques necessary to generate the
specified data quality. The process also ensures that the resources required to generate the data are
justified. The DQO process consists of the following format: (1) detail the DQO format to be used for
particular “problems,” (2) identify the “goals” that the SAP-QAP annexes are anticipated to address, (3)
identify the general data quality principles.
11.1 DQO PROCESS OR FORMAT

The DQO process must be conducted in accordance with the “Guidance on Systematic Planning Using
the Data Quality Objectives Process” (USEPA 2006). The DQO process consists of seven steps; output
from each step influences the choices that will be made later in the process. These steps include:
1. State the problem – Clearly define the problem so that the focus of the project or task is
unambiguous;
2. Identify the decision – Develop the decision statements that address the concerns of the problem
statement;
3. Identify the inputs to the decision – Identify the information required to resolve the decision
statements identified in Step 2, and determine which inputs require environmental measurements;
4. Define the study boundaries – Define the spatial and temporal boundaries that is covered by each
decision statement;
5. Develop a decision rule – Combine the parameter of interest, scale of decision making, action level
and alternative actions (ARARs) to produce decision rules that provide a logical basis for choosing
between alternative actions;
6. Specify limits on decision errors – Define the tolerable limits on the decision errors ; and
7. Optimize the design – Present alternative data collection designs that meet the requirements
previously specified.
The above are a series of logical steps that guides managers or staff to a plan for the resource effective
acquisition of environmental data. It is both flexible and iterative, and applies to both decision-making (e.g.,
compliance/non-compliance with a standard) and estimation (e.g., ascertaining the mean concentration
level of a contaminant). The DQO Process is used to establish performance and acceptance criteria, which
serve as the basis for designing a plan for collecting data of sufficient quality and quantity to support the
goals of the study. Use of the DQO Process leads to efficient and effective expenditure of resources;
consensus on the type, quality, and quantity of data needed to meet the project goal; and the full
documentation of actions taken during the development of the project.
11.2 DQO GOALS

This Site-Wide SAP-QAPP provides the overall DQO process for the Project. Task-specific DQO’s will
be developed in Annexes to this Site-Wide SAP-QAPP by applying the seven steps described above for
each problem identified under the two main types of data collection:

1. Site Evaluation/Design Goals
2. Site Remediation/Implementation Goals
11.2.1 SITE-EVALUATION/DESIGN GOALS

During the Project, there will be multiple activities that will include site evaluation and design. Collection
of soil, sediment, surface and groundwater, air and waste material samples and testing of their chemical
and physical properties as required will be conducted to define/support at a minimum the activities as
follows:
• Data collection to establish baseline conditions - of air, sediment, and surface water prior to site
investigation and construction at each work site and/or Bien Hoa Airbase boundaries, as
applicable;
• Data collection to develop statistical-based background conditions at a location to be determined
that is not impacted by site or Airbase activities;
• Supplemental data collection to refine nature and extent of contamination;
• Supplemental data collection in support of Human Health and Ecological Risk Assessment;
• Supplemental data collection to support treatment design:
o Chemical
o Geotechnical
• Data collection to support PPE requirements and potential changes to those;
• Data collection to support siting studies for Storage Areas; and
• Data collection to ensure adequate decontamination of collection equipment and personnel as
applicable.
11.2.2 SITE REMEDIATION/IMPLEMENTATION GOALS

During the Project, there will be multiple site remediation and implementation activities. Collection of
soil, sediment, surface and groundwater, air, and waste material samples and testing of their chemical and
physical properties will be conducted to define/support a minimum of activities listed below:
• Confirmation of achievement of dioxin cleanup action levels after IM1 excavation of soil/sediments;
• Confirmation of achievement of dioxin treatment goal following treatment of soil/sediments;
• Confirmation of no increased health or environmental risk from arsenic due to project activities;
• Confirmation of no increased health or environmental risk from air quality due to project activities:
o Excavation, hauling, storage;
o Treatment off-gassing;
• Mass balance calculations to ensure full contaminant destruction;
• Determination of any modifications to treatment processes or disposal methods for treatment waste
streams;

• Determination of any modifications to handling water discharged from soil de-watering and/or site
stormwater run-off;
• Determination of actions necessary to protect human health and the environment on and off-site
during implementation of all remediation activities;
• Confirmation of achievement of effective decontamination of equipment and materials during
demobilization;
• Determination of disposal methods for waste streams.
11.3 GENERAL DQO PRINCIPLES

The DQO principles provide the team with tools that will assist them in resolving project problems. The
ARARs for the project have been submitted under separate cover and are maintained to ensure the most
current versions are available to the Project. As regulations are continuously being revised, ARARs will
be included in the activity Annexes with up-to-date regulations. Principle study questions for land use,
soil/sediment, water, and air are summarized as follows:
11.3.1 LAND USE DECISIONS

Based on the ARAR – QCVN 45:2012/BTNMT, National Technical Regulation on Allowable Limits of
Dioxin in Soils Regulation defines seven land use types and provides a limit on dioxin allowable in soils as
follows for the protection of human health and the environment.
The following are the four Soil Land Use Project action limits (PALs) adopted to date at Bien Hoa Airbase
in ng/kg TEQ (ppt TEQ):
1) Land Use No. 2 Forest land/perennial trees – Maximum Allowable Limit: 100 ppt TEQ.
2) Land Use No. 4 Urban residential land – Maximum Allowable Limit: 300 ppt TEQ.
3) Land Use No. 6 Commercial Land – Maximum Allowable Limit: 1,200 ppt TEQ.
4) Land Use No. 7 Industrial Land – Maximum Allowable Limit: 1,200 ppt TEQ.
11.3.2 SOIL/SEDIMENT SAMPLING DECISIONS

Dioxin soil/sediment data quality standards adopted to date at Bien Hoa for sampling under this Project:
1) Design Level – 30-point composite samples of various sized soil masses/areas to design excavations.
2) IM1 Post-Excavation Decision Level – Applicable only to IM1 contract which is a design/build
contract. 30-point composite samples of various soil masses/areas to determine need for action, post-
excavation, to achieve remediation soil/sediment standards.
3) Storage vs. Treatment Confirmatory Sampling – Applicable only to IM1 contract. 30-point
composite samples of excavated soil/sediment masses no greater than 1,000 m3 in size to determine
if excavated material needs transport to long-term storage or requires treatment.
Analytical data to be collected at each site will augment data provided in the EA. Soil samples and
groundwater samples will be analyzed with a standard turnaround time (TAT). Samples will be shipped
with required preservative and chain-of-custody (COC) as specified in Worksheet #27.

11.3.3 WATER SAMPLING DECISIONS
Multiple types of water samples will be required throughout the Project. Water samples will be collected
as per SOPs provided in this Site-Wide SAP-QAPP or in activity-specific annexes. Water samples will be
discrete or composite samples depending on ultimate use of the data.
Discrete samples will be collected to evaluate single point sources (time or location) of water. Examples
include samples collected from groundwater wells, up-stream surface water samples, and effluent samples
(treatment or off-base). Sample data will be evaluated against applicable ARARs, and as such, all collection
and laboratory protocols must be conducive to meeting the data requirements of the applicable ARARs.
Composite samples may be collected as an areal composite (open water bodies) or a time composite
(stream or effluent sampling over a given period). Sample data will be evaluated against applicable ARARs,
and as such, all collection and laboratory protocols must be conducive to meeting the data requirements
of the applicable ARARs.
11.3.4 AIR SAMPLING DECISIONS

Air samples will be collected to evaluate air quality with respect to worker safety, ambient air quality, and
impact to areas adjacent to the work areas. Air will be monitored for fugitive dust and dioxin. These
contaminants each require unique collection and analysis. Sample data will be evaluated against applicable
ARARs, and as such, all collection and laboratory protocols must be conducive to meeting the data
requirements of the applicable ARARs. Three basic types of air monitoring will be conducted.
Background/Baseline
Before remedial actions begin, time-composite air samples will be collected for total particulates and
dioxin. Sample location and duration of sampling will be identified in the task-specific SAP-QAPP Annex.
Background levels will be statistically defensible data collected over time from a location where as little
Airbase operational impact possible occurs. Baseline data will be collected from specific work areas and
will measure normal Airbase operational effects to air quality to serve as a baseline prior to initiation of
Project activities. Baseline sampling will be conducted at site boundaries as well as Airbase boundaries.
Worker Safety
Worker Safety will be evaluated by personnel monitoring and/or exclusion zone monitoring for dust and
dioxin. Total dust can be measured real-time with properly calibrated field equipment. Dioxin will require
collection and then shipment of samples to a lab for analysis. Minimum of 5 days is expected before sample
results would be available.
Site and Airbase Boundary
During site work, air monitoring will be conducted at site and Airbase boundaries to monitor for fugitive
dust and Dioxin. Fugitive dust may be monitored as real time with alarms to ensure work is stopped if
criteria are exceeded. Dioxin concentrations will not be available for a minimum of five days. These data
will be used to evaluate the effectiveness of dust control measures. Revisions to the control measures
will be made as necessary based on the data.

11.4 ANALYTIC APPROACH
Laboratories must achieve data quality objectives consistent with EPA Guidance (as referenced in
https://www.epa.gov/quality and the Interstate Technology and Regulatory Guidance
(https://www.itrcweb.org/ism-1/pdfs/ISM-1_final.pdf) whenever multi-incremental sampling technology is
required.

WORKSHEET #12 MEASUREMENT PERFORMANCE CRITERIA
Project Measurement Performance Criteria (MPC) are summarized in this worksheet to provide a dataset
that will achieve DQOs and support technically defensible project decisions. The criteria are related to
the data quality indicators (DQIs) of precision, accuracy/bias, representativeness, comparability,
completeness, and sensitivity. The parameters that will be used to measure outliers associated with the
project results are described in the following subsections.
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
12.2 ACCURACY/BIAS CONTAMINATION

Results for all laboratory method blanks and field blanks (e.g., trip blanks, field equipment rinseate blanks,
and ambient field blanks) will be reviewed by the data validator. In addition, LCS/LCSDs, MS/MSDs,
surrogates, internal standards, post digestion spikes, and serial dilutions will be reviewed. The results for
each analyte will be checked against the measurement performance criteria presented on Tables 12-1
through 12-3 of Worksheet #12. Results for analytes that exceed criteria will be identified in the data
validation report. A discussion will summarize the results of the laboratory accuracy/bias. Conclusions
about the accuracy/bias of the analyses based on contamination or outlying recoveries and limitations on
the use of the data will be described in the report.
Bias values for spiked samples are commonly expressed as Percent Recovery (%R), which is calculated as
follows:
𝐶𝐶𝑆𝑆 − 𝐶𝐶𝑅𝑅
%𝑅𝑅 = × 100;
𝐶𝐶𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆
Where:
%R = Percent recovery
CR = Measured concentration of the original sample result
CS = Measured concentration of the spiked sample result

CSknown = Known concentration of the spike added
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

concentration that must be present in order to be detected with 99 percent (%) confidence. Non-
detections are reported at the MDL.
Worksheet #15 will include the MDLs and LOQs as well as the site PALs for each analyte. The project
team will compare LOQs against the site PALs for each analyte to ensure, wherever possible, that the
selected analytical method will achieve the site PALs. In the event that the PAL cannot be achieved by the
method, the Report will discuss the limitations on the use of the data with respect to laboratory sensitivity.
In accordance with DoD QSM v5.0 requirements, the laboratory is required to run quarterly LOQ
standards, for which LOQ verification may be performed on a batch basis. The results of the LOQ
verification standards are typically not included in the data packages, but results are retained by the
laboratory and are available for review upon request.
A discussion in the report will summarize the results of the laboratory sensitivity. Conclusions about the
sensitivity of the analyses will be described in the report.
MPC for each matrix and laboratory analysis are compiled in Tables 12-1 to 12-26.

TABLE 12-1. MEASUREMENT PERFORMANCE CRITERIA TABLE FOR VOC, SOIL
Matrix Soil
Analytical Group VOA
Concentration Level Low
QC Sample and/or QC Sample Assesses
Analytical
Data Quality Measurement Performance Activity Used to Assess Error for Sampling
Sampling Procedure Method/SOP
Indicators (DQIs) Criteria Measurement (S), Analytical (A) or
(or equivalent)
Performance Both (S&A)
SW-846
Soil sampling Accuracy Laboratory statistical limits Surrogate Spike A
8260C/TBD
Laboratory Control
SW-846 Accuracy / Bias/ Laboratory statistical limits or
Soil sampling Spike/Matrix Spike and S&A
8260C/TBD Precision RPD ≤35%
their Duplicates
No analytes detected > RL or
SW-846 Accuracy/Laboratory
Soil sampling >1/10 the amount measured in Method Blank A
8260C/TBD Contamination
any sample
SW-846
Soil sampling Precision RPD as set by project Field Duplicate S&A
8260C/TBD
SW-846 Accuracy/Field
Soil sampling No detected target compounds Field Blank S&A
SW-846 Accuracy/Transport
Soil sampling No detected target compounds Trip Blank A
SW-846
Soil sampling Completeness As determined by the project Reported Sample Data S&A
8260C/TBD
SW-846
Soil sampling Bias/Holding Time ≤ 14 days Reported Sample Data A
8260C/TBD
SW-846
Soil sampling Sensitivity Detection limits ≤ to PALs Detection limits S
8260C/TBD
Notes:
> – greater than
≤ – less than or equal to
PAL – Project Action Limit
QC – Quality Control
RL – Reporting Limit
RPD – Relative Percent Difference
SW-846 – Test Methods for Evaluating Solid Waste, Physical/Chemical Methods
VOA – Volatile Organic Analysis

TABLE 12-2. MEASUREMENT PERFORMANCE CRITERIA TABLE FOR VOCS, WATER
Matrix Water
Analytical
Data Quality Measurement Performance Activity Used to Error for Sampling
Indicators (DQIs) Criteria Assess Measurement (S), Analytical (A) or
(or equivalent)
SW-846
Water sampling Accuracy Laboratory statistical limits Surrogate Spike A
8260C/TBD
Laboratory Control
Water sampling Spike/Matrix Spike and S&A
8260C/TBD Precision RPD ≤20%
their Duplicates
Water sampling >1/10 the amount measured in Method Blank A
any sample
SW-846
Water sampling Precision RPD as set by project Field Duplicate S&A
8260C/TBD
Water sampling No detected target compounds Field Blank S&A
SW-846 Accuracy/Transport
Water sampling No detected target compounds Trip Blank A
SW-846
Water sampling Completeness As determined by the project Reported Sample Data S&A
8260C/TBD
SW-846
Water sampling Bias/Holding Time ≤ 14 days Reported Sample Data A
8260C/TBD
SW-846
Water sampling Sensitivity Detection limits ≤ to PALs Detection limits S
8260C/TBD
Notes:
> – greater than

TABLE 12-3. MEASUREMENT PERFORMANCE CRITIERA TABLE FOR SVOCS, SOIL
Matrix Soil
Analytical Group SVOA
Analytical
Measurement Performance Activity Used to Error for Sampling
Sampling Procedure Method/SOP 111q
Criteria Assess Measurement (S), Analytical (A) or
(or equivalent)
SW-846
Soil sampling Accuracy Laboratory statistical limits Surrogate Spike A
8270D/TBD
Laboratory Control
Soil sampling Spike/Matrix Spike and S&A
8270D/TBD Precision RPD ≤35%
their Duplicates
Soil sampling >1/10 the amount measured in Method Blank A
8270D/TBD Contamination
any sample
SW-846
8270D/TBD
Soil sampling No detected target compounds Field Blank S&A
SW-846
8270D/TBD
SW-846 ≤14 days to extraction/≤40 days
Soil sampling Bias/Holding Time Reported Sample Data A
8270D/TBD to analysis
SW-846
8270D/TBD
Notes:
> – greater than
SVOA – Semi Volatile Organic Analysis

TABLE 12-4. MEASUREMENT PERFORAMCE CRITIERA TABLE FOR SVOCS, WATER
Matrix Water
Analytical Group SVOA
Analytical
(or equivalent)
SW-846
8270D/TBD
Laboratory Control
8270D/TBD Precision RPD ≤20%
their Duplicates
any sample
SW-846
8270D/TBD
SW-846
8270D/TBD
SW-846 ≤7 days to extraction/≤40 days
Water sampling Bias/Holding Time Reported Sample Data A
8270D/TBD to analysis
SW-846
8270D/TBD
Notes:
> – greater than
SVOA – Semi Volatile Organic Analysis

TABLE 12-5. MEASUREMENT PERFORMANCE CRITERIA TABLE FOR PCBS, SOIL
Matrix Soil/Tissue/Wipes
Analytical Group PCBs
Analytical
(or equivalent)
Soil, Tissue or Wipe SW-846
Accuracy Laboratory statistical limits Surrogate Spike A
Sampling 8082A/TBD
Laboratory Control
Soil, Tissue or Wipe SW-846 Accuracy / Bias/ Laboratory statistical limits or
Spike/Matrix Spike and S&A
Sampling 8082A/TBD Precision RPD ≤35%
their Duplicates
Soil, Tissue or Wipe SW-846 Accuracy/Laboratory
>1/10 the amount measured in Method Blank A
Sampling 8082A/TBD Contamination
any sample
Precision RPD as set by project Field Duplicate S&A
Sampling 8082A/TBD
Soil, Tissue or Wipe SW-846 Accuracy/Field
No detected target compounds Field Blank S&A
Sampling 8082A/TBD Contamination
Completeness As determined by the project Reported Sample Data S&A
Sampling 8082A/TBD
Bias/Holding Time 365 days Reported Sample Data A
Sampling 8082A/TBD
Sensitivity Detection limits ≤ to PALs Detection limits S
Sampling 8082A/TBD
Notes:
> – greater than
PCB – Polychlorinated Biphenyl

TABLE 12-6. MEASUREMENT PERFORMANCE CRITIERA TABLE FOR PCBS, WATER
Matrix Water
Analytical
(or equivalent)
SW-846
8082A/TBD
Laboratory Control
8082A/TBD Precision RPD ≤20%
their Duplicates
8082A/TBD Contamination
any sample
SW-846
8082A/TBD
SW-846
8082A/TBD
SW-846
Water sampling Bias/Holding Time 365 days Reported Sample Data A
8082A/TBD
SW-846
8082A/TBD
Notes:
> – greater than

TABLE 12-7. MEASUREMENT PERFORMANCE CRITIERA TABLE FOR HERBICIDES, SOIL
Matrix Soil
Analytical Group Herbicides
Analytical
(or equivalent)
Soil or Tissue SW-846 8151A
Accuracy Laboratory statistical limits Surrogate Spike A
sampling TBD
Laboratory Control
Soil or Tissue SW-846 8151A Accuracy / Bias/ Laboratory statistical limits or
Spike/Matrix Spike and S&A
sampling TBD Precision RPD ≤35%
their Duplicates
Soil or Tissue SW-846 8151A Accuracy/Laboratory
>1/10 the amount measured in Method Blank A
sampling TBD Contamination
any sample
Precision RPD as set by project Field Duplicate S&A
sampling TBD
Soil or Tissue SW-846 8151A Accuracy/Field
No detected target compounds Field Blank S&A
sampling TBD Contamination
Completeness As determined by the project Reported Sample Data S&A
sampling TBD
Soil or Tissue SW-846 8151A ≤14 days to extraction/≤40 days
Bias/Holding Time Reported Sample Data A
sampling TBD to analysis
Sensitivity Detection limits ≤ to PALs Detection limits S
sampling TBD
Notes:
> – greater than

TABLE 12-8. MEASUREMENT PERFORMANCE CRITIERA TABLE FOR HERBICIDES, WATER
Matrix Water
Analytical
(or equivalent)
SW-846 8151A
Soil Sampling Accuracy Laboratory statistical limits Surrogate Spike A
TBD
Laboratory Control
SW-846 8151A Accuracy / Bias/ Laboratory statistical limits or
Soil Sampling Spike/Matrix Spike and S&A
TBD Precision RPD ≤20%
their Duplicates
SW-846 8151A Accuracy/Laboratory
Soil Sampling >1/10 the amount measured in Method Blank A
TBD Contamination
any sample
SW-846 8151A
Soil Sampling Precision RPD as set by project Field Duplicate S&A
TBD
SW-846 8151A Accuracy/Field
Soil Sampling No detected target compounds Field Blank S&A
TBD Contamination
SW-846 8151A
Soil Sampling Completeness As determined by the project Reported Sample Data S&A
TBD
≤14 days to leaching; ≤7 days
SW-846 8151A
Soil Sampling Bias/Holding Time from leaching to extraction/ ≤40 Reported Sample Data A
TBD
days to analysis
SW-846 8151A
Soil Sampling Sensitivity Detection limits ≤ to PALs Detection limits S
TBD
Notes:
> – greater than

TABLE 12-9. MEASUREMENT PERFORMANCE CRITIERA TABLE FOR ARSENIC SPECIATION, WATER
Matrix Water
Analytical Group Arsenic Speciation
Analytical
(or equivalent)
±50% for TIAs Laboratory Control
USEPA 1632 Mod. / Accuracy / Bias/
Water sampling ±70% for As3+ Spike/Matrix Spike and A
TBD Precision
RPD ≤35% their Duplicates
No analytes detected >RL or
USEPA 1632 Mod. / Accuracy/Laboratory
TBD Contamination
any sample
USEPA 1632 Mod. /
Water sampling Precision RPD ≤35% Lab Duplicate S&A
TBD
USEPA 1632 Mod. /
TBD
USEPA 1632 Mod. / Accuracy/Field
TBD Contamination
USEPA 1632 Mod. /
TBD
USEPA 1632 Mod. / Samples analyzed within 28
TBD days of collection
USEPA 1632 Mod. / MDL determined by 40 CFR
Water sampling Sensitivity Detection limits S
TBD Part 136 Appendix B
Notes:
± – plus or minus
> – greater than
CFR – Code of Federal Regulations
MDL – Method Detection Limit
USEPA – United States Environmental Protection Agency

TABLE 12-10. MEASUREMENT PERFORMANCE CRTIERIA TABLE FOR ARSENIC SPECIATION, SOLID
Matrix Solid
Analytical
(or equivalent)
±50% for TIAs Laboratory Control
USEPA 1632 Mod. / Accuracy / Bias/
Water sampling ±70% for As3+ Spike/Matrix Spike and A
TBD Precision
RPD ≤35% their Duplicates
No analytes detected >RL or
USEPA 1632 Mod. / Accuracy/Laboratory
TBD Contamination
any sample
USEPA 1632 Mod. /
TBD
USEPA 1632 Mod. /
TBD
USEPA 1632 Mod. / Accuracy/Field
TBD Contamination
USEPA 1632 Mod. /
TBD
USEPA 1632 Mod. / Samples analyzed within 180
TBD days from collection
USEPA 1632 Mod. / MDL determined by 40 CFR
Water sampling Sensitivity Detection limits S
TBD Part 136 Appendix B
Notes:
> – greater than
CFR – Code of Federal Regulations

TABLE 12-11. MEASUREMENT PERFORMANCE CRITERIA TABLE FOR ANIONS, WATER
Matrix Water
Analytical Group Anions
Analytical
(or equivalent)
USEPA 300.0/9056; Laboratory Control
Water sampling Accuracy/Bias Method limits A
TBD Spike/Matrix Spike
No analytes detected <MDL or
USEPA 300.0/9056; Accuracy/Laboratory
Water sampling >1/10 the amount measure in Method Blanks A
TBD Contamination
any sample.
USEPA 300.0/9056;
Water sampling Precision Laboratory statistical Lab Duplicate S&A
TBD
USEPA 300.0/9056;
TBD
USEPA 300.0/9056; Accuracy/Field No detected target
Water sampling Field Blank S&A
TBD Contamination compounds
USEPA 300.0/9056;
TBD
USEPA 300.0/9056; SO4, Br, Cl, F ≤28 days, NO3,
TBD NO2, PO4 ≤48 hrs
USEPA 300.0/9056;
TBD
Notes:
< – less than
> – greater than

TABLE 12-12. MEASUREMENT PERFORMANCE CRITIERA TABLE FOR ANIONS, SOIL
Matrix Soil
Analytical
(or equivalent)
Laboratory Control
Soil sampling USEPA 300.0; TBD Accuracy/Bias Method limits A
Spike/Matrix Spike
No analytes detected <MDL or
Accuracy/Laboratory
Soil sampling USEPA 300.0; TBD >1/10 the amount measure in Method Blanks A
Contamination
any sample.
Soil sampling USEPA 300.0; TBD Precision Laboratory statistical Lab Duplicate S&A
Soil sampling USEPA 300.0; TBD Precision RPD as set by project Field Duplicate S&A
Accuracy/Field No detected target
Soil sampling USEPA 300.0; TBD Field Blank S&A
Contamination compounds
Soil sampling USEPA 300.0; TBD Completeness As determined by the project Reported Sample Data S&A
SO4, Br, Cl, F ≤28 days, NO3,
Soil sampling USEPA 300.0; TBD Bias/Holding Time Reported Sample Data A
NO2, PO4 ≤48 hrs
Soil sampling USEPA 300.0; TBD Sensitivity Detection limits ≤ to PALs Detection limits S
Notes:
< – less than
> – greater than

TABLE 12-13. MEASUREMENT PERFORMANCE CRITIERA TABLE FOR DIOXINS, WATER
Matrix Water
Analytical Group Dioxins
Analytical
(or equivalent)
Water Sampling USEPA 1613B; TBD Accuracy Laboratory statistical limits Surrogate Spike A
Laboratory Control
Accuracy / Bias/ Laboratory statistical limits;
Water Sampling USEPA 1613B; TBD Spike/Matrix Spike and S&A
Precision RPD ≤25%
their Duplicates
2378-TCDF and 2378-TCDD
Accuracy/Laboratory
Water Sampling USEPA 1613B; TBD <10 pg/l; OCDD and OCDF Method Blank A
Contamination
<100 pg/l; all others <50 pg/l
Water Sampling USEPA 1613B; TBD Precision RPD as set by project Field Duplicate S&A
Water Sampling USEPA 1613B; TBD Completeness As determined by the project Reported Sample Data S&A
Water Sampling USEPA 1613B; TBD Bias/Holding Time ≤ 365 days Reported Sample Data A
Water Sampling USEPA 1613B; TBD Sensitivity Detection limits ≤ to PALs Detection limits S
Notes:
< – less than
OCDD – octachlorodibenzo-p-dioxin
OCDF – octachlorodibenzo-p-furan
pg/l – picogram per liter
TCDD – 23,7,8-tetrachlorodibenzo-p-dioxin
TCDF – tetrachlorodibenzofuran

TABLE 12-14 MEASUREMENT PERFORMANCE CRITERIA TABLE FOR DIOXINS, SOIL
Matrix Soil
Analytical
(or equivalent)
Water Sampling USEPA 1613B; TBD Accuracy Laboratory statistical limits Surrogate Spike A
Laboratory Control
Water Sampling USEPA 1613B; TBD Spike/Matrix Spike and S&A
their Duplicates
2378-TCDF and 2378-TCDD
Accuracy/Laboratory
Water Sampling USEPA 1613B; TBD <10 pg/l; OCDD and OCDF Method Blank A
Contamination
<100 pg/l; all others <50 pg/l
Water Sampling USEPA 1613B; TBD Precision RPD as set by project Field Duplicate S&A
Water Sampling USEPA 1613B; TBD Completeness As determined by the project Reported Sample Data S&A
Water Sampling USEPA 1613B; TBD Bias/Holding Time ≤ 365 days Reported Sample Data A
Water Sampling USEPA 1613B; TBD Sensitivity Detection limits ≤ to PALs Detection limits S
Notes:
< – less than
OCDD – octachlorodibenzo-p-dioxin
OCDF – octachlorodibenzo-p-furan
pg/l – picogram per liter
TCDD – 23,7,8-tetrachlorodibenzo-p-dioxin
TCDF – tetrachlorodibenzofuran

TABLE 12-15. MEASUREMENT PERFORMANCE CRITIERA TABLE FOR DIOXINS, AIR
Matrix Air
Analytical
(or equivalent)
Air Sampling USEPA TO-9/TBD Accuracy Laboratory statistical limits Surrogate Spike A
Laboratory Control
Air Sampling USEPA TO-9/TBD Spike/Matrix Spike and S&A
their Duplicates
Accuracy/Laboratory
Air Sampling USEPA TO-9/TBD TBD Method Blank A
Contamination
Air Sampling USEPA TO-9/TBD Precision RPD as set by project Field Duplicate S&A
Air Sampling USEPA TO-9/TBD Completeness As determined by the project Reported Sample Data S&A
Air Sampling USEPA TO-9/TBD Bias/Holding Time ≤ 365 days Reported Sample Data A
Air Sampling USEPA TO-9/TBD Sensitivity Detection limits ≤ to PALs Detection limits S
Notes:

TABLE 12-16. MEASUREMENT PERFORMANCE CRITERIA TABLE FOR FERROUS IRON, WATERS
Matrix Water
Analytical Group Ferrous Iron
Analytical
(or equivalent)
Laboratory statistical or Laboratory Control
SM 3500 Fe B-2011/ Accuracy / Bias/
Water sampling method window and RPD, Spike/Matrix Spike and A
TBD Precision
whichever is tighter their Duplicates
No analytes detected > LOQ
SM 3500 Fe B-2011/ Accuracy/Laboratory
Water sampling or >1/10 the amount Method Blank A
TBD Contamination
measured in any sample
SM 3500 Fe B-2011/
Water sampling Precision Laboratory statistical RPD Lab Duplicate S&A
TBD
SM 3500 Fe B-2011/
TBD
SM 3500 Fe B-2011/ Accuracy/Field No detected target
SM 3500 Fe B-2011/
TBD
SM 3500 Fe B-2011/
Water sampling Bias/Holding Time N/A Reported Sample Data A
TBD
SM 3500 Fe B-2011/
TBD
Notes:
> – greater than
LOQ – Limit of Quantitation
N/A – Not Applicable

TABLE 12-17. MEASUREMENT PERFORMANCE CRITERIA TABLE FOR WET CHEMISTRY PARAMETERS
Matrix Water
Wet Chemistry – Ferric
Analytical Group
Iron
QC Sample and/or Activity QC Sample Assesses Error for
Sampling Analytical Data Quality Measurement
Used to Assess Measurement Sampling (S), Analytical (A) or
Procedure Method/SOP Indicators (DQIs) Performance Criteria
Ferric iron is a calculation performed by subtracting ferrous iron from total iron
Notes:

TABLE 12-18. MEASUREMENT PERFORMANCE CRITERIA TABLE FOR METALS, WATER
Matrix Water
Analytical Group Metals - ICP/MS
Analytical
(or equivalent)
Laboratory Control
Accuracy / Bias/ Spike/Laboratory
Water sampling USEPA 200.8 / TBD 80-120%; RPD ≤20% A
Precision Control Spike
Duplicate
Accuracy / Bias/ Matrix Spike/Matrix
Water sampling USEPA 200.8 / TBD 70-130%; RPD ≤20% A
Precision Spike Duplicate
No analytes detected > 1/2
LOQ or 2.2x MDL, whichever
Accuracy/Laboratory
Water sampling USEPA 200.8 / TBD is greater, or >1/10 the Method Blank A
Contamination
amount measured in any
sample.
Water sampling USEPA 200.8 / TBD Precision RPD ≤20% Lab Duplicate S&A
Water sampling USEPA 200.8 / TBD Precision RPD as set by project Field Duplicate S&A
Accuracy/Field No detected target
Water sampling USEPA 200.8 / TBD Field Blank S&A
Contamination compounds
Water sampling USEPA 200.8 / TBD Completeness As determined by the project Reported Sample Data S&A
Water sampling USEPA 200.8 / TBD Bias/Holding Time ≤ 6 months Reported Sample Data A
Water sampling USEPA 200.8 / TBD Sensitivity Detection limits ≤ to PALs Detection limits S
Notes:
> – greater than

TABLE 12-19. MEASUREMENT PERFORMANCE CRITERIA TABLE FOR METALS, WATER
Matrix Water
Analytical Group Metals - ICP
Analytical
(or equivalent)
Laboratory Control
SW-846 6010C/ Accuracy / Bias/ Laboratory Statistical Limits; Spike/Laboratory
Water sampling A
TBD Precision RPD ≤20% Control Spike
Duplicate
SW-846 6010C/ Accuracy / Bias/ Laboratory Statistical Limits; Matrix Spike/Matrix
Water sampling A
TBD Precision RPD ≤20% Spike Duplicate
No analytes detected > 1/2 RL
SW-846 6010C/ Accuracy/Laboratory
TBD Contamination
SW-846 6010C/
TBD
SW-846 6010C/
TBD
SW-846 6010C/ Accuracy/Field No detected target
SW-846 6010C/
TBD
SW-846 6010C/
Water sampling Bias/Holding Time ≤ 6 months Reported Sample Data A
TBD
SW-846 6010C/
TBD
Notes:
> – greater than

TABLE 12-20. MEASUREMENT PERFORMANCE CRITIERA TABLE FOR METALS, SOIL
Matrix Soil
Analytical Group Metals - ICP
Analytical
(or equivalent)
Laboratory Control
SW-846 6010C/ Accuracy / Bias/ Laboratory Statistical Limits; Spike/Laboratory
Soil sampling A
TBD Precision RPD ≤30% Control Spike
Duplicate
SW-846 6010C/ Accuracy / Bias/ Laboratory Statistical Limits; Matrix Spike/Matrix
Soil sampling A
No analytes detected > 1/2
SW-846 6010C/ Accuracy/Laboratory
Soil sampling RL or >1/20 the amount Method Blank A
TBD Contamination
SW-846 6010C/
Soil sampling Precision RPD ≤30% Lab Duplicate S&A
TBD
SW-846 6010C/
TBD
SW-846 6010C/ Accuracy/Field No detected target
Soil sampling Field Blank S&A
SW-846 6010C/
TBD
SW-846 6010C/
Soil sampling Bias/Holding Time ≤ 6 months Reported Sample Data A
TBD
SW-846 6010C/
TBD
Notes:
> – greater than

TABLE 12-21. MEASUREMENT PERFORMANCE CRITIERA TABLE FOR METALS, WATER
Matrix Water
Analytical Group Metals- Hg
Analytical
(or equivalent)
Laboratory Control
SW-846 Accuracy / Bias/ Laboratory Statistical Limits; Spike/Laboratory
Water sampling A
7470A/TBD Precision RPD ≤20% Control Spike
Duplicate
SW-846 Accuracy / Bias/ Laboratory Statistical Limits; Matrix Spike/Matrix
Water sampling A
7470A/TBD Precision RPD ≤20% Spike Duplicate
SW-846
7470A/TBD
SW-846
7470A/TBD
SW-846 Accuracy/Field No detected target
7470A/TBD Contamination compounds
SW-846
7470A/TBD
SW-846
Water sampling Bias/Holding Time ≤ 28 days Reported Sample Data A
7470A/TBD
SW-846
7470A/TBD
Notes:
> – greater than

TABLE 12-22. MEASUREMENT PERFORMANCE CRITERIA TABLE FOR METALS, SOILD
Matrix Solid
Analytical
(or equivalent)
Laboratory Control
SW-846 7471A/B Accuracy / Bias/ Laboratory Statistical Limits;
Soil sampling Spike/Matrix Spike and A
TBD Precision RPD ≤30%
their Duplicates
SW-846 7471A/B Accuracy / Bias/ Laboratory Statistical Limits; Matrix Spike/Matrix
Soil sampling A
SW-846 7471A/B Accuracy/Laboratory
Soil sampling or >1/20 the amount Method Blank A
TBD Contamination
SW-846 7471A/B
Soil sampling Precision RPD ≤30% Lab Duplicate S&A
TBD
SW-846 7471A/B
TBD
SW-846 7471A/B Accuracy/Field No detected target
SW-846 7471A/B
TBD
SW-846 7471A/B
Soil sampling Bias/Holding Time ≤ 28 days Reported Sample Data A
TBD
SW-846 7471A/B
TBD
Notes:
> – greater than

TABLE 12-23. MEASUREMENT PERFORMANCE CRITIERA TABLE FOR DISSOLVED GASES, WATER
Matrix Water
Analytical Group Dissolved Gases
Analytical
(or equivalent)
Water sampling RSK175/TBD Accuracy Laboratory statistical windows Surrogate Spike A
Laboratory Control
Accuracy / Bias/
Water sampling RSK175/TBD Laboratory statistical limits Spike/Matrix Spike and S&A
Precision
their Duplicates
Accuracy/Laboratory
Water sampling RSK175/TBD >1/10 the amount measured in Method Blank A
Contamination
any sample
Water sampling RSK175/TBD Precision RPD as set by project Field Duplicate S&A
Accuracy/Field
Water sampling RSK175/TBD No detected target compounds Field Blank S&A
Contamination
Accuracy/Transport
Water sampling RSK175/TBD No detected target compounds Trip Blank A
Contamination
Water sampling RSK175/TBD Completeness As determined by the project Reported Sample Data S&A
Water sampling RSK175/TBD Bias/Holding Time 14 days Reported Sample Data A
Water sampling RSK175/TBD Sensitivity Detection limits ≤ to PALs Detection limits S
Notes:
> – greater than

TABLE 12-24. MEASUREMENT PERFORMANCE CRITERIA TABLE FOR TOTAL ORGANIC CARBON, SOIL
Matrix Soil
Total Organic Carbon
Analytical Group
(aka FOC)

Analytical
Indicators (DQIs) Criteria Assess Measurement (S), Analytical (A)
(or equivalent)
Performance or Both (S&A)
SM 5310B/415.1/SW- Laboratory Control

Soil sampling Accuracy/Bias Laboratory statistical limits A
946 9060; TBD Spike/Matrix Spike
or >1/10 the amount
SM 5310B/415.1/SW- Accuracy/Laboratory
Soil sampling measured in any sample or Method Blank A
946 9060; TBD Contamination
1/10 the regulatory limit,
whichever is greater
SM 5310B/415.1/SW-
Soil sampling Precision Laboratory statistical RPD Lab Duplicate S&A
946 9060; TBD
SM 5310B/415.1/SW-
946 9060; TBD
SM 5310B/415.1/SW- Accuracy/Field No detected target
946 9060; TBD Contamination compounds
SM 5310B/415.1/SW- Reported Sample
Soil sampling Completeness As determined by the project S&A
946 9060; TBD Data
SM 5310B/415.1/SW- Reported Sample
Soil sampling Bias/Holding Time ≤28 days A
946 9060; TBD Data
SM 5310B/415.1/SW-
946 9060; TBD
Notes:
> – greater than

TABLE 12-25. MEASUREMENT PERFORMANCE CRITIERA TABLE FOR TOTAL ORGANIC CARBON, WATER
Matrix Water
Total Organic
Analytical Group
Carbon
Analytical
(or equivalent)
SM 5310C/EPA Accuracy / Bias/ Laboratory statistical limits Laboratory Control
Water sampling A
415.1; TBD Precision and RPD Spike/Matrix Spike
SM 5310C/415.1; Accuracy/Laboratory
TBD Contamination
SM 5310C/415.1;
Water sampling Precision Laboratory statistical RPD Lab Duplicate S&A
TBD
SM 5310C/415.1;
TBD
SM 5310C/415.1; Accuracy/Field No detected target
SM 5310C/415.1;
TBD
SM 5310C/415.1;
Water sampling Bias/Holding Time ≤28 days Reported Sample Data A
TBD
SM 5310C/415.1;
TBD
Notes:
> – greater than

TABLE 12-26. MEASUREMENT PERFORMANCE CRITERIA TABLE FOR PH, SOLID
Matrix Solid
Analytical Group pH
Concentration level
Analytical Data Quality
Measurement Performance Activity Used to Assess Error for Sampling
Sampling Procedure Method/SOP Indicators
Criteria Measurement (S), Analytical (A) or
(or equivalent) (DQIs)
Soil sampling SW-846 9045D / TBD Precision Laboratory statistical RPD Duplicates S&A
Soil sampling SW-846 9045D / TBD Accuracy/Bias Laboratory statistical window LCS A
Bias/Holding
Soil sampling SW-846 9045D / TBD Immediately Reported Sample Data A
Time
Soil sampling SW-846 9045D / TBD Completeness As determined by project Reported Sample Data S&A
Notes:
LCS – Laboratory Control Sample

WORKSHEET #13 SECONDARY DATA USES AND LIMITATIONS
Table 13-1 identifies sources of historical data pertinent to project decisions. For each data source, the following considerations were evaluated:
whether the data were validated or reviewed, whether the analytical methodologies or technical protocols are comparable to current data handling
procedures, and if limitations on use of the data can be identified.
TABLE 13-1. SECONDARY DATA CRITERIA AND LIMITATIONS
Data Source Data Generator(s)
(Originating Organization, (Originating Org., Data Types,
Secondary Data Report Title, and Date) Data Generation/Collection Dates) How Data Will Be Used Limitations on Data Use
Site history and soil, USAID, Environmental CDM International, Inc. and Hatfield  General site history. Limited. Data quality was reportedly
sediment, surface Assessment of Dioxin Consultants  Historical media analysis reviewed and results summarized in
water, and Contamination at Bien Hoa results. Data Quality Review
groundwater sample Airbase, May 3, 2016  Locate current SI/RI sampling Memorandums; however, memos
locations and to determine
analytical data COPC.
are not available.
Consequently, the data will be used
for historical screening level data
for general site evaluation only.
Analytical data TBD N/A  General site history. Data were collected using USEPA
collected during  Historical media analysis methods, and all data were
other studies results. validated. As a result of the data
 To locate current/RI sampling validation performed for the study,
locations and to determine
COPC.
the quality of the data was
determined as acceptable for the
preparation of technically defensible
documents. Soil data will be used
for site characterization, delineation,
and risk assessment.
Notes:
COPC – Contaminant(s) of Potential Concern
RI – Remedial Investigation
SI – Site Investigation

WORKSHEET #14 AND #16 PROJECT TASKS AND SCHEDULE
The implementation of the investigations and remedial actions will consist of several project tasks
including, but not limited to: securing access to the installation and obtaining digging permits; utility
clearance; investigation-derived waste (IDW) staging, management, and disposal; surveying;
photoionization detector (PID) monitoring; soil sampling; monitoring well (MW) installation/development
and sampling; air sampling; data management; and documentation and recordkeeping. Suitable SOPs have
been developed to cover currently known aspects of field operations, environmental sampling, field
measurements, and recordkeeping. SOPs are included in Appendix A. As all requirements of the Project
are not currently known, additional SOPs will be added as needed to address additional activities as
required.
14.1 MOBILIZATION TASKS

Mobilization tasks will occur prior to initiating sampling tasks.
14.1.1 INSTALLATION ACCESS AND DIGGING PERMITS

Prior to any intrusive work, the locations and scope of work will be coordinated with Regiment 935 with
respect to locating any underground utilities. Known utilities will be marked with flags and or paint.
Installation access permits, if required, will be obtained through Bien Hoa Airbase with a minimum of three
days’ notice. It is planned that Pacer Ivy area will have an isolated access gate with A&E Bien Hoa
Contractor access without Bien Hoa Airbase escort.
14.1.2 UTILITY CLEARANCE

Regiment 935 will be consulted with respect to locations of known utilities. The Regiment 935 will be
notified of areas to be investigated or excavated. Locations of all known utilities will be verified within 10
feet (ft) of each excavation/drilling location. If anything indicates that utilities may be present, the boring
location will be moved to an area that is definitively cleared. All boring locations will be hand cleared to 2
ft prior to use of mechanized drilling or digging. Additional third-party location will be conducted as
required.
14.1.3 UNEXPLODED ORDNANCE CLEARANCE

As required, all areas will be cleared for unexploded ordnance (UXO) prior to entry and intrusive work.
UXO clearance and oversight will be conducted in accordance with the site-wide UXO Clearance Plan.
In addition, UXO avoidance training will be provided to all staff conducting intrusive work and will be
included in each daily tailgate meeting.
14.1.4 INVESTIGATION-DERIVED WASTE

Prior to intrusive activities, a staging area for solid and liquid IDW will be designated by the Airbase for
storage of drums for solid and liquid waste. Waste containers will include soil cuttings and water from
well development/purging activities and decontamination activities. All drums will be labeled as described
in the below subsection (Section 14.2.3.1), “Management of Investigation-Derived Waste” in Appendix A.
All IDW storage containers and contents will be removed within the appropriate timeframe, after the
contents have been characterized for disposal.

14.1.4.1 INVESTIGATION-DERIVED WASTE MANAGEMENT
A Waste Inventory Tracking Log will be kept by the Installation Lead during sampling events (Appendix
B). Non-investigative waste, such as litter and household garbage, will be collected on an as-needed basis
to maintain each site in a clean and orderly manner. This waste will be containerized in sealed boxes or
plastic garbage bags and transported to the designated sanitary landfill or collection bin.
IDW will be properly containerized and temporarily stored at a central staging area, prior to
transportation for off-site disposal. IDW will be properly labeled, containerized, and stored as described
in SOP in Appendix A. The number of containers will be estimated on an as-needed basis. Acceptable
containers will be sealed. The containers will be Department of Transportation (DOT)-approved metal
drums (solid) and polyurethane or steel close-top drums (liquid). Containers will be transported in such
a manner to prevent spillage or particulate loss to the atmosphere.
The IDW will be segregated at the site according to matrix (solid or liquid). Each container will be properly
labeled. Label information will be placed directly on the container with indelible ink pen and on a plastic-
coated adhesive label with indelible marker (Sharpie™). All containers will be labeled with the following
information:
• Container number;
• Contract and delivery order number;
• Contents (development water and well identifiers);
• Dates of development activities; and
• Project Manager (PM) name and phone number.
Information for drums will be recorded on the Waste Inventory Tracking Log (Appendix B).
All containerized waste will be staged in an area designated by the Bien Hoa Airbase representative. The
waste may require staging for up to 90 days while waiting for analytical results and proper profiling before
shipping the waste off-site or to an appropriate on-site storage or treatment facility.
SOPs for handling and sampling IDW are provided in Appendix A.
14.1.4.2 INVESTIGATION-DERIVED WASTE SAMPLING
Soil cuttings, groundwater, and rinse water generated during soil sampling and well installations will be
sampled and analyzed in accordance with disposal requirements for on-base or off-base requirements
depending on available facilities during generation.
For soil cuttings placed in drums, each drum will be opened and scanned using a PID if site-specific COPC
include VOCs. A soil column from each drum will be removed, and a composite sample will be collected
from grab samples from all drums using the following methods when required for waste characterization:
• For non-volatile analyses, sample aliquots will be collected and placed in a new disposable bucket liner
or decontaminated sample bowl and homogenized for 1 minute. One sample will then be collected
directly into the sample container for each analysis.
• For volatile analyses, samples will be collected directly from the sampler and placed in the specified
laboratory container. Sample volume from each drum will be adjusted such that equal volumes will be
used to fill the sample container.

• Samples will be analyzed for site-specific COPC group parameters in accordance with local landfill
requirements. Samples will also be analyzed for reactivity, corrosivity (pH), and ignitability (flashpoint)
as required by the disposal facility.
IDW soil samples will be collected into containers specific for each analysis, as defined in Worksheet #19.
Liquid IDW will be containerized into 30-gallon polyurethane closed-top drums or 55-gallon closed-top
steel drums. Laboratory analytical data for samples collected directly from the drums for characterization
purposes will be utilized for compliance with disposal facility requirements.
Liquid IDW will be sampled as follows:
• A column of water will be collected from each drum using a bottom-loading bailer and placed in a new
disposable bucket liner. One sample will then be collected directly into the sample container for each
analysis, as defined by the analytical method in Worksheet #19, Site-Wide SAP–QAPP.
• For volatile analyses, samples will be collected directly from the sampler and placed in the specified
laboratory container. Sample volume from each drum will be adjusted such that equal volumes will be
used to fill the sample container.
• Samples will be analyzed for site-specific COPC group parameters in accordance with local landfill
requirements. Samples will also be analyzed for reactivity, corrosivity (pH), and ignitability (flashpoint)
as required by the disposal facility.
The contractor will provide a preliminary waste characterization for the containerized IDW based on
Resource Conservation and Recovery Act (RCRA) characteristics, pH, and flashpoint for soil and
groundwater. The analytical data will be reviewed to determine if the waste exhibits a hazardous waste
characteristic as identified by 40 Code of Federal Regulations (CFR), Part 261, Subpart C, and to
recommend a disposal option. The preliminary waste characterization will be submitted to the Bien Hoa
Airbase for review and for waste determination (including determination on whether the IDW is regulated
as a listed hazardous waste).
If wastes are determined to require off-site disposal, after the manifest(s) and other appropriate
documentation is signed by a Bien Hoa Airbase representative, the A&E field team will coordinate the
pickup and provide the transporter with the relevant portions of the manifest on behalf of the Bien Hoa
Airbase. The contractor will provide the Bien Hoa representative with the original generator copy of the
waste manifest subsequent to release of the shipment. The treatment/disposal facility-signed generator
copy should be returned directly to the A&E by the treatment/disposal facility within 30 days of shipment.
The A&E will forward the required copy to the Bien Hoa Airbase and, on behalf of the Airbase, to the
appropriate agency contacts.
14.2 GROUNDWATER MONITORING WELL INSTALLATION

Permanent groundwater MWs will be installed using hollow stem auger (HSA) techniques in accordance
with the MW Construction SOP included in Appendix A. New MWs at the airbase will be installed in the
shallow aquifer to a depth of approximately 5 to 20 m to assess current groundwater conditions at the
site. The actual depth of each well will be determined in the field based on the depth to groundwater and
observed geology.
All groundwater MWs will be:
• Completed as flush mounts with traffic rated vault covers;

• Constructed with 5 cm schedule 40 polyvinyl chloride (PVC) blank casing and 0.010 slot size screen;
• Screened across the water table with approximately 250-cm interval submerged and 100 cm above
groundwater table for shallow wells;
• Developed in accordance with the MW Development SOP in Appendix B to remove sediments and
ensure representative aquifer samples;
• Surveyed for vertical and horizontal location by a certified surveyor, including a groundwater
measurement datum located at the north point of the top of casing, with precision/accuracy of ± 3
cm horizontal and ± 0.3 cm vertical; and
• Secured with a lock after installation.
Groundwater MW construction details are further described in the SOP.
14.2.1 GROUNDWATER ELEVATION MEASUREMENTS

Groundwater elevations will be measured at each groundwater MW that is surveyed to the accuracy
described above at least twice during each sampling event, in accordance with the following procedures
and the SOP in Appendix A:
• Groundwater elevations will be measured for each well on site over a very short timeframe
(approximately 1 hour) to provide a “snapshot” of groundwater elevations across the site. This site-
wide measurement will be conducted each time the site is visited prior to any well purging.
• Groundwater elevations will also be measured immediately before sample purging, following release
of cap pressure and before any sampling activities that will have the potential to affect water levels
within the well to be unrepresentative of the surrounding static water level of the aquifer.
14.2.2 HYDRAULIC CONDUCTIVITY TESTING

Hydraulic conductivity testing (slug testing) will be completed, when determined to be necessary, at the
newly installed MWs to estimate horizontal hydraulic conductivity values, in accordance with the following
procedures and the SOP W-6 “Slug Test Aquifer Testing” in Appendix A.
• The depth to water in each well will be measured with an electronic water level meter prior to
initiating testing activities.
• An appropriate pressure transducer will then be lowered into the MW to approximately 60 cm from
the bottom of the well and the water level in the well allowed to stabilize. The transducer data will
be accessed prior to initiating each test to confirm that the equipment is functioning properly.
• A slug will be used to create the necessary water displacements within each well during the falling and
rising head tests. For the falling head test, the slug will be introduced to the water column, as quickly
as possible, until it is fully submerged.
• A data logger will continuously record water level displacement values using a logarithmic setting for
the initial 10 minutes of each test, followed by a linear setting for the remainder of each test. A test
will be considered complete when the water level in the well has recovered a minimum of 75% from
the initial displacement, as indicated from the real-time data logger readings.
• For the subsequent rising head test, the slug will be removed from the water column, as quickly as
possible, and the resulting displacements continuously recorded with the data logger using the same

frequency of readings as the falling head test. Upon completion of the rising head test and following
re-stabilization of the water table, these falling and rising head test procedures will be immediately
repeated in each monitoring well utilizing the same slug.
14.3 SAMPLING TASKS

The names and locations of the soil borings (SBs), MWs, and vertical groundwater profiles to be sampled
will be described in Worksheet #17. Worksheet #17 will also describe the air samples that will be
collected at the airbase. The samples to be collected will be outlined in Worksheet #18, and the sampling
requirements for each type of analysis (e.g., bottle ware, preservation, and holding time) are listed in
Worksheet #19.
14.3.1 SOIL SAMPLES

Borings will be advanced using direct push technology (DPT) or HSA for soil. Soil samples may also be
collected from test pits. Samples for lithologic description will be obtained at each change in lithology or
at 5-ft intervals, whichever is less. Soil cuttings will be examined for color, odor, and PID readings (as
appropriate) and will be containerized in accordance local requirements.
Soil samples will be collected in accordance with SOPs for “Soil Sampling” and “Subsurface Soil Sampling”
in Appendix A. For each boring or test pit, the location, lithology, drilling information, sample intervals,
and sample description will be logged on a drill log form (Appendix B).
Soil samples collected for analysis will be collected from the site as identified in Worksheet #17.
14.3.2 GROUNDWATER SAMPLES

Groundwater samples will be collected from permanent MWs or as grab samples from SBs that contact
groundwater. MWs will be purged and sampled using low-flow techniques using a low-speed submersible,
bladder, or peristaltic pump with an adjustable flow rate in accordance with the SOP for “MW Sampling
SOP” included in Appendix A. In each well, the pump will be positioned within the middle of the well
screen interval. The purge water discharge will be monitored for the water quality indicator parameters
of temperature, pH, specific conductivity, turbidity, oxidation-reduction potential (ORP), and dissolved
oxygen (DO). Samples will be collected after water quality parameters have stabilized, as described in an
SOP in Appendix A, or after a maximum of 2 hours of low-flow purging. For each well, the water quality
readings for parameter stabilization will be recorded on the groundwater sample log sheet.
Grab samples, if required, will be collected directly from SBs or through direct-push water samples using
mini-bailers or peristaltic pumps. These samples may be collected after initial settling of suspended solids
has occurred. The results will only be used for screening of groundwater for use in optimizing permanent
well locations.
14.3.3 AIR SAMPLES

Air samples will be collected in accordance with an SOP for “Air Sampling SOP” in Appendix A at the site.
14.4 ANALYSIS TASKS

All chemical analyses will be performed by the subcontracted laboratories. Chemical analyses will be
performed in accordance with this Site-Wide SAP–QAPP, the DoD QSM v5.0, and the analytical methods.
The laboratory will meet the LOQs specified in Worksheet #15.

14.5 QUALITY CONTROL SAMPLES
The following field QC samples will be collected for all methods and matrices: field duplicates and
MS/MSDs. Field duplicates will be collected from areas known or suspected to be contaminated. Triple
sample volume will be collected for MS/MSDs from relatively clean sampling locations (e.g., upgradient) to
capture effects of the matrix sampled.
Trip blanks, prepared by the laboratory using water demonstrated to be free of COPC, will be placed in
the cooler used to ship volatile samples (e.g., VOCs). Equipment blanks are only collected if non-dedicated
sampling equipment is used in accordance with an SOP. Equipment blanks will be collected at a frequency
of 10% of investigative samples and analyzed for the same analytes as the samples. A temperature blank
will be placed in each cooler to ensure that samples are preserved at or below 6 degrees Celsius (°C)
during shipment.
Worksheet #20 will specify the number and type of field QC samples as well as the frequency of collection.
14.6 SECONDARY DATA

Secondary data summarized in Worksheet #13 will be reviewed and evaluated for project use. Any
samples collected as screening or secondary samples will not be used for risk assessment purposes.
14.7 DATA MANAGEMENT TASKS

Field forms will be electronically generated and reviewed by the A&E Field Team Leader prior to sample
shipment. The sample handling and custody requirements, including field logs, sample collection
paperwork, sample labels, and custody seals as described in Worksheets #26 and #27 will be followed.
To facilitate the use of the project database, the Data Manager will provide the laboratory with an
electronic file, which contains project sampling event information, the installation, the contract and
delivery order number, the beginning and ending sampling dates, and type of sampling for all samples
collected.
The Project Chemist will track the samples from sample collection, through analysis and data validation.
All final laboratory data will be submitted in a format consistent with Contract Laboratory Program (CLP)-
like deliverables. Data validation will be performed by the A&E Bien Hoa Contractor or a subcontracted
validation firm in accordance with the procedures described in Worksheets #35 and #36. The validator
will review all definitive and summary analytical data and will note any validation findings in data validation
reports. Data validation reports will be submitted as an appendix of the Investigational Report. Validation
qualifiers will be entered into an electronic spreadsheet by the data validator. A 100% QC check will be
performed by the project chemist (or designee) to ensure the accuracy of all hand-entered data (e.g.,
validation flags added during data validation). Sample locations, field measurements, and laboratory
analytical data that will be uploaded into the data management system after data validation.
A master tracking spreadsheet (MS-Excel) will be kept for all project samples collected and analyzed for
each phase of the project. The master tracking spreadsheet assists in making sure all samples collected
are analyzed, reviewed, and approved for use on the project and for payment of laboratory and data
validation services. The master tracking sheet will record the sample date, laboratory analyses specified
on the COC, confirmation the samples were correctly analyzed, laboratory sample processing and
analytical data report due dates, data validation processing and report due dates, laboratory and data
validation invoice numbers and amounts, and when the laboratory and data validation companies are paid.
This spreadsheet will be placed in the data management system available to all team members.

The sample handling and custody paperwork, including field logs, sample collection paperwork, COC
forms, and other field documents will be scanned and placed in the data management system in a folder
called Sample Collection which will be available to all team members. This Sample Collection folder will
contain subfolders for all of the previously mentioned sample collection paperwork. Laboratory data
packages, data validation reports, electronic data deliverables (EDDs) will also be placed in the data
management system in a separate folder named Analytical Data. This folder will contain subfolders for all
of the previously mentioned laboratory data reports and data validation reports and other QC review
files.
The data will be archived to CDs at the end of the project and will be kept for a period of not less than
10 years.
14.8 DOCUMENTATION AND RECORDS

Information regarding field tasks will be recorded on site field logs in accordance with SOPs, “General
Record Keeping” and “Log Books.” Sample collection information will be recorded on individual sample
field forms. Any changes that are made to the field logs or the field forms will be initialed and dated.
Documents will be maintained in project files and will be submitted as an appendix to the report. COC
forms and airbills will also be completed for each sampling event. SOPs for general recordkeeping and
logbooks are provided in Appendix A in an SOP. Field Forms are provided in Appendix B.
14.9 PROJECT SCHEDULE

Table 16-1 shows the tentative schedule of the major project activities to be performed for each
investigation.

WORKSHEET #15 PROJECT ACTION LIMITS AND LABORATORY -
SPECIFIC DETECTION/QUANTITATION LIMITS
These worksheets provide the target analytes, the laboratory’s LOQ/MDL values, and the LCS limits,
where applicable. Investigation results for definitive data will be compared to ARARs (TBD) or PALs.
Please note that the PALs are discussed and presented in Section 11. The ARARs/PALs were determined
by the risk assessors. PAL’s will be different for each appropriate GVN regulation that will apply to various
phases of the overall project, such as soil sampling, sediment sampling, groundwater sampling, run-
off/dewatering water, treatment emissions, and other demobilization wastes.
The target analytes or COPCs are dioxin and arsenic in soil in the example tables presented in this section.
Please note that the detection limit and QC values presented in the tables should be changed for each
project-specific interim measure or task and each laboratory. These revisions will be addressed in the
task-specific Annexes to this site-wide SAP–QAPP.
Where LCS or other control limits are not available, the laboratory’s in-house control limits can be used.
Tables 15-1 through 15-2 provide the definitive data target analyte lists for this example project.

TABLE 15-1. REFERENCE LIMITS AND EVALUATION TABLE FOR DIOXIN AND FURANS, SOIL
Matrix Soil
Analytical Group Dioxin and Furans
USEPA 1613B
Analytical Method
(or equivalent)
Compound CAS Number LOQ MDL Units LCS/LCSD Windows FD/MS/MSD RPD Limit
1234678-HpCDD 35822-46-9 5.00 0.250 ng/kg 70-140 70-140
1234678-HpCDF 67562-39-4 5.00 0.250 ng/kg 82-122 82-122
123478-HxCDD 39227-28-6 5.00 0.250 ng/kg 70-164 70-164
123478-HxCDF 70648-26-9 5.00 0.250 ng/kg 72-134 72-134
1234789-HpCDF 55673-89-7 5.00 0.250 ng/kg 78-138 78-138
123678-HxCDD 57653-85-7 5.00 0.250 ng/kg 76-134 76-134
123678-HxCDF 57117-44-9 5.00 0.250 ng/kg 84-130 84-130
12378-PeCDD 40321-76-4 5.00 0.321 ng/kg 70-142 70-142
12378-PeCDF 57117-41-6 5.00 0.250 ng/kg 80-134 80-134
123789-HxCDD 19408-74-3 5.00 0.250 ng/kg 64-162 64-162
123789-HxCDF 72918-21-9 5.00 0.250 ng/kg 78-130 78-130
234678-HxCDF 60851-34-5 5.00 0.250 ng/kg 70-156 70-156
23478-PeCDF 57117-31-4 5.00 0.250 ng/kg 68-160 68-160
2378-TCDD 1746-01-6 1.00 0.133 ng/kg 67-158 67-158
2378-TCDF 51207-31-9 1.00 0.151 ng/kg 75-158 75-158
OCDD 3268-87-9 10.0 1.38 ng/kg 78-144 78-144
OCDF 39001-02-0 10.0 0.543 ng/kg 63-170 63-170
Notes:
CAS Number – Chemical Abstract Service Registration Number
FD – Field Duplicate
LCS/LCSD – Laboratory Control Sample/Laboratory Control Sample Duplicate
MS/MSD – Matrix Spike/Matrix Spike Duplicate

TABLE 15-2. REFERENCE LIMITS AND EVALUATION TABLE FOR ARSENIC, SOIL
Matrix Soil
Analytical Group Total Arsenic
SW-846 6010D
Analytical Method
(or equivalent)
Compound CAS Number LOQ MDL Units LCS/LCSD Windows FD/MS/MSD RPD Limit
Arsenic 7440-38-2 2.00 0.250 ug/kg 80-120 70-130
Notes:
CAS Number – Chemical Abstract Service Registration Number

WORKSHEET #17 SAMPLING DESIGN AND RATIONALE
Worksheet #17 will be used to discuss the sampling design and rationale for a given annex. The overall
scope of the site evaluation will be discussed including collection of soil, sediment, surface water, air and
groundwater samples as required to support various tasks. These tasks may include site evaluation and
engineering evaluation projects. Analytical data collected as part of this assessment will augment data
provided in the EA (USAID 2016) and other historical data identified in the Introduction to this SAP–
QAPP. This information will be provided in each task-specific Annex to this site-wide SAP–
QAPP. The field samples are identified in Worksheet #18.

WORKSHEET #18 SAMPLING LOCATIONS AND METHODS
Table 18-1 will be used to summarize the investigative samples to be collected. Though the primary
contaminants are dioxins, additional analyses are included in the event that site conditions warrant
evaluation of unknown sources such as underground storage tanks that may be encountered. This
information will be provided in each task-specific Annex to this site-wide SAP–QAPP.
Additional field QC samples are identified in Worksheet #20.

WORKSHEETS #19 AND #30 SAMPLE CONTAINERS, PERSERVATION, AND HOLD TIMES
Table 19-1 & 30-1 summarizes the sample containers, preservation requirements, and holding times for each analytical group.
TABLE 19-1 & 30-1 ANALYTICAL REQUIREMENTS TABLE – WATER
Data Package
Turnaround
Analyte/ Preparation Analytical
Method/SOP Sample (to be
Analyte Matrix Container(s) Preservation Holding Holding
(or equivalent) Volume determined
Group Time1 Time
on task-
specific basis)
EnCore Samplers
SW-846 8260C/ 48 hours to
VOA Soil 15 g or 2-oz glass jar, None, 2-6C 14 days
TBD preserve
no headspace
14 days 14 days
SW-846 8260C/ 3 x 40 mL glass HCl or None, 2- preserved; 7 preserved;
VOA 5 ml Water 120 mL
TBD vials 6C days not 7 days not
preserved preserved
EnCore Samplers
SW-846 8260C/ 48 hours to
VOA Soil 15 g or 2-oz glass jar, None, 2-6C 14 days
TBD preserve
no headspace
14 days 14 days
SW-846 8260C/ 3 x 40 mL glass HCl or None, 2- preserved; 7 preserved;
VOA 5 ml Water 120 mL
TBD vials 6C days not 7 days not
preserved preserved
SW-846 8082A 2 x 250 mL amber
PCBs Water 250 mL None, 2-6C 365 days 40 days
/TBD glass bottle
SW-846 8082A
PCBs Soil 100 g 4- or 8-oz glass jar None, 2-6C 365 days 40 days
/TBD
SW-846 8151A 1,000 2 x 1,000 mL
Herbicides Water None, 2-6C 7 days 40 days
/TBD mL amber glass bottle
SW-846 8151A
Herbicides Soil 100 g 4- or 8-oz glass jar None, 2-6C 14 days 40 days
/TBD
Hydrochloric
Acid to pH < 2,
Immediately 28 Days
Arsenic USEPA 1632 Mod. HDPE, Teflon, stored at 0-6°C
Water 250 mL in the field for from
Speciation /TBD PETG from
As species collection
preservation to
analysis

Data Package
Turnaround
Group Time1 Time
on task-
specific basis)
180 days
Preserve/ship at
from
Arsenic USEPA 1632 Mod. < 6°C. Long-
Solid 4 oz PP Jar 180 days collection,
Speciation /TBD term store at < -
5 days from
11°C
preparation
SO4, Br, Cl,
USEPA 300.0 or F ≤28 days,
Anions Water 50 ml 50 ml plastic vial Cool, 6C NA
SW-846 9056; /TBD NO3, NO2
≤48 hrs
28 days
(nitrite &
Anions Solid USEPA 300.0; /TBD 10 g 50 g Cool, 6C 28 days nitrate 48
hrs post
extraction)
8-oz amber glass
Dioxins/Furans Soil USEPA 1613; /TBD 100 g None, 2-6C 365 days 365 days
jar
1,000 2 x 1,000 mL
Dioxins/Furans Water USEPA 1613; /TBD None, 2-6C 365 days 365 days
mL amber glass bottle
SM3500 FeB-2011; 250 mL amber Cool, 6C, HCl
Ferrous Iron Water 100 ml NA NA
/TBD glass bottle to pH < 2
Metals Water USEPA 200.8/ TBD 250 mL 250 mL plastic HNO3, 2-6C 6 months 6 months
SW-846 6010C/
Metals Soil 100 g 4- or 8-oz glass jar None, 2-6C 6 months 6 months
TBD
SW-846 6010C/
Metals Water 250 mL 250 mL plastic HNO3, 2-6C 6 months 6 months
TBD
SW-846 7471B/
Mercury Soil 100 g 4- or 8-oz glass jar None, 2-6C 28 days 28 days
TBD
SW-846 7470A/
Mercury Water 250 mL 250 mL plastic HNO3, 2-6C 28 days 28 days
TBD
HCL to pH<2;
Dissolved 2 x 40mL glass
Water RSK175/TBD 40 mL Cool, 6C, no 14 days 40 days
Gases vials, no headspace
headspace

Data Package
Turnaround
Group Time1 Time
on task-
specific basis)
Cool, 6C,
Total Organic SM 5310C/USEPA 2 x 40 mL amber
water 40 mL H3PO4 to pH NA 28 days
Carbon 415.1; TBD glass vial
<2
SM 5310B/USEPA
Total Organic
solid 415.1/SW-946 9060; 20 g 4- or 8-oz glass jar Cool, 6C NA 28 days
Carbon
TBD
SW-846 9045C;
pH solid 50 g 4- or 8-oz glass jar Cool, 6C NA NA
TBD
Air Sampling
Dioxins Air Method TO-9/ TBD 1L None 28 days 40 days
Canister
Geotechnical
Soil ASTM Varies Shelby Tube None NA NA
Analyses
Notes:
1
Maximum holding time is calculated from the time the sample is collected to the time the sample is prepared/extracted.
°C – degree Celsius
ASTM – American Society for Testing and Materials
g – gram
HDPE – high-density polyethylene
mL – milliliter
oz – ounce

WORKSHEET #20 FIELD QUALITY CONTROL SUMMARY
Table 20-1 summarizes the field QC samples to be collected and their collection frequency. This information will be provided in each task-specific
Annex to this site-wide SAP–QAPP when ample numbers are known for each analyte.
TABLE 20-1. FIELD QUALITY CONTROL SAMPLE SUMMARY FOR OW004
No. of
No. of No. of Total No. of
No. of Field Equipment No. of No. of Trip
Matrix Analytical Group Sampling Temperature Samples to
Duplicates Rinseate MS/MSDs2 Blanks3
Locations Blanks Laboratory
Blanks1
Minimum 1 per cooler
Sampling Frequency: Minimum 10% Minimum 5% 1 per cooler
10% with VOCs
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
No. – Number

WORKSHEET #21 FIELD SOPS
Table 21-1 summarizes suitable SOPs used for sampling and other field activities that may occur on the project. These SOPs are presented in
Appendix A. Please insert the respective reference number for the SOPs that are necessary for each project.
TABLE 21-1. PROJECT SAMPLING SOP REFERENCES
Modified for
Project
Reference Originating Organization of Equipment Work? SOP
Number1 Title, Revision Date and/or Number Sampling SOP Type (Yes/No) Location
FO-01 Geologic Standards SOP Contractor Investigation Guidance See SOP No Appendix A
FO-02 Site Reconnaissance, Preparation, and Restoration SOP Contractor Investigation Guidance See SOP No Appendix A
FO-03 Utilities Location SOP Contractor Investigation Guidance See SOP No Appendix A
FO-04 Geophysical Survey SOP Contractor Investigation Guidance See SOP No Appendix A
FO-05 Dust Monitoring SOP Contractor Investigation Guidance See SOP No Appendix A
FO-06 Drilling Preparation SOP Contractor Investigation Guidance See SOP No Appendix A
FO-07 Lithologic Logging SOP Contractor Investigation Guidance See SOP No Appendix A
FO-08 Borehole Abandonment SOP Contractor Investigation Guidance See SOP No Appendix A
FO-09 HSA Drilling and Sampling SOP Contractor Investigation Guidance See SOP No Appendix A
FO-10 Direct Push Drilling and Sampling SOP Contractor Investigation Guidance See SOP No Appendix A
FO-11 MW Construction SOP Contractor Investigation Guidance See SOP No Appendix A
FO-12 MW Development SOP Contractor Investigation Guidance See SOP No Appendix A
FO-13 MW Abandonment SOP Contractor Investigation Guidance See SOP No Appendix A
FO-14 Water Level Measurement SOP Contractor Investigation Guidance See SOP No Appendix A
FO-15 Test Pit Excavation SOP Contractor Investigation Guidance See SOP No Appendix A
FO-16 Equipment Decontamination SOP Contractor Investigation Guidance See SOP No Appendix A
FO-17 Waste Handling SOP Contractor Investigation Guidance See SOP No Appendix A
FO-18 Surveying SOP Contractor Investigation Guidance See SOP No Appendix A
FO-19 Aquifer Testing for Hydraulic Parameters SOP Contractor Investigation Guidance See SOP No Appendix A
ES-01 General Water Sampling SOP Contractor Investigation Guidance See SOP No Appendix A
ES-02 MW Sampling SOP Contractor Investigation Guidance See SOP No Appendix A
ES-03 Surface Water Sampling SOP Contractor Investigation Guidance See SOP No Appendix A
Method 5035 Requirements for VOCs in Soil and Contractor Investigation Guidance See SOP No Appendix A
ES-04
Sediments SOP
ES-05 Soil Sampling SOP Contractor Investigation Guidance See SOP No Appendix A
ES-06 Surface Soil Sampling SOP Contractor Investigation Guidance See SOP No Appendix A
ES-07 Subsurface Soil Sampling SOP Contractor Investigation Guidance See SOP No Appendix A
ES-08 Air Sampling SOP Contractor Investigation Guidance See SOP No Appendix A

TABLE 21-1. PROJECT SAMPLING SOP REFERENCES
Modified for
Project
Reference Originating Organization of Equipment Work? SOP
Number1 Title, Revision Date and/or Number Sampling SOP Type (Yes/No) Location
ES-09 Field Headspace Screening SOP Contractor Investigation Guidance See SOP No Appendix A
ES-10 Geotechnical Sampling SOP Contractor Investigation Guidance See SOP No Appendix A
ES-11 Sediment Sampling SOP Contractor Investigation Guidance See SOP No Appendix A
ES-12 Sample Handling SOP Contractor Investigation Guidance See SOP No Appendix A
ES-13 Field Quality Control Samples SOP Contractor Investigation Guidance See SOP No Appendix A
FM-01 General Field Measurement Parameter SOP Contractor Investigation Guidance See SOP No Appendix A
FM-02 Field Equipment Calibration and Quality Control SOP Contractor Investigation Guidance See SOP No Appendix A
FM-03 Equipment Maintenance and Decontamination SOP Contractor Investigation Guidance See SOP No Appendix A
FM-04 Organic and Explosive Vapor Measurement SOP Contractor Investigation Guidance See SOP No Appendix A
FM-05 Groundwater Level Measurement SOP Contractor Investigation Guidance See SOP No Appendix A
FM-06 Immiscible Layer Measurement SOP Contractor Investigation Guidance See SOP No Appendix A
Electrical Conductivity, pH, Temperature, Contractor Investigation Guidance See SOP No Appendix A
FM-07 Oxidation/Reduction Potential and Dissolved Oxygen
Measurement SOP
FM-08 Groundwater Turbidity SOP Contractor Investigation Guidance See SOP No Appendix A
RK-01 General Record Keeping SOP Contractor Investigation Guidance See SOP No Appendix A
RK-02 Log Books SOP Contractor Investigation Guidance See SOP No Appendix A
RK-03 Field Data Forms Contractor Investigation Guidance See SOP No Appendix A
Notes:
1
Reference Number for SOP included in Appendix A, Standard Operating Procedures.

WORKSHEET #22 FIELD EQUIPMENT CALIBRATION, MAINTENANCE, TESTING, AND
INSPECTION
Table 22-1 summarizes commonly used field equipment and details calibration, maintenance, testing, and inspections.
TABLE 22-1. FIELD EQUIPMENT CALIBRATION, MAINTENCE, TESTING, AND INSPECTION
Field
Equipmen Calibration Maintenance Testing Inspection Acceptance Resp. SOP
t Activity Activity Activity Activity Frequency Criteria Corrective Action Person Reference
Field test in Inspect for
Charge battery
accordance external Refer to Refer to See
Hand-held and place in case Any trained
N/A with the damage (e.g., Daily manufacturer’s manufacturer’s Worksheet
GPS unit1 at the end of each field staff
equipment screen dents, instructions. instructions. #21
day.
manual. etc.).
Rental agency to
Perform Measures
Water calibrate quarterly Per See
maintenance per depth-to-liquid Notable Beep; Check battery Any trained
Level to determine the manufacturer’ Prior to use Worksheet
manufacturer’s and total well ±0.01 foot condition field staff
Indicator accuracy of the s instructions. #21
instructions. depth.
measurement.
Calibrate daily If sensor fails to
prior to collecting calibrate, the sensor
Check
water quality data will be cleaned and
operations
according to the Perform a span calibration
Per manual for See
Turbidity manufacturer maintenance per Measures Daily before will be performed, Any trained
manufacturer’ acceptable Worksheet
Meter calibration manufacturer’s turbidity use or the unit will be field staff
s instructions. range of #21
specifications instructions. returned to a
calibrated
developed for the qualified service
probes.
instrument being representative for
calibrated. repairs.
Any trained
Charge batteries.
Check field staff in
Allow the batteries
operations the work
Calibrate for to totally discharge
Screens for manual for zone with
organic vapors before recharging
potential Ensure probe acceptable If meter fails to oversight See
using compressed to prevent battery Daily before
PID volatile tip not range of calibrate, do not use from Lead Worksheet
gas cylinders, per memory from use
compound fouled. calibrated this meter. Safety and #21
manufacturer’s occurring. Perform
concentrations. probe for the Environment
instructions. maintenance per
specific lamp al
manufacturer’s
model. Compliance
instructions.
Specialist

TABLE 22-1. FIELD EQUIPMENT CALIBRATION, MAINTENCE, TESTING, AND INSPECTION
Field
Equipmen Calibration Maintenance Testing Inspection Acceptance Resp. SOP
t Activity Activity Activity Activity Frequency Criteria Corrective Action Person Reference
Within the
Daily pH
specified range
calibration
for pH in the
SOP
Within the
Daily specified range
Calibrate daily Conductivity for If sensor fails to
prior to collecting calibration Conductivity in calibrate, the sensor
water quality data the SOP will be cleaned and
Multi- Measures DO,
according to the Perform Within the a span calibration
Parameter ORP, turbidity, Per See
manufacturer’s maintenance per Daily specified range will be performed, Any trained
Water conductance, manufacturer’ Worksheet
calibration manufacturer’s Temperature for or the unit will be field staff
Quality pH, and s instructions. #21
specifications instructions. calibration Temperature in returned to a
Meter temperature
developed for the the SOP qualified service
instrument being Within the representative for
calibrated. Daily DO specified range repairs.
calibration for DO in the
SOP
Within the
Daily ORP specified range
calibration for ORP in the
SOP
Notes:
1
GPS units will be checked against a known survey point to ensure their accuracy to within ±5 meters prior to their use in the field. Field conditions, such as confining topography, may reduce the
level of accuracy of the GPS. Additional reference points generally consisting of building corners, road intersections, permanent fencing/walls/infrastructure, or other similar structures will be
acquired as local control points for spatial orientation of the GPS.
DO – Dissolved Oxygen
ORP – Oxidation-Reduction Potential
GPS – Global Positioning System

WORKSHEET #23 ANALYTICAL SOPS
Table 23-1 summarizes suitable laboratory analytical SOPs for the project. Specific SOP’s will be presented in the task-specific Annex to this Site-
Wide SAP–QAPP with input from the selected lab for the task.
TABLE 23-1 ANALYTICAL SOP REFERENCES
Definitive Modified for
Organization
Lab SOP or Matrix and Analytical Project
Title Instrument Performing
Number Screening Group Work?
Analysis
Data (Y/N)
VOCs
VOCs and GRO by GC/MS in Waters and
TBD Definitive Water GC/MS VOCs GC/MS TBD N
Wastewaters by USEPA 8260C/D
VOCs and GRO by GC/MS in Soils and Solids by Solid, Tissue GC/MS
TBD Definitive GC/MS TBD N
USEPA 8260C/D VOCs
Organic Solids Preparation
TBD GC/MS Bulk Solid Matrix Sample Preparation N/A SW-846 5030A, 5035A N/A TBD N
Mod.
TBD Balance, Syringe, Pipette Verification N/A Maintenance Balance TBD N
TBD GC and GC/MS Instrumentation Maintenance N/A Maintenance GC/MS TBD N
GC/MS Preventative and Corrective
TBD N/A Maintenance GC/MS TBD N
Maintenance1.
SVOCs
SVOCs by Method 8270D/E in Aqueous and Water, solid, tissue,
TBD Definitive GC/MS TBD N
Non-Aqueous Matrices Using GC-MS leachate GC/MS SVOCs
Separatory Funnel Extraction by Method 3510C
TBD N/A Method 3510C water prep N/A TBD N
for BNAs in Wastewater
Microwave Extraction by Method 3546 for Method 3546 microwave
TBD N/A N/A TBD N
Semivolatiles Soil prep
GC/MS Preventative and Corrective
TBD N/A Maintenance GC/MS TBD N
Maintenance
PCBs
Separatory Funnel Extraction by Method 3510C,
Organic Preparation
TBD 608 or 622 for Pesticides and PCBs in N/A N/A TBD N
Method 3510C
Wastewater
Analysis of PCBs by 8082A in Aqueous Samples
TBD Definitive PCBs GC TBD N
using GC-ECD
TBD PCBs in Solid Samples by 8082A using GC-ECD Definitive PCBs GC TBD N
Microwave Extraction Method 3546 for PCBs in Organic Preparation
TBD N/A N/A TBD N
a Solid Matrix Method 3546

Organization
Analysis
Data (Y/N)
Analysis of Chlorinated Herbicides by 8151A in
TBD Definitive Herbicides GC TBD N
Water
Extraction of Chlorinated Herbicides in a Water Organic Preparation
TBD N/A N/A TBD N
Matrix by SW-846 8151A Method 8151A
Chlorinated Herbicides by 8151A in Solids by
TBD Definitive Herbicides GC TBD N
GC-ECD
Ultrasonic Extraction of Chlorinated Herbicides Organic Preparation
TBD N/A N/A TBD N
by Method 3550B/C in Solids Method 3550C
TBD Preventive and Corrective GC Maintenance N/A Maintenance N/A TBD N
Arsenic
Arsenic Speciation by Hydride-Generation Cryo- Water, Solid HG-CT-
TBD Definitive TBD N
Trapping GC-AAS As Speciation GC-AAS
Anions
Determination of Inorganic anions by Ion
TBD Chromatography in Waters and Soil by USEPA Definitive Water and Solid IC TBD N
300.0, SW 846 9056, and SW 846 9056A
Reagent Water Extraction of Ions in soil, for
TBD analysis by method USEPA 300.0 or SW 846 Definitive Solid IC TBD N
9056
Balances, Syringe, Pipette, and Labware
TBD N/A Maintenance Balance TBD N
Verification
Dioxin and Furans
Determination of Tetra- through Octa-
Chlorinated Dioxins and Furans in
HRGC/HR
TBD water/solid/food/feed samples using Definitive Dioxins and Furans TBD N
MS
HRGC/HRMS by USEPA 1613B or SW-846
8290A
Separatory Funnel Extraction Procedure for
TBD HRMS Analysis in an Aqueous Matrix Using N/A Extraction N/A TBD N
Method 1613B, 8290A, 16681A, and 1668C
Soxhlet Extraction Procedure for HRMS Analysis
TBD in a Solid Matrix by Methods 1613B, 8290A, N/A Extraction N/A TBD N
1668C and 1668A

Organization
Analysis
Data (Y/N)
DFS™ HRGC/HRMS Preventative and
TBD N/A Maintenance N/A TBD N
Corrective Maintenance
Standards Management in the High Resolution
TBD N/A Standards N/A TBD N
Mass Spectrometry Laboratory
Ferrous Iron
Ferrous Iron (Colorimetric) in Waters and Solids
TBD Definitive Water NA TBD N
by Method 3500-Fe B-2011
Metals
Metals by Inductively Coupled Plasma Mass
Spectrometry for SW-846 Methods
TBD Definitive Water ICP/MS TBD N
6020/6020A/6020B (aqueous, solid, tissue), and
USEPA 200.8 (aqueous)
Liquid Inorganic
Digestion by USEPA 200.8 for the Analysis of
TBD N/A Preparation USEPA N/A TBD N
Total Recoverable Metals in Water by ICPMS
200.8 Rev 5.4
Metals by ICP for Methods SW-846 6010/B/C/D
TBD (aqueous, solid, tissue) and USEPA Definitive Solid, liquid, tissues Metals ICP TBD N
200.7(aqueous)
Mercury in Aqueous, Solid, and Tissue Samples
TBD Definitive Solid, liquid, tissues Metals ICP TBD N
by Cold Vapor AA
Solid and tissues Inorganic
Sample Prep of Sediments, Sludges, Soils, and
TBD N/A Preparation SW-846 N/A TBD N
Tissues for Analysis of Metals by ICP and ICP-MS
3050B
Liquid Inorganic
Digestion of Aqueous Samples by SW-846
TBD N/A Preparation SW-846 N/A TBD N
Method 7470A and USEPA 254.1
7470A or 245.1
Solid, tissue, and oil
Preparation of Solids by USEPA 7471A or B for Inorganic Preparation
TBD N/A N/A TBD N
Mercury Analysis SW-846 7471A & SW-846
7471B
Sample Preparation of Waters for the Analysis of Liquid Inorganic
TBD Total Recoverable Metals by Inductively Coupled N/A Preparation SW-846 N/A TBD N
Plasma Optical Emission Spectroscopy 3005A

Organization
Analysis
Data (Y/N)
Volatile Hydrocarbons in Water by Method
Volatile Headspace
TBD RSK-175 Modified and SW-846 8015 Using Definitive GC TBD N
Hydrocarbons
Headspace Sampling Techniques and GC-FID
Maintenance and Troubleshooting Procedures
TBD N/A Maintenance N/A TBD N
for GC/FID Instrumentation
TOC
TOC, DOC, and TIC by SM 5310C or USEPA TOC
TBD Definitive Water TBD N
415.1 in Waters Analyzer
Determination of TOC and TC in Solids and
TOC
TBD Sludges by Combustion by SM 5310B, USEPA Definitive Solid TBD N
Analyzer
415.1, SW-846 9060/9060A
pH by USEPA 9045C, 9045D and Corrosivity by
TBD SW-846 Chap 7 of Solids, Soils and Solvents Definitive Solid pH meter TBD N
using Electrometic Methods
Notes:
DOC – Dissolved Organic Carbon
GC – gas chromatograph
GC/MS – gas chromatograph/mass spectrometer
GC-AAS – gas chromatography-atomic absorption spectrometry
GC-ECD – gas chromatography-electron capture detector
GRO – gasoline range organic
HG-CT-GC-AAS – Hydride Generation-Cyrotrapping-Gas Chromatography-Atomic Absorption Spectrometry
HRGC/HRMS- High Resolution Gas Chromatography/ High Resolution Mass Spectrometry
IC – Ion Chromatograph
ICP/MS – Inductively Coupled Plasma Spectrometry
SVOC – semi volatile organic compound
TC – Total Carbon
TIC – Total Inorganic Carbon
TOC – Total Organic Carbon
VOC – volatile organic compound

WORKSHEET #24 ANALYTICAL INSTRUMENT CALIBRATION
This worksheet describes the calibration procedures and schedule for analytical instruments used on this project. Values provided in Table 24-1
were derived from the DoD QSM v5.0. Any replacement values need to be from a comparable quality source. Specific SOPs and person responsible
will be presented in the task-specific Annex to this Site-Wide SAP–QAPP with input from the selected lab for the task.
TABLE 24-1. ANALYTICAL INSTRUMENT CALIBRATION
SOP
Person
Reference
Responsible
(to be
Calibration Frequency of for CA (to be
Instrument Acceptance Criteria Corrective Action (CA) provided in
Procedure/Range Calibration provided in
task-
task-specific
specific
Annex)
Annex)
Tune with BFB
Retune, injection port
before an ICAL Per ion abundance criteria in
GC/MS Tuning maintenance, clean the source
and every 12 SW-846 method
and/or change the column
hours
The % RSD for each
compound must be ≤ 20% in
Initial Calibration with
order for the average RRF to
minimum 5 points:
be used. 10% of the analytes
Solids and waters - 1
After may fail this criterion. Perform more aggressive
ppb through 300 ppb;
continuing Alternatively, a linear fit or instrument maintenance and
25 mL waters - 0.2
calibration fails quadratic curve (6 pts for recalibrate
ppb through 25 ppb;
quad) fit may be used. The
UST - 0.5 ppb to 200
GC/MS correlation coefficient or
ppb
Volatiles 8260C coefficient of determination
must be ≥ 0.99.
Once per ICAL Position is set using the
Retention Time and at the midpoint standard of the ICAL
Window beginning of the curve when ICAL is NA
Establishment analytical performed. On days with no
sequence ICAL use the initial CCV
Evaluation of Relative
With each RRT of each reported analyte Correct problem, then
Retention Times
sample within ±0.06 RRT units recalibrate
(RRT)
After each All compounds must be Repeat tuning and ICAL

MDL Standard
calibration detected procedure prior to analyzing

SOP
Person
Reference
Responsible
(to be
task-
task-specific
specific
Annex)
Annex)
samples. Repeat maintenance if
needed.
Reanalyze the ICV. If ICV fails

After each again do system maintenance,
ICV Standard % Drift of ≤30% for all analytes
calibration recalibrate, and reanalyze
samples.
Sample analysis must be
suspended and the CCV must
be reanalyzed. If the reanalysis
fails any of the criteria then
adjustments are to be made to
the analytical system to return
it to its original condition,
followed by the analyses of 2
CCV standard Every 12 hours % Drift of ≤20% for all analytes
consecutive CCVs at the same
level that failed. If both CCVs
pass the criteria, then sample
analysis can continue.
Otherwise, the system must
be recalibrated and the
samples reanalyzed, or the
data can be qualified.
Per ion abundance criteria in
Tune with
GC/MS SW-846 method; DDT Retune, injection port
DFTPP before
Semivolatiles GC/MS Tuning breakdown ≤20%; tailing maintenance, clean the source
an ICAL or
8270D factors: benzidine ≤2; and/or change the column
CCV
pentachlorophenol ≤2

SOP
Person
Reference
Responsible
(to be
task-
task-specific
specific
Annex)
Annex)
%RSD for each compound
should be ≤ 20%. A linear fit
can be used if CC is ≥0.99. A
quadratic fit using 6 points can
be used if the COD is 0.≥99. If
a linear calibration is used, the
low calibration is re-fitted back
Initial calibration with
into the curve and the
a minimum 5 points:
recalculated concentration
Solid, tissue and water After Perform more aggressive
of the low calibration point
1000 mL= 0.5 ppm continuing instrument maintenance and
must be within plus or minus
through 120 ppm; calibration fails. recalibrate
30% of the standard’s true
Water 250 mL= 0.125
concentration to verify the
ppm through 30 ppm
linearity of the curve. If more
than 10% of the compounds in
the ICAL exceed 20% RSD
and/or also do not meet the
minimum CC or COD criteria
then the analysis cannot
proceed.
Repeat tuning and ICAL
After each
All compounds must be procedure prior to analyzing
MDL standard initial
detected samples. Repeat maintenance if
calibration
needed.
Once per ICAL Position is set using the
Retention Time and at the midpoint standard of the ICAL
Window beginning of the curve when ICAL is NA
Establishment analytical performed. On days with no
sequence ICAL use the initial CCV
Evaluation of Relative
With each RRT of each reported analyte Correct problem, then
Retention Times
sample within ±0.06 RRT units recalibrate
(RRT)

SOP
Person
Reference
Responsible
(to be
task-
task-specific
specific
Annex)
Annex)
Reanalyze the ICV and samples
associated with the non-
After each
All target compounds ≤30% compliant ICV. If ICV fails
ICV standard initial
drift again do system maintenance,
calibration
recalibrate, and reanalyze
samples.
Reanalyze CCV in duplicate
immediately. If both pass,
samples can be report. If
RF ≥ the recommended
either fails or if immediate
minimum response factor as
reanalysis of CCV in duplicate
defined in the method. No
CCV standard Every 12 hours cannot be performed all
more than 20% of target
samples since acceptable CCV
compounds ≥20% drift, no
must be reanalyzed. If the
target compounds ≥50% drift
CCV fails high any associated
samples that are ND can be
reported.
After % RSD ≤20%, if >20% then Perform more aggressive
a minimum 5 points.
continuing alternate fit linear with instrument maintenance and
Ranges from 50 ug/L
calibration fails correlation coefficient of ≥0.99 recalibrate
to 1000 ug/L
After each Repeat ICAL procedure prior
All compounds must be
Gas MDL Standard initial to analyzing samples. Repeat
detected
Chromatograp calibration maintenance if needed.
hy PCBs 8082A Reanalyze the ICV and samples
Target arochlors +/- 20% of associated with the non-
After each
the nominal concentration and compliant ICV. If ICV fails
ICV Standard initial
within established retention again do system maintenance,
calibration
time windows recalibrate, and reanalyze
samples.

SOP
Person
Reference
Responsible
(to be
task-
task-specific
specific
Annex)
Annex)
Prior to sample
analysis, after
every 20 All samples since acceptable
Target arochlors +/- 20% of
samples or 12 CCV must be reanalyzed. If
CCV Standard (PCB the nominal concentration and
hours, the CCV fails high, any
1016 & 1260) within established retention
whichever associated samples that are
time windows
comes first and ND can be reported.
at the end of
the sequence.
Calibration and QC criteria are
the same for the confirmation
Confirmation of All positive analysis as for primary analysis.
Flag outliers
positive results results RPD for results between
primary and confirmation is
≤40%
a minimum 5 points.
% RSD ≤20%, if >20% then
Ranges from a After Perform more aggressive
alternate fit linear r2 ≥0.99 or
standard at or near continuing instrument maintenance and
quadratic r2 ≥0.99. Must use
the reporting limits calibration fails recalibrate
6 points for quadratic curve.
through 40x the first
Gas level
Chromatograp After each Repeat ICAL procedure prior
hy Herbicides MDL Standard initial to analyzing samples. Repeat
detected
8151A calibration maintenance if needed.
Reanalyze the ICV and samples
Target compounds +/- 15% of associated with the non-
After each
the nominal concentration and compliant ICV. If ICV fails
ICV Standard initial
within established retention again do system maintenance,
calibration
time windows recalibrate, and reanalyze
samples.

SOP
Person
Reference
Responsible
(to be
task-
task-specific
specific
Annex)
Annex)
Prior to sample
Each target compound +/- 15% All samples since acceptable
analysis, after
of the nominal concentration CCV must be reanalyzed. If
every 10 field
CCV Standard (or can use average %Ds) and the CCV fails high, any
samples, and at
within established retention associated samples that are
the end of the
time windows ND can be reported.
sequence.
Calibration and QC criteria are
the same for the confirmation
Confirmation of All positive analysis as for primary analysis.
Flag outliers
positive results results RPD for results between
primary and confirmation is
≤40%
Initial calibration is a Recalibrate, perform
Curve RSD < 20% or
6-point calibration instrument maintenance if
Each new run correlation coefficient ≥0.995,
curve from 0.01-0.5 calibration cannot conform to
Passing ICV
µg/L criteria, recalibrate
Reanalyze the ICV. If criteria
still not met, recalibrate and
After each ±20% of true value for TIAs,
ICV reanalyze. Samples cannot be
calibration ±30% of true value for As3+
reported until ICV criteria
have been met.
HG-CT-GC- Associated samples must be
AAS Immediately reanalyzed. Samples cannot be
ICB < RL
after the ICV reported until ICB criterion is
met.
Result of a spike 2-3x the Re-prep and reanalyze LOQ. If
LOQ Annually current MDL > method blank second failure, redo MDL
mean + 3s study
Reanalyze in duplicate, both
Every 10 ±20% of true value for TIAs, reanalyses must meet criteria.
CCV
samples ±30% of true value for As3+ Reanalyze samples associated
with failing CCV

SOP
Person
Reference
Responsible
(to be
task-
task-specific
specific
Annex)
Annex)
Immediately
after the CCV Associated samples must be
and at a reanalyzed. Samples cannot be
CCB < RL
frequency of reported until CCB criterion
every 10 is met.
samples
a minimum of 5 points
Every 60 days r >0.995; Level 1 standard Perform more aggressive
with a concentration
or when CCV must recover ≥50% of the true instrument maintenance and
span of 15x or 30x
fails value recalibrate
depending on the
analyte
After each Correct problem and
IC Anions
ICB initial No analytes detected > MDL reanalyze the ICB. Recalibrate
300.0 or SW-
calibration if needed.
846 9056
After each
Within +/- 10% of the nominal If ICV fails again do system
ICV initial
concentration maintenance and recalibrate.
calibration
Every 10 Within +/- 10% of the nominal Recalibrate; reanalyze affected
CCV
injections concentration samples
Every 10 Recalibrate; reanalyze affected
CCB No analytes detected > MDL
injections samples
Thermo Fisher Tune with DFS
Tuning of Mass resolution >10,000; mass
Scientific before initial Retune and recalibrate
HRGC/HRMS deviation less than 5 ppm
HRGC/HRMS calibration

SOP
Person
Reference
Responsible
(to be
task-
task-specific
specific
Annex)
Annex)
Dioxins/Furans 1. S/N ratio ≥10
/EPA 1613B 2.Ion abundance ratios within
±15% of theoretical ion
abundance ratios.
3. Absolute retention time for
13C12-1234-TCDD> 25 min.
4. Absolute retention times of
13C12-1234-TCDD must be
within ±15 seconds of the
retention time established in
the ICAL or the RT established
following column maintenance.
Recalibrate, perform
Initial Calibration with After 5. RRT must be within limits
instrument maintenance. If
a minimum of five continuing listed in Table 3 of method
calibration does not meet
standards. calibration fails. 1613B.
method criteria, recalibrate.
6. The quant mass and ratio
mass of a given compound
must maximize within ±2
seconds
7. Native compounds must
elute with -1 to +3 seconds of
the labeled analogue.
1613: % RSD for native
analytes <20% and <35% for
labeled analytes. 8290: % RSD
for native and labeled analytes
within ±20%.
Reanalyze the ICV. If ICV fails
Once with
ICV Target compounds ≤20% drift again do system maintenance
every ICAL
and recalibrate.

SOP
Person
Reference
Responsible
(to be
task-
task-specific
specific
Annex)
Annex)
The start of > 25% chromatographic
Perform column maintenance
CPS every 12-hour resolution of 2,3,7,8-TCDD or
and/or replace the column
shift 2,3,7,8-TCDF
1613: % recoveries per method
Reanalyze the CCV. If CCV
8290: RPDs ±20% of avg RF for
CCV Every 12 hours fails again do system
native compounds and ±30%
maintenance and recalibrate.
for labeled compounds
End of each 12- 8290: RPDs ±25% of avg RF for
Ending CCV (method
hour tune native compounds and ±35%
8290 only)
period for labeled compounds
Initial Calibration with Recalibrate, perform
a minimum 6 points Correlation Coefficient of instrument maintenance if
Quarterly
ranging from 0.0 mg/L >0.995 calibration cannot conform to
to 4.0 mg/L. criteria, recalibrate
Reanalyze the RLV. If RLV fails
Reporting Limit After each
50-150% recovery again do system maintenance
Verification Std (RLV) ICAL
Ferrous Iron by and recalibrate.
Discrete Reanalyze the ICV. If ICV fails
After each
Analyzer: 3500 ICV Standard ±5% D again do system maintenance
ICAL
Fe B-2011 and recalibrate.
Do system maintenance and
ICB Standard After the ICV < MDL
recalibrate
Every 10
CCV Standard ±10% D Reanalyze affected samples
injections
After each
CCB Standard < 1/2 reporting limit Reanalyze affected samples
CCV
No AMU diff. of >0.1 P.W.
≥0.64 and ≥0.66 (Elan 9000) or Perform mass calibration for
ICP/MS: 200.8 Tuning Daily P.W. <0.9 at 10% height AMU. Adjust mass calibration
(Agilent); %RSD <5 for masses for P.W.
used for tuning

SOP
Person
Reference
Responsible
(to be
task-
task-specific
specific
Annex)
Annex)
Initial Calibration
consists of Blank and 1
point: 0 and 10,000
ppb for Al, Ca, Fe, Mg, Recalibrate, perform
K, Na; 0 and 1,000 instrument maintenance if
Each new run Passing ICV and ICB
ppb for As, Ba, Cr, calibration cannot conform to
Co, Cu, Mn, Ni, Ti, V, criteria, recalibrate
Zn; 0 and 100 ppb for
Sb, Be, Cd, Pb. Mo, Se,
Ag, Sr, Tl, Sn
After each
ICV ±10% of true value Reanalyze
calibration
Positive result: accept sample
results >10X the ICB or < 1/2
Immediately RL. Negative result: accept
ICB Less than 3x IDL
after the ICV results >10x ICB. All other
samples must be reanalyzed
with compliant ICB
If the CCV is out of
specification and the result is
Immediately not < - LOQ, accept results
after the ICSAB that report as non-detect for
CCV ±10% of true value
and every 10 the affected analyte(s). Results
samples for the affected analyte(s) ≥ to
the reporting limit must not be
reported (reanalyze).
Immediately results >10X the ICB or < 1/2
after the CCV RL. Negative result: accept
CCB Less than 3x IDL
and every 10 results >10x ICB. All other
samples samples must be reanalyzed
with compliant CCB

SOP
Person
Reference
Responsible
(to be
task-
task-specific
specific
Annex)
Annex)
At the
beginning of
Interference Check each run ± 20% of the true value for
Recalibrate
Sample immediately each analyte
following the
LLC
Beginning of
± 50% of the true value. Not
each sequence
Low Level Check applicable if sample
and before the Reanalyze the sample
(LLC) concentrations are >10x the
interference
true value of the LLC.
check samples
Samples > 90% of the linear
Linear Range Quarterly ±10% of true value range must be reanalyzed as a
dilution
Initial Calibration
consists of Blank and 1
Recalibrate, perform
point: 0 ppm and 50
instrument maintenance if
ppm for Al, Ca, Fe, Each new run Passing ICV and ICB
calibration cannot conform to
Mg, K, Na, S, and Si. 0
criteria, recalibrate
ppm and 1 ppm for all
other metals
If the ICV is out of
ICP: 6010C, specification high for an analyte
and the result is not < - LOQ,
accept results that report as
After each ±10% of true value, RSD must non-detect for affected
ICV
calibration be <5% analyte. Results for the
affected analyte(s) ≤ to the
reporting limit must not be
reported from the run
(reanalyze).

SOP
Person
Reference
Responsible
(to be
task-
task-specific
specific
Annex)
Annex)
results >10X the ICB or < 1/2
Immediately 6010B/C: Less than 3x IDL RL. Negative result: accept
ICB
after the ICV 6010D: <1/2 RL results >10x ICB. All other
samples must be reanalyzed
with compliant ICB
Immediately
after the ICSAB
CCV ±10% of true value Reanalyze
and every 10
samples
Immediately Positive result: accept sample
after the CCV results >10X the ICB or < 1/2
and at a 6010B/C: Less than 3x IDL RL. Negative result: accept
CCB
frequency of 6010D: <1/2 RL results >10x ICB. All other
every 10 samples must be reanalyzed
samples with compliant CCB
At the
± 20% of the true value for
beginning of
each analyte spiked (or
Interference Check each run
6010B/C: <2x RL for analytes Recalibrate
Sample immediately
not spiked; 6010D <RL for
following the
analytes not spiked)
LLC
6010B: N/A if sample
concentration is >10x the true
value of the LLC. For LLC
Beginning of
results > the high limit,
each sequence 6010B: ±50% of true value
Low Level Check samples <RL can be reported.
and before the 6010C: ±30% of true value
(LLC) 6010C/D: N/A if sample
interference 6010D: ±20% of true value
concentration is <LOQ or if
check samples
sample concentrations are >
compliant CCV. Otherwise,
reanalyze the sample

SOP
Person
Reference
Responsible
(to be
task-
task-specific
specific
Annex)
Annex)
Samples > 90% of the linear
Linear Range Quarterly ±10% of true value range must be reanalyzed as a
dilution
Initial Calibration Recalibrate, perform
consists of a Blank and Correlation coefficient (r) instrument maintenance if
Each new run
5 points ranging from >0.995 calibration cannot conform to
0.2 ppb to 5 ppb criteria, recalibrate
If the ICV is out of
specification high report the
elements that are < LOQ.
For elements > LOQ, data
cannot be reported.
CVAA: 7470A,
Reanalyze the ICV, if the
7471B After each
ICV ±10% of true value recovery is acceptable,
calibration
proceed with sample analysis.
If the acceptance criteria are
not met after reanalysis,
redigest and reanalyze the
curve and all associated
samples.
Immediately
ICB No analytes > Reporting Limit Reanalyze
after the ICV

SOP
Person
Reference
Responsible
(to be
task-
task-specific
specific
Annex)
Annex)
If the CCV is out of
specification high and the
sample is not < - LOQ, accept
samples that report as non-
detect. Data bracketing the
CCV cannot be reported from
other samples on the run
Immediately (reanalyze). If the CCV is out
after the CRA of specification, it is read in
CCV ±20% of true value
and every 10 duplicate. If both CCVs are
samples within specification, the data
from the last good CCV is
reanalyzed. If one or both
CCVs are still out of
specification, then the run is
terminated and the samples
after the last good CCV must
be analyzed on a new run
Data bracketing the CCB
cannot be reported from the
run (reanalyze). If the CCB is
out of specification, it can be
Immediately
read in duplicate. If both
after the CCV
CCBs are within specification,
and at a
CCB No analytes > Reporting Limit the data from the last good
frequency of
CCB is reanalyzed. If one or
every 10
both CCBs are still out of
samples
specification, then the run is
terminated and the samples
after the last good CCB must
be reanalyzed on a new run.

SOP
Person
Reference
Responsible
(to be
task-
task-specific
specific
Annex)
Annex)
Immediately ± 50% True Value for 7470; ±
CRA Reanalyze
after the ICB 30% for 7471B
6 points ranging from After Perform more aggressive
%RSD for ICAL ≤20%, linear r2
2 ppb to 500 ppb continuing instrument maintenance and
≥0.99
depending on the calibration fails recalibrate
compound
After each Repeat ICAL procedure prior
MDL Standard initial to analyzing samples. Repeat
detected
Gas calibration maintenance if needed.
Chromatograph Target compounds +/- 15% of
After each Reanalyze the ICV. If ICV fails
y Dissolved the nominal concentration and
ICV Standard initial again do system maintenance
Gases within established retention
calibration and recalibrate.
time windows
Prior to sample For RSK-175: Target
All samples since acceptable
analysis, after compounds +/- 15% of the
CCV must be reanalyzed. If
every 10 field nominal concentration
CCV Standard the CCV fails high, any
samples, and at For SW-846 8015C/D: Target
associated samples that are
the end of the compounds +/- 20% of the
ND can be reported.
sequence. nominal concentration
Monthly or Perform more aggressive
a minimum 6 points
after continuing r2 ≥0.995 instrument maintenance and
ranging from 1.0 ppm
calibration fails recalibrate
to 100 ppm
After each Perform more aggressive
TOC Analyzer:
ICB Standard initial No analytes detected > LOQ instrument maintenance and
TOC, DOC, &
calibration recalibrate
TIC in Water
Within +/- 10% of the nominal
ICV Standard initial again do system maintenance
concentration
calibration and recalibrate.
Total Inorganic Check Within +/- 20% of the nominal All affected samples are
Daily
Standard concentration reanalyzed

SOP
Person
Reference
Responsible
(to be
task-
task-specific
specific
Annex)
Annex)
If instrument is
idle > 4 hours,
after every 10 Within +/- 10% of the nominal All affected samples are
CCV Standard
field samples, concentration reanalyzed
and at the end
of the sequence
If instrument is
idle > 4 hours,
after every 10 All affected samples are
CCB Standard No analytes detected > LOQ
field samples, reanalyzed
and at the end
of the sequence
Monthly or Perform more aggressive
a minimum 4 points
after continuing r2 ≥0.995 instrument maintenance and
ranging from 0.3 mg C
calibration fails recalibrate
to 6 mg C
After each Perform more aggressive
ICB Standard initial No analytes detected > LOQ instrument maintenance and
calibration recalibrate
Within +/- 10% of the nominal
TOC Analyzer: ICV Standard initial again do system maintenance
concentration
TOC, TC, & calibration and recalibrate.
TIC in Soil Repeat ICAL procedure prior
MDL Standard Yearly to analyzing samples. Repeat
detected
maintenance if needed.
If instrument is
idle > 4 hours,
after every 10 Within +/- 10% of the nominal All affected samples are
CCV Standard
field samples, concentration reanalyzed
and at the end
of the sequence

SOP
Person
Reference
Responsible
(to be
task-
task-specific
specific
Annex)
Annex)
If instrument is
idle > 4 hours,
after every 10 All affected samples are
CCB Standard No analytes detected > LOQ
field samples, reanalyzed
and at the end
of the sequence
Each new run Recalibrate, perform
Independent and continuing
and continuing instrument maintenance if
pH solid 3-point calibration calibration verification (CCV)
calibration per calibration cannot conform to
within ±10%. CCB < RL.
10 samples criteria, recalibrate
Tune / Mass At the Resolving power ≥ 10,000 at Retune instrument & verify. Lab Manager /
Resolution Check beginning and m/z=304.9842 & m/z=380.9760 Assess data for impact if end Analyst
(PFK) the end of each + 5ppm of expected mass. resolution is less than 10,000
12-hour period Lock-mass ion between lowest narrate or reinject as
GC/HRMS
of analysis. and highest masses for each necessary.
descriptor and level of
reference ≤ 10% full-scale
deflection.
GC Column Prior to ICAL Peak separation between 1) Readjust windows. Lab Manager /
Performance Check or calibration 2,3,7,8-TCDD and other 2) Evaluate system. Analyst
(CPSM/WDM per verification. TCDD isomers result in a 3) Perform maintenance.
method) valley of ≤ 25%; and 4) Reanalyze CPSM.
identification of all first and last 5) No corrective action is
eluters of the eight homologue necessary if 2,3,7,8-TCDD is
retention time windows and not detected and the % valley
HRGC/HRMS
documentation by labeling (F/L) is greater than 25%.
on the chromatogram; and
absolute retention times for
switching from one
homologous series to the next
≥ 10 seconds for all
components of the mixture.

SOP
Person
Reference
Responsible
(to be
task-
task-specific
specific
Annex)
Annex)
Minimum five-point ICAL prior to RSD ≤ 20% for response Evaluate standard and Lab Manager /
initial calibration for sample analysis, factors for 17 unlabeled instrument response. If Analyst
target analytes, lowest as needed by isomers, ≤ 30% for labeled problem with instrument
concentration the failure of IDA, and ion abundance ratios (autosampler failure, response
standard at or near calibration within limits specified in SOP; poor, etc.) or standards,
the reporting limit. verification, and and S/N ≥ 10:1for target correct as appropriate, then
(ICAL) when a new lot analytes. repeat initial calibration.
is used as a
GC/HRMS
standard
source for calib
verification,
internal
standard or
recovery
standard
solutions.
Second-source Immediately All project analytes within ± Evaluate standards and Lab Manager /
calibration verification following ICAL. 30% of the expected value instrument response. If Analyst
from the ICAL. standard issue, repeat or
GC/HRMS
remake then repeat standard
as appropriate. If still fails,
repeat initial calibration

SOP
Person
Reference
Responsible
(to be
task-
task-specific
specific
Annex)
Annex)
Calibration At the Ion abundance ratios in Correct problem, repeat Lab Manager / WS-ID-0005
Verification (CCV) beginning of accordance with SOP; and RF calibration verification. If fails, Analyst a
each 12-hour (unlabeled standards) within ± repeat ICAL and reanalyze all
period, and at 20%D of average RF from samples analyzed since last
the end of each ICAL; and RF (labeled successful CCV End of Run
analytical standards) within ± 30%D of CCV: If RF (unlabeled
sequence. average RF from ICAL. standards) > ± 20%D and ≤ ±
25%D and/or RF (labeled
standards) > ± 30%D and ≤ ±
35%D of the average RF from
GC/HRMS ICAL use mean RF from
bracketing CCVs to quantitate
impacted samples. If
bracketing CCVs differ by
more than 25% RPD
(unlabeled) or 35% RPD
(labeled), run a new ICAL
within 2 hours, and
requantitate samples.
Otherwise, reanalyze samples
with positive detections.
Notes:
a
The analyst initiates the corrective action and the lab manager and analyst are responsible for the corrective action.
AMU – Atomic Mass Unit
CCB – Continuing Calibration Blank
CCV – Continuing Calibration Verification
CPS – Column Performance Solution
CRA – Cancer Risk Assessment
CVAA – Cold Vapor Atomic Absorption
DOC – Dissolved Organic Carbon
GC/MS – Gas Chromatography/Mass Spectrometry
HG-CT-GC-AAS – Hydride Generation-Cyrotrapping-Gas Chromatography-Atomic Absorption Spectrometry
HRGC/HRMS – High Resolution Gas Chromatography/ High Resolution Mass Spectrometry
ICAL – Instrument Calibrations
ICB – Initial Calibration Blank

ICV – Initial Calibration Verification
IDL – Instrument Detection Limit
LOQ – Limit of Quantification
ND – Non-Detect
RLV – Reporting Limit Verification
RSD – Relative Standard Deviation
TCDD – Tetrachlorinated Dibenzo-p-Dioxin
TIC – Total Inorganic Check

WORKSHEET #25 ANALYTICAL INSTRUMENT AND EQUIPMENT MAINTENANCE,
TESTING, AND INSPECTION
Table 25-1 describes the maintenance, testing, and inspection procedures for commonly used analytical instruments. Suitable laboratory SOP’s
associated with each instrument/analysis is listed in Worksheet #23. Specific SOP’s will be presented in the task-specific Annex to this Site-Wide
SAP–QAPP with input from the selected lab for the task for laboratory-specific instrumentation.
TABLE 25-1. ANALYTICAL INSTRUMENT AND EQUIPMENT MAINTENANCE, TESTING, AND INSPECTION
Inspect
Instrument/ Maintenance Testing ion Acceptance Responsible SOP
Frequency Corrective Action
Equipment Activity Activity Activit Criteria Person Reference
y
1) verify cleanliness of
The reading weights
must be ±0.1% 2) remove balance
or ±0.5mg, from service and place Outside
Annual Daily Check Visual Annual whichever is a call to service firm vendor for
Analytical
Calibration/ with Class 1 inspecti Calibration/ greater. Weight 3) management must calibration/ TBD
Balance
Verification weights on Daily Check must be 1000X evaluate data generated Analyst for
heavier than since last acceptable daily checks
sensitivity of reading to determine
balance. any potential impacts
to data quality
Initial calibration
Visual
or continuing Perform additional
As needed, inspecti
Agilent 6890 calibration maintenance prior to Analysts or
replacement of CCV on of As needed TBD
GC/5973 MSD verification instrument calibration group leaders
components compon
passes method or CCV
ents
criteria
Continuing Daily routine
Agilent 6890 As needed, Initial calibration
calibration Visual maintenance
or 7890 replacement of or continuing
verification inspecti (injection Perform maintenance
GC/5973, components calibration Analysts or
(CCV) and on of port); as again; recalibration if TBD
5975, or 5977 (Injection port; verification group leaders
DFTPP per compon needed for necessary
MSD (or column, ion passes method
12-hour tune ents other
equivalent) source; other) criteria
period components
Gas Injection port Calibration Visual Initial calibration
Perform maintenance TBD
Chromatograp maintenance; Check Inspecti As needed after GC analyst
again DFTPP
h, HP5890, HP ECD maintenance All analytes on maintenance is

Inspect
y
6890, and within +/- within
HP7890 with 20% of the specifications
ECD Detector nominal
concentratio
n and within
established
retention
time
windows
Visual As needed
80-120% for
As needed inspecti maintenance/
Buck Scientific Calibration TIAs
replacement of on of calibration Recalibration Analyst TBD
200 A AAS checks 70-130% for
components compon checks every
As3+
ents 10 injections
Annual Professional
Annual As per vendor's As per vendor's
calibrati calibration
Analytical Annual calibration calibration specifications in specifications in
on and Annual vendor (ISO TBD
balance and maintenance and compliance with compliance with ISO
mainten 17025
maintenance ISO certification certification
ance certified)
Visual As needed 90-110% for
As needed inspecti maintenance/ calibration
Calibration
IC replacement of on of calibration checks (95-105% Recalibration Analyst TBD
checks
components compon checks every for method
ents 10 injections 218.6)
Initial calibration Perform additional
Thermo Injection port,
or calibration maintenance prior to
Fisher column, ion Calibration
Visual As needed verification instrument calibration Analysts TBD
Scientific source, others as Check
passes method or calibration
HRGC/HR/MS needed
specifications verification
Visual As needed
As needed inspecti maintenance/ 90-110% for the
Agilent 7500 Calibration
replacement of on of calibration calibration Recalibration Analyst TBD
CE checks
components compon checks every checks
ents 10 injections

Inspect
y
Visual As needed
Calibration
Agilent 7700X replacement of on of calibration calibration Recalibration Analyst TBD
checks
ents 10 injections
Visual As needed
Thermo 6000 As needed inspecti maintenance/ 90-110% for the
Calibration
Series ICP- replacement of on of calibration calibration Recalibration Analyst TBD
checks
AES components compon checks every checks
ents 10 injections
Visual As needed
Leeman Labs
Hydra II Calibration
replacement of on of calibration calibration Recalibration Analyst TBD
Mercury checks
Analyzer
ents 10 injections
HP5890,
HP6890, or
Agilent 7890 Injection port
Continuing Visual Initial Calibration Perform Maintenance
Gas maintenance;
Calibration Inspecti As Needed within again; recalibrate if Analyst TBD
Chromatograp Column; FID
Check on Specifications necessary
h with Flame maintenance
Ionization
Detector
Visual As needed
As needed inspecti maintenance/ 90-110% for
Calibration
TOC Analyzer replacement of on of calibration calibration Recalibration Analyst TBD
checks
ents 10 injections
Visual As needed
As needed inspecti maintenance/ 90-110% for
Calibration
pH/ISE Meter replacement of on of calibration calibration Recalibration Analyst TBD
checks
ents 10 injections
Physical Physical Initially; prior Correct
GC/HRMS Parameter Setup Reset if incorrect Analyst TBD
check check to DCC Parameters

Inspect
y
Confor
mance
Compliance to
Instrument to Initially; prior Correct the problem
GC/HRMS Tune Check ion abundance Analyst TBD
Performance instrum to DCC and repeat tune check
criteria
ent
tuning.
Notes:
AAS – Atomic Absorption Spectrometry
CE – Cerium
DFTPP – Decafluorotriphenylphosphine
ECD – Electron Capture Detector
FID – Flame Ionization Detector
GC/MS – Gas Chromatography/Mass Spectrometry
HRGC – High Resolution Gas Chromatography
HRMS – High Resolution Mass Spectrometry
IC – Initial Calibration
ICP-AES – Inductively Coupled Plasma/ Atomic Emission Spectroscopy
ISE – Ion-Selective Electrode
ISO – International Organization for Standardization
MSD – Matrix Spike Duplicate
MSD – Matrix Spike Duplicate
TBD – To Be Determined

WORKSHEETS #26 & #27 SAMPLE HANDLING, CUSTODY, AND DISPOSAL
Table 26-1 lists all personnel who are primarily responsible for ensuring proper handling, custody, and storage of field samples from the time of
collection, to laboratory delivery, to sample disposal.
TABLE 26-1 SAMPLE HANDLING SYSTEM
Responsible Person Organization SOP Reference
Sample Collection, Packaging, and Shipment
Sample Collection Sampling Personnel Contractor
Sample Packaging Sampling Personnel Contractor
Coordination of Shipment Sampling Personnel Contractor See Worksheet #21
Completion of COC Sampling Personnel Contractor
Type of Shipment/Carrier: FedEx, UPS, DHL, or Courier Service – Priority Overnight as needed
Sample Receipt and Analysis
Sample Receipt Laboratory Receiving Supervisor
Sample Custody and Storage Laboratory Sample Custodian
Sample Preparation Organic and/or Inorganic Prep Supervisor See Worksheet #23
Sample Determinative Analysis Organic and/or Inorganic Laboratory Analyst
Sample Disposal Analytical Laboratory
Notes:
COC – Chain-of-custody

Worksheet #27 presents the procedures used for sample identification. Sample documentation (labels,
COC, field logbooks, etc.) protocols are presented in Appendix A. Appendix A also includes the
procedures that will be used to maintain sample custody and integrity (e.g., labels, COCs, field logbooks)
and the protocols for sample shipment.
27.1 SAMPLE IDENTIFICATION

Each sample collected will be given a unique sample identifier (ID). A record of all sample IDs will be kept
with the field records and recorded on a COC form. In addition, the sample IDs will be used to identify
and retrieve analytical results from the laboratory, validation, and upload into the database. Sample IDs
will format:
• “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).

If non-dedicated sampling equipment is used, equipment blanks will be collected at a frequency of one per
event per site and analyzed for the same analytes as the samples. Equipment blanks will be designated by
“EB” followed by a date identifier (e.g., BH-EB-040220 for the equipment blank collected on April 2, 2020).
Additional sample volume will be collected and submitted to the laboratory for analysis of MS/MSDs. The
sample ID will be the same as the parent with the addition of MS or MSD; for example, BH-SS014-MW001-
G-1MS and BH-SS014-MW001-G-1MSD. The COCs will designate which sample locations are associated
with the extra volume for MS/MSD analysis. Although the MS/MSDs should not be listed separately on the
COC, the laboratory will make this distinction when they submit the EDD.

WORKSHEET #28 ANALYTICAL QUALITY CONTROL AND CORRECTIVE ACTION
This worksheet identifies the QC samples and their respective acceptance limits for commonly used analytical groups. Values provided in Tables
28-1 through 28-6 were derived from the DoD QSM v5.0. Any replacement values need to be from a comparable quality source.
TABLE 28-1 LABORATORY QC SAMPLES TABLES FOR VOCS BY 6260C, SOIL
Matrix Soil
Sampling SOP
Analytical Method/ SOP SW-846 8260C / WI8236
Reference (or equivalent)
Sampler’s Name
Field Sampling Organization
Analytical Organization TBD
No. of Sample Locations
Person(s)
Method/SOP QC Data Quality Measurement
Responsible for
QC Sample Frequency/Number Acceptance Corrective Action Indicator Performance
Corrective
Limits (DQI) Criteria
Action
If obvious matrix interference
Per sample (including Laboratory Results within
Surrogate Spike report data with a comment. Analyst Accuracy
MS/MSD, LCS, and Blanks) statistical limits acceptance limits
Otherwise, reanalyze.
No analytes
Reanalyze to confirm detections. No analytes detected
detected >1/2 LOQ Accuracy /
1 per prep batch of up to If detects confirm reanalyze >1/2 LOQ or >1/10
Method blanks or >1/10 the Analyst Laboratory
20 samples samples that are not ND or not the amount measured
amount measured in Contamination
>10x the blank value in any sample
any sample
Laboratory
1 per prep batch of up to Accuracy / Bias Results within
MS/MSD statistical limits; Flag outliers Analyst
20 samples / Precision acceptance limits
RPD ≤30%
Analytes in the LCS that fail high
and are ND in the samples can be
reported. For all others
Laboratory
1 per prep batch of up to reanalyze LCS and samples. If it Accuracy / Bias Results within
LCS/LCSD statistical limits; Analyst
20 samples still fails, perform instrument / Precision acceptance limits
RPD ≤30%
maintenance, restart the tune
period and reanalyze all QC and
samples.

TABLE 28-1 LABORATORY QC SAMPLES TABLES FOR VOCS BY 6260C, SOIL
-50% to + 100% of
the area in the
Check the instrument for
associated reference
Internal Per sample (including possible problems and then Results within
standard. RT within Analyst Precision
standards MS/MSD, LCS, and blanks) reanalyze samples. If reinject acceptance limits
30 seconds of RT
confirms, report with a comment.
for associated
reference standard
Notes:
> – greater than
LCS/LCSD – Laboratory Control Sample/ Laboratory Control Sample Duplicate
ND – Non-Detect
RT – Radiographic Testing

TABLE 28-2. LABORATORY QC SAMPLES TABLES FOR VOCS BY 6260C, WATER
Matrix Water
Sampling SOP
Analytical Method/ SOP SW-846 8260C / TBD
Reference (or equivalent)
Sampler’s Name
Person(s)
Measurement
Method/SOP QC Responsible for Data Quality
QC Sample Frequency/Number Corrective Action Performance
Acceptance Limits Corrective Indicator (DQI)
Criteria
Action
If obvious matrix
Surrogate Per sample (including Laboratory statistical interference report data with Results within
Analyst Accuracy
Spike MS/MSD, LCS, and Blanks) limits a comment. Otherwise, acceptance limits
reanalyze.
No analytes
No analytes detected Reanalyze to confirm
detected > 1/2
> 1/2 Reporting Limit detections. If detects
1 per prep batch of up to Accuracy/Laboratory Reporting Limit or
Method blanks or >1/10 the amount confirm reanalyze samples Analyst
20 samples Contamination >1/10 the amount
measured in any that are not ND or not >10x
measured in any
sample the blank value
sample
1 per prep batch of up to Laboratory statistical Accuracy / Bias/ Results within
MS/MSD Flag outliers Analyst
20 samples limits; RPD ≤30% Precision acceptance limits
Analytes in the LCS that fail
high and are ND in the
samples can be reported.
For all others reanalyze LCS
1 per prep batch of up to Laboratory statistical Accuracy / Bias/ Results within
LCS/LCSD and samples. If it still fails, Analyst
20 samples limits; RPD ≤30% Precision acceptance limits
perform instrument
maintenance, restart the
tune period and reanalyze all
QC and samples.
Internal Per sample (including -50% to + 100% of Check the instrument for Results within
Analyst Precision
standards MS/MSD, LCS, and blanks) the area in the possible problems and then acceptance limits

TABLE 28-2. LABORATORY QC SAMPLES TABLES FOR VOCS BY 6260C, WATER
associated reference reanalyze samples. If reinject
standard. RT within confirms, report with a
30 seconds of RT for comment.
standard
Notes:
> – greater than
less than or equal to
ND – Non-Detect

TABLE 28-3. LABORATORY QC SAMPLES TABLES FOR SVOCS BY 6270D, SOIL
Matrix Soil
Analytical Group SVOC
Sampling SOP
SW-846 8270D / TBD
Analytical Method/ SOP Reference
(or equivalent)
Sampler’s Name
Person(s) Measurement
Method/SOP QC Data Quality
QC Sample Frequency/Number Corrective Action Responsible for Performance
Acceptance Limits Indicator (DQI)
Corrective Action Criteria
Per sample (including
Surrogate Laboratory statistical report data with a comment. Results within
MS/MSD, LCS, and Analyst Accuracy
Spike limits Otherwise, re-extract and acceptance limits
Blanks)
reanalyze.
Reanalyze to confirm
No analytes detected No analytes detected
detections. If detects
1 per prep batch of up > RL or >1/10 the Accuracy/Laboratory > RL or >1/10 the
Method blanks confirm re-extract samples Analyst
to 20 samples amount measured in Contamination amount measured in
that are not ND or not >10x
any sample any sample
the blank value
1 per prep batch of up Laboratory statistical Accuracy / Bias/ Results within
to 20 samples limits Precision acceptance limits
Reanalyze LCS and associated
samples. Analytes in the LCS
LCS/LCSD that fail high and are ND in Analyst
the samples can be reported.
All others are re-extracted.
-50% to +100% of
internal standard area
Internal of 12-hour STD. Reanalyze, document if Results within
MS/MSD, LCS, and Analyst Precision
standards RT change ≤30 sec. of confirmed. acceptance limits
blanks)
standard
Notes:
> – greater than

ND – Non-Detect
STD – Standard
SVOCs – Semi-Volatile Organic Compounds

TABLE 28-4. LABORATORY EC SAMPLES TABLES FOR SVOCS BY 6270D, WATER
Matrix Water
Analytical Group SVOC
Sampling SOP
SW-846 8270D / TBD
(or equivalent)
Sampler’s Name
Spike limits Otherwise, retract and acceptance limits
Blanks)
reanalyze.
No analytes detected No analytes detected
detections. If detects confirm
Method 1 per prep batch of up > RL or >1/10 the Accuracy/Laboratory > RL or >1/10 the
re-extract samples that are Analyst
blanks to 20 samples amount measured in Contamination amount measured in
not ND or not >10x the
blank value
Reanalyze LCS and associated
samples. Analytes in the LCS
LCS/LCSD that fail high and are ND in Analyst
the samples can be reported.
All others are re-extracted.
-50% to +100% of
internal standard area
Internal of 12-hour STD. Reanalyze, document if Results within
MS/MSD, LCS, and Analyst Precision
standards RT change ≤30 sec. of confirmed. acceptance limits
blanks)
standard
Notes:
> – greater than

ND – Non-Detect
STD – Standard
SVOCs – Semi-Volatile Organic Compounds

TABLE 28-5. LABORATORY QC SAMPLES TABLES FOR PCBS BY 6082A, SOIL
Matrix Soil
Sampling SOP
8082A / TBD
(or equivalent)
Sampler’s Name

Person(s)
Method/SOP QC
Responsible for Data Quality Measurement
QC Sample Frequency/Number Acceptance Corrective Action
Corrective Indicator (DQI) Performance Criteria
Limits
Action
Surrogate Laboratory report data with a comment. Results within
Spike statistical limits Otherwise, retract and acceptance limits
Blanks)
reanalyze.
No analytes Reanalyze to confirm
detected > RL or detections. If detects confirm No analytes detected >
1 per prep batch of up Accuracy/Laboratory
Method blanks >1/10 the amount retract samples that are not Analyst RL or >1/10 the amount
to 20 samples Contamination
measured in any ND or not >10x the blank measured in any sample
sample value
1 per prep batch of up Laboratory Accuracy / Bias/ Results within
to 20 samples statistical limits Precision acceptance limits
1 per prep batch of up Laboratory high and are ND in the Accuracy / Bias/ Results within
LCS/LCSD Analyst
to 20 samples statistical limits samples can be reported. All Precision acceptance limits
others are re-extracted.
Notes:
> – greater than
ND – Non-Detect
PCBs – Polychlorinated Biphenyls


TABLE 28-6. LABORATORY QC SAMPLES TABLES FOR PCBS BY 6082A, WATER
Matrix Water
Sampling SOP
8082A / TBD
(or equivalent)
Sampler’s Name
Person(s)
Method/SOP Measurement
Responsible for Data Quality
QC Sample Frequency/Number QC Acceptance Corrective Action Performance
Corrective Indicator (DQI)
Limits Criteria
Action
Laboratory report data with a comment. Results within
Surrogate Spike MS/MSD, LCS, and Analyst Accuracy
statistical limits Otherwise, re-extract and acceptance limits
Blanks)
reanalyze.
No analytes Reanalyze to confirm
No analytes detected
detected > RL or detections. If detects confirm
1 per prep batch of up Accuracy/Laboratory > RL or >1/10 the
Method blanks >1/10 the amount re-extract samples that are not Analyst
to 20 samples Contamination amount measured in
measured in any ND or not >10x the blank
any sample
sample value
1 per prep batch of up Laboratory Accuracy / Bias/ Results within
to 20 samples statistical limits Precision acceptance limits
1 per prep batch of up Laboratory high and are ND in the samples Accuracy / Bias/ Results within
LCS/LCSD Analyst
to 20 samples statistical limits can be reported. All others are Precision acceptance limits
re-extracted.
Notes:
> – greater than
MS/MSD- Matrix Spike/Matrix Spike Duplicate
ND – Non-Detect
PCBs – Polychlorinated Biphenyls


TABLE 28-7. LABORATORY QC SAMPLES TABLES FOR HERBICIDES BY 6151A, SOIL
Matrix Soil
Concentration Level low
Sampling SOP
SW-846 8151A / TBD
(or equivalent)
Sampler’s Name
Spike limits Otherwise, re-extract and acceptance limits
Blanks)
reanalyze.
No analytes detected > No analytes detected
detections. If detects confirm
1 per prep batch of up RL or >1/10 the Accuracy/Laboratory > RL or >1/10 the
Method blanks re-extract samples that are not Analyst
to 20 samples amount measured in Contamination amount measured in
ND or not >10x the blank
value
1 per prep batch of up Laboratory statistical high and are ND in the samples Accuracy / Bias/ Results within
LCS/LCSD Analyst
to 20 samples limits can be reported. All others are Precision acceptance limits
re-extracted.
Notes:
> – greater than
ND – Non-Detect

TABLE 28-8. LABORATORY QC SAMPLES TABLES FOR HERBICIDES BY 6151A, WATER
Matrix Water
Sampling SOP
SW-846 8151A / WI9202
(or equivalent)
Sampler’s Name
Eurofins Lancaster Laboratories
Analytical Organization
Environmental, LLC (ELLE)
Method/SOP QC Data Quality Indicator
Acceptance Limits (DQI)
Per sample (including Laboratory statistical report data with a comment. Results within
Surrogate Spike ELLE Analyst Accuracy
MS/MSD, LCS, and Blanks) limits Otherwise, re-extract and acceptance limits
reanalyze.
No analytes detected > Reanalyze to confirm detections. If No analytes detected
1 per prep batch of up to RL or >1/10 the detects confirm re-extract samples Accuracy/Laboratory > RL or >1/10 the
Method blanks ELLE Analyst
20 samples amount measured in that are not ND or not >10x the Contamination amount measured in
any sample blank value any sample
1 per prep batch of up to Laboratory statistical Results within
MS/MSD Flag outliers ELLE Analyst Accuracy / Bias/ Precision
20 samples limits acceptance limits
Analytes in the LCS that fail high
1 per prep batch of up to Laboratory statistical and are ND in the samples can be Results within
LCS/LCSD ELLE Analyst Accuracy / Bias/ Precision
20 samples limits reported. All others are re- acceptance limits
extracted.
Advisory windows of If obvious matrix interference
50-150% recovery of perform a sample dilution and/or
Internal Per sample (including Results within
internal standard area report with a comment about ELLE Analyst Precision
standards MS/MSD, LCS, and blanks) acceptance limits
as compared to the potential bias. Otherwise, re-
closest CCV. extract and reanalyze.
Notes:
> – greater than
ELLE – Eurofins Lancaster Laboratories Environmental
ND – Non-Detect

TABLE 28-9. LABORATORY QC SAMPLES TABLES FOR ARSENIC SPECIATION BY USEPA 1632, SOILD
Matrix Solid
Sampling SOP
EPA 1632 Mod / TBD
(or equivalent)
Sampler’s Name
Method/SOP QC Data Quality Indicator
Acceptance Limits (DQI)
Reanalyze blank to confirm
Accuracy/Laboratory Results within
Method Blank 1 per 10 samples < RL result. If result confirm, redigest EFGS Analyst
Contamination acceptance limits
samples
Reanalyze result and examine
TIAs: 50-150% recovery,
other QC results. An analytical
1 pair per prep batch up to <35% RPD Results within
MS/MSD spike should be analyzed. For EFGS Analyst Accuracy / Bias/ Precision
20 samples As3+: 30-170% recovery, acceptance limits
RPD failures, qualify data or
<35% RPD
analyze additional aliquot...
TIAs: 50-150% recovery,
Reanalyze result for
1 pair per prep batch up to <35% RPD Results within
LCS/LCSD confirmation. If the result EFGS Analyst Accuracy / Bias/ Precision
20 samples As3+: 30-170% recovery, acceptance limits
confirms recalibrate.
<35% RPD
Qualify data where appropriate.
MS/MSD fulfills Results within
Duplicate <35% RPD If qualification is not possible an EFGS Analyst Precision
requirement. acceptance limits
additional aliquot is analyzed.
Notes:
< – less than
EFGS – Eurofins Frontier Global Services
ND – Non-Detect
TlAs – Thallium and Arsenic compound

TABLE 28-10. LABORATORY QC SAMPLES TABLES FOR ARSENIC SPECIATION BY USEPA 1632, WATER
Matrix Water
Sampling SOP
EPA 1632 Mod / TBD
(or equivalent)
Sampler’s Name
Accuracy/Laboratory Results within
Method Blank 1 per 10 samples < RL result. If result confirm, EFGS Analyst
Contamination acceptance limits
redigest samples
Reanalyze result and
TIAs: 50-150%
examine other QC results.
1 pair per prep batch up recovery, <35% RPD Accuracy / Bias/ Results within
MS/MSD For RPD failures, qualify EFGS Analyst
to 20 samples As3+: 30-170% Precision acceptance limits
data or analyze additional
recovery, <35% RPD
aliquot.
TIAs: 50-150%
Reanalyze result for
1 pair per prep batch up recovery, <35% RPD Accuracy / Bias/ Results within
LCS/LCSD confirmation. If the result EFGS Analyst
to 20 samples As3+: 30-170% Precision acceptance limits
confirms recalibrate.
recovery, <35% RPD
Qualify data where
MS/MSD fulfills appropriate. If qualification Results within
Duplicate <35% RPD EFGS Analyst Precision
requirement. is not possible an additional acceptance limits
aliquot is analyzed.
Notes:
< – less than
EFGS – Eurofins Frontier Global Services
ND – Non-Detect

TlAs – Thallium and Arsenic compound
TABLE 28-11. LABORATORY QC SAMPLES TABLES FOR ANIONS BY USEPA 600.0, SOIL
Matrix Soil
Sampling SOP
EPA 300.0 / TBD
(or equivalent)
Sampler’s Name
Method/SOP QC Person(s) Measurement
Data Quality
QC Sample Frequency/Number Acceptance Corrective Action Responsible for Performance
Indicator (DQI)
Limits Corrective Action Criteria
No analytes Reanalyze to confirm No analytes
detected <MDL or detections. If detects detected > 1/2 LOQ
Method 1 per prep batch of up to Accuracy/Laboratory
>1/10 the amount confirm retract samples that Analyst or >1/10 the
blanks 20 samples Contamination
measure in any are not ND or not >10x the amount measured in
sample. blank value any sample
Results within
MS 1 per 10 samples Method limits Flag outliers Analyst Accuracy/Bias
acceptance limits
Reanalyze LCS and
associated samples. Analytes
1 per prep batch of up to in the LCS that fail high and Results within
LCS Method limits Analyst Accuracy/Bias
20 samples are ND in the samples can acceptance limits
be reported. All others are
re-extracted.
Laboratory Results within
Duplicate 1 per 10 samples Flag outliers Analyst Precision
statistical acceptance limits
Notes:
< – less than
> – greater than
MS – Matrix Spike
ND – Non-Detect

TABLE 28-12. LABORATORY QC SAMPLES TABLES FOR ANIONS BY USEPA 600.0, WATER
Matrix Water
Sampling SOP
EPA 300.0/9056 / TBD
(or equivalent)
Sampler’s Name
Reanalyze to confirm No analytes
detections. If detects detected > 1/2 LOQ
1 per prep batch of up to <MDL or >1/10 the Accuracy/Laboratory
Method blanks confirm re-extract samples Analyst or >1/10 the
20 samples amount measure in Contamination
that are not ND or not amount measured in
any sample.
>10x the blank value any sample
Results within
MS 1 per 10 samples Method limits Flag outliers Analyst Accuracy/Bias
acceptance limits
Reanalyze LCS and
associated samples. Analytes
1 per prep batch of up to in the LCS that fail high and Results within
LCS Method limits Analyst Accuracy/Bias
20 samples are ND in the samples can acceptance limits
be reported. All others are
re-extracted.
Results within
Duplicate 1 per 10 samples Laboratory statistical Flag outliers Analyst Precision
acceptance limits
Notes:
< – less than
> – greater than
MS – Matrix Spike
ND – Non-Detect

TABLE 28-13. LABORATORY QC SAMPLES TABLES FOR DIOXINS/FURANS BY USEPA 1613B, SOIL
Matrix Soils
Analytical Group Dioxins/Furans
Sampling SOP
EPA 1613B / TBD
(or equivalent)
Sampler’s Name
Re-extract sample. If the
labeled compound fails high
Per sample (including Results within
Labeled Spike Method Defined and the associated native is Analyst Accuracy
OPR and Blank) acceptance limits
ND, the sample can be
reported.
Re-extract to confirm
detection or report if
detection is less than
2378-TCDF and 2378- 2378-TCDF and
minimum level in Table 2
TCDD <10 pg/l; 2378-TCDD <10
1 per prep batch of up to of USEPA 1613B or one- Accuracy/Laboratory
Method blanks OCDD and OCDF Analyst pg/l; OCDD and
20 samples third the compliance level, Contamination
<100 pg/l; all others OCDF <100 pg/l; all
whichever is greater, or if
<50 pg/l others <50 pg/l
the analyte present in the
method blank is not
detected in the sample.
1 per prep batch of up to
Laboratory statistical Accuracy / Bias/ Results within
LCS/LCSD 20 samples as defined by Flag outliers Analyst
limits; RPD ≤25% Precision acceptance limits
project
1 per prep batch of up to
MS/MSD 20 samples as defined by Flag outliers Analyst
project

TABLE 28-13. LABORATORY QC SAMPLES TABLES FOR DIOXINS/FURANS BY USEPA 1613B, SOIL
Analytes in the OPR that
OPR (Ongoing fail high and are ND in the
1 per prep batch of up to Accuracy / Bias/ Results within
Precision and Method Defined samples can be reported. Analyst
20 samples Precision acceptance limits
Recovery) All others are re-
extracted.
Internal Per sample (including Reanalyze, document if Results within
Method Defined Analyst Precision
Standards OPR and Blank) confirmed. acceptance limits
Notes:
< – less than
MS/MSD – Matrix Spike/ Matrix Sample Duplicate
ND – Non-Detect
OCDD – Octachlorodibenzodioxin
OCDF – Octachlorodibenzofuran
TCDD – Tetrachlorodibenzodioxin
TCDF – Tetrachlorodibenzofuran

TABLE 28-14. LABORATORY QC SAMPLES TABLES FOR DIOXINS/FURANS BY USEPA 1613B, WATER
Matrix Water
Analytical Group Dioxins/Furans
Sampling SOP
EPA 1613B / TBD
(or equivalent)
Sampler’s Name
Re-extract sample. If the
labeled compound fails
Per sample (including Results within
Labeled Spike Method Defined high and the associated Analyst Accuracy
OPR and Blank) acceptance limits
native is ND, the sample
can be reported.
Re-extract to confirm
detection or report if
detection is less than
2378-TCDF and
2378-TCDF and 2378- minimum level in Table 2
2378-TCDD <10
1 per prep batch of up TCDD <10 pg/l; OCDD of USEPA 1613B or one- Accuracy/Laboratory
Method blanks Analyst pg/l; OCDD and
to 20 samples and OCDF <100 pg/l; all third the compliance level, Contamination
OCDF <100 pg/l; all
others <50 pg/l whichever is greater, or if
others <50 pg/l
the analyte present in the
method blank is not
detected in the sample.
1 per prep batch of up
LCS/LCSD to 20 samples as defined Flag outliers Analyst
by project
1 per prep batch of up
MS/MSD to 20 samples as defined Flag outliers Analyst
by project
OPR (Ongoing Analytes in the OPR that
1 per prep batch of up Accuracy / Bias/ Results within
Precision and Method Defined fail high and are ND in the Analyst
to 20 samples Precision acceptance limits
Recovery) samples can be reported.

TABLE 28-14. LABORATORY QC SAMPLES TABLES FOR DIOXINS/FURANS BY USEPA 1613B, WATER
All others are re-
extracted.
Internal Per sample (including Reanalyze, document if Results within
Method Defined Analyst Precision
Standards OPR and Blank) confirmed. acceptance limits
Notes:
< – less than
ND – Non-Detect
OCDF – Octachlorodibenzofuran
TCDD – Tetrachlorodibenzodioxin
TCDF – Tetrachlorodibenzofuran

TABLE 28-15. LABORATORY QC SAMPLES TABLES FOR FERROUS IRON BY 5M 3500
Matrix Water
Analytical Group Ferrous Iron
Sampling SOP
SM 3500 Fe B-2011/ TBD
(or equivalent)
Sampler’s Name
Reanalyze blank to confirm No analytes
detections. If detects detected > LOQ or
1 per prep batch of up to > LOQ or >1/10 the Accuracy/Laboratory
Method blank confirm, reanalyze samples Analyst >1/10 the amount
20 samples amount measured in Contamination
that are not ND or not measured in any
any sample
>10x the blank value. sample
Laboratory statistical
MS/MSD QC windows and Flag outliers Analyst
RPD
Reanalyze LCS and
associated samples.
1 per prep batch of up to Analytes in the LCS that Accuracy / Bias/ Results within
LCS QC windows and Analyst
20 samples fail high and are ND in the Precision acceptance limits
RPD
samples can be reported.
All others are reanalyzed.
1 per prep batch of up to Laboratory statistical Results within
Duplicate Flag data Analyst Precision
20 samples RPD acceptance limits
Notes:
> – greater than
ND – Non-Detect
RPD – Relative Percentage Difference

TABLE 28-16. LABORATORY QC SAMPLES TABLES FOR METALS BY USEPA 200.8, WATER
Matrix Water
Analytical Group Metals
Sampling SOP
EPA 200.8 / TBD
(or equivalent)
Sampler’s Name
No analytes
No analytes detected detected > 1/2 LOQ
> 1/2 LOQ or 2.2x or 2.2x MDL,
detections. If detects
1 per prep batch of up to MDL, whichever is Accuracy/Laboratory whichever is
Method Blank confirm, redigest samples Analyst
20 samples greater, or >1/10 the Contamination greater, or >1/10
that are not ND or not
amount measured in the amount
>10x the blank value.
any sample. measured in any
sample.
Recovery limits - 70-
1 per prep batch of up to Analyze post digestion Accuracy / Bias/ Results within
MS/MSD 130% Analyst
20 samples spike and serial dilution Precision acceptance limits
RPD ≤20%
Analytes in the LCS that
Recovery limits - 85- fail high and are ND in the
LCS/LCSD 115% samples can be reported. Analyst
RPD ≤20% All others are re-digested
and reanalyzed.
1 per prep batch of up to Results within
Duplicate RPD must be ≤20% Flag data Analyst Precision
20 samples acceptance limits
Must be prepared with
each background sample, The percent
Serial Results within
evaluated only when difference must be Flag data Analyst Precision
Dilutions acceptance limits
analyte concentrations ≤10%
are >50x the MDL
Post Digestion Prepare with each No specific action needed Results within
± 15% True Value Analyst Accuracy/Bias
Spike (PDS) background sample unless required by the acceptance criteria

TABLE 28-16. LABORATORY QC SAMPLES TABLES FOR METALS BY USEPA 200.8, WATER
project. PDS is reported
in data package
Internal Must be 60%-125% of Results within
Every sample and QC Reanalyze at a dilution Analyst Precision
Standard the calibration blank acceptance criteria
Notes:
> – greater than
ND – Non-Detect
PDS – Post Digestion Spike

TABLE 28-17. LABORATORY QC SAMPLES TABLES FOR METALS BY 6010C, SOIL
Matrix Soil
Sampling SOP
SW-846 6010C / TBD
(or equivalent)
Sampler’s Name
Person(s)
Measurement
Method/SOP QC Responsible for Data Quality
QC Sample Frequency/Number Corrective Action Performance
Acceptance Limits Corrective Indicator (DQI)
Criteria
Action
Reanalyze blank to
No analytes
No analytes detected confirm detections. If
detected > 1/2 RL
1 per prep batch of up > 1/2 RL or >1/20 the detects confirm, Accuracy/Laboratory
Method Blank Analyst or >1/20 the
to 20 samples amount measured in redigest samples that Contamination
amount measured
any sample are not ND or not
in any sample
>20x the blank value.
1 per prep batch of up Laboratory Statistical; Analyze post digestion Accuracy / Bias/ Results within
MS/MSD Analyst
to 20 samples RPD ≤20% spike and serial dilution Precision acceptance limits
fail high and are ND in
1 per prep batch of up Laboratory Statistical; the samples can be Accuracy / Bias/ Results within
LCS/LCSD Analyst
to 20 samples RPD ≤20% reported. All others Precision acceptance limits
are re-digested and
reanalyzed.
1 per prep batch of up Results within
to 20 samples acceptance limits
The percent
Serial each background Results within
difference must be Flag data Analyst Precision
Dilutions sample, evaluated only acceptance limits
≤10%
when analyte

TABLE 28-17. LABORATORY QC SAMPLES TABLES FOR METALS BY 6010C, SOIL
concentrations are
>50x the MDL
No specific action
6010B: ± 25% True
Post needed unless required Results within
Prepare with each Value
Digestion by the project. PDS is Analyst Accuracy/Bias acceptance
background sample 6010C/D: ± 20%
Spike (PDS) reported in data criteria
True Value
package
Results within
Internal Must be 50%-130% of
Every sample and QC Reanalyze at a dilution Analyst Precision acceptance
Standard the calibration blank
criteria
Notes:
> – greater than
ND – Non-Detect

TABLE 28-18. LABORATORY QC SAMPLES TABLES FOR METALS BY 6010C, WATER
Matrix Water
Sampling SOP
SW-846 6010C / TBD
(or equivalent)
Sampler’s Name
Person(s)
Measurement
QC Method/SOP QC Responsible for Data Quality
Frequency/Number Corrective Action Performance
Sample Acceptance Limits Corrective Indicator (DQI)
Criteria
Action
Reanalyze blank to
No analytes detected No analytes
confirm detections. If
> 1/2 RL or >1/20 detected > 1/2 RL
Method 1 per prep batch of up detects confirm, Accuracy/Laboratory
the amount Analyst or >1/20 the
Blank to 20 samples redigest samples that Contamination
measured in any amount measured
are not ND or not >20x
sample in any sample
the blank value.
1 per prep batch of up Laboratory Analyze post digestion Accuracy / Bias/ Results within
MS/MSD Analyst
to 20 samples Statistical; RPD ≤20% spike and serial dilution Precision acceptance limits
1 per prep batch of up Laboratory the samples can be Accuracy / Bias/ Results within
LCS/LCSD Analyst
to 20 samples Statistical; RPD ≤20% reported. All others are Precision acceptance limits
re-digested and
reanalyzed.
1 per prep batch of up Results within
to 20 samples acceptance limits
The percent
Serial each background Results within
difference must be Flag data Analyst Precision
Dilutions sample, evaluated only acceptance limits
≤10%
when analyte

TABLE 28-18. LABORATORY QC SAMPLES TABLES FOR METALS BY 6010C, WATER
concentrations are
>50x the MDL
No specific action
6010B: ± 25% True
Post needed unless required Results within
Prepare with each Value
Digestion by the project. PDS is Analyst Accuracy/Bias acceptance
background sample 6010C/D: ± 20%
Spike (PDS) reported in data criteria
True Value
package
Must be 50%-130% Results within
Internal
Every sample and QC of the calibration Reanalyze at a dilution Analyst Precision acceptance
Standard
blank criteria
Notes:
> – greater than
ND – Non-Detect

TABLE 28-19. LABORATORY QC SAMPLES FOR METALS HG BY 7471A/B, SOIL
Matrix Soil
Sampling SOP
SW-846 7471A/B / TBD
(or equivalent)
Sampler’s Name
Reanalyze blank to confirm No analytes
No analytes detected >
detections. If detects detected > 1/2 RL
1 per prep batch of up to 1/2 RL or >1/20 the Accuracy/Laboratory
Method Blank confirm, redigest samples Analyst or >1/20 the
20 samples amount measured in any Contamination
that are not ND or not amount measured in
sample
>20x the blank value. any sample
1 per prep batch of up to Laboratory Statistical Accuracy / Bias/ Results within
20 samples Limits; RPD ≤20% Precision acceptance limits
fail high and are ND in the
LCS/LCSD samples can be reported. Analyst
All others are re-digested
and reanalyzed.
Notes:
> – greater than
ND – Non-Detect

TABLE 28-20. LABORATORY QC SAMPLES TABLES FOR METALS HG BY 7470A, WATER
Matrix Water
Sampling SOP
SW-846 7470A / TBD
(or equivalent)
Sampler’s Name
Reanalyze blank to
No analytes detected > confirm detections. If
> 1/2 RL or >1/20
1 per prep batch of up to 1/2 RL or >1/20 the detects confirm, redigest Accuracy/Laboratory
Method Blank Analyst the amount
20 samples amount measured in samples that are not ND Contamination
measured in any
any sample or not >20x the blank
sample
value.
1 per prep batch of up to Laboratory Statistical the samples can be Accuracy / Bias/ Results within
LCS/LCSD Analyst
20 samples Limits; RPD ≤20% reported. All others are Precision acceptance limits
re-digested and
reanalyzed.
Notes:
> – greater than
ND – Non-Detect

TABLE 28-21. LABORATORY QC SAMPLES TABLES
Matrix Water
Analytical Group Dissolved Gases
Concentration Level low
Sampling SOP
RSK175 / TBD
(or equivalent)
Sampler’s Name
Method/SOP Person(s) Measurement
Data Quality
QC Sample Frequency/Number QC Acceptance Corrective Action Responsible for Performance
Indicator (DQI)
Limits Corrective Action Criteria
Reanalyze if outside
Surrogate Per Sample(including Laboratory Results within
limits, if confirmed, Analyst Accuracy
Spike Blanks, LCS/D, MS/D statistical limits acceptance limits
report
No analytes
detected > RL or
Method 1 per prep batch of up to Reanalyze to confirm Accuracy/Laboratory > RL or >1/10 the
>1/10 the amount Analyst
Blanks 15 samples detections Contamination amount measured in
measured in any
any sample
sample
Laboratory
MS/MSD statistical limits, Flag outliers Analyst
RPD ≤30%
Reanalyze LCS and
associated samples.
Laboratory
1 per prep batch of up to Analytes in the LCS Accuracy / Bias/ Results within
LCS/D statistical limits, Analyst
15 samples that fail high and are Precision acceptance limits
RPD ≤20%
ND in the samples can
be reported.
Notes:
> – greater than
ND – Non-Detect


TABLE 28-22. LABORATORY QC SAMPLES TABLES FOR TOTAL ORGANIC CARBON, WATER
Matrix Soil/Sediment
Analytical Group Total Organic Carbon (TOC)
Concentration Level
Sampling SOP
SM 5310B/415.1/SW-946 9060 / TBD
(or equivalent)
Sampler’s Name
Method/SOP QC Corrective Data Quality
QC Sample Frequency/Number Responsible for Performance
Acceptance Limits Action Indicator (DQI)
Reanalyze blank to
No analytes detected > LOQ confirm detections.
> LOQ or >1/10 the
or >1/10 the amount measured If detects confirm,
Method 1 per prep batch of up to Accuracy/Laborator amount measured in
in any sample or 1/10 the re-prep samples Analyst
blanks 20 samples y Contamination any sample or 1/10 the
regulatory limit, whichever is that are not ND or
regulatory limit,
greater not >10x the blank
whichever is greater
value.
Results within
MS 1 per 10 samples Laboratory statistical limits Flag outliers Analyst Accuracy/Bias
acceptance limits
Correct problem,
re-prepare and
LCS Laboratory statistical limits reanalyze the LCS Analyst Accuracy/Bias
and all sample
associated
Results within
Duplicate 1 per 10 samples Laboratory statistical RPD Flag data Analyst Precision
acceptance limits
Notes:
> – greater than
MS – Matrix Sample
ND – Non-Detect

TABLE 28-23. LABORATORY QC SAMPLES TABLES FOR TOTAL ORGANIC CARBON, WATER
Matrix Water
Analytical Group Total Organic Carbon
Concentration Level
Sampling SOP
SM 5310C/EPA 415.1 / TBD
(or equivalent)
Sampler’s Name
No analytes detected Reanalyze blank to No analytes detected
1/2 LOQ or >1/10 the confirm detections. If > LOQ or >1/10 the
1 per prep batch of up to amount measured in any detects confirm, re- Accuracy/Laboratory amount measured in
Method blanks Analyst
20 samples sample or 1/10 the prep samples that are Contamination any sample or 1/10 the
regulatory limit, not ND or not >10x regulatory limit,
whichever is greater the blank value. whichever is greater
Accuracy / Bias/ Results within
MS 1 per 10 samples limits for compounds Flag outliers Analyst
Precision acceptance limits
and RPD
Correct problem, re-
1 per prep batch of up to prepare and reanalyze Accuracy / Bias/ Results within
LCS limits for compounds Analyst
20 samples the LCS and all sample Precision acceptance limits
and RPD
associated
Laboratory statistical Results within
Duplicate 1 per 10 samples Flag data Analyst Precision
RPD acceptance limits
Notes:
> – greater than
MS – Matrix Sample
ND – Non-Detect

TABLE 28-24. LABORATORY QC SAMPLES TABLES FOR PH BY 9045DC, SOILD
Matrix Solid
Analytical Group pH
Concentration Level
Sampling SOP
SW-846 9045D / TBD
(or equivalent)
Sampler’s Name
Correct problem, re-
Laboratory
Laboratory statistical prepare and reanalyze Results within
Control 1 per batch Analyst Accuracy/Bias
window the LCS and all sample acceptance limits
Standard
associated
No corrective action, Results within
Duplicate 1 per 10 samples Laboratory statistical RPD Analyst Precision
matrix related acceptance limits
Notes:

TABLE 28-25. LABORATORY QC SAMPLES TABLES FOR DIXINS BY USEPA 6290, WATER AND SOIL
Matrix Water and Soil
EPA Method 8290 / TBD
(or equivalent)
Person(s)
Data Quality Measurement
Frequency / Method / SOP QC Responsible
QC Sample Corrective Action Indicator Performance
Number Acceptance Limits for Corrective
(DQI) Criteria
Action
Method Blank One per Project-specific criteria, if Verify instrument clean Chemist Accuracy/Bias No target analytes ≥
preparation available. Otherwise, no (evaluate calibration Contamination Reporting Limit.
batch target analytes detected RL blank & samples prior to
or ≥ 20% of the associated method blank), then
regulatory limit or ≥ 5% of reanalyze.
the sample result for the “Totals” are not
analyte, whichever is greater. considered “target
(OCDD is considered a analytes” – no
common laboratory corrective action or
contaminant and treated flagging is necessary for
accordingly). "totals".
Internal Every field % recovery for each IS in the Correct problem, then Lab Manager / Precisions and Meets all USEPA
Standard Spike sample, standard original sample (prior to re-prep and reanalyze Analyst Accuracy/Bias Method
(aka Isotope and QC sample dilutions) must be within 50- the samples with failed requirements 50-
Dilution 120 (tetra- through hexa-) IS. 120 (tetra- through
Analyte) and 40-120 (hepta- and octa- hexa-) and 40-120
). (hepta- and octa-).
Laboratory One pair per Recovery 70-130, RPD 30%. Reanalyze LCS once. If Lab Manager / Accuracy/Bias Method limits of 70-
Control Sample sample acceptable, report. Analyst Contamination 130 for recovery, 30
& Laboratory preparation Otherwise, evaluate for for RPD.
Control Sample batch impact (high bias and
Duplicate non-detects, or sporadic
(LCS/LCSD) marginal exceedance
may be narrated and
reported). If impact too
great, re-prep and
reanalyze the LCS and all
samples in the
associated prep batch
for failed analytes, if

TABLE 28-25. LABORATORY QC SAMPLES TABLES FOR DIXINS BY USEPA 6290, WATER AND SOIL
sufficient sample
material is available.
Notes:
≥ – greater than or equal to

WORKSHEET #29 PROJECT DOCUMENTS AND RECORDS
Table 29-1 identifies project documents and records that will be generated for every aspect of the project. Logbooks will be scanned weekly during
use with .pdf files electronically archived.
TABLE 29-1. PROJECT DOCUMENTS AND RECORDS
Record Generation Verification Storage Location/Archival
Sample Collection, On-Site Analysis, and Data Assessment Documents and Records
Project QA/QC, Scanned PDF copies in the project file. Hard copy (bound notebook)
Site-Wide SAP–QAPP Project Staff
Chemist, COP in the project file. Archived at project closeout.
Lead Health and Safety
Field Logbooks Field Team Lead and Environmental Scanned PDF copies in the project file. Hard copy (bound notebook)
Specialist in the project file. Archived at project closeout.
Field Team Lead Lead Health and Safety
COC Records and Environmental Scanned PDF copies in the project file. Hard copy in the project file.
Specialist Archived at project closeout.
Field Team Lead Lead Health and Safety
Air Bills and Environmental
Specialist Hard copy in the project file. Archived at project closeout.
Electronic Field Data Deliverables Installation Lead and Environmental Loaded in the Field Database, then electronic data deliverables are
Specialist saved in secure project-specific databases.
Various field measurements Field Team and Environmental Recorded in field logbooks, then electronic data deliverables are
Specialist saved in secure project-specific databases.
Field equipment calibration
Field Team and Environmental
information
Specialist Recorded in field logbooks.
Field equipment maintenance records Field Team and Environmental
Specialist Inspected by Installation Lead. Not maintained.
Lead Health and
Safety and
Safety Meeting Attendance Log Field Team Lead
Environmental
Specialist Hard copy in the project file. Archived at project closeout.
Sampling/Drilling Forms Field Team Field Team Lead Scanned PDF copies in the project file, hard copies in logbooks.
Laboratory Forms and Documents
Sample Receipt, Custody, and Tracking Laboratory Receiving Scanned PDF copies in the project file. Hard copy including the full
Field Sampling Team
Records Group data package stored in project file.

TABLE 29-1. PROJECT DOCUMENTS AND RECORDS
Record Generation Verification Storage Location/Archival
Validator Scanned PDF copies in the full data package. Archived at project
Equipment Calibration Logs Laboratory
Project Chemist closeout.
Sample Prep Logs Laboratory
Run Logs Laboratory
Equipment Maintenance, Testing, and Validator Scanned PDF copies in the full data package. Archived at project
Laboratory
Inspection Logs Project Chemist closeout.
Laboratory Forms and Documents
Reported Results for Standards, QC Validator Scanned PDF copies in the full data package. Archived at project
Laboratory
Checks, and QC Samples Project Chemist closeout.
Instrument Printouts (raw data) for
Field Samples, Standards, QC Checks, Laboratory
and QC Samples
Validator Scanned PDF copies in the data validation report. Archived at project
Data Package Completeness Checklists Laboratory
Validator
Sample Disposal Records Laboratory Maintained by the laboratory.
Project Chemist
Validator Scanned PDF copies in the full data package Archived at project
Extraction/Cleanup Records Laboratory
Validator If completed, electronic copy in the project file. Archived at project
Fixed Laboratory Audit Checklists Laboratory
Data Validation Reports Validator Project Chemist PDF copies in the project file. Archived at project closeout.
Electronic Data Deliverables and Electronic data deliverables are saved in secure project-specific
Laboratory Project Chemist
Electronic Log-in Deliverables databases.
Laboratory Accreditation Certificates Laboratory Project Chemist Electronic copy in the project file. Archived at project closeout.
Quality Assurance Manual/Laboratory Laboratory Project Chemist Electronic copy in the project file. Archived at project closeout.
SOPs
Notes:
COC – Chain of Custody
PDF – Portable Document Format
QA – Quality Assurance

WORKSHEET #31, #32, AND #33 ASSESSMENTS AND CORRECTIVE ACTIONS
Table 31-1 identifies the assessments/audits planned for the project.
TABLE 31-1. PLANNED PROJECT ASSESSMENTS
Person(s)
Person(s) Responsible for Person(s) Person(s)
Internal Organization Responsible for Responding to Responsible for Responsible for
Assessment or Performing Performing Assessment Identifying and Monitoring
Type Frequency External Assessment Assessment Findings Implementing CA Effectiveness of CA
Lead Health and Lead Health and
Daily quality A&E
Safety and Safety and
control Daily Internal Contractor Field Team Lead Field Team Lead
Environmental Environmental
assessment Bien Hoa
Specialist Specialist
A&E Lead Health and Field Team Lead Field Team Lead Lead Health and
Review of Field Contractor Safety and Safety and
Daily Internal
Notes/Logbooks Bien Hoa Environmental Environmental
A&E Lead Health and Field Team Lead Field Team Lead Lead Health and
Review of Field
Contractor Safety and Safety and
Instrument Daily Internal
Bien Hoa Environmental Environmental
Calibration
Completed A&E
prior to Contractor Laboratory Project Laboratory Quality
Laboratory
identifying a Internal Bien Hoa Project Chemist Manager or Assurance Manager Project Chemist
Verification
laboratory for designee or designee
the project
1 month and 48 A&E
Facility hours prior to Contractor
Internal PM N/A N/A N/A
Notification start of field Bien Hoa
work
1 month and 48 A&E
Subcontractor hours prior to Contractor
Internal PM N/A N/A N/A
Notifications start of Bien Hoa
sampling
Once prior to A&E Laboratory QA
Laboratory Laboratory QA Program QA
start of field Both Contractor Manager/Project Project Chemist
System Audit Manager Manager
activities Bien Hoa Chemist

Person(s)
Person(s) Responsible for Person(s) Person(s)
Internal Organization Responsible for Responding to Responsible for Responsible for
Assessment or Performing Performing Assessment Identifying and Monitoring
Type Frequency External Assessment Assessment Findings Implementing CA Effectiveness of CA
Laboratory Once during A&E Program QA Program QA Program QA
Program QA
Performance course of the Both Contractor Manager/ Project Manager/ Project Manager/ Project
Manager
Assessment project Bien Hoa Chemist Chemist Chemist
A&E Program QA
Laboratory Data Data Validator/ Laboratory QA Program QA
Once per SDG Both Contractor Manager/ Project
Review Audit Project Chemist Manager Manager
Bien Hoa Chemist
Once prior to Laboratory QA
Laboratory Laboratory QA Program QA
start of field Both Contractor Manager/Project Project Chemist
System Audit Manager Manager
activities Chemist
Laboratory Once during Program QA Program QA Program QA
Program QA
Performance course of the Both Contractor Manager/ Project Manager/ Project Manager/ Project
Manager
Assessment project Chemist Chemist Chemist
Program QA
Laboratory Data Data Validator/ Laboratory QA Program QA
Once per SDG Both Contractor Manager/ Project
Review Audit Project Chemist Manager Manager
Chemist
Notes:
A&E – Architect and Engineering
CA – Corrective Action
QA – Quality Assurance
SDG – Sample Delivery Group

31.1 LABORATORY VERIFICATION
Contracted laboratories that perform analysis on definitive data will be USEPA National Environmental
Laboratory Accreditation Program (NELAP)-accredited for each method specified, or equivalent for the
country they are based in. Laboratory verification consists of ensuring that USEPA NELAP accreditation,
or equivalent for the country they are based in of primary and secondary laboratories have not expired.
In addition, prior to the start of sampling, if any future variances are requested by the laboratories after
the approval of this Site-Wide SAP–QAPP, they will be reviewed and verified that they are acceptable and
meet the DQOs listed in this SAP–QAPP. The stakeholders will review and provide concurrence before
the laboratory variances are approved for use.
Facility Notification
At least one week prior to the start of sampling, the Bien Hoa Airbase will be notified of field activities.
Site access requests require three weeks to process.
Subcontractor Notification
Subcontractors will be notified of the start of field work within a week before field work commences.
They will be required to provide Health and Safety and specialty certifications no later than 1 week before
field work commences. Subcontractors will be provided with the Final Site-Wide SAP–QAPP and a Health
and Safety Plan (HASP) for review and sign-off no later than 1 week before field work commences.
Subcontractors will provide a signature for all employees who will be working on the project verifying
that they have read and understand the requirements of the project.
Field Audits
Prior to start of the project, a visit to the project site will be performed to verify site conditions.
Throughout the duration of the project, field documentation and sample receipt forms will be reviewed
as needed.
Project QA will be a function of the Quality Manager (or designee), who is assigned the authority to
inspect all activities and may stop work if activities detrimental to the quality of the work product are
detected. Project personnel will evaluate compliance of the laboratory QA program and procedures with
the DoD QSM v5.0 requirements. Oversight may include internal and external audits, as needed,
documentation of findings, and reports of corrective action (CA). The Program QA Manager will
coordinate a management review of any deficiencies that are noted.

Table 32-1 describes the sequence of events that include documentation of deficiencies, notification of findings, request for CA, implementation
of CA, and follow-up assessment of the CA’s effectiveness for each assessment/audit performed on the project.
TABLE 32-1. ASSESSMENT FINDINGS AND CORRECTIVE ACTION RESPONSES
Nature of Corrective Individual(s)
Nature of Deficiencies Individual(s) Timeframe of Action Response Receiving Corrective Timeframe for
Assessment Type Documentation Notified of Findings Notification Documentation Action Response Response
Logbooks or 24 hours after 24 hours after
Field Sampling Audit COP (or designee) Written Letter Field Team Lead
nonconformance report audit notification
24 hours after Project Chemist
Field Documentation Nonconformance 24 hours after
Quality Manager document Written Memorandum
Review report Field Team Lead notification
review
COP
Laboratory Quality Manager
Assessment (if Installation Points of 2 weeks after
5 days after Laboratory Project
significant QA/QC Written audit report Contact or their Corrective Action Plan receiving
audit Manager
issues are representative notification
encountered) Laboratory Project
Manager
Notes: Project personnel are identified in Worksheets #4, #7, and #8.
QA/QC – Quality Assurance/Quality Control

32.1 FIELD SAMPLING AUDIT
The Quality Manager may schedule surveillance of field activities at any time to evaluate the execution of
sample collection, identification, and control in the field. The Quality Manager (or designee) may conduct
surveillance of field activities during the project during a scheduled visit. Sampling operations may be
reviewed and compared to the requirements listed in this Site-Wide SAP–QAPP. Use of proper sample
containers, proper handling of samples, and adequate documentation of the sampling operation will be
verified. The surveillance may include observations of COC procedure, field documentations, instrument
calibrations, and field measurements.
32.2 FIELD DOCUMENT REVIEW

Field documents and COC records will be reviewed to ensure that all entries are printed or written in
indelible black or blue ink, dated, and signed. The COC will be reviewed for completeness by the Project
Chemist. A copy of the COC form will be retained by the Project Chemist and kept in the project file
until the completion of the project.
32.3 LABORATORY ASSESSMENT

The primary and secondary laboratories selected for this project must be current on their certification of
accreditation. The contractor may conduct a laboratory assessment if warranted during the project. The
scope of the laboratory assessment by the contractor will be determined based on quality issues
encountered.
32.4 CORRECTIVE ACTION PROCEDURES

The Quality Manager or senior technical staff will document problems and the CAs to provide a complete
record of QA activities and to help identify necessary preventive actions. Non-conformances that affect
the findings or recommendations of the project or that have impacts to work outside of the project will
be reported to Installation Points of Contact or their representative and the Project Team.
If the laboratories encounter issues during the project that may impact data quality, the Laboratory PM
will notify the Project Chemist within 1 business day of discovery to discuss CAs. A written CA plan will
be provided in a timely manner and implemented immediately by the laboratory.

Table 33-1 lists the periodic QA management reports ensuring that managers and stakeholders are updated on project status and the results of
the QA assessments.
Frequency
(daily, weekly monthly, Person(s) Responsible for
Type of Report quarterly, annually, etc.) Projected Delivery Date(s) Report Preparation Report Recipient(s)
Daily Field Report Daily/after start of sampling Daily/after start of sampling Field Team Lead Field Team Lead/COP
Monthly Progress Monthly Monthly COP COP/Deputy COP
Report
Data Usability After all data are generated Submitted with Final Report Project Chemist Quality Manager, COP
Assessment Report and validated
Notes:

WORKSHEET #34 DATA VERIFICATION AND VALIDATION INPUTS
Table 34-1 presents the Data Review Process for Verification (Step I). Verification is a completeness check performed before the data review
process to determine whether the required measurements are collected and all data deliverables (the complete data package) are present. It
involves a review of all data inputs to ensure that they are present. The column titled Internal/External is in relation to the data generator.
TABLE 34-1 VERIFICATION (STEP 1) PROCESS
Internal/ Responsible for
Verification Input Description External Verification
COC forms will be reviewed internally upon their completion and verified against the packed
sample coolers they represent. The shipper’s signature on the COC should be initialed by Project Chemist or
COC forms Internal
the reviewer, a copy of the COC retained in the project file, and the original and remaining designee
copies taped inside the cooler for shipment.
Upon report completion, a copy of all audit reports will be placed in the project file. If CAs
are required, a copy of the documented CA taken will be attached to the appropriate audit
report in the project file. At the beginning of each week, and at the completion of the site COP and Quality
Audit reports Internal
work, project file audit reports will be reviewed internally to ensure that all appropriate CAs Manager
have been taken and that CA reports are attached. If CAs have not been taken, the PM will
be notified to ensure action is taken.
Field notes will be reviewed internally and placed in the project file. A copy of the field
Field notes/logbooks Internal Field Team Leader
notes will be attached to the Final Report.
For samples shipped via courier or by air, the Project Chemist will verify receipt of samples
Sample Receipt Internal Project Chemist
by the laboratory.
Sample log-in information will be reviewed for completeness in accordance with the COC Internal Filed Team Leader
Sample log-in
forms. External Laboratory PM
Laboratory data prior to Laboratory data will be reviewed and verified for completeness against analyses requested on
External Laboratory PM
release the COC forms.
Laboratory data due at
Laboratory data will be verified that the analyses reported are consistent with the analyses
turnaround time listed on Internal Project Chemist
requested on the COC forms.
COC
Laboratory data packages will be verified internally by the laboratory performing the work Laboratory PM or
Laboratory data packages External
for completeness and technical accuracy prior to submittal. designee.
All received data packages will be verified externally by the data validator or project chemist
for completeness. All screening level data and site evaluation/natural
attenuation/geochemical conditions parameters will only undergo Verification (Step I), unless Data Validator and
Laboratory data packages External
otherwise dictated by project requirements. All definitive data will be validated externally Project Chemist
according to the data validation procedures specified in Site-Wide SAP–QAPP Worksheet
#35.

TABLE 34-1 VERIFICATION (STEP 1) PROCESS
Internal/ Responsible for
Verification Input Description External Verification
IDW Disposal Manifests will be reviewed for accuracy and included as an appendix in the
IDW Disposal Manifests Internal Field Team Leader
Final Report.
100 percent of manual entries will be reviewed against the hardcopy information and 10 Field Team Leader
Field and electronic data Internal
percent of electronic uploads will be checked against the hardcopy. and Data Manager
Notes:
IDW – Investigation-Derived Waste

WORKSHEET #35 DATA VERIFICATION PROCEDURES
Table 35-1 presents the Data Review Process for Validation (Step IIa and IIb). Validation procedures and criteria ensure that data are evaluated
properly, completely, and consistently for use in meeting project goals.
Step IIa Validation activities ensure compliance with methods, procedures, and contracts for both sampling and analytical data. Examples of Step
IIa validation activities are listed as follows:
Data Deliverables and Site-Wide SAP–QAPP Sampling Methods and Procedures Standards
Analytical Parameters Field Transcription Communication
COC Analytical Methods and Procedures Audits
Holding Times Validation Flags

QC acceptance criteria (blanks, surrogates, Sample Handling
LCS, MS/MSD, serial dilutions, post digestion
Laboratory Transcription
spikes)
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

TABLE 35-1. VALIDATION (STEP 11A AND 11B) PROCESS
Step
1
IIa/ IIb Validation Input Description Responsible for Validation
Field logbooks will be reviewed weekly for accuracy and completeness associated with each Field Team Leader
IIa Field logbooks
sampling event. The inspection will be documented in daily quality control report. Quality Manager
COC forms will be reviewed daily to ensure that project information, sample analyses Field Team Leader
requested, number of field QC samples collected, and selection of Stage 2B or 3 validation are
Quality Manager
IIa COC forms accurate and in accordance with the requirements in this Site-Wide SAP–QAPP.
COC forms will be reviewed by the validator for completeness and that sample preservations
Data Validator
are in accordance with this Site-Wide SAP–QAPP.
Use of the required sampling methods will be established and any deviations will be noted. The Field team Leader
Sampling Methods
IIa sampling procedures and field measurements will be confirmed to have met performance
and Procedures Quality Manager
criteria and any deviations will be documented.
Laboratory PM
The sample cooler will be checked for compliance with temperature and packaging
IIa Sample receipt Project Chemist or Data
requirements listed in Worksheet #27 of this Site-Wide SAP–QAPP.
Validator
Sample log-in will be reviewed for accuracy against the COC form. Sample log-ins will be Laboratory PM
IIa Sample log-ins reviewed by the project chemist or validator that preservation, temperature, and sample Project Chemist or Data
receipt conditions are in accordance with this Site-Wide SAP–QAPP. Validator
Data reported are compliant with method- and project-specific QC requirements; the
reported information is complete; the information in the report narrative is complete and
accurate; and results are reasonable. Laboratory PM or designee
100 percent of the data comply with the method- and project-specific requirements and that
any deviations or failure to meet criteria are documented in the data package case narrative.
Laboratory data
IIa 100 percent of manual entries are free of transcription errors and manual calculations are
prior to release
accurate; computer calculations are spot-checked to verify program validity; data reported are
compliant with method- and project- specific QC requirements; raw data and supporting
Laboratory PM or designee
materials are complete; spectral assignments are confirmed; descriptions of deviations from
method or project requirements are documented; significant figures and rounding have been
appropriately used; reported values include dilution factors; and results are reasonable.

TABLE 35-1. VALIDATION (STEP 11A AND 11B) PROCESS
Step
1
IIa/ IIb Validation Input Description Responsible for Validation
All data packages will consist of sample results and summary forms for all QC samples. At least
10 percent of the data packages submitted for definitive data will be USEPA Level IV (includes
raw data). For definitive data results, data packages will be evaluated by undergoing data
validation in accordance with USEPA Contract Laboratory Program National Functional
Guidelines for Organic Data Review and using acceptance criteria specified in this SAP–QAPP
Data Validator
which is based on DoD QSM v5.0 (or current version) along with requirements of the
analytical methods. Data validation reports will also be reviewed in conjunction with the
project DQOs and data quality indicators. Data validation reports will include validation of
holding time, sample handling, analytes, analytical methods, and laboratory performance criteria.
Field duplicate and field blanks results will be identified and any outlier will be discussed.
Data validation The remaining 90 percent of the definitive data will undergo Stage 2B data validation, which
IIb
reports includes a verification and validation based on completeness and compliance checks of sample
receipt conditions and both sample-related and instrument-related results. At least 10 percent
of the definitive data (or if anomalies, outliers, or other potential problems are identified during Data Validator
Stage 2B validation) will undergo further evaluation of the dataset, including recalculation of
results, review of chromatograms, discussions with the analytical laboratory personnel, etc. as
warranted.
The following data qualifiers will be used for all validation:
J – Result is estimated
U – Analyte is not detected at or above the stated concentration Data Validator
R – Result is rejected and the data are unusable
UJ – Analyte is not detected, but there is an uncertainty concerning the reported value
Notes:
Project Personnel are identified in Worksheet #7
1
IIa=compliance with methods, procedures, and contracts; IIb=comparison with measurement performance criteria in this Site-Wide SAP-–QAPP
DoD QSM v5.0 – Department of Defense Quality Systems Manual, Version 5.0
DQO – Data Quality Objective
SAP-–QAPP – Sampling and Analysis Plan-Quality Assurance Project Plan

WORKSHEET #36 DATA VALIDATION PROCEDURES
Table 36-1 identifies the criteria that will be used to validate data under Steps IIa and IIb.
TABLE 36-1. ANALYTICAL DATA VALIDATION (STEP 11A AND 11B)
Summary Step
IIa/ IIb Matrix Analytical Group Validation Criteria Data Validator
All except wet chemistry USEPA Methods, DoD QSM v5.0, and USEPA CLP Functional Guidelines for
IIa Soil Data Validator
and geotechnical parameters Data Review.
All except wet chemistry USEPA Methods, DoD QSM v5.0, and USEPA CLP Functional Guidelines for
IIa Water Data Validator
USEPA Method TO-9, DoD QSM v5.0, and the USEPA CLP Functional
IIa Air Dioxins Data Validator
Guidelines for Data Review.
All except wet chemistry USEPA Methods, DoD QSM v5.0, and USEPA CLP Functional Guidelines for Data Validator
IIb Soil
All except wet chemistry USEPA Methods, DoD QSM v5.0, and USEPA CLP Functional Guidelines for Data Validator
IIb Water
USEPA Method TO-9, DoD QSM v5.0, and the USEPA CLP Functional Data Validator
IIb Air Dioxins
Guidelines for Data Review.
Notes:
CLP – Contract Laboratory Program
DoD QSM v5.0 – Department of Defense Quality Systems Manual, Version 5.0

WORKSHEET #37 DATA USABILITY ASSESSMENT
The usability assessment is an evaluation of data based upon the results of data validation and verification
for the decisions being made. In the usability step, reviewers will assess whether the process execution
and resulting data meet quality objectives based on criteria established in this Site-Wide SAP–QAPP. The
usability assessment will consider data from sampling activity, on-site analytical, off-site laboratory, and
validation reports. The usability assessment will be performed by the data assessment team and
documented in the investigation report by the Project Chemist. The data assessment team will consist of
the COP, Quality Manager, Project Chemist, and Database Manager. In addition, other stakeholders may
be involved with the determination of whether data meet project quality objectives (PQOs).
The data assessment team will:
• Identify project requirements and verify field activities were performed in accordance to the SOPs
detailed in Worksheets #14 and #21;
• Review the project DQOs and data validation process detailed in Worksheets #34, #35, and #36;
• Verify that all samples and analytical data collected meet the PQOs;
• Evaluate validated data to assess if they satisfy PQOs (e.g., tolerable limits on decision errors) and are
adequate to make the decision regarding additional investigation for the site; and
• Provide input on the suitability of the results for the purposes intended.
In the Usability Assessment, the team will determine the impacts of any deviations from the planned
procedures documented in this Site-Wide SAP–QAPP, guidance documents, or SOPs, for the following
items:
• Sampling Locations;
• COCs;
• Damaged Samples;
• Holding Times; and
• SOPs and Methods.
In addition, the team will evaluate the possible effects of outliers or anomalous data from the following:
• QC Samples;
• Matrix;
• Meteorological Data and Site Conditions;
• Comparability;
• Completeness;
• Background; and
• Critical Samples.
These considerations for the Usability Assessment are discussed in detail in Section 5.2.3.2 of the SAP–
QAPP Manual (USEPA 2005a). The usability assessment will include an evaluation of the data quality
indicators (precision, accuracy/bias, representativeness, comparability, completeness, and sensitivity). The

impact of any data gaps or deviations from planned procedures will be evaluated. This includes rejected
data based on the results of the data validation process. The usability assessment will evaluate the overall
dataset for the entire site, and any trends, relationships, or correlations will be described.
After the data usability assessment has been performed, data deemed appropriate for use will be presented
in the Final Report. The Final Report will include conclusions and optimization recommendations, as
applicable.

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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

funded by the Ford Foundation Special Initiative on Agent Orange/Dioxin, New York, USA.
Hatfield Consultants Ltd., North Vancouver, BC, Canada; 10-80 Division, Hanoi, Vietnam.
_____. 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;
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Hatfield and Vietnam – Russia Tropical Centre. 2009. Evaluation of Contamination at the Agent Orange
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Ministry of National Defense, Air Defense – Air Force Command, 2019. Report of Environmental
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National Academy of Sciences. 1983. Risk Assessment in the Federal Government: Managing the
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Nevada Division of Environmental Protection. 2015. Technical Guidance for the Calculation of Asbestos
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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
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Thanh Nien News, December 3, 2015.
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Draft Technical Memorandum Site Conceptual Model and Data Gaps Analysis. October 4, 2019.
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_____. 2016. Environmental Assessment of Dioxin Contamination at Bien Hoa Airbase, Final
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_____. 2019. Architect-Engineer Services for Dioxin Remediation at Bien Hoa Airbase Area Project,
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24-28.

APPENDIX A
Field Standard Operating Procedures

SITE-WIDE SAMPLING & ANALYSIS PLAN – QUALITY

ASSURANCE PROJECT PLAN
APPENDIX A: STANDARD OPERATING PROCEDURES
MAY 6, 2020
SITE-WIDE SAMPLING & ANALSIS PLAN –

APPENDIX A: STANDARD OPERATING PROCEDURES

MAY 6, 2020

USA
DISCLAIMER
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

SITE-WIDE SAMPLING & ANALYSIS PLAN–QUALITY ASSURANCE PROJECT PLAN | A-2
A.1.11 MONITORING WELL DEVLOPMENT SOP (FO-12) A-25
A.1.12 MONITORING WELL ABANDONMENT SOP (FO-13) A-26
A.1.13 WATER LEVEL MEASUREMENT SOP (FO-14) A-28
A.1.14 TEST PIT EXCAVATION SOP (FO-15) A-29
A.1.15 EQUIPMENT DECONTAMINATION SOP (FO-16) A-29
A.1.15.1 Heavy Equipment Decontamination A-29
A.1.15.2 Instrument and Reusable Sampling Equipment Decontamination A-29
A.1.16 WASTE HANDLING SOP (FO-17) A-30
A.1.16.1 IDW Sampling A-31
A.1.17 SURVEYING SOP (FO-18) A-32
A.1.18 AQUIFER TESTING FOR HYDRAULIC PARAMETERS SOP (FO-19) A-32
A.1.18.1 Slug Testing A-33
A.1.18.1.1 Pre-Field Procedures A-33
A.1.18.1.2 Field Procedures A-34
A.1.18.1.3 Test Analyses Procedures A-34
A.1.18.2 Specific Capacity Step – Drawdown Pump Test A-34
A.1.18.2.1 Field Procedures A-35
A.1.18.3 Test Analyses Procedures A-36
A.2 ENVIRONMENTAL SAMPLING A-38
A.2.1 GENERAL WATER SAMPLING SOP (ES-01) A-38
A.2.2 MONITORING WELL SAMPLING SOP (ES-02) A-39
A.2.2.1 Purging Prior To Sampling A-40
A.2.2.1.1 Low-Flow/Volume Purging Procedures A-40
A.2.2.2 Purging Wells With In-Place Plumbing A-41
A.2.2.3 Purging Temporary Monitoring Wells A-42
A.2.2.4 Groundwater Sampling Collection From Wells A-42
A.2.2.5 Sampling WElls With In-Place Plumbing A-43
A.2.2.6 Sampling WElls WIthout Plumbing A-43
A.2.3 SURFACE WATER SAMPLING SOP (ES-03) A-44
A.2.4 METHOD 5035 REQUIREMENTS FOR VOCS IN SOIL AND SEDIMENT SOP (ES-04) A-46
A.2.5 SOIL SAMPLING SOP (ES-05) A-46
A.2.5.1 Manual Collection Techniques and Equipment A-47

A.2.5.2 Surface Soil Sampling SOP (ES-06) A-47
A.2.6 SUBSURFACE SOIL SAMPLING SOP (ES-07) A-48
A.2.6.1 Powered Sampling Devices A-48
A.2.6.1.1 Split-Spoon Samples A-49
A.2.6.2 Backhoe Soil (TEST PIT) Sampling A-50
A.2.7 AIR SAMPLING SOP (ES-08) A-51
A.2.7.1 Ambient Air Monitoring A-51
A.2.7.2 Worker Exposure Monitoring A-51
A.2.8 FIELD HEADSPACE SCREENING SOP (ES-09) A-52
A.2.9 GEOTECHNICAL SAMPLING SOP (ES-10) A-52
A.2.10 SEDIMENT SAMPLING SOP (ES-11) A-53
A.2.11 SAMPLE HANDLING SOP (ES-12) A-53
A.2.11.1 Sample Containers A-53
A.2.11.2 Sample Volumes, Container Types, and Perservation Requirements A-54
A.2.11.3 Sample Identification A-54
A.2.11.4 Sample Labels A-54
A.2.11.5 Sample Documentation A-54
A.2.11.5.1 Field Log Book A-55
A.2.11.5.2 Sample Custody A-55
A.2.11.6 Sample Shipment A-56
A.2.12 FIELD QUALITY CONTROL SAMPLES (ES-13) A-57
A.2.12.1 Equipment Blank A-57
A.2.12.2 Trip Blank A-57
A.2.12.3 Field Duplicates A-58
A.2.12.4 Matrix/Matrix Spike Duplicates A-58
A.3 FIELD MEASUREMENTS A-59
A.3.1 GENERAL FIELD MEASUREMENT PARAMETERS SOP (FM-01) A-59
A.3.2 FIELD EQUIPMENT CALIBRATION AND QUALITY CONTROL SOP (FM-02) A-59
A.3.2.1 Calibration Frequencies A-59
A.3.2.2 Calibration Procedures A-59
A.3.2.2.1 Photoionization Detector A-59
A.3.2.2.2 Electrical Conductivity, PH, Temperature, Dissolved Oxygen,
and Turbidity A-59

A.3.2.3 Field Quality Assurance/Quality Control Program A-60
A.3.2.3.1 Control Parameters A-60
A.3.2.3.2 Control Limits A-60
A.3.2.3.3 Corrective Action A-60
A.3.3 EQUIPMENT MAINTENANCE AND DECONTAMINATION SOP (FM-03) A-60
A.3.4 ORGANIC AND EXPLOSIVE VAPOR MEASUREMENT SOP (FM-04) A-60
A.3.5 GROUNDWATER LEVEL MEASUREMENT SOP (FM-05) A-61
A.3.6 IMMISCIBLE LAYER MEASUREMENT SOP (FM-06) A-61
A.3.7 ELECTRICAL CONDUCTIVITY, PH, TEMPERATURE, OXIDATION/REDUCTION
POTENTIAL AND DISSOLVED OXYGEN MEASUREMENT SOP (FM-07) A-61
A.3.8 GROUNDWATER TURBIDITY SOP (FM-08) A-62
A.4 RECORD KEEPING A-63
A.4.1 GENERAL RECORD KEEPING SOP (RK-01) A-63
A.4.2 LOG BOOKS SOP (RK-02) A-63
A.4.3 FIELD DATA FORMS SOP (RK-03) A-64
A.5 REFERENCES A-66

< Less Than mL milliliter
> Greater Than MS/MSD Matrix Spike/Matrix Spike Duplicate
% Percent mV millivolt
± Plus or Minus MW Monitoring Well
°C degree Celsius N Standard Penetration Test Result
µg/kg microgram per kilogram NAPL Non-Aqueous Phase Liquid
ASTM American Society for Testing and NTU Nephelometric Turbidity Unit
Materials
BGS below ground surface OD Outside Diameter
CA Corrective Action ORP Oxidation/Reduction Potential
cm centimeter oz ounce
cm/sec centimeter per second PAH Polycyclic Aromatic Hydrocarbon
COC Chain of Custody pH Measure of acidity/basicity in aqueous
solution
DNAPL Dense Non-Aqueous Phase Liquid PID Photoionization Detector
DOT Department of Transportation PM Project Manager
DO Dissolved Oxygen PPE Personal Protective Equipment
DQO Data Quality Objective PVC Polyvinyl Chloride
EB Equipment Blank QA Quality Assurance
EC Electrical Conductivity QC Quality Control
ft foot/feet RCRA Resource Conservation and Recovery Act
g/cm3 grams per cubic centimeter Sc Specific Capacity
gal gallon SOP Standard Operating Procedure
gal/day gallons per day SP Spontaneous Potential
gal/day/ft gallons per day per foot SVOC Semi-volatile organic compound
GPR ground penetrating radar SWL Static Water Level
GPS global positioning system TCLP Toxicity Characteristic Leaching Procedure
HASP Health and Safety Plan UFP–QAPP Uniform Federal Policy – Quality Assurance
Project Plan
HSA hollow-stem auger U.S. United States
ID Inside Diameter USCS Unified Soil Classification System
IDW Investigation-Derived Waste USEPA United States Environmental Protection
Agency
lbs/gal pounds per gallon VOA Volatile Organic Analysis
LNAPL light non-aqueous phase liquid VOC Volatile Organic Compound

A.1 INTRODUCTION
Standard Operating Procedures (SOPs) are in place for the project team to follow for routine activities.
The SOPs provide step-by-step methods to ensure procedures are conducted consistently and in
reproducible means by anyone conducting a given procedure. If a new task is required that does not have
an established SOP, one will be written and approved by the appropriate stakeholders. If an SOP cannot
be followed due to field conditions or other situations, the variance will be documented in the field logs
as well as in final documentation.
A.1.1 GEOLOGIC STANDARDS SOP (FO-01)
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."

Table A-1. Symbol Chart
Group
Major Divisions Group Name
Symbol
gravel clean gravel well-graded gravel, fine to coarse
GW
> 50% of <5% smaller gravel
coarse fraction than #200 Sieve GP poorly graded gravel
Coarse grained
retained on GM Silty gravel
soils gravel with
No. 4 (4.75
more than 50% >12% fines GC clayey gravel
mm) sieve
retained on or
sand SW well-graded sand, fine to coarse sand
above No.200 clean sand
≥ 50% of SP poorly graded sand
(0.075 mm) sieve
coarse fraction SM silty sand
sand with >12%
passes No.4
fines SC clayey sand
sieve
silt and clay ML silt
inorganic
liquid limit < CL clay of low plasticity, lean clay
50 organic OL organic silt, organic clay
Fine grained soils
silt and clay
50% or more
liquid limit < MH silt of high plasticity, elastic silt
passing the inorganic
50
No.200 sieve
silt and clay CH clay of high plasticity, fat clay
liquid limit ≥
organic OH organic clay, organic silt
50
Highly organic soils Pt peat
A.1.2 SITE RECONNAISSANCE, PREPARATION AND RESTORATION SOP (FO-02)
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

current Airbase procedures for obtaining dig permits and utility clearances are followed. In addition, any
fieldwork activities along active flight line corridors or other controlled access areas will require close
coordination with the COR to obtain access approval before fieldwork is initiated.
A centralized decontamination area shall be provided for drilling rigs and equipment. The decontamination
area shall be large enough to allow storage of cleaned equipment and materials prior to use, as well as to
stage drums of decontamination waste. Smaller decontamination areas for personnel and portable
equipment shall be provided as necessary. A designated location has been provided for the field office at
the west end of the aircraft taxiway at the intersection between Pacer Ivy Decision Units PI-2 and PI-5.
Efforts shall be made to minimize impacts to work sites and sampling locations, particularly those in or
near sensitive environments such as wetlands and open water bodies. Following the completion of work
at a site, all drums, trash, and other waste shall be removed and disposed of properly. Decontamination
and/or purge water and soil cuttings shall be transported to the designated locations, as described in the
Uniform Federal Policy – Quality Assurance Project Plan (UFP–QAPP).
Each work site or sampling location shall be returned to its original condition when possible. Site
restoration shall be coordinated with the COR and the Airbase to ensure that site restoration is properly
conducted.
A.1.3 UTILITIES LOCATION SOP (FO-03)
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

signs of manmade material such as conduit, metal, or concrete. This is required within 3 ft of known or
suspected utilities, or if exact locations are not known.
If there is any indication that the drill may have encountered a manmade obstruction within the first 10 ft
below ground surface (BGS), operations shall stop immediately, and the excavation shall be investigated
prior to proceeding with subsurface work to determine if an unknown or improperly located utility may
have been encountered.
If an existing utility is damaged, the A&E Bien Hoa Contractor COP shall be notified immediately. The
onsite Lead Safety and Environmental Compliance Specialist or on-site Construction Manager shall
document the damage and pertinent circumstances surrounding the incident as soon as possible (in writing
and with photographs or video), and a detailed incident/accident report shall be prepared. The utility will
be repaired immediately by a licensed contractor with final approval of the repair given to the owner of
the utility.
A.1.4 GEOPHYSICAL SURVEY SOP (FO-04)
A.1.4.1 GENERAL REQUIREMENTS FOR GEOPHYSICAL SURVEYS
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.
A.1.4.2 SURFACE GEOPHYISCAL SURVEYS
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

at the same site as the survey; and (2) the location and elevation of at least two points of the geophysical
survey grid shall be surveyed.
A.1.4.3 BOREHOLE GEOPHYSICAL SURVEYS
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.
A.1.5 DRILLING PREPARATION SOP (FO-06)
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.

All drill cuttings will be placed in labeled drums and moved to a central secured location for storage. Any
water generated during drilling will be contained in labeled drums or tanks. All work areas around borings
will be restored, as near as practical, to a physical condition equivalent to that of predrilling. This will
include drill cuttings removal and rut repair.
A.1.6 LITHOLOGIC LOGGING SOP (FO-07)
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.
A.1.7 BOREHEAD ABANDONMENT SOP (FO-08)
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

by backfilling with bentonite chips or un-coated pellets. Borings greater than 5 ft in depth shall be
completely filled from the bottom of the borehole to the land surface with bentonite-cement, neat cement,
or 20 percent high-solids sodium bentonite grout. The boring shall be abandoned by forced injection of
grout or pouring through a tremie pipe starting at the bottom of the borehole and proceeding to the
surface in one continuous operation. All abandoned boreholes shall be checked 24 to 48 hours after
mud/solid bentonite emplacement to determine whether curing is occurring properly. More specific
curing specifications may be recommended by the manufacturer and shall be followed. If settling has
occurred, a sufficient amount of mud/solid bentonite shall be added to fill the hole to the ground surface.
These curing checks and any addition of mud/solid bentonite shall be recorded in the field log book.
A.1.8 HOLLOW-STEM AUGER DRILLING AND SAMPLING SOP (FO-09)
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.1.8.1 DRILLING PROCEDURE

Prior to intrusive work, digging permits must be completed, utility surveys must be completed, and utilities
in the area must be marked on the ground and mapped as per SOP FO-03. The drilling rig shall be located
in a way to avoid traffic and an area centered on the borehole of radius defined by the height of the
extended mast above ground surface shall be demarcated as the exclusion zone. Barriers and caution
tape shall be used to define the exclusion zone as per the HASP. The drill rig shall be levelled using
hydraulic jacks to ensure the rods and augers will excavate a borehole plumb to the earth. A level shall
be used to ensure the rods are plumb prior to initializing the intrusive work. The drilling team shall consist
of at least:
• Master driller and one support member (drilling subcontractor);
• A&E Bien Hoa Contractor Geologist; and
• A&E Bien Hoa Contractor Lead Safety and Environmental Compliance Specialist.
Auger sections, inner rod, and drill bits shall be cleaned and inspected and counted by the A&E Bien Hoa
Contractor Geologist prior to intrusive work and values shall be recorded in the field notebook. Similarly,
all annular fill material should be counted and recorded (amount and type) prior to initiating drilling

activities. The A&E Bien Hoa Contractor Geologist shall document adequate equipment and set up
procedures prior to drilling including:
• Drill rig condition;
• Decontamination pad or truck;
• Adequate containers (55-gallon [gal] drums or other) for soil cuttings, and shovels;
• At least two split-spoon samplers and adequate stainless steel/brass sleeves for soil samples;
• Adequate well casing, screen, annular fill material, well completion boxes;
• Sounding tape, tremie pipe, grout mixer, water supply;
• Proper Personal Protective Equipment (PPE) (hard hat, safety glasses, hearing protection, hard-toed
boots, leather gloves, harness for climbing mast);
• Drilling log forms, well construction forms, Munsell charts, anticipated well construction diagram;
• Adequate sampling jars, terra core kits, sample labels, homogenization containers (clean disposable
bags, bucket liners) and trowels, sample coolers, ice, chain of custody (COC), shipping labels, custody
seals, packing tape; and
• Air monitoring equipment in accordance with the HASP.
Prior to drilling, the A&E Bien Hoa Contractor Geologist and/or Lead Safety and Environmental
Compliance Specialist will develop communication protocol, including hand signals, safe distance for soil
logging, procedures for sample delivery, evacuation locations, and health and safety protocol, such as
breathing zone monitoring.
Drilling will commence once the lead end of the auger column is fitted with an auger head (i.e., cutter
head) that contains replaceable teeth or blades, which break up formation materials during drilling. A
pilot assembly, which is commonly comprised of a solid center plug and pilot bit (i.e., center head), is
inserted within the hollow center of the auger head. The purpose of the center plug is to prevent
formation materials from entering the hollow-stem of the lead auger, and the pilot bit assists in advancing
the auger column during drilling. A center rod, which is attached to the pilot assembly, passes through
the hollow axis of the auger column. The assembly is attached to the overhead rotating drive, centered
on the boring location and excavation drilling commences with rotating and pressure moving the assembly
downward. The cuttings are carried upward by the flights, which are welded onto the hollow-stem. Once
the borehole is advanced to a desired depth for either sampling the formation or installing the MW, the
center rod is used to remove the pilot assembly.
Soil samples are collected using downhole hammers to drive the split-spoon sampler into the formation
as described in Section 2.6.1.1, Split-Spoon Samples. Geotechnical samples are collected in accordance
with Geotechnical Sampling SOP (ES-08). After a sample of the formation has been collected, the center
rod is used to reinsert the pilot assembly into the auger head prior to continue drilling to the next sampling
interval.
In most geotechnical explorations, HSA drilling is combined with other sampling methods. Split-barrel
penetration tests (Test Method D 1586) are often performed to provide estimates of engineering
properties of soils. Thin-wall tube (Practice D 1587) and ring-lined barrel (Practice D 3550) samples are
also frequently taken. This document discusses borehole preparation for these sampling events. For
information on the sampling process, consult the related standards. Other in situ tests, such as the vane

shear Test Method D 2573, can be performed below the base of the boring by access through the drill
string.
A.1.9 DIRECT PUSH DRILLING AND SAMPLING SOP (FO-10)
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.
A.1.9.2 SETUP OF DIRECT PUSH RIG
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.
A.1.9.3 SAMPLE COLLECTION
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

outer barrel, and inserting the soil core sampler and driving to the required depth. The soil core sampler
is then removed and split length-wise for lithologic description, organic vapor screening, head space
sampling, or sampling for laboratory analysis.
Soil vapor samples can be collected at depth by driving rods to the required depth using an expendable
drive point, then raising rod 0.5 - 1.0 ft above the drive point. Insert soil sampling tubing and screw to
sampling port at depth above soil void. Sample shall be collected following purging of void space, and can
be contained in a tedlar bag, sampling syringe, or Summa canister, as required.
Groundwater samples can be collected at depth by driving a slotted rod with a drive point threaded to
the end to below the potentiometric water table. A water level measuring tape should be used to ensure
water is encountered and at static water level (SWL). Some time may be required for the water table to
reach static levels, depending on the permeability of the aquifer material. Static depth to water should be
measured and recorded prior and following groundwater collection. Groundwater samples shall be
collected with a pumping device.
A.1.9.4 PREPACK SCREEN MONITORING WELL INSTALLATION
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.

Regulations generally require a grout barrier that extends at least to 2 ft above the top prepack (Figure
A-1) to avoid contaminating the well screens with bentonite or cement during installation. The filter pack
sand must be installed through the probe rods to provide the minimum 2-ft grout barrier.
Granular bentonite or a high-solids bentonite slurry is installed in the annulus above the grout barrier to
form a well seal at least 2 ft thick (Figure A-1). A high-pressure grout pump is then used to tremie a high-
solids bentonite slurry or neat cement grout to fill the well annulus as the probe rods are retracted. The
grout mixture must be installed with a tremie tube from the bottom up to accomplish a tight seal without
voids to meet regulatory requirements.
Once the well is set, conventional flush-mount or aboveground well protection can be installed to prevent
tampering or damage to the well head. These wells can be sampled by several available methods
(mechanical bladder pump, peristaltic pump, tubing check valve, etc.) to obtain high integrity water quality
samples. These wells also provide accurate water level measurements and can be used as observation
wells during aquifer pump tests.
Attachment 1 includes the manufacturer’s detailed SOPs for installing a 2-inch prepack using Direct Push
tools and techniques.

FIGURE A-1. PREPACK WELL CONSTRUCTION USING DIRECT PUSH TECHNOLOGY

A.1.10 MONITORING WELL CONSTRUCTION SOP (FO-11)
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.
A.1.10.1 WELL STANDARDS REQUIREMENT
All MWs shall have stakeholder approval prior to installation or abandonment.

All MWs shall be drilled, constructed, maintained, operated, and/or abandoned to ensure that
underground sources of drinking water are not contaminated and shall yield water samples and water
levels that are representative of the zone monitored.
Any MW which is destroyed, rendered unusable, or abandoned, shall be reported to the appropriate
stakeholders, and shall be properly abandoned, revitalized, or replaced as appropriate or as required by
permit or regulation.
Well completion or abandonment forms shall be completed within 30 days and shall be submitted to the
appropriate stakeholders. At a minimum, the form shall contain the following information:
1. Legal description and the global positioning system (GPS) coordinates of the location of the water
well or test hole;
2. Description and depth of geologic materials encountered;
3. Depth and diameter or dimension of constructed water well and test hole;
4. Diameter and depth or dimension of excavated hole, if applicable;
5. Depth and volume of formation stabilizer or gravel pack and size of particles, if used;
6. Depth and thickness (intervals and volume) of grout or other sealing material if applicable;
7. Casing and/or loop pipe information, including length, ID and OD, wall thickness, and type of
material, if applicable;
8. Screen information, including length, trade name, ID and OD, slot size, and type of material, if
applicable;
9. SWL;
10. Water level when pumped at the designed rate giving the rate of pumping and amount of time
pumped, if applicable;
11. Yield of water well in gal per minute or gal per hour, if applicable;

12. Signature of water well contractor;
13. Dates drilling commenced and construction completed;
14. Intended use of the water well;
15. Name and address of the landowner; and
16. Identification number of any permit for the water well issued.
Any well that acts as a source of contamination shall be repaired or permanently abandoned immediately
after receipt of notice from appropriate stakeholders.
Well Identification
All MWs shall be properly labeled with an identification plate immediately upon well completion. The
identification plate shall be constructed of a durable, weatherproof, rustproof, material. The identification
plate shall be permanently secured to the well casing or enclosure floor around the casing where it is
readily visible. 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:
1. The well identifier (name);
2. Company name and certification number of the driller who installed the well;
3. Date well was completed;
4. Total depth (ft);
5. Casing depth (ft);
6. Screened interval (ft);
7. Casing material and diameter;
8. Screened material and diameter; and
9. Top of casing surveyed elevation (ft), Northing (m), and Easting (m).
Development shall be complete when the well produces water typical of the aquifer being utilized. Well
development shall be conducted in accordance with MW Development SOP (FO-12).
When installing wells through more than one water-bearing zone or aquifer, the A&E Bien Hoa Contractor
shall take measures to prevent cross-connection or cross-contamination of the zones or aquifers.
A.1.10.2 BOREHOLE REQUIREMENTS
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

to be hazardous because of abnormal color, odor, or organic vapor monitor readings shall be
containerized in conformance with RCRA and the state and local requirements. Rock cores shall be
stored in standard core boxes, and missing sections of core shall be replaced with spacers.
The field log book and field data forms, Section 4.0, shall document the following information for each
boring: (1) boring or well identification (this identification shall be unique, and the A&E Bien Hoa
Contractor is responsible for ensuring it has not been used previously at the installation); (2) purpose of
the boring (e.g., soil sampling, MW); (3) location in relation to an easily identifiable landmark; (4) names
of licensed drilling contractor and logger; (5) start and finish dates and times; (6) drilling method; (7) types
of drilling fluids and depths at which they were used; (8) diameters of surface casing, casing type, and
methods of installation; (9) depth at which saturated conditions were first encountered; (10) lithologic
descriptions and depths of lithologic boundaries; (11) sampling interval depths; (12) zones of caving or
heaving; (13) depth at which drilling fluid was lost and the amount lost; (14) changes in drilling fluid
properties; (15) drilling rate; and (16) drilling rig reactions, such as chatter, rod drops, and bouncing.
In addition to the above, the following information shall be recorded when rock core samples are
collected: (1) the depth interval and top and bottom of each core shall be marked on the core box, (2)
percentage of core recovered, (3) number of fractures per ft, (4) angle of fractures relative to the core
axis, and (5) breaks due to coring and core handling shall be distinguished from naturally occurring
fractures.
A.1.10.3 CASING REQUIREMENTS
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.
A.1.10.4 WELL SCREEN REQUIREMENTS
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 A&E Bien Hoa Contractor may propose open-hole wells in bedrock where cave-in is unlikely. Prior
approval for such wells shall be obtained, in writing, from appropriate stakeholders.
A.1.10.5 ANNULAR SPACE REQUIREMENTS
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.
A.1.10.6 FILTER PACK REQUIREMENTS
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.
A.1.10.7 BENTONITE SEAL REQUIREMENTS
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

sufficiently viscous to ensure it will not be compromised by the casing grout emplacement; and (5) only
100 percent sodium bentonite shall be used. For wells less than 15 ft, the A&E Bien Hoa Contractor may
propose alternate sealing methods. Prior approval for any alternate method shall be obtained, in writing,
from the appropriate stakeholders before well construction begins.
A.1.10.8 CASING GROUNT REQUIREMENTS
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.
A.1.10.9 SURFACE COMPLETION REQUIREMENTS
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:

1. The well identifier (name);
2. Company name and certification number of the driller who installed the well;
3. Date well was completed;
4. Total depth (ft);
5. Casing depth (ft);
6. Screened interval (ft);
7. Casing material and diameter;
8. Screened material and diameter; and
9. Top of casing surveyed elevation (ft), Northing (m), and Easting (m).
Install three 3-inch diameter concrete-filled steel guard posts. The guard posts shall be approximately 5
ft in total length and installed radially from each well head. Recess the guard posts approximately 2 ft into
the ground and set in concrete. Do not install the guard posts in the concrete pad placed at the well base.
The protective sleeve and guard posts shall be painted with a color specified by the installation civil
engineer. In areas of extreme frost heaving, the concrete pads specified may not be appropriate, and
alternate designs maybe required. Special consideration and approvals may be needed in these areas.
All wells shall be secured as soon as possible after drilling. Provide corrosion-resistant locks for both
flush and aboveground surface completions. The locks must either have identical keys or be keyed for
opening with one master key. Deliver the lock keys to the COR following completion of the field effort.
A.1.10.10 PIEZOMETER REQUIREMENTS
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.1.10.11 WELL/PIEZOMETER COMPLETION DIAGRAM REQUIREMENTS
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.
A.1.10.12 TEMPORARY WELL INSTALLATION AND ABANDOMENT
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

interval of groundwater will be sampled per well. Well nests will be installed to evaluate all specified
groundwater intervals.
Temporary wells will be installed as Sections 1.11.1 through 1.11.11 with the following exceptions:
• Boreholes for temporary wells may be less than 4 inches in diameter when using 1 inch diameter well
screens.
• Surging will not be required during filter pack placement.
• The bentonite seal shall be no less than 3 ft thick.
• The annulus above the bentonite seal will be left open.
• There will be no surface completion; however, the well riser will be protected by the use of traffic
cones or other devices.
• Temporary wells are not required to be developed prior to collecting grab samples.
• The temporary wells will be active for less than 24 hours prior to abandonment. Abandonment will
be in accordance with Well Abandonment SOP (FO13) presented in Section 1.13 below, with the
exception that all screen and casing will be removed prior to grouting.
Water point samplers may also be used as temporary wells when left in place to collect groundwater
samples. Construction of well screen and casing is not required as it is provided through drill rod and the
sampler. Borehole abandonment will be in accordance with SOP FO-13.
A.1.11 MONITORING WELL DEVLOPMENT SOP (FO-12)
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:

1. Collect water level measurement and depth to well bottom prior to begin surging the well.
2. Attach surge block to development rig mast wireline and place clean surge block in well to 1 ft from
the bottom of the well. Mark wireline at top of casing with duct tape or similar as for surge block
descent. Manual operation of surge blocks is acceptable for shallow wells.
3. Move surge block through each 5 ft of submerged screen for 3 minutes each.
4. Remove surge block from well and measure water level and sediment on bottom of well from
surging.
5. Use development pump to remove water from well at rate that does not draw down water in the
well more than 1 ft.
6. Collect water quality measurements at approximately 3 minute intervals for water quality
stabilization for 12 minutes.
7. Repeat items 2 through 6 until water quality stabilizes. Stabilization is defined as follows:
a. Temperature ± 1 degree Celsius (°C);
b. pH ± 0.1 units;
c. EC ± 10%;
d. Turbidity ± 10% and < 50 Nephelometric Turbidity Units (NTUs); and,
e. Redox potential + 10 millivolts (mV).
8. If stabilization is not reached, conclude well development after removal of 5 well volumes if bailing,
or 6 hours maximum development if pumping.
Development water shall be containerized in 55-gal drums with bolt-tightened lids. All drums shall be
labeled with an indelible paint pen (drum surface) and an adhesive drum label attached to the drum with
the following information:
1. Drum number;
2. Contract and delivery order number;
3. Contents (development water and well identifiers);
4. Dates of development activities;
5. Airbase contact name and phone number; and
6. If previous samples from the media have not been analyzed or if previous analyses indicate the
material is not hazardous, a “NonHazardous – Pending Analysis” label shall be used until analytical
results are provided.
Information for each well development water drum shall be recorded on a Waste Inventory Tracking Log.
A.1.12 MONITORING WELL ABANDONMENT SOP (FO-13)
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

filled with either neat cement, bentonite-cement, or 20 percent high-solids sodium bentonite grout, from
the bottom of the well to the land surface. All abandoned MWs shall be checked 24 to 48 hours after
mud/solid bentonite emplacement to determine whether curing is occurring properly. More specific
curing specifications or quality assurance checks may be recommended by the manufacturer and shall be
followed. Additionally, if significant settling has occurred, a sufficient amount of mud/solid bentonite shall
be added to attain its initial level. These slurry/solid bentonite curing checks and any addition of mud/solid
bentonite shall be recorded in the field logs.
Surface completions will meet the specifications of the well location:
• Grassy areas will be completed with topsoil and resodded;
• Asphalt areas will be compacted to 6 inches BGS, followed by 4 inches of base rock and 2 inches of
asphalt to flush with surface; and
• Concrete areas will be compacted to 6 inches BGS, followed by 2 inches of base rock and 4 inches of
concrete to flush with surface.
Special surfaces will meet the completion requirements of the surface, including runway surfaces, if drilling
is necessary in these locations.
Any MWs which are destroyed, rendered unusable, or abandoned, shall be reported to the appropriate
stakeholders, and shall be properly abandoned, revitalized, or replaced, as appropriate, or as required by
permit or regulation.
A Water Well Record Form 1903 or other form provided and/or approved by the appropriate
stakeholders shall be completed and submitted within 30 days after well completion or abandonment. At
a minimum, the form shall contain the following information:
• Legal description and the GPS coordinates of the location of the water well or test hole;
• Description and depth of geologic materials encountered;
• Depth and diameter or dimension of constructed water well and test hole;
• Diameter and depth or dimension of excavated hole, if applicable;
• Depth and volume of formation stabilizer or gravel pack and size of particles, if used;
• Depth and thickness (intervals and volume) of grout or other sealing material, if applicable;
• Casing and/or loop pipe information, including length, ID and OD, wall thickness, and type of material,
if applicable;
• Screen information, including length, trade name, ID and OD, slot size, and type of material, if
applicable;
• SWL;
• Water level when pumped at the designed rate giving the rate of pumping and amount of time pumped,
if applicable;
• Yield of water well in gal per minute or gal per hour, if applicable;
• Signature of water well contractor;
• Dates drilling commenced and construction completed;

• Intended use of the water well;
• Name and address of the landowner; and
• Identification number of any permit for the water well issued.
If overdrilling of wells is required by stakeholders, a drilling technology will be used that will drill out all
well construction materials including the screen and riser, grout, bentonite seal, and filter pack. The
overall diameter of the downhole drilling equipment shall be a minimum of 4 inches greater than the
nominal diameter of the well materials (borehole of initial well). Overdrilling will be conducted to a depth
of 4 feet greater than the measured depth of the well being abandoned.
An additional method of abandonment may include pulling the casing without overdrilling. If casing is
pulled, the remaining borehole will be pressure grouted as described above.
A.1.13 WATER LEVEL MEASUREMENT SOP (FO-14)
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.1.14 TEST PIT EXCAVATION SOP (FO-15)
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.
A.1.15 EQUIPMENT DECONTAMINATION SOP (FO-16)
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.
A.1.15.1 HEAVY EQUIPMENT DECONTAMINATION
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.
A.1.15.2 INSTRUMENT AND REUSABLE SAMPLING EQUIPMENT DECONTAMINATION
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

and solvents, such as the pH meter, shall be rinsed with potable and deionized water. The probes shall
be cleaned daily and stored overnight according to the manufacturer’s recommended procedures.
All reusable field equipment used to collect, handle, or measure samples shall be decontaminated before
coming into contact with any soil or groundwater samples. The decontamination procedure must match
the degree of contamination of the sampling tool. For example, steam cleaning shall be necessary to
remove dirt from auger flights and to prepare well screens and riser pipe for installation into the borehole.
Brushes and soap may be required to remove dirt from split-spoon samplers. Sampling equipment that
comes into contact with oil and grease shall be cleaned with methanol and hexane to remove any oily
material. Clean, disposable gloves shall be worn during and after decontamination so that equipment shall
not be re-contaminated.
General decontamination procedures for sampling and drilling devices such as split-spoon samplers, and
other equipment that can be hand manipulated are as follows.
• Steam clean or pressure wash if practical;
• Scrub equipment with a solution of potable water and a laboratory grade phosphate-free detergent
(e.g., Alconox) to remove all dirt from sampling or drilling item;
• Rinse sampling item thoroughly with potable water to remove residual dirt and rewash, if necessary;
• Rinse thoroughly with distilled water;
• For dioxin samples, wipe with pesticide-grade acetone;
• If glass sampling equipment is used and metals are part of the analysis program, rinse the
interior/exterior surfaces of the glass equipment that will come in contact with the sample matrix with
a 10 percent nitric acid solution;
• Rinse item with ASTM Type II analyte-free water; and
• Rinse a final time with analyte-free water. This last rinse water can be captured and containerized,
labeled, wrapped, and cooled to 4°C in a cooler as the Equipment Blank (EB) for the specific
equipment.
Each lot of reagent-free water obtained shall be tested by collecting and submitting one sample to the
laboratory for analysis of target analyte types.
A.1.16 WASTE HANDLING SOP (FO-17)
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.

The IDW shall be segregated at the site according to matrix (solid or liquid) and as to how it was derived
(drill cuttings, drilling fluid, decontamination fluids, and purged groundwater). Each container shall be
properly labeled. Label information shall be placed directly on the drum with indelible paint pen and on a
plastic-coated label with indelible marker (Sharpie attached directly to the drum). All drums shall be
labeled with the following information:
1. Drum number;
2. Contract and delivery order number;
3. Contents (development water and well identifiers);
4. Dates of development activities;
5. Airbase Contact name and phone number; and
6. If previous samples from the media have not been analyzed or if previous analyses indicate the
material is not hazardous, a “NonHazardous – Pending Analysis” label shall be used until analytical
results are provided.
Information for each drum shall be recorded on a Waste Inventory Tracking Log (Appendix D of the
Work Plan [WP]).
A.1.16.1 IDW SAMPLING
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

Code of Federal Regulations, Part 261, Subpart C and recommend a disposal option. The preliminary
waste characterization will be submitted for review and for waste determination (including determination
on whether the IDW is regulated as a listed hazardous waste).
If wastes are determined to be protective for onsite disposal, the Airbase will designate an onsite disposal
area for waste disposal. If wastes require off-site disposal, once the manifest(s) and/or other appropriate
documentation is signed by the COR or representative, the A&E Bien Hoa Contractor will coordinate the
pickup and provide the transporter with the relevant portions of the manifest on behalf of the Installation.
The A&E Bien Hoa Contractor will provide the COR with the original generator copy of the waste
manifest subsequent to release of the shipment. The treatment/disposal facility-signed generator copy
should be returned directly to the COP by the treatment/disposal facility within 30 days of shipment. The
COP will forward the required copy to the COR and, on behalf of USAID, to the stakeholders.
A.1.17 SURVEYING SOP (FO-18)
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.
A.1.18 AQUIFER TESTING FOR HYDRAULIC PARAMETERS SOP (FO-19)
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.

A.1.18.1 SLUG TESTING
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.

A.1.18.1.2 FIELD PROCEDURES
1. Open the well and manually measure the depth to water (Section 1.14). Record this information in
the field log book.
2. Lower the transducer down the well and place it at least 2 ft deeper than the length of the slug.
The depth of the transducer should not exceed the maximum design depth for the transducer used.
3. Fasten the transducer data cable or string holding the transducer at the top of the well so it cannot
move.
4. Let the transducer equilibrate to the well for at least 15 minutes.
5. Measure the water level again to see if the level has returned to equilibrium after the insertion of
the transducer in the water. If it has not, repeat this step in 5-minute intervals until equilibrium is
reached. Record this information in the field log book.
6. Lower the slug into the well and place the slug just above the water level.
7. For falling head slug test, lower the slug quickly into the water. Record the time that the slug was
placed into the water in the field log book.
8. Monitor the water level until it has recovered to within 90 percent of the SWL. This portion of the
test is now complete.
9. Allow time for the water level to recover to a static condition. For the rising head slug test, quickly
pull the slug out of the water. Record the time that the slug was pulled from the water in the field
log book.
10. Monitor the water level until it has recovered to within 90 percent of the SWL.
11. Stop transducer from logging data. Download the data file from the transducer and record the file
name in the field log book. The data collected from the transducer should be reviewed in the field
to determine if the test should be repeated.
12. Decontaminate both the transducer, water level meter, and slug in accordance with Section 1.16 of
this SOP document.
A.1.18.1.3 TEST ANALYSES PROCEDURES
Currently, software programs are used to evaluate slug test results, though it is important that these
analyses are conducted under the oversight of an experienced hydrogeologist. Several methods are
available based on the intrinsic aquifer characteristics and the design of the wells tested. These include
confined aquifers with unsteady state flow (Cooper’s Method or Uffink’s Method for oscillating response)
and unconfined aquifers with steady state flow (Bouwer-Rice’s Method, Hvorslev’s Method). It is
recommended that literature should be reviewed before data analysis is conducted.
A.1.18.2 SPECIFIC CAPACITY STEP – DRAWDOWN PUMP TEST
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

complex tests can be very valuable for developing hydraulic parameters in a heterogeneous aquifer, but
can be expensive and time consuming. The procedures presented below are for a simplified step
drawdown pump test to estimate the specific capacity for a single pumping well and does not require
observation wells. The following elements shall be developed prior to conducting the test:
• Well construction information;
• Well development procedure;
• Well access for water level measurements;
• Reliable power source;
• Type of pump;
• Discharge-control and measurement equipment; and
• Method of water disposal.
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;
• Pump with constant discharge rate settings;
• Sufficient discharge water storage capacity;
• Graduated 5-gal bucket to measure discharge rate (1/2 gal increments);
• 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.
A.1.18.2.1 FIELD PROCEDURES
1. Open the well and manually measure the depth to water (Section 1.14). Record this information in
the field log book.

2. Lower the transducer down the well and place it at least 2 ft deeper than the maximum drawdown
anticipated. The depth of the transducer should not exceed the maximum design depth for the
transducer used.
3. Fasten the transducer data cable or string holding the transducer at the top of the well so it cannot
move.
4. Lower the pump inlet to 1 ft above the pressure transducer.
5. Let the transducer equilibrate to the well for at least 15 minutes and water level return to 90
percent of its initial condition.
6. Begin pump at lowest anticipated discharge rate and run pump for 1.5 hours at that rate;
a. Measure pump discharge rate in graduated bucket in volume per 30 seconds at 5-minute
intervals and record on pump test field form.
b. Measure drawdown at 1-minute intervals with electronic water level meter and record
on pump test field form.
c. Note when drawdown stops and ensure constant discharge rate.
7. Increase pump rate to next rate and run pump for 1.5 hours at that rate and continue as in 6 above.
10. Stop pump.
11. Monitor the water level until it has recovered to within 90 percent of the SWL.
12. Stop transducer from logging data. Remove transducer and pump from the well.
13. Download the data file from the transducer and record the file name in the field log book. The data
collected from the transducer should be reviewed in the field to determine if the test should be
repeated.
14. Decontaminate both the transducer, water level meter, and pump in accordance with Section 1.16
of this SOP document.
15. Label groundwater discharge containers collect samples of each container based on compounds of
potential concern at the site.
Store discharge containers as presented in the Site-Specific Waste Handling Procedure until results of
analytical results are available. Treat the waste groundwater as described in the Site- Specific Waste
Handling Procedure.
A.1.18.3 TEST ANALYSES PROCEDURES
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

h0 - h is the drawdown (ft).
The specific capacity of a well is also a function of the pumping rate it is determined at. Due to non-linear
well losses, the specific capacity will decrease with higher pumping rates. This complication makes the
absolute value of specific capacity of little use and it should always be used with the pumping rate or
provided as a function of the pumping rate.

A.2 ENVIRONMENTAL SAMPLING
In general, all sampling activities should include a pre-mobilization phase to ensure sampling equipment
and supplies are available onsite during the sampling activity; the subcontracted laboratory Project
Manager (PM) is prepared for samples to arrive and be analyzed within site-specific holding times, and data
required for specialized data deliverables are available to be input into the Laboratory Information
Management System. The contract laboratory will provide certified clean sampling containers properly
preserved, shipping containers, packing supplies, de-ionized water for field blanks, COC forms, and
custody seals. All sampling activities shall include the UFP–QAPP and HASP as reference documents.
Prior to sample collection, Sample Field Forms should be completed to the extent possible, and finalized
at each sampling location to track associated quality assurance/quality control (QA/QC) samples, sample
times and dates, sample analytical method requirements, and samplers. Each sampling location shall be
screened for potential exposure based on the expected target compounds, with general use of the project-
specific readings at all sampling locations to be recorded on sampling forms and/or in the field log book.
Each sample activity shall require a field log book to be completed, a camera and pictures to be taken to
document the activities (noted in the log book), decontamination supplies, containers for IDW, sufficient
supplies of new, clean, non-powdered disposable nitrile gloves or similar, and other PPE required in the
HASP. To the extent possible, sampling activities should be conducted with disposable or dedicated
sampling equipment to limit the potential for cross-contamination and the need for rinseate blanks.
In addition, material of the sampling devices (e.g., plastic, PVC, metal) discussed below shall be appropriate
for the contaminant of concern and shall not interfere with the chemical analyses being performed. These
will be described in the UFP–QAPP addenda. All purging and sampling equipment that is not certified
clean and disposable shall be decontaminated according to the specifications in Section Error! Reference
source not found. (F0-16) prior to any sampling activities and shall be protected from contamination
until ready for use.
A.2.1 GENERAL WATER SAMPLING SOP (ES-01)
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

2. Redevelopment of permanent groundwater MWs.
Containers, Preservation Methods, Volumes, and Holding Times: Required sample containers,
preservation methods, volumes, and holding times are given in the appropriate sections of the UFP–QAPP.
Sampling equipment shall be decontaminated in accordance with Section 1.14 upon completion of sampling
activities.
A.2.2 MONITORING WELL SAMPLING SOP (ES-02)
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

warranted). Procedures in the HASP shall be followed when high concentrations of organic vapors or
explosive gases are detected.
Following organic vapor readings, groundwater elevations shall be collected in each well to be sampled
during the days sampling event. Groundwater levels shall be collected in a continuous event until all wells
at the site are measured and recorded before water is removed from any well in the vicinity to ensure
that the water table measured is not affected by the sampling activity. Water levels will be collected in
accordance with Section 1.14, Water Level Measurement SOP.
Purging and sampling shall be performed in a manner that minimizes aeration in the well bore and agitation
of sediments in the well and formation. The A&E Bien Hoa Contractor shall anticipate the use of a
portable low-flow submersible pump system to purge and collect groundwater samples from the MWs
screened in the basal aquifer. Groundwater samples shall be collected from the discharge line of the
submersible pump (or from a petcock or flow control valve) after stabilization has been achieved by
purging.
The following information shall be recorded on a MW Purge and Sample Form each time a MW is purged
and sampled:
• Depth to water before and after purging;
• Well bore volume calculation;
• Sounded total depth of the MW;
• The condition of each well;
• The thickness of any non-aqueous phase liquid (NAPL) layer; and
• Field parameters, such as pH, temperature, EC, oxidation/reduction potential (ORP), alkalinity,
dissolved oxygen (DO), and turbidity. Before groundwater sampling begins, wells shall be inspected
for signs of tampering or other damage.
A.2.2.1 PURGING PRIOR TO SAMPLING

Purging of MWs is performed to evacuate water that has been stagnant in the well and may not be
representative of aquifer conditions. Stagnant water is not considered representative because it does not
interact or mix with groundwater moving through the screened portion of the MW. Well purging shall
be accomplished using submersible pumps.
A.2.2.1.1 LOW-FLOW/VOLUME PURGING PROCEDURES
When performing low-flow/low stress purging, the device with the lowest water removal rate and the
least tendency to stress the well during purging should be selected for use. Alternatives to the low-flow
purging procedures exist and may be acceptable. The low-flow/low volume purging is a procedure used
to minimize purge water volumes. The pump intake is placed within the screened interval at the zone of
sampling. Low-flow rate purging is conducted after hydraulic conditions within the well have re-stabilized.
The rate of pumping from a well should not exceed the rate that the aquifer can recharge the well (i.e.,
the water level in the well should remain relatively constant). This is monitored by measuring the top of
the water column with a water level recorder or similar device while pumping. A low purge rate shall
also reduce the possibility of stripping VOCs from groundwater and will reduce the likelihood of mobilizing
colloids in the subsurface that are immobile under natural flow conditions. Care shall be exercised by the
A&E Bien Hoa Contractor field personnel to avoid exposing the well screen or purging the MWs to

dryness. This could result in recharging groundwater cascading down the sides of the well screen resulting
in accelerated loss of VOCs.
Low-flow purging rates are site-specific and are based on the permeability sedimentary nature of the
formation being sampled. The parameters that determine the pumping rate are:
• Drawdown of the aquifer generally set at 10 cm(0.32 ft);
• Low turbidity, depending upon the formation;
• It is anticipated that MWs shall be sampled using low-flow methods to reduce the requirement to
evacuate the entire water column. In the sedimentary aquifer, it is anticipated low-flow rates shall be
on the order of 0.1 to 0.5 liter per minute. Actual rates shall be measured in the field; and
• Samples shall be collected after water quality parameters have stabilized over a minimum of three
measurements or after a maximum of two hours of low-flow purging.
When monitoring groundwater chemistry, a flow-through cell shall be used to measure temperature, pH,
specific conductivity, turbidity, and ORP. Water quality readings shall be recorded on purge forms every
3 to 5 minutes until stabilization has occurred.
When monitoring to the groundwater chemistry, an adequate purge is achieved when measurements are
within the following:
1. Temperature ± 1 °C;
2. pH ± 0.1 units;
3. EC ± 10%;
4. Turbidity ± 10% and < 50 NTUs;
5. DO + 10%; and
6. Redox potential + 10 mV.
Measurements shall be stable for at least three consecutive readings.
A.2.2.2 PURGING WELLS WITH IN-PLACE PLUMBING
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.

A.2.2.3 PURGING TEMPORARY MONITORING WELLS
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.
A.2.2.4 GROUNDWATER SAMPLING COLLECTION FROM WELLS
Groundwater samples shall be collected no sooner than 24 hours following MW development.

Groundwater samples shall be collected from MWs using a low-flow pump unless otherwise authorized
by the regulatory agency. Pumps that exert a vacuum on the sample (e.g., centrifugal pumps) shall not be
used.
The sample shall be collected after appropriate specifications have been reached according to
requirements presented in Section 2.2.1.
Before collecting groundwater samples, the A&E Bien Hoa Contractor sampling team shall don clean,
phthalate-free protective gloves. Groundwater MWs shall be sampled in order of increasing
contamination. MWs that are expected to be the least contaminated shall be sampled first. At each MW

installation, groundwater samples shall be collected in descending order of potential volatility: VOC
samples, Polycyclic Aromatic Hydrocarbons (PAHs), metals, total organic carbon, anions/cations, and DO.
Pre-preserved bottles shall be used as applicable. For a low-flow sample, samples shall be collected from
the discharge end of the submersible or peristaltic pump without the water passing through the flow-
through cell.
For VOC samples, the sample shall be collected from the discharge end of the submersible/peristaltic
pump tubing using a slow, controlled pour down the side of a tilted sample vial to minimize volatilization.
The sample vial shall be filled until a meniscus is visible and then it shall be immediately sealed. When the
sample vial is capped, it shall be inverted and gently tapped to ensure that no air bubbles are present. Vials
with trapped air shall be refilled until no bubbles are present. After the containers are sealed, sample
degassing may cause bubbles to form; these bubbles shall be left in the container. These samples shall
never be composited, homogenized, or filtered (USEPA 2007a).
A.2.2.5 SAMPLING WELLS WITH IN-PLACE PLUMBING
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.
A.2.2.6 SAMPLING WELLS WITHOUT PLUMBING
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.

After purging has been accomplished with a bladder pump, the sample may be obtained directly from the
pump discharge. The discharge rate of the pump must be minimized during sampling to diminish sampling
disturbance. This is especially important for the collection of VOC and metals samples.
Diffusion Sampling: Diffusion sampling is a method of groundwater sampling for certain VOCs. No purging
is required for this method of sampling. A water diffusion sampler consists of a diffusible bag, like
polyethylene, filled with deionized water and sealed. Commercially available samplers should be used
when possible. Proper QA/QC on the quality of the deionized water needs to be obtained in order to
adequately interpret sample results. The bag must be positioned within the screened interval of the well
by hanging the bag from a nylon or stainless steel cord attached to the top of the well. The diffusion bag
sampler needs to remain in the well until concentrations within the bag reach equilibrium with those in
the surrounding groundwater. Typically after a period of 2 weeks the bag can be withdrawn from the well,
emptied into a standard sampling container (e.g., a volatile organic analysis [VOA] vial), sealed and shipped
for analysis.
Diffusion samplers may also be used to collect samples from the groundwater/surface water interface or
transition zone. The sampler is emplaced (buried) within the transition zone and allowed to equilibrate
for a period of 2 weeks. The sampler is then removed and water is withdrawn from the bag for analysis.
Direct Push Sampling: Direct push sampling may be used when an investigation focuses on constituents
that are not affected by sample turbidity. Direct Push sampling is not generally recommended for metals
or polychlorinated biphenyls. The Direct Push unit allows a micro-screen to be opened at various intervals
to the formation of interest. Methods of water sample collection using Direct Push technology employ
either a vacuum pump or an inert gas lift system. The inert gas lift system reduces the chance for
volatilization of constituents from the sample. Sampling occurs from the chamber within the screen (gas
lift) or from tubing attached to the screen (vacuum lift). All Direct Push well screens must be cleaned in
accordance with the decontamination procedures between sample locations and before usage. For
vacuum pump sampling, new tubing must be used at each sample location.
A.2.3 SURFACE WATER SAMPLING SOP (ES-03)
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

with respect to the surface water sampling locations presented to scale. Locations should be staked and
photographed for photo documentation and the time and date of the picture and location identification
should be documented in the field notebook. The Surface Water Field Sampling Report form should be
completed as required. In addition, the following information should be documented at each sampling
location:
• Location of the sample in the body of water sampled;
• The presence or absence of possible interfering surface water features such as:
• Tributaries,
• Outfalls Disturbances (eddies, rapids, falls), and
• Subsurface stratification (in still water or slow flow bodies).
• Sample collection method;
• Physical description of the collected sample;
• Water depth; and
• Measured field parameters.
To collect a representative sample of a stream or canal, the technician must also take into account the
approximate depth and width of the body at the anticipated location. USEPA provides guidance on the
selection of sampling points and compositing techniques in the USEPA SOP/QA Manual (USEPA 1996b)
document. For most locations where the depth and width of the stream is not great, a single sample
collected in midstream at mid-depth is usually sufficiently representative. A subsurface water grab-
sampling device (such as the Kemmer® sampler) allows the technician to submerge a sample collection
vessel beneath the surface and then open to collect a single point, depth integrated sample. In cases where
surface water and sediment samples are to be collected in the same location, the surface water will be
collected first, followed by the sediment sample to avoid undue disturbance of the sediment and possible
contaminant release into the surrounding surface water.
Compositing samples in response to observed subsurface stratification poses an additional problem to the
sampling technician. To maintain sample representativeness in a body of deep, still water or a low-flow
water body where stratification is obvious, the technician should prepare a composite sample of the major
layers using depth integrated sampling devices, or submit a sample of the largest, most representative
layer. Overall, adequate documentation of the sampling approach used by the technician in the field is the
key to understanding how to use the associated analytical data.
General sampling requirements should be followed, including site-specific health and safety concerns, use
of new nitrile sampling gloves with every sample collected, sample collection at the anticipated lowest
concentration point first, and grading to the highest anticipated concentration point last to minimize the
effects of cross-contamination. If possible, work should be segregated, so that one member of the team
takes all notes, pictures, fills out labels, COCs, etc., while the other members collect the samples
(SESDPROC-201-R1, USEPA 2007b). If multiple samples are to be collected along a stream or water
body, sampling should begin downstream and work upstream to reduce the potential for sampling cross-
contamination from disturbances due to the sample collection activity.
1. Surface water samples shall be collected using a clean 1-liter glass sample jar (or similar) from the
certified clean laboratory containers, then decanting the water into the correct properly labeled and

taped sample container per the appropriate section of the UFP–QAPP. The collection container
should not be reused at a different sampling location (dedicated).
• If the collection device is reused, it must be decontaminated between each sample location and an EB
must be analyzed at a rate of 10 percent of investigative samples for each constituent that may be
cross contaminated at the end of each day.
2. Before laboratory samples are collected, an aliquot of the sample will be analyzed for geochemical
characteristics using the field water quality instrumentation for temperature, pH, ORP, conductivity,
turbidity, and DO. Results will be recorded on the Field Sampling Report form.
3. During sample collection, if transferring the sample from a collection device, make sure that the
device does not come in contact with the sample containers.
4. Place the sample into appropriate, labeled containers. Samples collected for VOC analysis must not
have any headspace. All other sample containers must be filled with an allowance for headspace.
5. All samples requiring preservation must be preserved as soon as practically possible (if sample
bottles are not pre-preserved by the laboratory), ideally immediately at the time of sample
collection.
6. Proper labeling, preservation, COC, and shipping procedures shall be followed as specified in
Section 2.11 of this document.
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.
A.2.5 SOIL SAMPLING SOP (ES-05)
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

characteristics of the material. Simple, manual techniques and equipment, such as hand augers, are usually
selected for surface or shallow subsurface soil sampling. As the depth of the sampling interval increases,
some type of powered sampling equipment is usually needed to overcome torque induced by soil
resistance and depth. The following is an overview of the various sample collection methods employed
over three general depth classifications: surface, shallow subsurface, and deep subsurface. Any of the deep
collection methods described may be used to collect samples from the shallower intervals.
A.2.5.1 MANUAL COLLECTION TECHNIQUES AND EQUIPMENT

These methods are used primarily to collect surface and shallow subsurface soil samples. Surface soils
are generally classified as soils between the ground surface and 12 inches BGS. The shallow subsurface
interval may be considered to extend from approximately 12 to 24 inches BGS or to a site-specific depth
at which sample collection using manual methods becomes impractical. The sample must be obtained
from an area that is not in contact with metal sampler surface.
A.2.5.2 SURFACE SOIL SAMPLING SOP (ES-06)

Collection of samples from near-surface soil can be accomplished with decontaminated tools such as
spades, shovels, trowels, and scoops. Surface material is removed to the required depth and a stainless
steel or plastic scoop is then used to collect the sample.
A flat, pointed disposable trowel or similar shall be used to cut a block of the desired soil when undisturbed
profiles are required. Tools plated with chrome or other materials shall not be used.
The following procedure is used to collect surface soil samples:
1. Carefully remove the top layer of soil or debris to the desired sample depth with a pre-cleaned
spade;
2. Using a pre-cleaned, disposable scoop, spoon, or trowel, remove and discard a thin layer of soil
from the area which came in contact with the spade;
3. If VOA is to be performed, sample should be collected according to method 5035 (Section 2.4);
4. For both VOC and non-VOC analyses place small aliquots of the sample directly into the sample
container with no pre-mixing until the sample jar is full.
Gravel, rock, and vegetation shall be excluded from surface soil samples. Samples shall be collected as
quickly as possible to minimize loss of organics. This method generates a less disturbed soil sample, which
is more suitable for volatile analysis. During field sampling activities, the A&E Bien Hoa Contractor shall
record surface conditions that may affect chemical analyses. These conditions may include:
• Approximate distance to roadways and access roads;
• Observations of seepage;
• Adjacent water level in ditch/stream;
• Distance of sample above surface water surface;
• Soil type (clay, silt, sand, gravel);
• PID reading;
• Site features, such as nearby drainage outfalls, activities occurring on plateau to west and east;

• Obvious deposition of contaminated or clean soil at the site;
• Evidence of dumping or spillage of contaminants; and
• Soil discoloration, unusual condition of growing plants, and stressed vegetation.
Surface soils may be collected with a wide variety of equipment. Spoons, shovels, hand- augers, push
tubes, and post-hole diggers (made of the appropriate material) may be used to collect surface soil samples.
As discussed in the section on powered equipment, surface soil samples may also be collected in
conjunction with the use of heavy equipment.
A.2.6 SUBSURFACE SOIL SAMPLING SOP (ES-07)
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.
A.2.6.1 POWERED SAMPLING DEVICES
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-

spoon samplers; specialized hydraulic cone penetrometer rigs; and backhoes. The use of each of these is
described below.
Power Augers - Power augers are commonly used to aid in the collection of subsurface soil samples at
depths where hand augers are impractical. This equipment is a sampling aid and not a sampling device,
and 20 to 25 ft is the typical lower depth range. It is used to advance a hole to the required sampling
depth, at which point a hand auger is usually used to collect the sample.
Drill Rigs - Drill rigs offer the capability of collecting soil samples from greater depths. For all practical
purposes, the depth of investigation achievable by this method is controlled only by the depth of soil
overlying bedrock, which may be in excess of 100 ft. When used in conjunction with drilling, split-spoon
samplers are usually driven either inside a HSA or inside an open borehole after rotary drilling equipment
has been temporarily removed. The spoon is driven with a 140-pound hammer through a distance of up
to 24 inches and removed. If geotechnical data are also required, the number of blows with the hammer
for each 6-inch interval should be recorded.
Backhoes - Backhoes are often utilized in shallow subsurface soil sampling programs. Samples may either
be collected directly from the backhoe bucket or they may be collected from the trench wall if proper
safety protocols are followed. Trenches offer the ability to collect samples from very specific intervals
and allow visual correlation with vertically and horizontally adjacent material. Prior to collecting samples
from trench walls, the wall surface must be dressed with a stainless steel shovel, spatula, knife, or spoon
to remove the surface layer of soil that was smeared across the trench wall as the bucket passed. If
backhoe buckets are not cleaned according to the procedures described in Section 1.16, samples should
be collected from material that has not been in contact with the bucket surface.
A.2.6.1.1 SPLIT-SPOON SAMPLES
When subsurface soil samples are collected using HSA drilling wire line methods and soil samples are to
be submitted for laboratory analysis, they shall be collected using stainless steel, continuous drive,
California modified split-spoon samplers, or equivalent. These samplers are 18 to 24 inches in length with
a 3-inch OD to accommodate three to four, 2-inch diameter brass/stainless steel rings, each of which is 6
inches in length.
Each time a split-spoon sample is taken, a standard penetration test shall be performed in accordance with
ASTM D-1586 "Standard Test Method for Penetration Test and Split-Barrel Sampling of Soils" (ASTM
1999). The sample is obtained by driving the sampler a distance of 1 ft into undisturbed soil with a 140-
pound hammer, free falling a distance of 30 inches. The sampler is first driven 6 inches to seat it in
undisturbed soil, then the test is performed. The number of hammer blows for seating the spoon and
making the test are then recorded for each 6 inches of penetration on the Drill Log (i.e., 5/7/8). The
standard penetration test result (N) is obtained by adding the last two figures (i.e., 7+8=15 blows per ft).
The sampler is then driven an additional 6 inches to fill the remainder of the split-spoon prior to retrieval.
As soon as the split-spoon is opened, the open ends of the brass/stainless steel rings shall be monitored
for organic vapors using the PID or flame ionization detector. Air monitor results shall be recorded on
the Drill Log and in the field log book.
Method 5035 shall be used to collect VOC samples directly from the split-spoon. Additional sample
material shall be collected for analysis of other required analytical types (PAHs, inorganics, pesticides, for
example) and homogenized prior to collection for analysis.

A.2.6.2 BACKHOE SOIL (TEST PIT) SAMPLING
In general, a backhoe shall be used for the following purposes:

• Exposing underground storage tanks and/or product pipelines;
• Excavation of petroleum impacted material; and
• Excavation of trenches and test pits.
During these activities, subsurface soil samples shall need to be collected to assess the soil quality within
the bottom and/or sides of the excavations, or to characterize the contamination. Where an excavation
cannot be safely accessed to collect grab or composite samples directly using hand-held equipment, the
backhoe shall be used to collect the representative soil sample; however, some precision with respect to
actual depth or location may be lost with this sampling method.
In order to ensure representativeness of the sample location, the surface of the sample location area shall
be prepared by using the backhoe bucket to expose fresh soil. The backhoe bucket shall then be cleaned
of any smeared or remnant material and a soil sample collected. In general, the backhoe operator shall
be requested to scrape an approximately 6-inch deep sample from the prepared ground. In some cases,
a channel sample may need to be collected with the bucket by scraping the side wall from the bottom of
the excavation to the ground surface or from a specific area on the side wall.
A soil sample shall be collected from the soil retrieved in the bucket of the backhoe by completing the
following procedures:
• The backhoe bucket shall be placed on the ground surface for safety;
• Field personnel shall describe the soil collected in the bucket noting the lithology, odors, volatile
vapors, and staining;
• A clean decontaminated stainless steel trowel or shovel shall be used to collect the samples;
• For homogeneous soil, the trowel or shovel shall be used to scrape off approximately 1 to 2 inches
of soil from the sampling point in the bucket and then sampling jars immediately filled from the freshly
exposed area;
• If the sample lithology does not appear to be homogeneous, a five point composite sample can be
collected. However, compositing is not recommended for VOA. A grab sample should be collected
from the area in the bucket that exhibits the highest noted volatile vapor reading. A five point
composite sample is completed by selecting five sampling points within the bucket sample and
collecting as above. The soils are placed into a decontaminated stainless steel bowl and mixed
thoroughly prior to filling the remaining sample bottles/jars. The stainless steel trowel or shovel does
not need to be decontaminated between the five sampling points;
• Samples shall be collected in the order of the most to least volatile;
• Sample jars shall be labeled and immediately placed on ice (4°C) in cooler; and
• Field notes (sample location and number, depth, description, time, observations, etc.) shall be
recorded in the appropriate field log as well as the field log book.

A.2.7 AIR SAMPLING SOP (ES-08)
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.
A.2.7.1 AMBIENT AIR MONITORING
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.
A.2.7.2 WORKER EXPOSURE MONITORING
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,

which will be worn by personnel during all fieldwork involving ground disturbance. This personal monitor
has been approved by the U.S. Mining Health and Safety Administration (MHSA) for use in measuring
worker exposure to coal dust, which has a lower regulatory limit than nuisance respirable dust (0.5 mg/m3
vs 5 mg/m3). The monitors are able to detect dust at 0.2 mg/m3. Monitors will be worn during an entire
shift if ground disturbance activities are occurring or are scheduled to occur at any point during the shift.
Specific instructions regarding the handling, operation, and analysis of the CPDMs shall be in accordance
with the manufacturer’s instructions.
Dioxin
No occupational exposure standard exists for TCDD, the dioxin byproduct of Agent Orange. Because
NIOSH recognizes TCDD as a potential occupational carcinogen and the International Agency for
Research on Cancer (IARC) designation of sufficient evidence in humans for the carcinogenicity of TCDD
(IARC 2018), the project exposure standard is any detectable concentration. There are no designated
worker exposure air monitoring techniques delineated in comprehensive guidelines like the OSHA Manual
of Sampling and Analytical Methods; however, wipe sampling of surfaces and biological monitoring can be
used to identify the presence of TCDD.
A.2.8 FIELD HEADSPACE SCREENING SOP (ES-09)
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.
A.2.9 GEOTECHNICAL SAMPLING SOP (ES-10)
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

with each end on the pertinent plastic cap, and store it at the sample station until all geotechnical samples
haven collected. The Installation Lead shall then review sampling locations, lithology, and sample integrity
and determine which samples shall be sent to the geotechnical laboratory for analysis. Samples shall be
stored vertically in the same orientation withdrawn from the borehole. Each sample shall be packed as
tightly as possible to minimize impact to the sample integrity. The samples shall be analyzed for
geotechnical parameters in accordance with the UFP–QAPP following the appropriate ASTM methods.
Geotechnical samples shall be sent to a qualified geotechnical laboratory that has been approved by
appropriate stakeholders.
A.2.10 SEDIMENT SAMPLING SOP (ES-11)
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.
A.2.11 SAMPLE HANDLING SOP (ES-12)
A.2.11.1 SAMPLE CONTAINERS
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

contaminants. Amber glass bottles are used routinely where glass containers are specified in the sampling
protocol.
A.2.11.2 SAMPLE VOLUMES, CONTAINER TYPES, AND PERSERVATION REQUIREMENTS
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.
A.2.11.3 SAMPLE IDENTIFICATION
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.
A.2.11.4 SAMPLE LABELS
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.
A.2.11.5 SAMPLE DOCUMENTATION
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.

A.2.11.5.1 FIELD LOG BOOK
Complete and accurate documentation is essential to demonstrate that field measurement and sampling
procedures are carried out as described. Field personnel will use permanently bound field log books with
sequentially numbered pages to record and document field activities. The log book will list the contract
name and number, the delivery order number, the project name and number, the site name and location,
and the names of A&E Bien Hoa Contractors, the service client, and the COP. At a minimum, the following
information will be recorded in the field log book:
• Name and affiliation of all on-site personnel or visitors;
• Weather conditions during the field activity;
• PPE;
• Summary of daily activities and significant events;
• Information regarding sample collection including collection date and time, sample identifier, sample
location, sample matrix (water or soil), sample type (regular, duplicate, blank, grab, composite), and
sampling depth;
• Notes of conversations with coordinating officials;
• References to other field log books or forms that contain specific information;
• Discussions of problems encountered and their resolution;
• Discussions of deviations from this UFP–QAPP or other governing documents; and
• Description of all photographs taken.
A.2.11.5.2 SAMPLE CUSTODY
Field personnel will use standard sample custody procedures to maintain and document sample integrity
during collection, transportation, storage, and analysis. A sample will be considered to be in custody if
one of the following statements applies:
• It is in a person’s physical possession or view;
• It is in a secure area with restricted access; or
• It is placed in a container and secured with an official seal such that the sample cannot be reached.
COC procedures provide an accurate written record that traces the possession of individual samples
from the time of collection in the field to the time of acceptance at the laboratory. The COC record also
will be used to document all samples collected and the analysis requested. The field personnel will record
the following information on the COC record:
• Project name and number;
• Sampling location;
• Name and signature of sampler;
• Destination of samples (laboratory name);
• Sample identification number;
• Date and time of collection;

• Number and type of containers filled;
• Analysis requested;
• Preservatives used (if applicable);
• Filtering (if applicable);
• Sample designation (grab or composite);
• Signatures of individuals involved in custody transfer, including the date and time of transfer;
• Airbill number (if applicable); and
• Project contact and phone number.
Unused lines on the COC record will be crossed out. COC records that are initiated in the field will be
signed by field personnel and the airbill number will be recorded. The COC will be reviewed for accuracy
and completeness by a second field team member and initialed to indicate the review was conducted. The
record will be placed in a waterproof plastic bag and taped to the inside of the shipping container used to
transport the samples. Signed airbills will serve as evidence of custody transfer between field personnel
and the courier, and between the courier and the laboratory. Copies of the COC record and the airbill
will be retained and filed by field personnel before the containers are shipped. Laboratory COC begins
with sample receipt and continues until samples are discarded. The laboratory should designate a specific
individual as the sample custodian. The custodian will receive all incoming samples, sign the accompanying
custody forms, and retain copies of the forms as permanent records. The laboratory sample custodian
will record all pertinent information concerning the samples, including the persons delivering the samples,
the date and time received, sample condition at the time of receipt (sealed, unsealed, or broken container;
temperature; or other relevant remarks), the sample identification numbers, and any unique laboratory
identification numbers for the samples. After the sample transfer process is complete, the custodian is
responsible for maintaining internal log books, tracking reports, and other records necessary to maintain
custody throughout sample preparation and analysis. The laboratory will provide a secure storage area
for all samples. Access to this area will be restricted to authorized personnel. The custodian will ensure
that samples requiring special handling, including samples that are heat- or light-sensitive, radioactive, or
have other unusual physical characteristics, will be properly stored and maintained prior to analysis.
A.2.11.6 SAMPLE SHIPMENT

The following procedures will be implemented when shipping samples collected during this project:
• Plastic bags will be used to line the inside of the sample shipping cooler. Samples will be placed in the
plastic bag with bubble wrap or other packing materials and ice. Sufficient packing material will be
used to prevent sample containers from breaking during shipment. Ice will be placed in double Ziploc®
bags. Enough ice will be added to maintain the sample temperature at less than 6°C (but not frozen).
A temperature blank will be placed in each cooler.
• The COC records will be placed inside a plastic bag. The bag will be sealed and taped to the inside
of the cooler lid. The air bill, if required, will be filled out before the samples are handed over to the
carrier. The laboratory will be notified if the sampler suspects that the sample contains any substance
that would require laboratory personnel to take safety precautions. Multiple coolers may be sent in
one shipment to the laboratory.

• The cooler will be closed and taped shut with strapping tape around both ends. If the cooler has a
drain, it will be taped shut both inside and outside of the cooler.
Signed and dated custody seals will be placed on the front of each cooler. Wide clear tape will be placed
over the seals to prevent accidental breakage. The COC record will be transported within the taped
sealed cooler. When the cooler is received at the analytical laboratory, laboratory personnel will open
the cooler and sign the COC record to document transfer of samples.
A.2.12 FIELD QUALITY CONTROL SAMPLES (ES-13)
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.
A.2.12.1 EQUIPMENT BLANK
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.
A.2.12.2 TRIP BLANK
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.2.12.3 FIELD DUPLICATES
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.2.12.4 MATRIX/MATRIX SPIKE DUPLICATES
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.

A.3 FIELD MEASUREMENTS
A.3.1 GENERAL FIELD MEASUREMENT PARAMETERS SOP (FM-01)
The following parameters shall be measured in the field:

• Organic vapors, using a Photovac 2020 PID or equivalent, as applicable;
• Explosive vapors using a lower explosive limit meter, as applicable;
• Water level, using a cable electronic water level indicator or equivalent;
• Immiscible layer, using the Solinst Model 121 Interface Meter or equivalent, as applicable;
• EC, pH, temperature, ORP, and DO, turbidity using an Horiba water quality meter or equivalent;
• Site features and certain sampling locations (Boreholes, surface soil samples, sediment samples, surface
water samples), elevation, and coordinates shall be surveyed using GPS; and
• MW, ditch bed, and water reference elevation and coordinates using a registered land surveyor.
A.3.2 FIELD EQUIPMENT CALIBRATION AND QUALITY CONTROL SOP (FM-02)
A.3.2.1 CALIBRATION FREQUENCIES
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.
A.3.2.2 CALIBRATION PROCEDURES
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

• Method of calibration (autocal, manual, etc.)
• Calibration standard, lot number, and expiration date
• Pre and post-instrument readings
A.3.2.3 FIELD QUALITY ASSURANCE/QUALITY CONTROL PROGRAM
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.
A.3.3 EQUIPMENT MAINTENANCE AND DECONTAMINATION SOP (FM-03)
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.
A.3.4 ORGANIC AND EXPLOSIVE VAPOR MEASUREMENT SOP (FM-04)
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

groundwater MWs (FO-14) and when performing field headspace screening of split-spoon soil samples
(ES-07) if VOCs are expected or observed.
A.3.5 GROUNDWATER LEVEL MEASUREMENT SOP (FM-05)
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).
A.3.6 IMMISCIBLE LAYER MEASUREMENT SOP (FM-06)
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.
A.3.7 ELECTRICAL CONDUCTIVITY, PH, TEMPERATURE, OXIDATION/REDUCTION

POTENTIAL AND DISSOLVED OXYGEN MEASUREMENT SOP (FM-07)
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.3.8 GROUNDWATER TURBIDITY SOP (FM-08)
A portable turbidimeter with an accuracy of 2 percent of reading or 0.05 NTU, shall be used to facilitate
well development.

A.4 RECORD KEEPING
A.4.1 GENERAL RECORD KEEPING SOP (RK-01)
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.
A.4.2 LOG BOOKS SOP (RK-02)
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

that has occurred in the field on any given day. Multiple logbooks will be assembled and maintained to
document all field activities through daily narratives and the use of established forms for specific activities.
Any administrative occurrences, conditions, or activities that have affected the field work shall be recorded
in the field log books.
All field activities entered into the field log books shall be signed and dated by the responsible party.
Electronic signatures may be used for electronic documentation and submittals The following is a list of
the type of information that are typically recorded in the appropriate field log books:
• Name and title of author, date and time of entry, and physical/environmental conditions during the
field activity;
• Name and address of field contact;
• Names and titles of field crew;
• Names and titles of all site visitors;
• Documentation of Health and Safety activities;
• Type of sampled media (e.g., soil, groundwater);
• Number and volume of samples taken;
• Description of sampling points;
• Date and time of overall sample collection;
• Sample identification numbers;
• References, maps and descriptions of photographs;
• General decontamination procedures;
• Instrument calibration;
• Records of telephone conversations; and
• Weather conditions.
A.4.3 FIELD DATA FORMS SOP (RK-03)
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;

• Drill Log;
• Well Construction Details (above ground completion);
• Well Construction Details (surface completion);
• Borehole Abandonment Log;
• Waste Inventory Tracking Log;
• Quality Assurance Report Daily Log; and
• Slug Test Data Form.

A.5 REFERENCES
American Society for Testing and Materials (ASTM). 1999. ASTM D-1586. Standard Test Method for
Penetration Test and Split-Spoon-Barrel Sampling of Soils. (D-1586-99).
. 1990. ASTM D-2488-90. Standard Practice for Description and Identification of Soils (Visual-
Manual Procedure).
Driscoll, F.G. 1986. Groundwater and Wells. 2nd Edition.
Tennissen, A.C. 1983. Nature of Earth Materials, 2nd Edition, p. 204-348.
Urquhart, L.C. 1962. Civil Engineering Handbook, 4th Edition. Pages 96-97.
U.S. Environmental Protection Agency (USEPA), 1994. Slug Test SOP # 2046. November.
. 1996a. Soil Gas Sampling SOP # 2042. June.
. 1996b. Standard Operating Procedure/Quality Assurance Manual.
. 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.
. 2015. What is Vapor Intrusion? Accessed February 9, 2016 at:

http://www.epa.gov/vaporintrusion/what-vapor-intrusion.

APPENDIX B - FIELD FORMS/COCS

SITE-WIDE SAMPLING & ANALYSIS PLAN–QUALITY ASSURANCE PROJECT PLAN | B-1

Annex for Task-Specific QAPP Documents


ANNEX 3 – SITE-WIDE HEALTH AND SAFETY PLAN (HASP)

INITIAL SITE-WIDE HEALTH & SAFETY PLAN
chain òpaat
DECEMBER 5, 2019
DISCLAIMER:
INITIAL SITE-WIDE HEALTH & SAFETY

PLAN

DECEMBER 5, 2019
PREPARED BY
USA
DISCLAIMER:
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

INITIAL SITE-WIDE HEALTH & SAFETY PLAN | i
7.2 SAFETY AUDITS 7-11
8 INCIDENT REPORTING AND INVESTIGATION 8-11
8.1 INCIDENT REPORTING 8-11
8.2 INCIDENT INVESTIGATION 8-12
8.3 INCIDENT FOLLOW-UP 8-13
8.4 MONTHLY EXPOSURE REPORT 8-14
9 PLANS AND PROGRAMS REQUIRED BY THE SAFETY MANUAL 9-1
9.1 FATIGUE MANAGEMENT PLAN 9-2
9.2 EMERGENCY PLANS 9-3
9.2.1 EMERGENCY PLAN: PROCEDURES AND TESTS 9-3
9.2.2 EMERGENCY PLAN: FIREFIGHTING PLAN 9-5
9.2.3 EMERGENCY PLAN: POSTING OF EMERGENCY TELEPHONE NUMBERS 9-6
9.2.4 EMERGENCY PLAN: SEVERE WEATHER 9-8
9.2.5 EMERGENCY PLAN: SPILL PREVENTION AND CONTROL PLAN 9-9
9.2.6 MEDICAL EMERGENCY PROCEDURES PLAN 9-9
9.2.7 FIRST AID AND CARDIOPULMONARY RESUSCITATION AVAILABILITY
PROGRAM 9-10
9.2.8 BLOODBORNE PATHOGENS PROGRAM 9-10
9.2.9 EMERGENCY DECONTAMINATION PROVISIONS PLAN 9-10
9.3 SITE SANITATION/HOUSEKEEPING PLAN 9-11
9.3.1 HOUSEKEEPING 9-11
9.3.2 DRINKING WATER 9-11
9.3.3 NON-POTABLE WATER 9-11
9.3.4 TOILETS 9-12
9.3.5 WASHING FACILITIES 9-12
9.3.6 WASTE DISPOSAL 9-12
9.4 MEDICAL SUPPORT AGREEMENT AND FIRST AID AVAILABILITY PROGRAM 9-13
9.5 BLOODBORNE PATHOGENS EXPOSURE CONTROL PLAN 9-13
9.6 SITE LAYOUT PLAN FOR TEMPORARY SITE FACILITIES 9-13
9.7 ACCESS AND HAUL ROAD PLAN 9-14
9.8 PERSONAL PROTECTIVE AND SAFETY EQUIPMENT, HEARING CONSERVATION,
RESPIRATORY PROTECTION PLAN 9-14
9.8.1 RESPIRATORY PROTECTION 9-15
9.8.2 HEARING CONSERVATION PROGRAM 9-16
9.9 HEALTH HAZARD CONTROL PROGRAM 9-17
9.9.1 CHEMICAL HAZARDS 9-17
9.9.2 BIOLOGICAL HAZARDS 9-17
9.9.3 MANUAL MATERIAL HANDLING HAZARDS 9-23
9.9.4 AIR CONTAMINANT HAZARDS 9-23
9.10 PPE REQUIREMENT PROGRAM 9-23
9.11 HAZARD COMMUNICATION PROGRAM 9-26
9.12 HEAT STRESS MONITORING AND PREVENTION PLAN 9-27
9.12.1 CONTRIBUTING FACTORS 9-27
9.12.2 HEAT STRESS PREVENTION PLAN 9-28
9.13 TRAFFIC CONTROL PLAN 9-30

INITIAL SITE-WIDE HEALTH & SAFETY PLAN | ii
9.14 FIRE PREVENTION PLAN 9-31
9.14.1 FIRE PREVENTION PLAN INFORMATION 9-31
9.15 ASSURED EQUIPMENT GROUNDING CONDUCTOR PROGRAM 9-33
9.16 HAZARDOUS ENERGY CONTROL PROGRAM & PROCEDURES 9-34
9.16.1 DEFINITIONS 9-35
9.16.2 EQUIPMENT SURVEY 9-36
9.16.3 SELECTION OF LOCKS, TAGS, AND BLOCKS 9-36
9.16.4 WRITTEN STANDARD OPERATING PROCEDURE 9-37
9.16.5 PERIODIC INSPECTIONS 9-40
9.16.6 TRAINING 9-40
9.17 EXCAVATION/TRENCHING PLAN 9-40
9.17.1 DEFINITIONS 9-41
9.17.2 UTILITY CLEARANCE SURVEYS 9-42
9.17.3 OVERHEAD UTILITIES 9-43
9.17.4 PERIMETER GUARDING OF EXCAVATIONS 9-43
9.17.5 COMPETENT PERSON SUPERVISION AND INSPECTIONS 9-43
9.17.6 PERSONNEL ENTRY INTO A TRENCH OR EXCAVATION 9-44
9.17.7 PERSONNEL WORKING NEAR TRENCHES OR EXCAVATIONS 9-45
9.17.8 EXCAVATION PROCEDURES 9-45
9.17.9 SOIL CLASSIFICATIONS 9-46
9.17.10 EXCAVATION PROTECTION SYSTEMS 9-47
9.17.11 EXCAVATIONS GREATER THAN 20 FEET (6 METERS) DEEP 9-48
9.17.12 TRAINING 9-48
9.18 SHASP FOR HAZARDOUS, TOXIC OR RADIOACTIVE WASTE (HTRW) WORK 9-48
9.18.1 DIOXIN MEDICAL SURVEILLANCE PROGRAM 9-50
9.18.2 BLOOD SERUM DIOXIN MONITORING 9-52
9.18.3 CONTRACTOR AND SUBCONTRACTOR HEALTH AND SAFETY PLAN
REQUIREMENTS 9-58
9.19 SITE CONTROL MEASURES 9-58
9.19.1 CLEAN ZONE 9-58
9.19.2 CONTAMINATION REDUCTION ZONE 9-58
9.19.3 EXCLUSION ZONE 9-60
9.19.4 ACCESS CONTROL 9-60
10 RISK MANAGEMENT PROCESSES 10-63
10.1 HEALTH AND SAFETY PLAN FORMS 10-63
10.2 REPORTING OF HAZARDS AND SAFETY INSPECTIONS 10-63
APPENDIX A. HEALTH AND SAFETY PLAN FORMS A-1
APPENDIX B. HEALTH AND SAFETY OFFICER AND LSECS RESUMES B-1
APPENDIX C. LIST OF DESIGNATED COMPETENT PERSONS C-1
APPENDIX D. ACTIVITY HAZARD ANALYSES D-1
APPENDIX E. SUBCONTRACTOR LIST E-1
APPENDIX F. PROJECT PERSONNEL TRAINING INFORMATION F-1

INITIAL SITE-WIDE HEALTH & SAFETY PLAN | iii
APPENDIX G. BLOODBORNE PATHOGENS EXPOSURE CONTROL PLAN G-1
APPENDIX H. HAZARD COMMUNICATION PROGRAM H-1
APPENDIX I. ASSURED EQUIPMENT GROUNDING CONDUCTOR
PROGRAM REQUIREMENTS I-1
APPENDIX J. LIST OF DESIGNATED FIRST AID RESPONDERS J-1
APPENDIX K. PERSONAL PROTECTIVE EQUIPMENT DONNING
PROCEDURES AND PERSONNEL DECONTAMINATION PROCESS K-1
APPENDIX L. DIOXIN MONITORING INFORMATION L-1
APPENDIX M. SHORT-FORM SUPPLEMENTAL HEALTH AND SAFETY PLAN
FORMAT (NON-INTRUSIVE SITE ACTIVITIES) M-1
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

INITIAL SITE-WIDE HEALTH & SAFETY PLAN | iv
RECORD OF REVISIONS
Revision Date Pages Revisions Approval
Initial development/submittal of draft Health &

000 November 11, 2019 All USAID CO/COR
Safety Plan.
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
001.3 December 28, 2020 Selected Updated personnel Not applicable

INITIAL SITE-WIDE HEALTH & SAFETY PLAN | v
ACRONYMS AND ABBREVIATIONS
% percent Organization Expert Committee on
°C degree(s) Celsius Food Additives
°F degree(s) Fahrenheit km kilometer
A&E Architecture and Engineering LEL Lower Explosive Limit
ACGIH American Conference of Industrial LSECS Lead Safety and Environmental
Hygienists Compliance Specialist
ADAFC Air Defense Air Force Command m3 Cubic meter
AED Automatic External Defibrillator mA milliampere
AEGCP Assured Equipment Grounding NHANES National Health and Nutrition
Conductor Program Examination studies
AHA Activity Hazard Analysis NIOSH National Institute of Occupational Safety
ANSI American National Standards Institute and Health
APR Air purifying respirator OPIM Other Potentially Infectious Materials
BBP Bloodborne Pathogens OSHA Occupational Safety and Health
CBC Complete Blood Count Administration
CDC Centers for Disease Control and PCDD/F polychlorobenzodioxins and
Prevention polychlorodibenzofurans
CFR Code of Federal Regulations PEL Permissible Exposure Limit (OSHA)
CIH Certified Industrial Hygienist pg/g picograms per gram
CIT Certified Instructional Trainer pg/kg-day picograms per kilogram per day
CM Construction Manager PPE Personal Protective Equipment
CO Contracting Officer QC Quality Control
COP Chief of Party SAP/QAPP Site-Wide Sampling and Analysis
COR Contracting Officer Representative Plan/Quality Assurance Project Plan
CPM Contractor Project Manager SAR Supplied air respirator
CPR Cardiopulmonary Resuscitation SCBA Self-contained breathing apparatus
CRZ Contamination Reduction Zone SCPM Site Contractor Project Manager
CSO Contractor Safety Officer SDS Safety Data Sheet
CSP Certified Safety Professional SHASP Supplemental HASP
CZ Clean Zone SMA Sequential Multi-channel Analysis
dB Decibels SOP Standard Operating Procedure
dBA Decibels measured on the A-Weighted SWEMMP Site-Wide Environmental Mitigation and
scale Monitoring Plan
DCOP Deputy Chief of Party TCDD 2,3,7,8-Tetrachlorodibenzodioxin
Decon Decontamination TDI Tolerable Daily Intake
EA Environmental Assessment TEF Toxicity Equivalence Factor
EM 385-1-1 USACE Safety and Health Requirements TEQ Toxicity Equivalent
Manual TLV Threshold Limit Value
EMR Experience Modification Rate tsf Tons per square foot
EPA U.S. Environmental Protection Agency TWA Total Weight Average
ERT Emergency Response Team U.S. United States
EZ Exclusion Zone USAID U.S. Agency for International
FMP Fatigue Management Plan Development
GFCI Ground-fault Circuit Interrupter USACE U.S. Army Corps of Engineers
GHS Globally Harmonized System USCG U.S. Coast Guard
GPS Global Positioning System UXO Unexploded ordnance
GVN Government of Vietnam VPAF Vietnam People’s Air Force
HASP Health and Safety Plan
Hazwoper Hazardous Waste Operations and
Emergency Response
HBV Hepatitis B Virus
HCS Hazard Communication Standard
HCV Hepatitis C Virus
HIV Human Immunodeficiency Virus
HSO Health and Safety Officer
HTRW Hazardous, Toxic, and Radioactive
Waste
JECFA Joint Food and Agriculture
Organization/World Health

INITIAL SITE-WIDE HEALTH & SAFETY PLAN | vi
1 SIGNATURE SHEET
Dioxin Remediation at
Bien Hoa Airbase Area Project
SITE-WIDE HEALTH & SAFETY PLAN SIGNATURE PAGE
United States Agency for International Development

Contract Number: AID-OAA-I-15-00053
Order Number: 72044019F00001
November 2019
Plan Prepared By:
Lynne Black, CIT

Health and Safety Officer; (434) 422-4656
Plan Reviewed By:
Michael R. Grasso, CIH, CSP

Safety and Health Advisor (607) 201-6737
Plan Submitted By:
Sal Mansour
Chief of Party
Plan Approval By:
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).

INITIAL SITE-WIDE HEALTH & SAFETY PLAN | 1-1
2 BACKGROUND INFORMATION
2.1 PROJECT INFORMATION AND BACKGROUND

Client: United States Agency for International Development (USAID)
Project Name: Dioxin Remediation at Bien Hoa Airbase Area Project (Project)
A&E Bien Hoa Contractor: Trigon Associates, Inc.
Contract Number: AID–OOAA-I-15-00053
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.
2.2 CONTRACTOR INFORMATION

This Site-Wide HASP applies to Project personnel and activities. Project activities will be implemented by
the Project Contractors including the A&E Bien Hoa Contractor. 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 all contractors and establishes the
minimum safety and health requirements for Project Contractors and personnel to follow.

2.3 SCOPE
This Site-Wide HASP defines the required Project health and safety procedures and programs that apply
to Project personnel and activities. Project workers speak either English and/or Vietnamese, and safety
and training material will be made available in the appropriate language through either written or oral
translation. As the Project progresses, supplemental HASPs (SHASPs) will be prepared by the Project
Contractors (including the A&E Bien Hoa Contractor) for site investigations/evaluations, remediation,
construction, and post-construction activities. The types of activities may expand to include confined space
entry, electrical, and elevated work depending on the Project needs. These SHASPs will comply with this
Site-Wide HASP and be included as annexes. The A&E Bien Hoa Contractor is responsible for maintaining
this Site-Wide HASP and implementing those portions of the Site-Wide HASP assigned to it.
1926; and the United States Army Corps of Engineers (USACE) “Safety and Health Requirements Manual”
(30 November 2014 edition) (EM 385-1-1).

FIGURE 2-1 BIEN HOA AIRBASE SITE MAP

3 SAFETY AND HEALTH POLICY STATEMENT
3.1 PROJECT SAFETY AND HEALTH POLICY STATEMENT

The objective of the Project safety and health program is to establish work procedures that ensure Project
work is performed in a safe and healthful manner. During the course of the Project, the safety and health
of Project personnel will be the first consideration when planning and executing work and will not be
questioned or compromised. To be successful, the Project safety and health program must encourage a
culture of safety that fosters proper attitudes toward incident prevention on the part of both supervisors
and employees. It also requires cooperation in all safety and health program aspects, not only between
supervisors and employees, but also between employees and their fellow workers. Only through such a
cooperative effort can an effective safety and health program be maintained.
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:
• Maintain a safe workplace, equipment, and materials;

• Establish and comply with safe work operations and accepted safe work rules, procedures,
and practices in compliance with safety and health regulations;
• Provide effective safety and health training that teaches Project personnel how to identify
potential hazards and provides the necessary protocols, tools, and equipment to
appropriately mitigate identified hazards;
• Understand that they have a duty and responsibility to maintain their own safety and the
safety of their coworkers; and
• Actively support the Project safety and health program and embrace the philosophy that
“Incidents Can Be Prevented.”
3.2 PROJECT SAFETY GOALS

The Project accident experience goal is zero incidents. Project personnel will complete required training
and, when necessary, retraining will be provided. Project personnel will report near misses and site hazards
in a timely manner. Several measures will be taken to achieve and maintain the goal of zero incidents.
• 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

hazards, mitigation measures, training requirements, engineering controls, work practices, and
PPE to be used.
• Project Contractors will require their personnel to report accidents or injuries. When an incident
occurs, Project Contractors must conduct a thorough investigation to ascertain the cause and
measures to be taken to prevent recurrence.
• Project Contractors must initiate a hazard and “Near Miss” reporting system for Project
personnel. Project Contractors will require their personnel to report identified hazards and, if
assistance is required in removing a hazard, measures will be identified to mitigate the hazard.
3.3 SITE-WIDE HEALTH AND SAFETY PLAN DESCRIPTION

This Site-Wide HASP establishes the written Project safety and health program that applies to Project
personnel and activities to be conducted at the Bien Hoa Airbase Area. Project activities will be
implemented by the Project Contractors (including the A&E Bien Hoa Contractor) and will include the
following activities related to the treatment and isolation of dioxin contaminated soil and sediment at the
Bien Hoa Airbase Area:
• 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:
• Provide personnel with a safe working environment;

• Establish an effective Project safety and health program;
• Identify key Project personnel, their safety and health responsibilities, and the lines of
authority;
• Establish procedures for identifying and evaluating workplace hazards and prescribe safety
control measures to mitigate them;
• Create and reinforce safety conscious attitudes amongst Project personnel;
• Establish a system to facilitate Project personnel compliance with safe work practices and
procedures for correcting unsafe conditions;
• Provide safety and health training for Project personnel;
• Establish a medical monitoring program for Project personnel that includes a blood serum
dioxin monitoring program; and
• Implement procedures for the reporting and investigation of Project site-related injuries,
illnesses, vehicular accidents, property damage, security incidents, and environmental damage.
USAID requires compliance with the Site-Wide HASP by Project Contractors and personnel and
associated third parties. A copy of the Site-Wide HASP will be maintained on site during work activities
and will be available for inspection and review. Project personnel are required to review applicable aspects
of the Site-Wide HASP before site work and sign a “Site-Wide HASP Review” acknowledgment form (see
HASP Appendix A – HASP Forms) indicating that they have reviewed the pertinent aspects of the Plan.
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.
4 RESPONSIBILITIES AND LINES OF AUTHORITIES

Responsibility for safety and health is shared by Project Contractors and personnel. An effective safety
and health program can only be maintained through a cooperative effort between supervisors and
employees, and employees and their fellow workers. This section identifies key Project personnel, their
safety and health responsibilities, and the lines of authority and cooperation. This section also describes
designated competent persons, establishes pre-task safety and health analysis procedures, and establishes
safety compliance and enforcement procedures.
4.1 KEY PROJECT PERSONNEL

USAID, the A&E Bien Hoa Contractor, Project Contractors, and Project personnel are responsible for
the implementation and compliance with the Project safety and health program as presented in this Site-

Wide HASP. Key USAID and A&E Bien Hoa Contractor Project personnel are identified in Table 4-1.
Additional Key Project personnel are identified in the Project “Emergency Contact List” (see Table 9-2).
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)

TABLE 4-1.KEY PROJECT PERSONNEL
Position Current Personnel Organization Contact Information Start Date Record of Revisions
Contracting Officer (CO) Phone: 02439351231
Suzanne Johnson USAID
USAID Email: [email protected]
Contracting Officer’s Mobile: +84 (96) 2002758
Representative (COR) Anthony (Tony) Kolb USAID Email: [email protected]
USAID
Chief of Party (COP) / Office: +1 504.585.5767 Formerly Souheil (Sal) Mansour
Trigon
Remediation Specialist Andrew Sayers-Fay, Ph.D. Mobile: +84 (84) 9360544
Associates
A&E Bien Hoa Contractor Email: [email protected]
Deputy Chief of Party Office: +1 504.585.5767 Formerly Andrew Sayers-Fay
Trigon
(DCOP)A&E Bien Hoa Suzan Samara Mobile: +84 (36) 7731624
Associates
Contractor Email: [email protected]
Lead Safety and
Environmental Compliance Trigon Mobile: +84 (91) 8077753
Thang Vu
Specialist (LSECS) Associates Email: [email protected]
Michael Grasso, Certified
Office: 504.585.5767
Safety and Health Advisor Industrial Hygienist (CIH), Trigon
Mobile: 607.201.6737
A&E Bien Hoa Contractor Certified Safety Professional Associates
Email: [email protected]
(CSP)
Health and Safety Officer
Lynne Black, Certified Office: +1 434-295-4446
(HSO) Cardno
Instructional Trainer (CIT) Email: [email protected]
Construction Manager
Trigon Mobile: +84 (90) 3511779
(CM) Quang Mai
Associates Email: [email protected]
Contractor Project
Manager
Project Contractor
Site Contractor Project
To be determined in SHASP’s for each contractor’s activities
Manager
Project Contractor
Contractor Safety Officer
Project Contractor
Notes:
A&E – Architect and Engineer

4.2 KEY PROJECT PERSONNEL SAFETY AND HEALTH RESPONSIBILITIES
Table 4-2 describes the safety and health responsibilities for the identified key Project personnel and site personnel, and established lines of
authority. The key Project personnel include USAID, A&E Bien Hoa Contractor, and other Project Contractor(s) personnel.
TABLE 4.2 KEY PROJECT PERSONNEL SAFETY AND HEALTH RESPONSIBILITIES

Title Role Safety and Health Responsibilities
USAID Key Project Personnel
USAID Contracting Officer Manages the Project contract and is the USAID • Provide final approval of the Site-Wide HASP prior to any work, except non-intrusive
primary point of contract for safety and health issues. site work, and
The USAID CO can designate their safety and health
responsibilities to the USAID COR.
USAID Contracting Manages and oversees the Project technical direction. • Review the Site-wide HASP and recommend approval to Contracting Officer . Review
Officer’s Representative and approve subsequent annexes to the Site-wide HASP, including SHASPs and new
AHAs.
A&E Bien Hoa Contractor Key Project Personnel
A&E Bien Hoa Contractor Leads the A&E Services for Dioxin Remediation at the • Direct, coordinate, and implement the A&E contract;
Chief of Party (also acts as Bien Hoa Airbase Area activity and is the primary • Review and submit to USAID the Site-Wide HASP and A&E Bien Hoa SHASPs;
A&E CPM and SCPM) point of contact with USAID on the Site-Wide HASP. • As requested by USAID, review and comment on SHASPs and new AHAs submitted by
other Project Contractors;
• Review addenda to the Site-Wide HASP to incorporate updates approved by the CO;
• Emphasize safety and health to workers and guests at the Bien Hoa Airbase Area;
• Request dismissal of Project personnel who consistently exhibit unsafe work
performance after notice to the worker from the CO and COR;
• Notify the USAID CO and COR and direct or suspend Project Contractor’s work when
the continued performance of the work will endanger the health, or safety of the public
or Project personnel;
• Communicate with the CO to evaluate and resolve contractor/subcontractor safety and
health issues.
• Allocate the necessary resources and support required to implement and enforce this
HASP;
• Provide resources and support to the A&E Bien Hoa Contractor CM and safety and
health staff (Safety and Health Advisor, HSO, and LSECS); and
• Communicate with the CO to evaluate and resolve safety and health issues.
A&E Bien Hoa Contractor Leads the technical aspects of the A&E Services for • Direct, coordinate, and implement the technical aspects of the A&E contract;
Deputy Chief of Party Dioxin Remediation at the Bien Hoa Airbase Area • Review the Site-Wide HASP and annexes including SHASPs and new AHAs;
activity. The A&E Bien Hoa Contractor COP can • Provide resources an-d support to the A&E Bien Hoa Contractor CM and safety and
designate their safety and health responsibilities to health staff (Safety and Health Advisor, HSO, and LSECS);
the A&E Bien Hoa Contractor DCOP. • Emphasize safety and health to workers and guests at the Bien Hoa Airbase Area; and
• Schedule safety and health inspections and audits for the A&E Bien Hoa Contractor
LSECS to conduct.
A&E Bien Hoa Contractor Supports and advises the A&E Bien Hoa Contractor • Advise and support the A&E Bien Hoa Contractor COP and DCOP on safety and health
Safety and Health Advisor COP and DCOP on safety and health aspects of the topics;

A&E Services for Dioxin Remediation at the Bien • Review the Site-Wide HASP and annexes including SHASPs and new AHAs; and
Hoa Airbase Area activity. • Work collaboratively with the A&E Bien Hoa Contractor HSO.
A&E Bien Hoa Contractor Overall safety manager assigned to support the • Develop the Site-Wide HASP and A&E Bien Hoa Contractor SHASPs;
Health and Safety Officer Project. The A&E Bien Hoa Contractor LSECS and • Review addenda to the Site-Wide HASP to incorporate updates approved by the CO;
CSO have a direct reporting relationship to the A&E • Review SHASPs for compliance with the Site-Wide HASP;
Bien Hoa Contractor HSO regarding all safety and • Review new AHAs for compliance with the Site-Wide HASP;
health matters. The A&E Bien Hoa Contractor HSO • Review modifications to existing AHAs;
implements the Site-Wide HASP and oversees the • Work collaboratively with the Safety and Health Advisor;
activities of the A&E Bien Hoa Contractor LSECS and • Provide safety and health technical assistance to the A&E Bien Hoa COP, DCOP, CM,
CSO. The HSO has an independent reporting and LSECS; and
relationship from Project management and • Communicate with the CO and designated representatives to evaluate/resolve safety
supervision. A resume for the HSO is provided (see and health issues.
Appendix B – Health and Safety Officer and LSECS
Resumes). The A&E Bien Hoa Contractor HSO can
designate their safety and health responsibilities to
the A&E Bien Hoa Contractor LSECS.
A&E Bien Hoa Contractor Provides primary oversight of Project Contractors • Review the Site-Wide HASP and annexes including SHASPs and new AHAs;
Construction Manager and directly reports to the A&E Bien Hoa Contractor • Allocate resources, as required, to implement the Site-Wide HASP;
COP. • Recognize and award the safety achievements of crews/team/contractors;
• Begin every meeting with a safety moment;
• Recognize unsafe acts and conditions and take the necessary corrective actions;
• Implement and enforce the Site-Wide HASP; and
• Emphasize safety and health to workers and guests at the Bien Hoa Airbase Area.
A&E Bien Hoa Contractor The onsite Project safety and health supervisor who • With HSO, develop the Site-Wide HASP and A&E Bien Hoa Contractor SHASPs;
Lead Safety and is present during fieldwork activities and responsible • Review addenda to the Site-Wide HASP to incorporate updates approved by the CO;
Environmental Compliance for ensuring site activities are being conducted in • Review SHASPs for compliance with the Site-Wide HASP;
Specialist (also acts as A&E accordance with Project documents such as the Site- • Review AHAs for compliance with the Site-Wide HASP;
CSO) Wide Environmental Mitigation and Monitoring Plan • Review modifications to existing AHAs;
and Site-Wide HASP. As per EM 385-1-1 • Maintain copies of the Site-Wide HASP on site during field activities;
requirements, the A&E Bien Hoa Contractor LSECS • Implement provisions of the Site-Wide HASP and the Project safety and health program;
must be present at the site when work is performed. • Recommend safety and health inspections and audits to the A&E Bien Hoa Contractor
If the A&E Bien Hoa Contractor LSECS must be COP;
absent from the site, the safety and health duties • Conduct safety and health inspections and audits as scheduled by the A&E Bien Hoa
must be delegated to another qualified responsible Contractor COP;
party. The A&E Bien Hoa Contractor LSECS must • Require that site personnel meet training and medical surveillance requirements;
ensure that the person assuming this temporary role • Conduct site orientation training and Site-Wide HASP reviews;
is first aid/cardiopulmonary resuscitation (CPR) • Conduct training as new activities and/or hazards are introduced;
certified and is fully aware of their role and • Emphasize safety and hold personnel accountable for safe work performance;
responsibilities during the A&E Bien Hoa Contractor • Review site hazards and establish safety control measures;
LSECS’s absence. The names of Competent and/or • Maintain a hazardous substance inventory list;
Qualified Persons that can act as replacements for • Maintain copies of each safety data sheet (SDS);
the A&E Bien Hoa Contractor LSECS and proof of • Maintain safety equipment and supplies;
their competency or qualification will be provided in • Perform weekly safety inspections and document safety and health findings;
Appendix C – List of Designated Competent

Persons as site activities progress. Several • Collect, review, and provide comments on copies of the Daily Safety Log prepared by
Competent and/or Qualified Persons will be named the CSO;
as replacements for the A&E Bien Hoa Contractor • Enforce implementation and compliance with the Site-Wide HASP and Project safety
LSECS to ensure that work is not delayed by a safety and health program;
stand-down until a qualified/certified person is • Ensure site control work zones and boundaries comply with the Site-Wide HASP;
available. • Determine PPE requirements and monitor proper use;
• Direct decontamination procedures to be used;
The resume for the A&E Bien Hoa Contractor LSECS • Perform and/or coordinate site exposure monitoring;
will be provided in Appendix B once the position is • Report safety violations or safety and health concerns promptly to the A&E Bien Hoa
filled Contractor COP and HSO;
• Request dismissal of Project personnel who consistently exhibit unsafe work
performance after notice to the worker from the USAID CO/COR;
• Notify the USAID CO and COR and direct or suspend Project Contractor’s work when
continued performance of the work will endanger the health, or safety of the public or
Project personnel;
• Ensure correction of unsafe work conditions and/or unsafe work practices;
• Monitor and evaluate safety and health performance of Project operations;
• Maintain Project safety and health records including anonymous blood serum dioxin
monitoring results to be shared with USAID;
• Maintain and update AHAs as Project activities progress;
• Report and investigate accidents and incidents;
• Serve as a member of the A&E Bien Hoa Contractor quality control staff on safety and
health matters;
• Communicate with the A&E Bien Hoa Contractor HSO regarding site activities and Site-
Wide HASP compliance; and
Project Contractor Key Project Personnel (to be identified in SHASPs)
Contractor Project Each Project Contractor (except the A&E Bien Hoa • Direct, coordinate, and implement their contract;
Manager Contractor) will have a CPM who is responsible for • Review the Site-Wide HASP;
overall direction, coordination, technical consistency, • Review and submit their contract-specific SHASP;
and review of the Project Contractor contract. • Emphasize safety and health, and hold their personnel accountable for safe work
performance;
• Enforce implementation and compliance with the Site-Wide HASP, contract-specific
SHASP, and Project safety and health program;
• Per its contract with USAID, establish a procedure to notify the USAID CO and COR
and to direct or suspend Project Contractor’s work when the continued performance of
the work will endanger the health, welfare, or safety of the public or Project personnel;
• Provide resources and support to the SCPM and CSO;
• Monitor and evaluate safety and health performance of their operations; and
• Communicate with the CO to evaluate and resolve contractor/subcontractor safety and
health issues.
Site Contractor Project Each Project Contractor (except the A&E Bien Hoa • Prepare and organize Project Contractor activities on site;
Manager Contractor) will have a SCPM who is responsible for • Review the Site-Wide HASP;
the successful completion of the Project Contractor • Review and concur with their contract-specific SHASP;

field operations. The SCPM reports to the CPM for • Provide equipment and materials for site operations;
site-related matters. • Emphasize safety and health and hold personnel accountable for safe work performance;
SHASP, and Project safety and health program;
• Monitor and evaluate safety and health performance of site operations;
• Report and investigate accidents and incidents and sign the reports; and
Contractor Safety Officer Each Project Contractor (except the A&E Bien Hoa • Review the Site-Wide HASP;
Contractor) will have a CSO who is the on-site • Prepare the contract-specific SHASP and submit for approval;
Project Contractor safety and health supervisor • Prepare and facilitate the Project Contractor serum dioxin monitoring program;
present during Project Contractor fieldwork • Maintain copies of the Site-Wide HASP and contract-specific SHASP on site during field
activities as required by EM 385 1-1. The CSO will activities;
work directly with the A&E Bien Hoa Contractor • Implement provisions of the Site-Wide HASP, contract-specific SHASP, and the Project
LSECS. If the CSO must be absent from the site, the safety and health program;
safety and health duties must be delegated to another • Ensure that Project Contractor personnel meet training and medical surveillance
qualified responsible party at the site (e.g., SCPM). requirements;
The CSO must ensure that the person assuming this • Conduct site orientation training, Site-Wide HASP and contract-specific SHASP review,
temporary role is first aid/CPR certified and is fully and daily safety meetings;
aware of their role and responsibilities during the • Conduct training as new activities and/or hazards are introduced;
CSO’s absence. If a qualified replacement is not • Emphasize safety and hold Project Contractor personnel accountable for safe work
available, then work shall stop for a safety stand- performance;
down until a qualified/certified person is available. • Review site hazards and establish safety control measures;
• Maintain a hazardous substance inventory list and provide to the A&E Bien Hoa
Contractor LSECS;
• Maintain copies of each SDS and provide updates to the A&E Bien Hoa Contractor
LSECS;
• Maintain safety equipment and supplies;
• Perform daily safety inspections and document safety and health findings on inspection
log and provide to the A&E Bien Hoa Contractor LSECS;
• Track safety and health deficiencies to ensure that they are corrected and report any
deficiencies to the A&E Bien Hoa Contractor LSECS;
SHASP, and Project safety and health Program;
• Establish site control work zones and boundaries;
• Enforce and monitor the PPE requirements in the Site-Wide HASP;
• Enforce and monitor the decontamination procedures established in the Site-Wide
HASP;
• Perform and/or coordinate site exposure monitoring;
• Report safety violations or safety and health concerns promptly to the SCPM and A&E
Bien Hoa Contractor LSECS;
• Monitor and evaluate safety and health performance of Project Contractor operations;

• Maintain and report safety and health records including anonymous blood serum dioxin
monitoring results to the A&E Bien Hoa LSECS to be shared with USAID;
• Work with the A&E Bien Hoa Contractor LSECS to maintain and update Activity Hazard
Analyses (AHAs) as Project Contractor activities progress;
• Report and investigate accidents and incidents and provide reports to the SCPM and
A&E Bien Hoa Contractor LSECS;
• Communicate with the A&E Bien Hoa Contractor LSECS regarding site activities and
Site-Wide HASP compliance; and
All Project Personnel
Site Personnel Perform designated work activities. • Understand and comply with the Site-Wide HASP and the applicable Project Contractor
SHASP,
• Follow instructions of the CSO or other competent authority,
• Promptly report any unsafe work conditions or unsafe work practices,
• Immediately report all injuries or illnesses to direct supervisors and the CSO, and
• Stop work for a safety stand-down if unsafe working conditions are encountered.

4.3 DESIGNATED COMPETENT PERSONS
A “Competent Person” (as defined by OSHA) is a person who is capable of identifying existing and
predictable hazards in the surroundings or working conditions that are unsanitary, hazardous, or
dangerous to employees, and who has authority to take prompt corrective measures to eliminate them.
The Project safety and health program requires that a designated competent person be present on the
job site for work to be performed. The names of Competent and/or Qualified Persons and proof of
competency or qualification to meet specific OSHA Competent/Qualified Persons requirements will be
provided as site operations progress (Appendix C – List of Designated Competent Persons). At a
minimum, the Designated Competent Persons shall successfully complete the OSHA 30-Hour
Construction Outreach Training Course or equivalent and the USACE 40-Hour EM 385-1-1 USACE Safety
& Health training course, and present certificates of successful completion of training. The competent
person shall present a letter from the CSO designating them as a Competent Person. For a list of
Competent Persons for this Project, refer to Appendix C.
4.4 PRE-TASK SAFETY AND HEALTH ANALYSIS

The first step in safety and health planning for a new work activity is defining the types of work and
associated risks. AHAs are tools to identify and define the work activities and associated tasks, identify
the sequence of work and specific anticipated hazards, and establish necessary control measures to
eliminated or reduce each hazard to an acceptable risk level. The Project safety and health program
requires that AHAs be prepared before beginning new work activities that involve hazards not previously
experienced or where a new Project Contractor is to perform the work activities. New work crews must
review and familiarize themselves with the applicable AHA. The AHA is developed to identify hazards and
control measures for primary work activities and tasks. Work does not proceed on a new activity (or one
with a modified AHA) until the AHA (or modified AHA) has been reviewed by the CSO and A&E Bien
Hoa Contractor HSO, accepted by the relevant, contract-specified USAID official, and the AHA has been
reviewed with involved Project personnel. AHAs are living documents that are continuously reviewed and
modified when appropriate to address changing site conditions or operations.
AHAs will be prepared for work activities and tasks considered potentially hazardous including the initial
work tasks listed below.
• General site activities,

• Site reconnaissance,
• Site characterization activities,
• Vehicle travel,
• Mobilization
• Decontamination/Demobilization,
• Excavation and earthmoving, and
• Working over or near water.
AHAs have been prepared for the first three tasks and are presented as example AHAs in Appendix D
– Activity Hazard Analyses Forms. However, preparation of AHAs will be required for all work activities
considered potentially hazardous. The blank AHA form is included in Appendix A. AHAs will be
developed to suit new site activities and annexed to the Site-Wide HASP. Project Contractors shall
prepare AHAs for their specific activities and include them in their contractor-specific SHASP.

4.5 SAFETY COMPLIANCE AND ENFORCEMENT
Compliance with safe work practices and the Project safety and health program is required of Project
personnel in every capacity. Project personnel have the right to stop work if they determine the conditions
are unsafe or will rapidly become unsafe. Effectiveness of the Site-Wide HASP is highly dependent upon
the involvement, direct supervision, and enforcement of safety requirements by supervisory personnel.
4.5.1 GENERAL SAFE WORK PRACTICES

Project personnel must work in a safe manner to ensure a safe work environment. Standard safe work
procedures include, but are not limited to, the following:
• 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.

Loose or frayed clothing, dangling ties, rings, etc., must not be worn around moving machinery or other
mechanical sources of entanglement.
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.
4.5.4 SAFETY RULE ENFORCEMENT

In accordance with its contract with USAID, the CPM must establish a procedure to direct or suspend
the Project Contractor’s work and notify the USAID CO/COR and LSECS when the continued
performance of the work will endanger the health, welfare, or safety of the public or Project personnel.
Project personnel must obey work orders from the A&E Bien Hoa Contractor COP and LSECS to suspend
the Project Contractor’s work if the A&E Bien Hoa Contractor COP and LSECS have determined that
continued performance of work will endanger the health, welfare, or safety of the public or any Project
worker. The A&E Bien Hoa Contractor COP and LSECS will notify the USAID CO/COR immediately
when such work suspensions are issued.
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

• Other disciplinary action.
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.
5 SUBCONTRACTORS AND SUPPLIERS

This section applies to subcontractors and suppliers that will support Project activities and establishes the
qualifications and safety requirements they will be held to.
5.1 LIST OF SUBCONTRACTORS

The names of subcontractors and suppliers and their provided services will be recorded in Appendix E
of this Site-Wide HASP. This list will be updated as new phases of work commence and new
subcontractors and suppliers are identified.
5.2 SELECTION OF QUALIFIED SUBCONTRACTORS

Selection of qualified safety-conscious subcontractors is essential for quality work performance and
necessitates including contractor safety performance as a criterion for subcontractor selection. The
standard operating procedure for contractor safety qualification review described below will be
implemented by Project Contractors during subcontractor selection.
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).
Required subcontractor safety and health submittals include:
• Completed and signed contractor safety qualification questionnaire;

• For U.S. subcontractors, copies of OSHA 300 logs for the last 3 years;
• For non-US subcontractors, information regarding any employment-related injuries or
illnesses requiring more than first aid treatment;
• For U.S. subcontractors, letter from the Workers’ Compensation insurance carrier certifying
the contractor’s Experience Modification Rate (EMR) for the most recent 3 years (an EMR
greater than 1.0 requires a written explanation of measures being taken to reduce this rate);
• For non-U.S. subcontractors, information regarding insurance coverage for all workers
experiencing employment-related injuries or illnesses;
• For U.S. subcontractors, copies of OSHA citations (as applicable);
• For non-U.S. subcontractors, copies of safety citations received as a result of employment-
related injuries or illnesses; and
• Listing or copy of the table of contents of the contractor’s written safety program.

The Contracts Administrator and applicable safety and health personnel reviews the questionnaire and
compares the information against the contractor safety qualification criteria. If all criteria are met, the
Contracts Administrator may deem the contractor’s safety qualification as acceptable.
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.
5.3 SUBCONTRACTOR SAFETY REQUIREMENTS

Subcontractors who come on site to perform fieldwork and/or enter controlled areas of the site are
subject to Site-Wide HASP requirements. Project requirements for controlling and coordinating
subcontractor compliance with safety and health requirements are detailed below.
• 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.

• Subcontractors are required to observe the buddy system during work activities 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.
• Subcontractors are required to report unsafe work conditions or unsafe work practices
promptly to the subcontractor supervisor and the CSO.
• Subcontractors are required to report all incidents immediately to the CSO.
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.
6.1 GENERAL TRAINING REQUIREMENTS

Employees will receive safety training regarding potential hazards associated with their work assignments.
Site orientation safety meetings involving review of pertinent aspects of the Site-Wide HASP are
completed for personnel before Project fieldwork. Daily safety meetings are conducted for field
operations, and attendance is documented.
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.
TABLE 6-1. TRAINING REQUIREMENTS

Name of Course Applies To Notes
40-Hour Hazardous Waste Operations All Project personnel who will work in Pre-Work completion is required.
and Emergency Response (Hazwoper) contaminated areas where exposure is Hands-on training with PPE, respiratory
Training or equivalent possible protection, decontamination, and
Anyone using PPE or respiratory general site procedures is required.
protection on the site
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

Name of Course Applies To Notes
Hazard Communication Training All site personnel Repeated as new hazards or chemicals
are discovered or introduced
First Aid / CPR Training All worksite emergency response Minimum of two are required for every
personnel work shift
Bloodborne Pathogens (BBP) Training First aid certified personnel Includes a review of procedures to be
followed in the event of exposure to
BBP
Site Orientation Briefing All site personnel Conducted by CSO and/or A&E Bien
Hoa Contractor LSECS and COP
Medical Surveillance Program Participants of the medical surveillance Conducted by CSO and/or A&E Bien
Orientation program (Level 1 and 2); and workers Hoa Contractor LSECS and COP prior
that will be onsite during intrusive or to commencement of work activities,
remedial treatment operation activities and/or before participation in the
for less than 30 days (8 hours per day) medical surveillance program
per year
Emergency Response Plan Training All site personnel Conducted by CSO prior to
commencement of work activities
Daily “Tailgate” Safety Meetings All site personnel Conducted by CSO. Discusses lessons
learned from previous day, planned
work activities for present day, and
special safety considerations
Monthly Supervisor Safety Meeting CM, LSECS, CSOs, supervisors, Conducted by A&E Bien Hoa
foremen Contractor LSECS. Discuss the
month’s safety performance and any
concerns for upcoming activities
UXO Avoidance Training All site personnel Conducted prior to commencement of
work activities
Fall Protection Training Any employees working at heights over For use of harnesses, retraction and
1.5 meters above the ground surface fall-stop systems, and use of barricades
Ladder Safety Training Any employees using portable or fixed For safe use of all types of ladders and
ladders portable stairs
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.
6.2 SITE ORIENTATION BRIEFING

Site Project personnel must receive a site orientation briefing and review the Site-Wide HASP before start
of their work activities. Project personnel will sign a form documenting that they have reviewed the Site-
Wide HASP, understand the requirements, and agree to follow them.
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):
• Provisions of the Site-Wide HASP,

• Facility background and scope of work,
• Key personnel and safety and health responsibilities,
• Site hazards anticipated,
• Exposure monitoring program,
• Site control procedures,
• PPE requirements,
• Procedures for reporting unsafe conditions or unsafe work practices,
• Procedures for reporting an injury/illness,
• Emergency procedures including warning signals and evacuation procedures,
• Location/route to the emergency hospital,
• Training requirements,
• Medical surveillance requirements, and
• Recordkeeping procedures.
6.3 MEDICAL SURVEILLANCE PROGRAM ORIENTATION

Participants of the medical surveillance program must receive a program orientation briefing before
participation in the medical surveillance program and the start of their work activities. The required
participants of the medical surveillance program are detailed in section 9.18.1. Workers that are not
required to participate in the medical surveillance program but will be onsite during intrusive and/or
remedial treatment operation activities for less than 30 days (8 hours per day) per year must receive the
program orientation training. Visitors to the site are not required to receive the medical surveillance
program orientation training. At a minimum, the program orientation training will include:
• Health risks related to dioxin exposure,

• Major site exposure routes for dioxin,
• Examinations included in the medical surveillance program,
• Frequency of examinations,
• Action limits for serum dioxin levels,
• Assurance of confidentiality, and
• Data management of anonymous dioxin blood serum results.
6.4 SAFETY MEETINGS

Daily safety meetings are required at the beginning of each work shift to discuss operational tasks to be
completed and pertinent site safety topics. Meetings are documented and those in attendance are required
to sign a “Tailgate Safety Meeting Record” or equivalent form.
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.

6.5 EMERGENCY RESPONSE PLAN TRAINING
Emergency response plan training is conducted by the CSO or A&E Bien Hoa Contractor LSECS during
initial site safety orientation briefings and elements are periodically reviewed during daily safety meetings.
Emergency response plan training reviews: Site-Wide HASP emergency response plan information that
includes escape procedures and routes, critical plant operations, employee accounting following an
emergency evacuation, rescue and medical duties, means of reporting emergencies, persons to be
contacted for information or clarification, and off-site emergency support services and agreements. In
addition, an emergency evacuation drill will be held quarterly or more frequently if required by GVN or
USAID.
7 SAFETY AND HEALTH INSPECTIONS

Periodic safety inspections are required to evaluate the effectiveness of the safety program. The
responsibility for conducting safety inspections is assigned to the CSO and A&E Bien Hoa Contractor
LSECS or designee. The frequency of inspections, documentation, deficiency tracking system, and follow-
up procedures are reviewed in Safety Inspections and Audits. A description of Project safety inspection
and audit procedures is provided in the following Sections.
7.1 SAFETY INSPECTIONS

The CSO and A&E Bien Hoa Contractor LSECS or designee will conduct periodic and random safety
inspections of Project operations. During the Project, daily jobsite safety inspections and daily equipment
inspections will be conducted when site activities require more than one day of field work. Examples of
inspections required are presented in Table 7.1.
TABLE 7.1. TABLE OF INSPECTIONS*

Equipment to be Inspected Person Responsible Frequency
PPE
Hard Hats Worker Before each use
Gloves Worker Before each use
Boots Worker Before each use
Impermeable Coveralls Worker Before each use
Eye Protection Worker Before each use
Hearing Protection Worker Before each use
RESPIRATORY PROTECTION
Dust Masks Worker Before each use
Respirators Worker Before each use
Cartridges Worker Before each use
SAFETY & HYGIENE
First Aid Kits CSO Weekly; replenish supplies as needed
Eyewash stations CSO, LSECS Monthly
Drench showers CSO, LSECS Monthly
Fire Extinguishers CSO, LSECS Monthly
Drinking water CSO Beginning of every work shift
Washing water, soap, towels CSO Beginning of every work shift
Cool-down area CSO Beginning of every work shift
Condition of toilets CSO Beginning of every work shift
Condition of showers CSO Beginning of every work shift
Condition of washing facilities CSO Beginning of every work shift
HAND TOOLS
Cords, plugs, receptacles, ground fault Worker Before each use
circuit interrupters

Equipment to be Inspected Person Responsible Frequency
Machine guards Worker Before each use
General condition Worker Before each use
VEHICLES/HEAVY EQUIPMENT
Seat belts Driver/Operator and all passengers Before each use
Fuel supply Driver/Operator Beginning of every work shift
Lubricant levels Driver/Operator Beginning of every work shift
Interior cleanliness and repair Driver/Operator Beginning of every work shift
Exterior cleanliness and repair Driver/Operator Beginning of every work shift
Tires/tracks Driver/Operator Beginning of every work shift
Hydraulics Driver/Operator Beginning of every work shift
Brakes Driver/Operator Beginning of every work shift
Lights, signals Driver/Operator Beginning of every work shift
Horn, backup warning Driver/Operator Beginning of every work shift
EXCAVATIONS
Soil conditions Competent Person Daily
Barriers/fencing at top Competent Person Daily
Shoring and shielding in place and in Competent Person Daily
good condition for excavations >1.5m
Safe exits in place for excavations Competent Person Daily
>1.25m
ELECTRICAL HAZARDS
Overhead line marking CSO or CM Daily
Buried cable marking CSO or CM Daily
Ladders more than 3.05m from power CSO or CM Daily
lines
All temporary power lines in good CSO or CM Daily
repair
GFCI in place and working CSO or CM Daily
SITE CONTROL
Zones clearly delineated CSO or LSECS Daily
Warning signs in place for each zone CSO or LSECS Daily
Sign-in sheet ready CSO or LSECS Daily
Decontamination set up and ready CSO or LSECS Daily
Receptacles in place for soiled PPE and CSO or LSECS Daily
decontamination fluids
Contaminated waste properly stored CSO or LSECS Daily
and containment provided
CRZ dikes and spill prevention CSO or LSECS Daily
Drinking water supply ready in CZ CSO or LSECS Beginning of every work shift
Cool-down area prepared in CRZ CSO or LSECS Daily
GENERAL HOUSEKEEPING
Trash receptacles CSO or LSECS Daily
Work areas clear of trash CSO or LSECS Daily
Tools properly stored CSO or LSECS Daily
Lights in good working order CSO or LSECS Daily
Office trailers clean CSO or LSECS Daily
*To be modified to suit introduction of new equipment, work activities, or hazards.
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.

After an inspection, the CSO and A&E Bien Hoa Contractor LSECS will record identified safety and health
issues and deficiencies and indicate the actions, timetable, and responsibility for correction of deficiencies
on the “Safety and Occupational Health Deficiency Tracking List” form. The CSO and A&E Bien Hoa
Contractor LSECS will conduct follow-up inspections to correct identified deficiencies and document the
inspection deficiencies on the “Safety and Occupational Health Deficiency Tracking List” form.
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.
7.2 SAFETY AUDITS

The A&E Bien Hoa Contractor HSO and/or COP may also conduct independent safety audits based on
the type of job activities and potential hazards to be encountered on the site. Compliance with the HASP
and SHASPs will be reviewed during audits to ensure that the Project safety goals are being met. A random
number of workers will be interviewed to check knowledge of the Project policies and procedures, and a
random sampling of training records will be reviewed for completeness and authenticity. Safety inspection
forms will be reviewed to check hazards identified and corrective actions taken. Incident reports will be
reviewed for complete investigation information, and the contractors’ Hazard Communication Program
will be reviewed for completeness and currency of information. Within 60 days of the conclusion of the
audit, findings will be presented to the COP. If needed, recommendations for revision of the HASP and
SHASPs will be included in the presentation.
8 INCIDENT REPORTING AND INVESTIGATION

An incident is defined as “an unplanned, undesired event that adversely affects completion of a task.”
Incidents range in severity from “near misses” to fatalities. Incidents will be reported in monthly exposure
data relative to man hours, or exposure hours, worked, and accident investigations, reports, and logs will
be compiled for annual submittal to the GVN and USAID. A review of Project incident reporting and
investigation procedures is provided in the following Sections.
8.1 INCIDENT REPORTING

Employees must immediately report all incidents, including injuries, illnesses, property damage, liability
exposure cases, spills, fires, and near miss incidents to their team supervisor/lead and/or CSO. CSOs are
responsible for notifying the A&E Bien Hoa Contractor LSECS and CM, who in turn are responsible for
notifying the A&E Bien Hoa Contractor COP and HSO. The USAID CO/COR and the A&E Bien Hoa
Contractor HSO must be contacted immediately in injury or illness cases requiring more than first aid
treatment.
Injured Worker's
CSO LSECS COP CO/COR
Worker Supervisor

FIGURE 8-1 INCIDENT REPORTING FLOW CHART
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:
• Time and date of accident;

• Employer's name, address, and telephone number;
• Name and job title of person reporting the accident;
• Location of the incident/accident site;
• Name of person to contact at the site of the accident;
• Name and address of any injured employee(s);
• Nature of injury;
• Location to which the injured employee was moved;
• List and identity of law enforcement agencies present at the site of the accident; and
• Description of the accident and whether the accident scene has been altered.
8.2 INCIDENT INVESTIGATION

The CSO responsible for an activity involved in an incident will participate in a complete investigation with
the A&E Bien Hoa Contractor LSECS and/or COP. Chargeable vehicle accidents are to be investigated by
the CSO and A&E Bien Hoa Contractor LSECS and/or COP and the findings reported immediately to
their USAID CO and COR. This will require employee interviews, inspection, and photographing of the
unaltered accident scene and equipment involved (as applicable). Project incident reporting and
investigation forms must be completed and submitted according to the Project incident reporting and
investigation procedures within 24 hours of the injury or accident (immediately for a serious injury

involving hospitalization or fatality). Forms to be completed include (as applicable) Injury/Illness Report
Form and On-Site Vehicle Accident Report Form. The root cause of the incident and recommendations
of prevention must be identified.
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:
• description of the circumstances leading up to the accident;

• cause of the accident;
• corrective measures taken to prevent recurrence;
• description of the injury;
• name and location of the medical facility giving examination and treatment;
• whether or not the employee was permitted to return to work after examination and
treatment by the doctor;
• if employee was not allowed to immediately return to work, an estimate or statement of the
number of days lost from work; and
• physician’s statement that the employee is fit to return to work.
8.3 INCIDENT FOLLOW-UP

After the incident investigation is complete, the CSO, LSECS, and CM will take measures to prevent a
repeat of the incident, including hazard mitigation, change in work practices, and revision of the AHA
where necessary.
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

illnesses occurring outside of the 50 Unites States and its territories. The OSHA form will be utilized
during the conduct of this Project as a means to maintain complete records of injuries/illnesses occurring
as a result of exposures on this Project site.
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.
8.4 MONTHLY EXPOSURE REPORT

During the Project, A&E Bien Hoa Contractor will provide Project hours worked and Project injury and
illness information to the USAID CO/COR on a monthly basis as requested. Incident investigation reports
and an updated Project OSHA 300 log will be provided to the USAID CO should an injury or illness occur.
The CSO shall provide the above information to the LSEC on a monthly basis in advance of the report to
the USAID CO/COR.

9 PLANS AND PROGRAMS REQUIRED BY THE SAFETY
MANUAL
This section of the Site-Wide HASP contains information specified in EM 385-1-1, Appendix A, Section
3i “Plans, Programs Procedures required by the Safety Manual.” Table 9-1 identifies the plans that are
required for this project from those in EM 385-1-1. As the Project progresses and SHASP are developed,
additional plans may become required.
TABLE 9-1. PLANS REQUIRED BY EM 385-1-1

REQUIRED FOR HASP
PLAN NAME EM385-1-1 SECTION
THIS PROJECT? SECTION
Fatigue Management Plan 01.A.20 Yes 9.1
Emergency Plans 01.E.01 Yes 9.2
Site Sanitation/Housekeeping Plan 02.B Yes 9.3
Medical Support Agreement 03.A.01, 03.A.03 Yes 9.4
Bloodborne Pathogen Program and Exposure 03.A.05 Yes 9.5, Appendix G
Control Plan
Automatic External Defibrillator (AED) 03.B.04 No --
Program
Site Layout Plan 04.A Yes 9.6
Access and Haul Road Plan 4.B Yes 9.7
Hearing Conservation Program 05.C Yes 9.8
Respiratory Protection and Personal 05.G Yes 9.8
Protective and Safety Equipment Plan
Health Hazard Control Program 06.A Yes 9.9
Hazard Communication Program 06.B.01 Yes 9.12, Appendix H
Process Safety Management Plan 06.B.04 No --
Lead Compliance Plan 06.C.02 and specifications No --
Asbestos Abatement Plan 06.C.03 and specifications No --
Radiation Safety Program 06.F No --
Abrasive Blasting procedures 06.I.01 No --
Heat Stress Monitoring Plan 06.J.02 Yes 9.13
Cold Stress Monitoring Plan 06.J.04 No --
Indoor Air Quality Management 06.L No --
Mold Remediation Plan 06.L.04 No --
Chromium (VI) Exposure Evaluation 06.M No --
Crystalline Silica Evaluation 06.N.02 No --
Lighting Planning for Night Operations 07.A.06 No --
Traffic Control Plan 08.C.05 Yes 9.14
Fire Prevention Plan 09.A.01 Yes 9.15
Wild Land Fire Management Plan 09.L No --
Arc Flash Hazard Analysis 11.B No --
Assured Equipment Grounding Conductor 11.D.05, Appendix E Yes 9.16, Appendix I
Program
Hazardous Energy Control Program & 12.A.01 Yes 9.17
Procedures
Standard Pre-Lift Plan – Load Handling 16.A.03 No --
Equipment
Critical Lift Plan – Load Handling Equipment 16.H No --
Naval Architectural Analysis – Load Handling 16.L No --
Equipment (Floating)
Floating Plant Inspection and Certification 19.A.01 No --
Severe Weather Plan for Marine Activities 19.A.03 No --
Emergency Plan for Marine Activities 19.A.04 No --
Man Overboard/Abandon Ship Procedures 19.A.04 No --

REQUIRED FOR HASP
PLAN NAME EM385-1-1 SECTION
THIS PROJECT? SECTION
Float Plan for Launches, Motorboats, and 19.F.04 No --
Skiffs
Fall Protection and Prevention Plan 21.D No --
Demolition/Renovation Plan (to include 23.A No --
engineering survey)
Rope Access Work Plan 24.H No --
Excavation/Trenching Plan 25.A.01 Yes 9.18
Fire Prevention and Protection Plan for 26.D.01 No --
Underground Construction
Compressed Air Work Plan for Underground 26.I.01 No --
Construction
Erection and Removal Plan for Formwork and 27.C No --
Shoring
Pre-Cast Concrete Plan 27.D.01 No --
Lift Slab Plan 27.E No --
Masonry Bracing Plan 27.F.01 No --
Steel Erection Plan 28.B No --
Explosives Safety Site Plan 29.A No --
Blasting Plan 29.A, 26.J No --
Dive Operations Plan 30.A.14, 30.A.16 No --
Safe Practices Manual for Diving Activities 30.A.15 No --
Emergency Management Plan for Diving 30.A.18 No --
Tree Felling and Maintenance Program 31.A.01 No --
Aircraft/Airbase Construction Safety and 32.A.02 No --
Phasing Plan
Aircraft/Airbase Safety Plan Compliance 32.A.02 No --
Document
Site Safety and Health Plan for HTRW 33.B Yes 9.19
Services Work
Confined Space Entry Procedures 34.A.05 No --
Confined Space Program 34.A.06 No --
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.
9.1 FATIGUE MANAGEMENT PLAN

Extended work hours in the field environment increase worker fatigue. A Fatigue Management Plan (FMP)
shall be completed by the A&E Bien Hoa Contractor and Project Contractors as part of the Site-Wide
HASP to provide guidance on reducing fatigue and associated hazards whenever work hours:
• exceed 10-hours a day for more than four consecutive days,

• exceed 50-hours in a seven-day work week,
• exceed 12-hours a day for more than three consecutive days, or
• exceed 58-hours a week for sedentary (to include office) work.
The FMP for site activities including operation of motor vehicles (specifically excavation contractors) shall
address the following conditions for operator work hour limitations:
• 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;
• 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.
Training shall include:
• 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.
9.2 EMERGENCY PLANS

Required Emergency Plans include (as applicable to Project work):
• Emergency Plan: Procedures and Tests

• Emergency Plan: Firefighting Plan
• Emergency Plan: Posting of Emergency Telephone Numbers
• Emergency Plan: Severe Weather
• Emergency Plan: Spill Prevention and Control Plan.
These required plans are presented in detail in the following Sections
9.2.1 EMERGENCY PLAN: PROCEDURES AND TESTS

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” (Table 9-2). The CSO and A&E Bien Hoa
Contractor LSECS is responsible for determining the route to the emergency hospital and the
transportation available (ambulance, military vehicle, private vehicle, etc.) before the start of field
operations. 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.

TABLE 9-2. EMERGENCY CONTACT LIST
Point of Contact Contact Number
Ambulance – Emergency 115
Emergency Hospital: Phone: +84 251 3955 955
DONG NAI INTERNATIONAL HOSPITAL
USAID Contracting Officer (CO) Office: + (84 4) 3935 2177
Suzanne Johnson Email: [email protected]
USAID Contracting Officer Representative (COR) Office: + (84 24) 3935-2190
Anthony (Tony) Kolb Mobile: +84 96 200-2758
Email: [email protected]
Government of Vietnam (GVN) Contact Office: Security Escort (daily assignment always on site)
TBD
A&E Bien Hoa Contractor Chief of Party (COP) Mobile: +84 (84) 9360544
Andrew Sayers-Fay Email: [email protected]
A&E Bien Hoa Contractor Deputy Chief of Party (DCOP) Mobile: +84 (36) 7731624
Suzan Samara Email: [email protected]
A&E Bien Hoa Contractor Construction Manager (CM) Mobile: +84 (90) 3511779
Quang Mai Email: [email protected]
A&E Bien Hoa Contractor Lead Safety and Environmental Mobile: +84 (91) 8077753
Compliance Specialist (LSECS) Email: [email protected]
Thang Vu
[Other Contractor TBD] Office:
Mobile:
Email:
[Subcontractor TBD] Office:
Mobile:
Email:
[Vendor or Service Provider TBD] Office:
Mobile:
Email:
[Contractor Safety Officer] Office:
Mobile:
Email:

9.2.1.1 EVACUATION ROUTES AND PROCEDURES:
Evacuation routes will be reviewed during site safety orientation briefings and periodically during daily
safety meetings.
9.2.1.2 SAFE DISTANCES AND PLACES OF REFUGE

Safe evacuation distances will be determined based on the hazards present and the magnitude of the
emergency. For a small fire which is largely contained in a small grassy area, the evacuation distance would
be shorter than from an area where flammable substances are stored or used. As the Project proceeds
and new work areas are created, the safe distances will be determined by the CSO, and places of refuge
during an emergency will be designated and communicated to site workers. All workers will be instructed
to proceed to the designated area and remain there until a headcount can be performed and safe
evacuation from the Project site can be afforded.
9.2.1.3 EMERGENCY ALARMS

For major emergency events (e.g., large fires, gas line or electrical line breaks) an emergency evacuation
alarm will be sounded. The alarm will be three long blasts on a vehicle horn or a compressed air horn.
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.
TABLE 9-3. EVACUATION ALARM AND ASSEMBLY INFORMATION

EVACUATION ALARM
A compressed air horn will be used to communicate an 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 LSECS and Site Superintendent.
Evacuation Alarm Vehicle horn or air horn (three long blasts)
9.2.2 EMERGENCY PLAN: FIREFIGHTING PLAN

The CSO will consult with the Bien Hoa Airbase’s emergency responders regarding response to fire
incidents associated with site work before initiating site activities.
In the event of a large fire (beyond the immediate control of a small onsite fire extinguisher) the
following five steps will be followed:

1. Site alarm will be sounded,
2. Work will stop,
3. Personnel will immediately evacuate and assemble at a predetermined upwind site location,
4. Emergency responders will be called, and
5. Personnel will not re-enter the fire area until it is cleared by emergency responders and the
CSO.
In the event of a small fire (within the immediate control of a small on-site fire extinguisher) and
depending on facility-specific requirements the following three steps will be followed:
2. Trained personnel will use an on-site fire extinguisher to put out the fire only if it can be
performed safely, and
3. Work in the immediate area will stop until fire is resolved and area cleared by the CSO.
If fire becomes too large for a hand held extinguisher, emergency responders will be notified and
procedure for a large fire (above) will be followed.
9.2.3 EMERGENCY PLAN: POSTING OF EMERGENCY TELEPHONE NUMBERS

An Emergency Contact List is provided in Table 9-2 of this Site-Wide HASP. An Emergency Hospital and
Route map with written instructions will be posted in the operations trailer on the site. The CSO and CM
will enter the location into a Global Positioning System (GPS) or mobile phone for audible directions to
the emergency hospital facility. The CSO must check the emergency hospital route before start of
fieldwork. NOTE: Due to driving restrictions for A&E Bien Hoa Contractor personnel, a hired car service
or emergency response vehicle will be used for transport to the closest hospital facility (Dong Nai
International Hospital) (Figure 9-1). The contractor SHASP will include specific procedures for
transportation of injured workers to the emergency treatment facility.

EMERGENCY HOSPITAL ROUTE MAP
Emergency Hospital:
NAME DONG NAI INTERNATIONAL HOSPITAL

Bệnh viện Quốc tế Hoàn Mỹ Đồng Nai
1048A Phạm Văn Thuận, Tân Mai, Thành phố Biên Hòa, Đồng Nai, Vietnam
PHONE +84 251 3955 955
FIGURE 9-1 VICINITY MAP OF DONG NAI INTERNATIONAL HOSPITAL AND EMERGENCY HOSPITAL
ROUTE:
Bien Hoa Airbase Worksites
NOTE: USE THE NEAREST GATE TO EXIT THE AIRBASE.
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.

9.2.4 EMERGENCY PLAN: SEVERE WEATHER
Safety procedures are required for cases of inclement weather for outside work locations or other
adverse environmental conditions (i.e., strong winds, rain, lightning, typhoon, tornado, earthquake, and
tsunami). The CSO or designated on-site personnel shall be responsible for checking the weather
conditions at a minimum of twice a day.
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.

9.2.5 EMERGENCY PLAN: SPILL PREVENTION AND CONTROL PLAN
In areas where drums and containers are stored, measures tobe taken to contain and isolate the entire
volume of the material in storage will be provided in Emergency Plan: Spill Prevention and Control Plan.
Materials stored could include fuel, decontamination fluids, lubricants, and other waste and unused
chemical products as required on the site.
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.
9.2.6 MEDICAL EMERGENCY PROCEDURES PLAN

In the event of a medical emergency, the following procedures will be implemented. The exposed or
injured person will be removed from immediate danger, first aid and/or CPR will be administered by
trained site personnel (a minimum of two trained and certified first aid/CPR personnel are required to be
present on site at all times). Individuals who are required to work alone or in remote areas shall be trained
in first aid and shall be provided with an effective means of communication to call for assistance in the
event of an emergency.
Emergency medical assistance will be called and will be informed of the following:
• Name and location of person reporting;

• Location of accident or incident;
• Specific directions to the emergency location, as needed;
• Phone number from which the person is calling;
• Number of persons needing help;
• What is currently being done for the victim (for life-threatening injuries, request instructions
from emergency services dispatcher);
• Name and affiliation of injured party;
• Description of injuries;
• Details of any chemical involved;
• Summary of the accident, including suspected causes and time of occurrence; and
• Temporary control measures taken to minimize further risk.

Nonessential personnel will be evacuated from the work area until the CSO determines that it is safe for
work to resume.
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.
9.2.7 FIRST AID AND CARDIOPULMONARY RESUSCITATION AVAILABILITY PROGRAM

A list of designated qualified first aid/CPR personnel will be posted by the first aid station/kit in the Project
Contractor office or maintained by the CSO. Copies of certificates will be maintained on site, and
retraining will be completed as required by the agency providing the certification. At least two certified
employees per shift are required on the site at all times. Appendix J presents the Project list of designated
first aid responders that will be maintained as the Project progresses.
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.
9.2.8 BLOODBORNE PATHOGENS PROGRAM

Designated first aid responders are required to complete BBP training as required in the OSHA BBP
standard (29 CFR 1910.1030). BBP training is provided to personnel who have potential exposure to
blood or other potentially infectious materials
9.2.9 EMERGENCY DECONTAMINATION PROVISIONS PLAN

Refuges established on the Project site will be equipped with adequate supplies for emergency, abbreviated
decontamination. Drums and containers will be used to store first aid kits and personnel decontamination
supplies, including water for washing, moistened towelettes for hands and face, and plastic bags for holding
reusable PPE until full decontamination can be performed. A supply of clean PPE will be included in the
drums in the event that modesty clothing worn underneath coveralls has been contaminated or damaged.
When emptied, the drums will be used for holding wastes generated during the abbreviated
decontamination procedure.

9.3 SITE SANITATION/HOUSEKEEPING PLAN
This section of the Site-Wide HASP reviews site sanitation plans.
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.
9.3.2 DRINKING WATER

An adequate supply of potable water shall be provided for personnel. Drinking water will be provided to
workers in portable drinking water dispensers with lids and a tap. Dispensers will be clearly marked
“Drinking Water” and will not be used for other purposes. Individual disposable cups will be used for
large containers of water. Use of a common cup or dipping from the container is prohibited. Unused
disposable cups will be stored in a sanitary container and a waste receptacle will be available for used cups
and empty disposable bottles.
9.3.3 NON-POTABLE WATER

Outlets for non-potable water, such as water for firefighting purposes, shall be identified by A&E Bien Hoa
Contractor as “Caution – Water Unsafe for Drinking, Washing, or Cooking” to clearly indicate that the
water is unsafe and is not to be used for drinking, washing, or cooking purposes. Tanks containing non-
potable water shall be marked by A&E Bien Hoa Contractor as “Non-Potable” to indicate that the water
is non-potable. A&E Bien Hoa Contractor personnel will be instructed to avoid the use of non-potable
water for purposes other than firefighting or dust control.

9.3.4 TOILETS
Toilets available for Project Contractors will be designated by A&E Bien Hoa Contractor personnel.
Portable toilets will be provided on site by a vendor when permanent toilets are not availbale. The
vendor will be responsible for properly emptying, cleaning, maintaining, and repairing all units
supplied throughout the duration of all site activities. Toilets shall be kept in a sanitary condition at
all times. The number of units required will be based on the number of personnel on site as
follows, per Annex 1 of Circular No. 19/2016/TT-BYT “Guidelines for Occupational Health and
Safety Management.”
TABLE 9-4. HYGIENIC WORKS IN WORKPLACES

Hygienic Utilities Per Shift Number of Employees
1. Urinals 11-20 persons/urinal <300
21-35 persons/urinal >300
2. Urinals* 11-20 persons/urinal <300
21-35 persons/urinal >300
3. Bathrooms 1-20 persons/bathroom 1 - 300
21-30 persons/bathroom 301-600
30 persons/bathroom >600
4. Menstruation rooms 1-3 female/room 1-300
30 female/room >300
5. Handwash taps 15-20 persons/tap <300
35 persons/tap >300
6. Wardrobes 1 person/drawer or small cabinet or Apply to businesses and workplaces where
hook workers contact with dangerous, hazardous and
poisonous factors that may cause occupational
diseases
*Note: this information is repeated in the Circular as shown here.
9.3.5 WASHING FACILITIES

Washing facilities available for Project Contractors will be identified by the CSO. If necessary, the CSO
will ensure provision of running water, soap, and individual means of drying in designated washing facilities;
however, moist towelettes may be used where it is not feasible to provide running water. Personnel shall
be required to wash their hands and face before breaks and lunch or use individual disposable sanitizing
cloths where water is not available. Good personal hygiene practices are to be followed at all times. Food,
beverages, tobacco products, or cosmetics are not allowed, in potentially contaminated areas. Eating,
drinking, chewing gum or tobacco, and smoking are allowed only in designated clean areas.
9.3.6 WASTE DISPOSAL

Garbage and refuse disposal shall be arranged for by Project Contractors at Project sites. In the event
that wastebaskets or trashcans are not made available by the facility, containers shall be provided for the
collection of trash and other non-hazardous waste. Containers used for garbage shall be equipped with
covers. Garbage and other waste shall be disposed of at least daily. Specific facility requirements for waste
recycling and disposal shall be met.
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-

hazardous or hazardous. Decontamination procedures will minimize potentially contaminated waste
materials stream. IDW management and handling procedures are detailed in the Site-Wide Sampling and
Analysis Plan/Quality Assurance Plan.
9.4 MEDICAL SUPPORT AGREEMENT AND FIRST AID AVAILABILITY PROGRAM

Prior to the commencement of work activities on the site, the CSO will meet with the proposed medical
treatment facility, Dong Nai International Hospital, to ensure the appropriate treatment is available, and
the hospital is aware of the work to be performed. Contractors will ensure that facilities for personnel
decontamination are made available in the event of an injury, to include full body flush (or shower) and
eyewash stations. Decontamination may be required before an injured worker can be treated.
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.
9.5 BLOODBORNE PATHOGENS EXPOSURE CONTROL PLAN

The Bloodborne Pathogens Exposure Control Plan was developed in accordance with the BBP standard
as outlined in 29 CFR 1910.1030. The purpose of this exposure control plan is to minimize employee
occupational exposure to blood and other infectious body fluids. Please see Appendix G for specific
details of the plan.
9.6 SITE LAYOUT PLAN FOR TEMPORARY SITE FACILITIES

Due to the multi-phase nature of the site work, site layout is expected to change as work areas are
expanded or reduced.
Temporary site construction may include the following:
• Site operations/office trailers;

• Storage areas for materials, tools, and equipment;
• Storage areas for vehicle and equipment fuel;
• Storage areas for hazardous chemicals (paints, adhesives, lubricants, etc.);
• Personnel and heavy equipment/truck decontamination areas;
• First aid stations;
• Sanitation facilities; and
• Any other temporary facilities necessary for the safe conduct of constructions activities.
Temporary construction, trailers, and portable toilet facilities shall be properly anchored to withstand
winds and must meet applicable local building standards.
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

designation of contaminated, decontamination, and clean zones, colored silt fencing may be used to clearly
identify each zone.
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.
9.7 ACCESS AND HAUL ROAD PLAN

Prior to commencement of site activities, the contractor shall provide a copy of the proposed Access and
Haul Road Plan to USAID, A&E Bien Hoa Contractor, and the Bien Hoa Airbase facility for review. Such
roadways shall be designed in accordance with local engineering criteria, and construction shall not begin
on access or haul roads until final approval is granted by USAID.
The plans shall address:
• Road layout on the site;

• Widths, curve data (horizontal and vertical), and sight distances;
• Signs, road markings, and traffic control (where needed);
• Access control locations and methods;
• Roadway surfacing;
• Dust control measures; and
• Hazards adjacent to roads.
When roadways are adjacent to work areas, adequate barriers are required to prevent vehicles colliding
with site workers. Where roads are adjacent to steep drop-off, waterways, or prohibited areas, adequate
barriers are required. Barriers will be constructed with the permission of the Bien Hoa Airbase leadership.
9.8 PERSONAL PROTECTIVE AND SAFETY EQUIPMENT, HEARING CONSERVATION,

RESPIRATORY PROTECTION PLAN
The use of personal protective and safety equipment (PPE) is a control measure that is to be used only
after a hazard evaluation identifies hazards associated with a particular job or activity, and it is determined
that the hazards cannot be eliminated and/or controlled to an acceptable level through engineering design
or administrative actions. Process and engineering controls shall be utilized before PPE to protect
employees.
Selection of PPE is based on:
• Site activities to be conducted;

• Areas of the site where activities will be conducted;
• Weather conditions;
• Physical hazards in the work area; and
• Chemical hazards in the work area.

Each contractor on the site will be responsible for providing the appropriate PPE for each of their
employees working on the site and for providing the Personal Protection and Safety Equipment Plan as
required for their specific activities. Each contractor will also be responsible for ensuring various sizes of
PPE are available to fit all personnel regardless of sex, gender, or disability. The A&E Bien Hoa Contractor
LSECS will provide the minimum PPE requirements to the Project Contractors, who will provide examples
of the specific choice of PPE in their PPE Plan. The CSO and A&E Bien Hoa Contractor LSECS will review
the selection of PPE materials and the PPE Plan for compliance with the Site-Wide HASP. USAID will
review and approve the PPE plan prior to commencement of any work activities on the site. For the
duration of this Project, the minimum basic PPE requirements are as follows:
• 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.
9.8.1 RESPIRATORY PROTECTION

A written respiratory protection program will be required as part of the Site-Wide HASP, designed to
suit each work site and work activity. The program will include requirements for:
• Medical evaluations of employees required to use respirators;

• Fit testing procedures;
• Procedures for proper use of respiratory protection;
• Procedures for cleaning, decontaminating, disinfecting, maintenance, repair, storage, and
cartridge changeout;
• Employee training;
• Respiratory hazards potentially present;
• Use and care of respiratory protection;
• Donning and doffing;
• Respirator maintenance, cleaning, decontamination, disinfection, and cartridge changeout;
• Emergency procedures should the atmosphere change;

• Voluntary use guidelines; and
• Periodic evaluation of effectiveness of program.
Each contractor will be responsible for writing their respiratory protection program and submitting it to
the A&E Bien Hoa Contractor LSECS for review of compliance with the Site-Wide HASP. Project
Contractor’s USAID CO and COR will provide final approval of the contract-specific respiratory
protection programs.
9.8.2 HEARING CONSERVATION PROGRAM

A hearing conservation program is required to provide guidance to staff regarding when and what type of
hearing protection for each activity. Each contractor is responsible for ensuring compliance with hearing
conservation controls and protection at the Project site. The CSO is responsible for identifying noise
control areas or operations and implementing the program on the Project site. Site workers are
responsible for wearing appropriate hearing protection devices and following hearing conservation
procedures in a noise control area.
9.8.2.1 ACTION LEVELS

The action level for noise is an 8-hour total weight average (TWA) of 85 decibels measured on the
A-weighted scale (dBA). When site workers are exposed to sound that equals or exceeds this action level,
contractors must implement specific hearing conservation program elements, including audiometric
testing for exposed employees, training, and providing suitable hearing protection. Whenever possible,
administrative or engineering controls will be used to reduce the sound level. If such controls are not
feasible or fail to reduce worker noise exposures to below the action level, hearing protection will be
provided to employees to reduce employee noise exposures to below the action level.
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.
9.8.2.2.1 Noise Level Measurements
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.
Noise level readings shall be documented as follows:
• Date and time of reading,

• Area of site being monitored,
• Activities conducted during the monitoring, and

• Determination of the need for hearing protection.
The LSECS will communicate recommended hearing conservation measures to USAID, who will
implement protective measures as required.
9.8.2.2.2 Estimating Noise Levels
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.
9.8.2.3 HEARING PROTECTION

Contractors will provide hearing protection to all personnel who may experience 8-hour TWA noise
exposures of 85 dBA or greater. Hearing protection must provide sufficient attenuation to limit worker
noise exposure to an 8-hour TWA of less than 85 dBA. Hearing protection will be replaced as necessary,
and the CSO will supervise the correct use of hearing protection by every worker affected. CSO will
provide training in the use, care, and maintenance of hearing protection.
9.9 HEALTH HAZARD CONTROL PROGRAM

A Health Hazard Control Program is required to manage the multiple types of hazards on each job site.
The six major groups of hazards are presented in the following Sections:
9.9.1 CHEMICAL HAZARDS

Specific chemical hazards have been delineated in the AHA, included in Appendix D, which identifies the
chemicals, controls to prevent exposure, and emergency procedures should accidental exposure occur.
This information is provided for use by all Project Contractors in the design of their SHASP.
9.9.2 BIOLOGICAL HAZARDS

Biological hazards, or “biohazards,” include plants, animals or their products, and parasitic or infectious
agents that may present potential risks to participant health. The following sections discuss 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.
9.9.2.1 INSECTS AND ARACHNIDS

Stinging or biting insects or arachnids in the area of Bien Hoa Airbase Area include mosquitoes, centipedes,
bees, wasps, ticks, and various spiders. Standard Operating Procedures (SOPs) for reducing the chance of
insect bites or stings and for treating bites or stings are listed below.
9.9.2.1.1 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 Contractor Safety
Officer (CSO) 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 should 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.
9.9.2.1.2 Bee or Wasp Stings
If stung by a bee or wasp:
• Carefully remove the stinger (if present).

• Wash thoroughly with soap and water.
• Apply cold pack.
• Use antidote kit if known to be allergic. Call for emergency assistance if symptoms appear.
• Monitor for allergic reaction:
o Extreme swelling
o Redness
o Pain
o Face, neck, or tongue swelling
o Difficulty breathing
9.9.2.1.3 Spider Bites
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.
• Wash the bite area with soap and water.

• Apply cold pack.
o Extreme swelling
o Redness
o Pain
o Face, neck, or tongue swelling
• Request advanced medical care if symptoms persist.
9.9.2.1.4 Centipede Stings
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.
• Wash the area with soap and water.

• Apply hot water or hot compress to help deactivate the poison.
• Follow hot pack with ice/cold pack.
o Extreme swelling
o Redness
o Pain
o Face, neck or tongue swelling
• Seek immediate advanced medical care for the pain or for secondary infection.
9.9.2.1.5 Mosquitoes
Mosquitoes in Vietnam are known to carry a variety of diseases, including:
• 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.
• 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.

• Malaria
o Not active in the Bien Hoa Airbase Area at this time, but present in most rural areas in
Vietnam.
o Some strains are resistant to conventional drug treatment.
o Requires pretreatment with antimalarial drugs before, during, and after visiting the area.
• Japanese Encephalitis – Mosquito-Borne
o Transmitted by evening-biting mosquitoes that have fed on infected wildlife.
o High fever, severe headache, vomiting, diarrhea, fatigue, and weakness. Some neurological
symptoms.
o 20-30% fatality rate.
o No antiviral treatment available.
o Immunization available.
9.9.2.2 SNAKES
Of approximately 140 species of snakes identified in Vietnam, at least 37 are poisonous and potentially
harmful to humans, including:
1. Azemiops feae – Fea’s Viper

2. Bungarus candidus – Malayan Krait, Common Krait, Blue Krait, Javan Krait
3. Bungarus fasciatus – Banded Krait, Golden Banded Snake
4. Bungarus flaviceps – Red-headed Krait, Yellow-Headed Krait, Kinabalu Krait
5. Bungarus slowinskii – Red River Krait
6. Calliophis intestinalis – Banded Long-glanded Coral Snake, Brown Long-glanded Coral Snake
7. Calliophis maculiceps – Small-spotted Coral Snake
8. Calloselasma rhodostoma – Malayan Pit Viper
9. Daboia siamensis – Eastern Russell’s Viper, Daboia, Siamese Russell’s Viper
10. Deinagkistrodon acutus – Sharp-nosed Pit Viper, Hundred-pacer
11. Naja atra – Chinese Cobra, Taiwan Cobra, Formosan Cobra
12. Naja kaouthia – Monocellate Cobra, Thailand Cobra, Monacled Cobra
13. Naja siamensis – Thai Spitting Cobra
14. Ophiophagus hannah – King Cobra, Hamadryad, Jungle Cobra
15. Ovophis monticola – Mountain Pit Viper, Blotched Pit Viper
16. Ovophis tonkinensis – Tonkin Pit Viper
17. Protobothrops cornutus – Horned Pit Viper, Fan-Si-Pan Horned Pit Viper
18. Protobothrops jerdonii – Jerdon’s Pit Viper, Bourret’s Pit Viper
19. Protobothrops mucrosquamatus – Chinese Habu, Taiwanese Pit Viper
20. Rhabdophis angeli – Angel’s Keelback
21. Rhabdophis callichroma –
22. Rhabdophis chrysargos – Speckle-bellied Keelback
23. Rhabdophis nigrocinctus – Green Keelback, Banded Keelback
24. Rhabdophis nuchalis – Hubei Keelback
25. Rhabdophis subminiatus – Red-necked Keelback, Heller’s Keelback
26. Sinomicrurus kelloggi – Kellog’s Coral Snake
27. Sinomicrurus macclellandi – Macclelland’s Coral Snake

28. Triceratolepidophis sieversorum – Three Horned-scaled Pitviper
29. Trimeresurus albolabris – White-lipped Green Pit Viper, White-lipped Pit Viper, White-lipped
Tree Viper
30. Trimeresurus gumprechti – Gumprecht’s Green Pit Viper
31. Trimeresurus macrops – Dark Green Pit Viper, Large-eyed Pit Viper
32. Trimeresurus popeiorum – Pope’s Pit Viper, Pope’s Green Pit Viper
33. Trimeresurus stejnegeri – Chinese Bamboo Pit Viper, Chinese Green Tree Viper
34. Trimeresurus truongsonensis – Quang Binh Pitviper
35. Trimeresurus vogeli – Vogel’s Green Pit Viper, Vogel’s Pitviper
36. Tropidolaemus philippinensis – South Philippine Temple Pit Viper
37. Tropidolaemus wagleri – Wagler’s Pit Viper, Temple Pit Viper
During site reconnaissance activities:
• 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.
9.9.2.2.2 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.
• 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.

o Cut or excise the area around the bite.
o Use suction.
o Apply poultices, ointments, or folk remedies to the bite.
o Apply ice or heat to the wound site.
o Administer medication, alcohol, or caffeine.
Treating medical personnel may prescribe acetaminophen (Paracetamol or Tylenol) for pain, which can
be extreme.
9.9.2.3 DOGS AND OTHER MAMMALS

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 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.
9.9.2.3.2 First Aid for Animal Bites or Scratches
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.
• Wash the area thoroughly with soap and water.

• Apply antibiotic cream and cover with a clean bandage.
• Seek advanced medical care at the nearest hospital facility.

9.9.3 MANUAL MATERIAL HANDLING HAZARDS
Material handling devices must be used for handling heavy or bulky items whenever possible rather than
manual material handling. Whenever handling heavy or bulky items, the material handling needs should be
evaluated in terms of weight, size, distance, and path of movement. The following hierarchy for selection
of material handling means must be used:
• elimination of material handling needs by engineering,

• movement of material by mechanical device (i.e., lift truck),
• movement by manual means with handling aid (i.e., dolly, cart), and
• movement using safe lifting techniques.
Personnel must be trained in safe lifting procedures including:
• size up the load first;

• get help if the load is bulky, heavy, or of unwieldy length;
• be sure of footing;
• lift with your legs while keeping your back straight;
• keep your balance; do not twist under strain or jerk the load; and
• keep the load close to your body.
When two or more persons are carrying long material, such as a portable ladder, all persons must carry
the material on the same shoulder and lift or lower the material in unison.
9.9.4 AIR CONTAMINANT HAZARDS

Air contaminants are of concern during excavation, earthmoving, and transportation activities during dry
months. Specific hazards are delineated in the AHA, included in Appendix D. The AHA includes
chemicals, controls to prevent exposure, and emergency procedures should accidental exposure occur.
While dioxin itself is not a volatile chemical, it is present in the soil and dust at the site.
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.
9.10 PPE REQUIREMENT PROGRAM

As stated in Section 9.8 Personal Protective and Safety Equipment, PPE will be required for intrusive field
operations based on the following criteria:
• Site activities to be conducted;

• Areas of the site where activities will be conducted;
• Weather conditions;
• Physical hazards in the work area; and
• Chemical hazards in the work area.

The A&E Bien Hoa Contractor LSECS and HSO will establish minimum required appropriate PPE
for work activities and assign the level of protection. PPE levels of protection are discussed below
in Section 9-10.1. CSOs are required to review the minimum PPE requirements and determine if
additional requirements are needed for their Project Contractor work activities. Project
Contractors must include in their SHASP a donning and doffing procedure to suit the level of
protection, type of PPE used, and decontamination procedures to be followed. A suggested
sequence for donning and doffing PPE is provided in Appendix K (PPE Donning Procedures and
Personnel Decontamination Process). The use of PPE has implications for heat stress which is
discussion in Section 9.12.
9.10.1 LEVELS OF PROTECTION

The individual components of clothing and equipment must be assembled into a full protective
ensemble that both protects the worker from site-specific hazards and minimizes the hazards and
drawbacks of the PPE ensemble itself.
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.
9.10.1.1 LEVEL A PROTECTION

Level A should be selected when the greatest level of skin, respiratory, and eye protection is
required. Level A protection should be used when:
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.
The following constitute Level A equipment; it may be used as appropriate.

• Positive-pressure, full face-piece, self-contained breathing apparatus (SCBA), or positive
pressure supplied air respirator (SAR) with escape SCBA, approved by National Institute of
Occupational Safety and Health NIOSH;
• Totally-encapsulating chemical-protective suit,
• Coveralls,*
• Long underwear,*
• Gloves, outer, chemical-resistant,
• Gloves, inner, chemical-resistant,
• Boots, chemical-resistant, steel toe and shank,
• Hard hat (under suit),* and
• Disposable protective suit, gloves and boots (depending on suit construction, may be worn
over totally-encapsulating suit.)
9.10.1.2 LEVEL B PROTECTION

Level B should be used when the highest level of respiratory protection is necessary but a lesser
level of skin protection is needed. Level B protection should be used when:
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.
The following constitute Level B equipment; it may be used as appropriate.
• Positive-pressure, fullface-piece SCBA, or positive-pressure SAR with escape SCBA

(NIOSH approved);
• Hooded chemical-resistant clothing (overalls and long-sleeved jacket; coveralls; one or two-
piece chemical-splash suit; disposable chemical-resistant overalls);
• Coveralls,*
• Gloves, outer, chemical-resistant;
• Gloves, inner, chemical-resistant;
• Boots, outer, chemical-resistant steel toe and shank;
• Boot-covers, outer, chemical-resistant (disposable);*
• Hard hat,* and
• Face shield.*
9.10.1.3 LEVEL C PROTECTION

Level C should be used when the concentration(s) and type(s) of airborne substance(s) is known
and the criteria for using air purifying respirators (APRs) are met. Level C protection should be
used when:
A. The atmospheric contaminants, liquid splashes, or other direct contact will not adversely
affect or be absorbed through any exposed skin;

B. The types of air contaminants have been identified, concentrations measured, and an APR is
available that can remove the contaminants; and
C. All criteria for the use of APRs are met.
The following constitute Level C equipment; it may be used as appropriate.
• Full-face or half-mask, APRs (NIOSH approved);

• Hooded chemical-resistant clothing (overalls; two-piece chemical-splash suit; disposable
chemical-resistant overalls);
• Coveralls,*
• Gloves, outer, chemical-resistant;
• Gloves, inner, chemical-resistant;
• Boots (outer), chemical-resistant steel toe and shank;*
• Boot-covers, outer, chemical-resistant (disposable);*
• Hard hat,*
• Escape mask,* and
• Face shield.*
9.10.1.4 LEVEL D PROTECTION

Level D should be used when a work uniform affording minimal protection is needed or for nuisance
contamination only. Level D protection should be used when:
A. The atmosphere contains no known hazard, and

B. Work functions preclude splashes, immersion, or the potential for unexpected inhalation of or
contact with hazardous levels of any chemicals
The following constitute Level D equipment; it may be used as appropriate.
• 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.*
9.11 HAZARD COMMUNICATION PROGRAM

A Hazard Communication Program will be required from all contractors working on the Bien Hoa Airbase
Area Site. The A&E Bien Hoa Contractor LSECS will request from each CSO a hazardous substance
inventory list and copies of SDSs for hazardous substances present, stored, or used by facility personnel
and contractors in Project work areas. The Hazard Communication Program must include procedures to
establish, clearly designate, and communicate the potential hazards at the Project work areas using signage,
fencing, barricades, warning tape, and/or construction cones. At a minimum, signs will be posted at the
approved entry points and along the perimeter of each work area. Site personnel will be informed of the

hazardous substances they will be working with through Site-Wide HASP review and attendance at daily
safety meetings. Project hazard communication procedures shall be referred to for guidance and
requirements if hazardous chemical exposure is possible at the work site. Refer to Appendix H for
details of the Program.
9.12 HEAT STRESS MONITORING AND PREVENTION PLAN

Heat stress monitoring shall be conducted by all employers during all site operations at the Bien Hoa
Airbase Area. Personnel must be made aware that heat stress can occur during periods of elevated
ambient temperatures, moderate to heavy workloads, and when impermeable protective clothing is in
use. Personnel will be informed about the various forms of heat stress (e.g., heat cramps, heat exhaustion,
heat stroke), the symptoms of exposure, treatment for exposure, and prevention measures.
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.
9.12.1 CONTRIBUTING FACTORS

Many factors contribute to heat stress, including PPE, ambient temperature and environmental conditions
such as humidity, workload, and the physical and medical conditions of the employee. However, the
primary factors are elevated ambient temperatures in combination with fluid loss. Because heat stress is
one of the more common health concerns that may be encountered during field activities, employees
must be familiar with the signs, symptoms, and various treatment methods of each form of heat stress.
Heat stroke is the most serious heat-related illness. It is a threat to life and has a 20 percent mortality
rate. Direct exposure to sun, poor air circulation, poor physical condition, and advanced age directly affect
the tendency to heat stroke. Table 9-5 lists the most serious heat conditions, their causes, signs and
symptoms, and treatment.
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:
• Heat exhaustion: headaches; dizziness or lightheadedness; weakness; mood changes such as

irritability, confusion, or the inability to think straight; upset stomach; vomiting; decreased
or dark-colored urine; and pale, clammy skin
• Heat stroke: dry, pale skin with no sweating; hot, red skin that looks sunburned; mood
changes such as irritability, confusion, or the inability to think straight.

TABLE 9-5. HEAT STRESS CONDITIONS
Condition Causes Signs and Symptoms Treatment
Heat Cramps Fluid loss and electrolyte Painful muscle cramps,  Move affected worker to cool location
imbalance from especially in legs and abdomen  Provide sips of electrolyte fluids
dehydration Faintness and/or water
Profuse perspiration  Stretch cramped muscles
 Call for medical treatment if condition
worsens.
Heat Exhaustion Blood transports to skin Weak pulse  Move affected worker to cool location
to dissipate excessive Rapid and shallow breathing  Remove as much clothing as possible
body heat, resulting in General weakness  Provide sips of cool liquid (only if
blood pooling in the skin Pale, clammy skin conscious)
with inadequate return to Profuse perspiration  Fan the person but do not overcool or
the heart Dizziness chill
Unconsciousness  Treat for shock
 Call for medical transport to nearest
emergency facility
Heat Stroke Life-threatening condition Dry, hot, and flushed skin (may  Immediately transport affected worker
from profound sometimes be cool and moist) to hospital.
disturbance of body’s Constricted pupils  Move affected worker to cool area
heat-regulating mechanism Lack of or reduced sweating  Remove as much clothing as possible
Confusion and dizziness  Reduce body heat promptly by dousing
Early loss of consciousness with water or wrapping in wet cloth
Rapid pulse  Place ice packs under arms, around
Deep breathing at first, and neck, at ankles, and wherever blood
then shallow breathing vessels are close to skin surface
Muscle twitching leading to  Protect affected worker during
convulsions convulsions
Body temperature reaching
105 or 106°F or higher
9.12.2 HEAT STRESS PREVENTION PLAN

Heat stress prevention is critical to worker safety in the high heat and humidity of Vietnam. The
following Sections present the requirements for heat stress prevention:
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.
9.12.2.2 PREVENTION MEASURES

When working in hot environments, specific steps must be taken to lessen the chances of heat-related
illnesses. These include the following:
• 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;

• Providing frequent reminders to employees to drink frequently, and providing water
breaks;
• Designating a responsible individual to monitor water supply every 30 minutes, and
encouraging employees to report low supplies or dirty water;
• Placing water containers as close as possible to the workers, not away from them;
• Providing disposable/single use drinking cups to employees, or making provisions to issue
employees their own cups each day;
• Revising work schedules, when necessary, to take advantage of the cooler parts of the day
(such as working from 5:00 a.m. to 11:00 a.m. and 6:00 p.m. to nightfall);
• Setting up an adequate number of; umbrellas, canopies or other portable devices, at the
start of the shift, in close proximity (i.e., no more than 50-100 yards) to the work activity;
• Wearing light, loose-fitting, breathable clothing, hats with wide brims, and wetted cloth
positioned in such a way as to protect and shade the neck of workers from the sun;
• Avoid eating large meals before working in hot environments;
• Avoid beverages with caffeine or alcohol; and
• Conducting short tailgate meeting each morning (in the employees’ language) to remind
workers about the importance of the above-mentioned procedures, rest breaks, adequate
hydration and the location of shade.
9.12.2.3 WORK/REST SCHEDULE

When PPE must be worn (especially respirators and coveralls made of low-permeability materials),
suggested guidelines relating to ambient temperature and maximum wearing time are as shown in
Table 9-6.
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
9.12.2.4 PHYSICAL CONDITION MONITORING

To monitor the level of heat stress in an employee exhibiting one or more of the warning signs or
symptoms, the following must be measured:
• 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

cycle by one-third and keep the rest period the same. If the heart rate still exceeds 110
beats per minute at the next period, shorten the following work cycle by one-third.
• Body Temperature: Use a tympanic thermometer to measure body temperature at the
beginning and end of the work period. If temperature exceeds 99.6 degrees Fahrenheit (°F)
(37.6 degrees Celsius [°C]), shorten the next work cycle by one-third without changing the
rest period. If temperature still exceeds 99.6°F (37.6°C) at the beginning of the next rest
period, shorten the following work cycle by one-third. Do not permit a worker to wear
impermeable PPE when temperature exceeds 100.6°F (38.1°C).
9.13 TRAFFIC CONTROL PLAN

General Traffic Control Plan elements and procedures are reviewed below. Project Contractors
are required to include a Traffic Control Plan in their SHASPs for their contract-specific activities.
Traffic control at the site is paramount as it is expected that there will be multiple Project
Contractor and Airbase activities occurring simultaneously at the site. A written Traffic Control
Plan is required whenever a hazard exists to employees because of traffic or haulage conditions at
work sites that encroach upon public streets or highways. The traffic control selected for each
situation must be based on type of highway, traffic conditions, duration of operation, physical
constraints, and the nearness of the work space to traffic. The plan must be in conformance with
the “Manual of Traffic Controls for Construction and Maintenance Work Zones – 1996”, published
by the California State Department of Transportation. Project Contractor’s Traffic Control Plans at
a minimum must require the following:
• 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.

9.14 FIRE PREVENTION PLAN
General Fire Prevention Plan elements and procedures are reviewed below. An addendum to the Site-
Wide HASP will be added to suit facility requirements and procedures as site conditions change. Project
Contractors and site worker response to fires shall be modified to suit the requirements of the Bien Hoa
Airbase Emergency Response Plans.
The Project Contractor Fire Prevention Plan for the work site will be developed to include:
• major workplace fire hazards;

• potential ignition sources;
• types and locations of fire suppression equipment;
• assignments of responsibilities of maintaining the equipment;
• personnel responsible for controlling the fuel source hazards; and
• housekeeping procedures, including the removal of waste materials.
Employees and emergency first responders will be briefed on the fire hazards, the material and processes
to which they are exposed, and the emergency evacuation procedures. As site conditions change,
employees will be briefed with the updated information.
9.14.1 FIRE PREVENTION PLAN INFORMATION

The following information will be required in a Fire Prevention Plan:
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
• Operation of fuel-operated vehicles and equipment

• Hot work or work that involves burning, welding, cutting, brazing, soldering, grinding, using
fire or spark-producing tools, or other work that produces a source of ignition
• Lightning
• Electrical arcing
• Static electricity build-up
Fire Suppression/Control Equipment
• Multiple multipurpose ABC fire extinguishers may be maintained at the site

• An onsite water source will be identified should it be needed for fire control.
• Fire suppression and Control measure shall be in compliance with Bien Hoa Airbase
emergency response procedures
Personnel Responsible for Fuel Source Hazard Control
• 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):
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.

In the event of a small fire (within the immediate control of a small on-site fire extinguisher) and
depending on facility-specific requirements:
• Site alarm will be sounded;
• Trained personnel will use an on-site fire extinguisher to put out the fire only if it can be
performed safely;
• Work in the immediate area will stop until fire is resolved and area cleared by the CSO;
and
• If fire becomes too large for a handheld extinguisher, emergency responders will be notified
and procedure for a large fire (above) will be followed.
Housekeeping Procedures
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.
9.15 ASSURED EQUIPMENT GROUNDING CONDUCTOR PROGRAM

An AEGCP is required to protect Project staff and equipment form electrical hazards. All receptacle
outlets (125-volt, 15-, 20-, 30-amperage and greater) that provide electrical power during construction,
remodeling, maintenance, repair, or demolition shall have GFCI protection for personnel. GFCI protection
shall be provided on all circuits serving portable electric hand tools or semi-portable electric power tools
(such as block/brick saws, table saws, air compressors, welding machines, and drill presses).
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 not part of the permanent wiring of the building or structure shall be GFCI
protected by one of the following means:
• A receptacle outlet with integral GFCI protection,

• A standard receptacle outlet connected downstream of a receptacle outlet with integral GFCI
protection, or
• Receptacles protected by a GFCI-type circuit breaker.
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 conditions, or need, for the exception;

• Implementation of the requirements of the AEGCP; and
• The request for the exception, the AHA, and the AEGCP must be submitted and accepted by the
CSO prior to implementing the program. In addition, the CSO must submit these to the A&E Bien
Hoa LSECS for review prior to implementing the program.
9.16 HAZARDOUS ENERGY CONTROL PROGRAM & PROCEDURES

The Project program for control of hazardous energy sources (lockout/tagout) covers servicing and
maintaining machines and equipment where the unexpected energization or start up of the machines
or equipment, or release of stored energy could cause injury to employees. This program covers
controlling all hazardous energies, including electrical, mechanical, hydraulic, pneumatic, chemical,
thermal, and other energy sources.
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.
This lockout/tagout program includes:

• Definitions associated with lockout/tagout.
• Survey of equipment.
• Selection of locks, tags, and blocks.
• Energy control procedures.
• Periodic inspections.
• Employee training.
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.
Energized: Connected to an energy source or containing residual or stored energy.

Energy isolating device: A mechanical device that physically prevents the transmission or release
of energy, including but not limited to the following: a manually operated electrical circuit breaker;
a disconnect switch; a manually operated switch by which the conductors of a circuit can be
disconnected from all ungrounded supply conductors, and, in addition, no pole can be operated
independently; a line valve; a block; and any similar device used to block or isolate energy. Push
buttons, selector switches and other control circuit type devices are not energy isolating devices.
Energy source: Any source of electrical, mechanical, hydraulic, pneumatic, chemical, thermal, or
other energy.
Lockout: The placement of a lockout device on an energy isolating device, in accordance with an
established procedure, ensuring that the energy isolating device and the equipment being controlled
cannot be operated until the lockout device is removed.
Lockout device: A device that utilizes a positive means such as a lock, either key or combination
type, to hold an energy isolating device in the safe position and prevent the energizing of a machine
or equipment; includes blank flanges and bolted slip blinds.
Servicing and/or maintaining: Workplace activities such as constructing, installing, setting up,
adjusting, inspecting, modifying, and maintaining and/or servicing machines or equipment. These
activities include lubrication, cleaning or unjamming of machines or equipment and making
adjustments or tool changes, where the employee may be exposed to the unexpected energization
or startup of the equipment or release of hazardous energy.
Tagout: The placement of a tagout device on an energy isolating device, in accordance with an
established procedure, to indicate that the energy isolating device and the equipment being controlled
may not be operated until the tagout device is removed.

Tagout device: A prominent warning device, such as a tag and a means of attachment, which can
be securely fastened to an energy isolating device in accordance with an established procedure, to
indicate that the energy isolating device and the equipment being controlled may not be operated
until the tagout device is removed.
9.16.2 EQUIPMENT SURVEY

A survey of the site must be conducted to identify all energy sources either by physical inspection
alone or in combination with a study of drawings and equipment manuals, when applicable.
9.16.2.1 IDENTIFY AND LABEL THE ENERGY DISCONNECTING MEANS

Locate and mark the disconnecting means, indicating their function. Categorize the identification
details as to equipment supplied and energy type and magnitude (ex. Line #1, Press #4, Electrical 480
volts).
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.
9.16.2.2 METHODS OF LOCKING OUT CONTROLS

There are many different ways to lock out a piece of equipment including the following situations:
• 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 SELECTION OF LOCKS, TAGS, AND BLOCKS

Locks, tags, and blocks must be selected and purchased prior to beginning any Project work that
may require lockout/tagout of equipment or machinery.
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

to place their locks on the disconnecting means. After the work is completed, each worker
removes their lock and the machine is then returned to service.
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:
• Reason for the lockout.

• Name of the employee who is working on the equipment and how that person may be reached.
• Date and time the tag was put in place.
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.
9.16.4 WRITTEN STANDARD OPERATING PROCEDURE

If an energy isolating device is capable of being locked out, lockout shall be used. If an energy
isolating device is not capable of being locked out, a tagout system may be used.
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

injury. Lockout usually requires coordination between production and maintenance employees and
may extend over two shifts, which adds to the number of employees involved.
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.
Preparation for lockout

Employees authorized to perform lockout shall:
• 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:
• Notify all affected employees that servicing or maintenance is required on a machine or

equipment and that the machine or equipment must be shut down and locked out to perform
the servicing or maintenance.
• The authorized employee shall identify the type and magnitude of the energy that the machine
or equipment utilizes, shall understand the hazards of the energy, and shall know the methods
to control the energy.
• If the equipment is operating, shut it down by the normal stopping procedure (such as:
depress stop button, open toggle switch). The machine operator must be informed before
the power is turned off. Sudden loss of power could cause an accident.
De-energization and lockout

Prior to servicing or maintaining energized equipment, 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.

• Attach tags, which give the reason for placing the tag (and lock), the name of the person
placing the tag, how he/she may be contacted, and the date and time the tag was
placed/locked out. The lock or tag must not be removed without proper authority.
• Stored energy, such as that in capacitors, springs, elevated machine members, rotating fly
wheels, hydraulic systems, and air, gas, steam or water pressure, must be dissipated or
restrained by methods such as grounding, repositioning, blocking, or bleeding down.
− Steam, air, and hydraulic lines must be bled, drained, and cleaned out. There should
be no pressure in these lines or in reservoir tanks.
− Any mechanism under load or pressure, such as springs, must be released and
blocked.
− Any raised equipment that could move by sliding, falling, or rolling must be blocked.
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.
Testing equipment during lockout

In many maintenance and repair operations, machinery may need to be tested and energized before
additional maintenance work can be performed. These procedures must be followed:
• Clear all personnel to safety.

• Clear away tools and materials from equipment.
• Remove lockout devices and re-energize systems.
• Proceed with tryout or test.
• Neutralize all energy sources once again; purge all systems, and lockout prior to continuing
work.
Restoring equipment to service

When the servicing or maintenance is completed and the machine or equipment is ready to return
to normal operating condition, the following steps shall be taken:
• 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.

• Remove the lockout devices; the lockout device must only be removed by the person who
applied the device.
• Reenergize the machine or equipment. Note: The removal of some forms of blocking may
require re-energization of the machine before safe removal.
• Notify affected employees that the servicing or maintenance is completed and the machine
or equipment is ready for used.
9.16.5 PERIODIC INSPECTIONS

The CSO will conduct periodic compliance inspections of the energy control procedures at least
once for activities with known lockout and tagout needs that are in operation for 6 months or
longer. For activities that are in operation for one year or more, the CSO and A&E Bien Hoa
Contractor LSECS will conduct annual compliance inspections that are scheduled at random.
The compliance inspection shall include:
• 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:
• Types of energy sources anticipated;

• Methods of energy isolation and control;
• Purpose and use of energy control procedures; and
• Limitations of tagout.
Retraining is required whenever there is a:
• Change in job assignment;

• Change in machines, equipment, or processes that provide a new hazard; or
• Change in energy control procedures.
9.17 EXCAVATION/TRENCHING PLAN

This excavation safety program addresses:

• Utility clearance surveys,
• Perimeter guarding of excavations,
• Competent Person supervision and inspections,
• Personnel entry into a trench or excavation,
• Personnel working near a trench or excavation,
• Excavation procedures,
• Soil classifications,
• Excavation protective systems, and
• Excavations greater than 20 feet deep.
This safety program is applicable to all employees, contractors, subcontractors, and site visitors working
on the Project. The CSO and A&E Bien Hoa Contractor LSECS shall ensure that all activities conducted
in or near excavations or trenches are conducted in accordance with the requirements outlined in this
excavation safety plan. The CSO and A&E Bien Hoa Contractor LSECS are responsible for on-site
enforcement of this program.
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.
Hazardous Atmosphere: An atmosphere which by reason of being explosive, flammable, poisonous,

corrosive, oxidizing, irritating, oxygen deficient, toxic, or otherwise harmful, may cause death, illness, or
injury.
Registered Professional Engineer: A person who is registered as a professional engineer in Vietnam.
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."

Shoring (Shoring system): A structure such as a metal hydraulic, mechanical, or timber shoring system
that supports the sides of an excavation and which is designed to prevent cave-ins.
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.
9.17.2 UTILITY CLEARANCE SURVEYS

9.17.2.1 UNDERGROUND UTILITIES
The contractor shall identify all underground utilities, such as sewer, telephone, fuel, gas, electric, water
lines, or any other underground installations that reasonably may be expected to be encountered during
excavation work, prior to beginning any excavation work. The contractor shall check site utility plans,
interview Bien Hoa Airbase personnel regarding utility locations, and confirm work locations with Bien
Hoa Airbase personnel before work activity begins. The contractor shall walk the site with the A&E Bien
Hoa Contractor CM and note observations indicating underground features (e.g., valve boxes, standpipes,
saw cut concrete, or settled areas). A geophysical survey for utility clearance may be required at job sites
as determined by Bien Hoa Airbase personnel and the A&E Bien Hoa Contractor.
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:

• Types of marking to be used,
• Spray paint,
• Stakes and flagging,
• Color scheme for various utilities, and
• Perimeter of excavation.
Excavation outside of the perimeter is not permitted until/unless utilities have been identified and marked.
While any excavation is open, underground utilities must be protected, supported, or removed as
necessary to protect employees.
9.17.3 OVERHEAD UTILITIES

The contractor shall identify and mark all overhead utilities prior to the beginning of excavation work or
movement of heavy equipment across the site. Equipment with overhead Projections shall not operate
within a 10-foot (3-meter) radius of overhead power lines. Overhead power lines greater than 50,000
volts require additional distance as shown in Table 9-7 below:
TABLE 9-7. GENERAL CLEARANCES REQUIRED FROM ENERGIZED OVERHEAD HIGH-VOLTAGE

CONDUCTORS
Nominal Voltage
Clearance (Feet) Minimum Required
(Phase to Phase)
600 to 50,000 6
over 50,000 to 345,000 10
over 345,000 to 750,000 16
over 750,000 to 1,000,000 20
9.17.4 PERIMETER GUARDING OF EXCAVATIONS

Excavations shall be properly marked and guarded to prevent personnel from falling into an open hole.
Open trenches shall be barricaded, taped off, or secured in an equivalent manner during non-work periods.
9.17.5 COMPETENT PERSON SUPERVISION AND INSPECTIONS

A “Competent Person” (defined in Section 4.4) must be designated for each excavation site. The
designated Competent Person must be able to identify hazards and have the authorization to take prompt
corrective measures to eliminate them. The responsibilities of the designated Competent Person
described in the sub-sections below will include on-site supervision, inspections, and other duties.
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.
9.17.5.2 DAILY INSPECTIONS

The Competent Person shall document all inspections using the “Daily Excavation Safety Checklist” in
Appendix A. The “Soil Classification Checklist” shall be used whenever the soil classification for the
excavation is re-evaluated; whenever any properties, factors, or conditions that affect the soil classification
change in any way.

The Competent Person must make daily inspections of excavations, the adjacent areas, and protective
systems for evidence of a situation that could result in possible cave-ins, indications of failure of protective
systems, hazardous atmospheres, or other hazardous conditions. The Competent Person shall conduct
an inspection prior to the start of work and as needed throughout the shift.
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.
9.17.5.3 OTHER DUTIES

The Competent Person, who must also be qualified in structural design, shall design all structural ramps
used for access or egress for equipment and personnel.
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.
9.17.6 PERSONNEL ENTRY INTO A TRENCH OR EXCAVATION

Safety requirements that must be in place prior to personnel entry into a trench or excavation include
access control, protective systems, potentially hazardous atmospheres, quick egress, and water
accumulation.
9.17.6.1 ACCESS CONTROL

Access to trenching areas must be controlled and limited to authorized personnel. Prior to entering a
trench or excavation, employees must notify the Competent Person or the CSO and nearby equipment
operators whose activities could affect the trench or excavation.
9.17.6.2 PROTECTIVE SYSTEMS

Employees shall not enter a trench or excavation unless protective systems are in place. Protective
systems include shoring, shielding, sloping, benching, and other systems. Protective systems are not
required when:
• Excavations are made entirely in stable rock,

• Excavations are less than 4 feet (1.5 meters) in depth and examination of the ground by a
Competent Person provides no indication of a potential cave-in, or
• Personnel will not enter the trench or excavation.
9.17.6.3 POTENTIALLY HAZARDOUS ATMOSPHERES

If the CSO determines that there is a possibility of a hazardous atmosphere in a trench or excavation,
portable real-time air monitoring equipment must be available, properly calibrated, and operated by a

trained individual to ensure a safe atmosphere before personnel enter the excavation or trench. All air
monitoring activities and instrument calibration will be documented in an air monitoring log, which will be
provided daily to the CSO and A&E Bien Hoa Contractor LSECS.
“Hazardous atmosphere” is defined as:
• Containing less than 19.5% oxygen,

• Presence of a flammable atmosphere (Lower Explosive Limit (LEL) over 10%), or
• Presence of other known potential contaminants.
If any atmospheric hazards exist, the excavation or trench shall not be entered by any site personnel. If
air monitoring instrumentation is not available, the atmosphere in the excavation or trench shall be
assumed to be hazardous and no entry will be permitted.
9.17.6.4 QUICK EGRESS

Ramps, stairways, or ladders must be provided in excavations 4 feet (1.5 meters) deep or greater to allow
quick egress. Ramps or ladders must be placed within 25 feet (7.6 meters) of any work area, must be
secured from shifting, and ladders must extend at least 3 feet (1 meter) above the top of the trench or
excavation.
9.17.6.5 WATER ACCUMULATION

Entry is not allowed into excavations where water has accumulated or is accumulating unless adequate
precautions have been taken to protect employees against hazards posed by water accumulation. The
precautions could include special support or shield systems to protect from cave-in, water removal to
control the level of accumulating water, or use of safety harness and lifeline.
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.
9.17.7 PERSONNEL WORKING NEAR TRENCHES OR EXCAVATIONS

• Employees shall wear safety vests marked with or made of reflectorized or high-visibility
material whenever working in heavy equipment areas.
• No employee shall be permitted underneath loads handled by lifting or digging equipment.
• Employees shall be required to stand away from any vehicle being loaded or unloaded to
avoid being struck by any spillage or falling materials.
• Walkways or bridges with standard guardrails shall be provided where employees are
required or permitted to cross over excavations deeper than 6 feet (2 meters) and wider
than 30 inches (1 meter).
9.17.8 EXCAVATION PROCEDURES

• Where necessary, protective systems must be in place to protect employees from cave-ins.
Protective systems include shoring, shielding, sloping and benching, and other systems.
Protective systems are not required when excavations are made entirely in stable rock or

are less than 4 feet (1.5 meters) in depth and examination of the ground by a competent
person provides no indication of a potential cave-in.
• Sufficient ramps, stairways, or ladders must be provided in excavations 4 feet (1.5 meters)
deep or greater to allow quick egress. Ramps or ladders may be placed no more than 25
feet (7.6 meters) from a work area, must be secured from shifting, and ladders must extend
at least 3 feet (1 meter) above the top of the trench or excavation. Structural ramps must
be designed by a competent person.
• Mobile equipment warning systems are required when equipment operators do not have a
clear and direct view of the edge of the excavation.
• Material removed from an excavation or trench must be placed far enough from the edge
(at least 3 feet or 1 meter) to prevent it from sliding into the excavation or trench or from
stressing the trench or excavation walls.
• Surface encumbrances near an excavation (e.g., trees, boulders, poles) must be removed
before personnel enter the excavation.
• If possible, trenches or excavations must be covered or filled in when unattended.
Otherwise, strong barriers must be placed around the trench or excavation and lighting
must be provided at night if the trench or excavation is near a walkway or roadway.
• Trenches and excavations must be assessed by a qualified, competent person, even in the
absence of working personnel, whenever heavy equipment will be operating nearby in
order to ensure that the trench or excavation will support the weight of the equipment and
will not cause the accidental overturning of machinery.
• When fissures or tension cracks are apparent anywhere in an excavation, all work must
stop until the problem is corrected.
• Worker protection must be provided for protection from loose rock or soil on the
excavation faces.
• If trenches or excavations are near walkways or roadways, guards or warning barriers must
be placed to alert pedestrians and drivers of the presence of the trench or excavation.
• Water accumulation in or adjacent to excavations shall be prevented through the use of
diversion ditches or dikes.
• No existing walls or other structures shall be used as retaining walls to hold part of an
excavation or backfill unless it will safely withstand all expected loads.
• Bracings or other supports are required for excavations adjacent to streets, runways, or
other sources of vibration of super-imposed loads.
• Bracings or other support systems are required if sidewalks, pavements and other
structures are undermined to protect employees from the possible collapse of such
structures.
9.17.9 SOIL CLASSIFICATIONS

Each soil and rock deposit shall be classified by a Competent Person as stable rock, Type A soil, Type B
soil, and Type C soil. Soil classification shall be made based on the results of at least one visual test and
one manual test to identify the properties, factors, and conditions affecting the classification of the soil.
Soil classification must be documented using the “Soil Classification Checklist” in Appendix A. Such
analyses shall be conducted by a Competent Person using approved methods of soil classification and
testing.

If, after classifying a deposit, the properties, factors, or conditions affecting its classification change in any
way, a competent person shall evaluate the changes. The deposit shall be reclassified as necessary to reflect
the changed circumstances.
9.17.10 EXCAVATION PROTECTION SYSTEMS

Excavation protective systems shall be required when workers are to enter a trench or excavation 4 feet
(1.5 meters) or more in depth. Protective systems must be designed in compliance with Bien Hoa Airbase
or local regulatory requirements for protective systems. Protective systems shall have the capacity to
resist without failure all loads that are intended or could reasonably be expected to be applied or
transmitted to the system.
Protective systems include sloping, benching, and shoring and shielding.
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).
TABLE 9-8. MAXIMUM ALLOWABLE SLOPING

Maximum Allowable Slope
Soil or Rock Type
(Horizontal:Vertical)
Stable Rock Vertical (90º)
Type A Soil ¾:1 (53º)
[½:1 (63º) for short-term excavations – less than 24 hours and less than 12 feet deep]
Type B Soil 1:1 (45º)
Type C Soil 1½:1 (34º)
9.17.10.2 BENCHING
Benching is 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. Bien Hoa Airbase or local regulatory requirements shall be referenced for detailed information on
benching protective systems requirements.
9.17.10.3 SHORING AND SHIELDING

Shoring and shielding are excavation protective systems that include structures such as a trench
box, metal hydraulic, mechanical, or timber shoring system that supports the sides of an excavation
and which is designed to prevent cave-ins. Bien Hoa Airbase or local regulatory requirements shall
be referenced for detailed information on shoring and shielding protective systems requirements.

9.17.11 EXCAVATIONS GREATER THAN 20 FEET (6 METERS) DEEP
A Registered Professional Engineer is required to design the sloping, benching, or other protective systems
for excavations greater than 20 feet (6 meters) deep. The Competent Person will be responsible for
ensuring that necessary Registered Professional Engineer support is obtained.
9.17.12 TRAINING
Training for excavation sites includes excavation-specific training and site safety meetings.
9.17.12.1 EXCAVATION SAFETY TRAINING

Employee training in excavation safety procedures shall be provided in order to allow employees to
acquire understanding, knowledge, and skills necessary for safe performance of duties assigned in the
program. Excavation safety training shall be required for those individuals who will be designated as the
Competent Person for trenching and excavation operations. Excavation safety training shall include:
• 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.
9.18 SHASP FOR HAZARDOUS, TOXIC OR RADIOACTIVE WASTE (HTRW) WORK
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.

TABLE 9-9. OSHA SAFETY AND HEALTH PROGRAM CROSS-REFERENCE TABLE
OSHA Reference Requirement HASP Section
29 CFR 1910.120(b)(1)(ii) An organizational structure Section 4 – Responsibilities and Lines of
Authorities
29 CFR 1910.120(b)(1)(ii)(B) A comprehensive workplan TBD

29 CFR 1910.120(b)(1)(ii)(C) A site-specific safety and health plan Contractor SHASP
29 CFR 1910.120(b)(1)(ii)(D) The safety and health training program Section 6 – Training
29 CFR 1910.120(b)(1)(ii)(E) The medical surveillance program Section 9.18.1 – Medical Surveillance
Program
29 CFR 1910.120(b)(1)(ii)(F) The employer’s SOPs for safety and Section 3 – Safety and Health Policy
health Statement
29 CFR 1910.120(b)(1)(ii)(G) Any necessary interface between Section 3 – Safety and Health Policy
general program and site-specific Statement
activities
29 CFR 1910.120(b)(1)(iii) Site excavation Section 9.17 – Excavation/Trenching
Plan
29 CFR 1910.120(b)(1)(iv) Contractors and subcontractors Section 2.2 – Contractor Information;
Section 3.1 Project Safety and Health
Policy Statement; Section 4
Responsibilities and Lines of
Authorities
29 CFR 1910.120(b)(1)(v) Program availability Section 3.3 – Site-Wide HASP
Description
29 CFR 1910.120(b)(2)(i)(A) – (D) Organizational structure Section 4 – Responsibilities and Lines of
Authorities
29 CFR 1910.120(b)(3) Comprehensive workplan Section 2.3 – Scope; Site-Wide
Sampling and Analysis Plan/Quality
Assurance Plan
29 CFR 1910.120(b)(3)(i) Anticipated cleanup activities TBD
29 CFR 1910.120(b)(3)(ii) Work tasks and objectives Section 2.3 – Scope; Site-Wide
Sampling and Analysis Plan/Quality
Assurance Plan
29 CFR 1910.120(b)(3)(iii) Personnel implementation Section 4 – Responsibilities and Lines of
requirements Authorities
29 CFR 1910.120(b)(3)(iv) Personnel training implementation Section 6 – Training
29 CFR 1910.120(b)(3)(v) PPE program implementation Section 9.8 – Personal Protective and
Safety Equipment
29 CFR 1910.120(b)(3)(vi) Medical surveillance program Section 9.18.1 – Medical Surveillance
implementation Program
29 CFR 1910.120(b)(4)(i) Safety and health hazards Appendix D
29 CFR 1910.120(b)(4)(ii)(A) Risk or hazard analysis Section 10 – Risk Management Process
29 CFR 1910.120(b)(4)(ii)(B) Employee training Section 6 – Training
29 CFR 1910.120(b)(4)(ii)(C) PPE Section 9.8 – Personal Protective and
Safety Equipment
29 CFR 1910.120(b)(4)(ii)(D) Medical surveillance Section 9.18.1 – Medical Surveillance
Program
29 CFR 1910.120(b)(4)(ii)(E) Air monitoring, personnel monitoring 9.9 – Health Hazard Control Program
and environmental sampling
29 CFR 1910.120(b)(4)(ii)(F) Site control measures 9.19 – Site Control Measures
29 CFR 1910.120(b)(4)(ii)(G) Decontamination procedures 9.19 – Site Control Measures
29 CFR 1910.120(b)(4)(ii)(H) Emergency response plan 9.2 – Emergency Plans
29 CFR 1910.120(b)(4)(ii)(I) Confined space entry procedures N/A
29 CFR 1910.120(b)(4)(ii)(J) Spill containment program TBD
29 CFR 1910.120(b)(4)(iii) Pre-entry briefing Section 6.2 – Site Orientation Briefing
29 CFR 1910.120(b)(4)(iv) Effectiveness of site safety and health Section 7 – Safety and Health
plan Inspections

9.18.1 MEDICAL SURVEILLANCE PROGRAM
A medical surveillance program will be required for all personnel working at the site while activities are
conducted that could lead to dioxin exposure. Site activities with the potential for dioxin exposure include
intrusive activities as well as activities related to remedial treatment operations. The following activities
are examples of site activities that could lead to dioxin or other chemical exposure:
• Sampling – soil, sediments, groundwater, and surface water;

• Excavation and on-site transportation – dust generation;
• Brush and tree removal;
• Equipment decontamination;
• Placement of contaminated soil in storage structures;
• Operation and maintenance of remedial treatment system(s); and
• Any other activities that disturb the existing ground surface or increase the risk of exposure
to dioxin.
Medical monitoring will include blood serum dioxin monitoring as well as general medical surveillance
monitoring for other chemicals. Medical monitoring will be performed at two different levels of effort
and intensity:
Level 1 - Workers who will wear PPE 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 not wear 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
c. Personnel as designated by USAID or GVN.
The medical surveillance program is intended to monitor the employees’ health over the course of this
Project to ensure that protective measures at the site are appropriate and are being utilized properly by
the employees.
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.

Project Contractors shall include a description of their specific medical surveillance program which meets
or exceeds the requirements of this section of the Site-Wide HASP. This will include the requirements of
the examinations, frequency of testing, physician’s statement of employee fitness to work, medical
surveillance program orientation training, and assurance of confidentiality.
9.18.1.1 EXAMINATION REQUIRMENTS

The requirements of the medical examinations shall be determined by the attending physician/nurse
practitioner for both levels of surveillance.
For Level 1, the medical examinations must include, at a minimum:
• Medical and work history,

• Hazardous substance handling history,
• Blood testing,
o Complete Blood Count (CBC)/Sequential Multi-channel Analysis (SMA) blood
analysis for organ function and blood quality monitoring,
o Serum dioxin analysis,
• Other biological systems testing as determined by the attending physician, and
• Cardiopulmonary function testing to determine ability to wear respiratory protection and
PPE.
For Level 2, the medical examinations must include, at a minimum:
• Medical and work history

• Blood testing - Serum dioxin analysis
9.18.1.2 FREQUENCY OF EXAMINATIONS

The following schedule of examinations is required:
• 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.

9.18.1.3 PHYSICIAN’S STATEMENT OF EMPLOYEE FITNESS
The examining occupational health physician will review the results of the medical examination and
laboratory analysis and shall provide the employer, CSO, and the A&E Bien Hoa Contractor LSECS with
a written opinion for each employee examined under Level 1. The opinion shall include only the following
information:
• 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.
9.18.1.4 ASSURANCE OF CONFIDENTIALITY

With the exception of the examining occupational health physician’s written statement, no employee
medical records will be retained on the site. The physician’s written statement shall be maintained on site,
in a secured file or in electronic format, with the original stored off site in the employer’s offices.
9.18.2 BLOOD SERUM DIOXIN MONITORING

Project personnel involved with site activities that could lead to dioxin exposure or those designated by
USAID or GVN shall be part of the medical surveillance program that includes a blood serum dioxin
monitoring program as discussed in Section 9.18.1. Participants of the medical surveillance program will
receive a program orientation briefing before participation and the start of site activities. The blood serum
dioxin monitoring program will begin with baseline monitoring prior to the commencement of intrusive
activities at the site, such as sampling, brush clearing, excavation, and haul road construction (or later on,
remedial treatment). When baseline blood serum samples are collected, Project personnel will be required
to complete the Health and Lifestyle Questionnaire presented in Appendix L. This questionnaire will be
shared with the attending physician to interpret baseline results and determine the potential for previous
dioxin exposure.

9.18.2.1 RESPONSIBILITY
Project Contractors at the work site are responsible for making the testing available to their employees
who will be working at the site during intrusive and/or remedial treatment operation activities. Project
Contractors shall submit a written plan for compliance with this requirement, to include the following:
• Medical surveillance program orientation training,

• List of employees to be tested,
• Identification of employees work duties and classification as Level 1 or Level 2,
• Date(s) of sample extraction,
• Name of physician/medical facility performing the sample extraction,
• Name of the laboratory performing the serum extraction and preservation,
• Method and date of shipment to the laboratory,
• Name of examining Occupational Health physician who will interpret results and provide
employee consultations, and
• Frequency of sampling and analysis.
Employees will be assigned a unique identification number for tracking their results. This number shall be
provided to the attending physician, the analytical laboratory, CSO, and the A&E Bien Hoa Contractor
LSECS. The associated names will be retained only by the attending physician and the employer. The
anonymous dioxin blood serum results must be reported to the CSO and A&E Bien Hoa Contractor
LSECS in electronic and tabulated format to be shared with USAID. USAID will compile and maintain the
anonymous dioxin blood serum results for the duration of the Project.
9.18.2.2 DIOXIN OR PCDD/F INFORMATION

The term “dioxin” or PCDD/F refers to a group of polychlorodibenzodioxins (PCDDs) and
polychlorodibenzofurans (PCDFs). PCDDs are comprised of 75 “congeners,” and PCDFs are comprised
of 135 congeners. A “congener” is a variant or configuration of a common chemical structure. 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-Tetrachlorodibenzodioxin (2,3,7,8-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 (TEFs), and are
measures of how toxic each congener is relative to 2,3,7,8-TCDD.
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.

In humans, dioxin is stored in body fat, blood, and breast milk. Because dioxins adhere more readily to
fats, serum dioxin testing is performed to assess the level of PCDD/F in blood lipids. On average, serum
dioxin levels will decrease by half after seven years with no additional exposure.
9.18.2.3 ACTION LIMITS FOR SERUM DIOXIN LEVELS

Action limits for serum dioxin levels can be based on two types of values, either a reference-based value
or a health-based value. A reference-based value is the serum concentration that is expected to be present
in the general population who are not exposed to a particular source of dioxins. A health-based value is
the serum concentration associated with exposure to a safe dose that is protective of a particular health
effect.
9.18.2.3.1 Reference-based Values
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.
9.18.2.3.2 Health-based Values
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

level, maternal rat serum concentration, was used to estimate the human serum concentrations by
accounting for species differences without using modeling to convert an external dose to an 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.
9.18.2.3.3 Project Values
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.
PCDD/F (DIOXIN) PROJECT ACTION LIMIT

TEQ 30.0 pg/g TEQ lipid
Notes: – TEQ Action Limit value based on 2003 ACC report.
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.

The use of the 30 TEQ pg/g lipid as the dioxin action limit is conservative compared to the more technically
appropriate levels of 40 – 70 TEQ pg/g lipid derived by Aylward et al. (2008). The upper end of the range
of background concentrations for some of the older age categories of the general U.S. population may
exceed this Project dioxin action limit. For example, the 95th percentile total TEQ concentration for the
general U.S. population older than 20 years based on the NHANES 2007/2008 is 39.9 TEQ pg/g lipid,
which indicates there is a 5% chance that a person with only background exposures to dioxin in the U.S.
will have total serum dioxin concentrations higher than TEQ 39.9 pg/g lipid (Bichteler et al. 2017). This
would mean that there is a chance that personnel from the United States or Vietnam may have total
baseline TEQ concentrations that exceed the 30 TEQ pg/g lipid action limit without having any exposures
to dioxins from the site.
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.
9.18.2.4 BASELINE BLOOD SERUM DIOXIN LEVELS

The TEQ and congener values of the blood serum dioxin results will be reviewed every time samples are
analyzed. If baseline blood serum dioxin levels are above the 30 pg/g TEQ action limit, the examining
occupational health physician will be consulted for recommended further action, which could include:
• 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 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 not work on the site.
9.18.2.5 INCREASE IN BLOOD SERUM DIOXIN LEVELS

The total TEQ and individual congener concentrations of the blood serum dioxin results will be reviewed
every time samples are analyzed. If a periodic (annual, closeout, or post-incident) serum dioxin analysis
indicates an increase in total serum dioxin levels (all congeners) or exceedance of the 30 TEQ pg/g action
limit, then the congener-specific concentrations will be compared to the 95th percentiles for the individual
congeners to identify which congeners are the source of the elevated levels. If the 2,3,7,8-TCDD congener
is substantially elevated, this may indicate a site-related exposure, and the A&E Bien Hoa Contractor must
lead a review with the CSOs of the implementation and compliance by Project personnel of the Site-Wide
HASP. The A&E Bien Hoa Contractor will provide recommend changes to USAID for consideration. The
attending occupational health physician will also be consulted for recommended further action, which
could include:

o Dermal assessment
• Employee consultation with the attending occupational health physician to understand the
• 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 not work on the site.
In addition, the employee’s work habits will be assessed to ensure:
• PPE was used properly and consistently throughout Project assignment,

• Decontamination was performed before departure from the site,
• Worker did not enter the Project site unprotected in areas where PPE was required, and
• Other work habits did not contribute to the elevation of serum dioxin level.
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.
9.18.2.6 SAMPLE PROCESSING AND PRESERVATION

The laboratory requirements for serum extraction and preservation are included in Appendix L.

9.18.3 CONTRACTOR AND SUBCONTRACTOR HEALTH AND SAFETY PLAN REQUIREMENTS
All Project Contractor operations shall be conducted in compliance with this Site-Wide HASP. The SHASP
shall address the occupational safety and health hazards associated with the Project Contractor’s specific
site operations. Changes and modifications to the SHASP are permitted to suit changes in operations or
changing site conditions. The changes shall be made in writing with the knowledge of the A&E Bien Hoa
Contractor LSECS, HSO, and COP and the approval of the USAID CO/COR.
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.
9.19 SITE CONTROL MEASURES

Work zones shall be established on the site to limit the spread of contamination to off-site or clean areas.
The exact boundaries and locations will be established based on activities being conducted and
equipment/materials being used. The following zones will be established and clearly designated in the work
area using fencing, barricades, warning tape, and/or construction cones. Signs will be posted at the
approved entry points and along the perimeter of each zone.
9.19.1 CLEAN ZONE

The Clean Zone (CZ) will include:
• 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.
9.19.2 CONTAMINATION REDUCTION ZONE

This zone includes all decon activities to be conducted prior to departure of personnel or equipment from
contaminated areas of the site into the CZ. The CRZ will be subdivided into two areas: personnel decon
and personal hygiene and equipment decon. The area will be clearly delineated in the field with signage
and barricades to prevent entry by unprotected personnel. The CRZ will be located in an area downwind
and down slope from the CZ to prevent spread of airborne and waterborne contaminants generated
during decon. The CRZ will also be located upwind and up slope from the Exclusion Zone (EZ).

9.19.2.1 PERSONNEL DECON AND PERSONAL HYGIENE AREA
This area will be separated from the equipment decon area by a distance of at least 33 feet (10 meters).
The area will include the following:
• 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.
A suggested Personnel Decontamination Procedure is included in Appendix I.
9.19.2.2 EQUIPMENT DECON AREA

This area will be established on an impermeable surface or on heavy, multiple layers of plastic sheeting.
This area will be separated from the personnel decon area by at least 33 feet (10 meters) and placed to
prevent wind and surface runoff from contaminating the CRZ and CZ. The perimeter of the equipment
decon area will be diked or bermed, and the perimeter barrier shall be strictly monitored to prevent

runoff into clean areas. If possible, contractor shall also provide curtains or enclosures to prevent
overspray from reaching other areas of the site.
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.
The equipment decon area will include:
• Pressure washing equipment and appropriate non-flammable cleaning fluids (detergents or

soaps);
• Adequate water supply to allow for cleaning and rinsing all equipment;
• Wet/dry vacuum to collect accumulated water on the impermeable surface or from a sump
constructed at the lowest point of the area;
• Buckets, basins, brushes, hand tools, and other cleaning equipment to ensure complete
removal of contaminants; and
• A separate area for personnel decon.
The buddy system will be strictly observed during all heavy equipment decon activities due to the elevated
hazards associated with working on a wet surface.
9.19.3 EXCLUSION ZONE

The EZ or “hot” zone, is the contaminated area of the site where earthmoving, storage of contaminated
soils, sampling, sample processing, and drilling activities will take place. This is the area where known and
suspected hazardous chemicals are present in soil, sediment, surface water, and groundwater.
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.
9.19.4 ACCESS CONTROL

Access to each zone will be controlled by the contractor’s designated site control personnel. Entrance to
the EZ will be restricted to personnel utilizing the appropriate PPE and respiratory protection. Exit from
the EZ will be via the CRZ only and exit from the CRZ will be allowed after decontamination is complete.

Any personnel, equipment, or materials entering the CRZ or EZ will not be released for reuse or entry
into the CZ until decontamination is verified.
See Figure 9-2 Site Zones.

EXCLUSION
ZONE
CONTAMINATION
REDUCTION
ZONE (CRZ)
PERSONNEL CLEAN ZONE

DECON (CZ)
EQUIPMENT
DECON
ACCESS CONTROL
POINTS
FIGURE 9-2 SITE ZONES

(Not To Scale)

10 RISK MANAGEMENT PROCESSES
This section contains information specified in EM 385-1-1, Appendix A, Section 3j “Risk Management
Process.” General safe work practices and safety rule enforcement are described in Section 4.6. The total
risk management process for the Project utilizes AHAs as the primary tool for identifying, evaluating, and
controlling hazards to eliminate or reduce the associated risk. A detailed review of Project-specific hazards
and safety control measures are provided in the AHAs (see Appendix D) for known major site activities
of the Project.
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
10.1 HEALTH AND SAFETY PLAN FORMS

Completed standard HASP forms are maintained on site by the CSO for the duration of the Project. HASP
forms (see Appendix A) that may be used during the Project are indicated below:
• Accident Prevention Plan Review

• Activity Hazard Analysis Preparatory Phase Training Log
• Air Monitoring Log
• BBP Exposure Plan Annual Training Information
• BBP Post-Exposure Evaluation
• Calibration Log: Direct-Reading Monitoring Instrument
• Daily Excavation Safety Checklist
• Emergency Medical Notification Form
• Hazardous Substance Inventory List
• Injury/Illness Report Form
• Safety Inspection Report
• Safety Meeting Attendance Roster
• Site Control Log
• Soil Classification Checklist
• Tailgate Safety Meeting Record
• Training Attendance Roster
• Vehicle Accident Report
10.2 REPORTING OF HAZARDS AND SAFETY INSPECTIONS

Site personnel are encouraged to immediately report unsafe work conditions or unsafe work practices
observed to their supervisor, CSO, and the A&E Bien Hoa Contractor LSECS without fear of reprisal.
The CSO and A&E Bien Hoa Contractor CM and the LSECS will conduct periodic safety inspections at
the site to identify and correct hazards. Inspections will include physical inspections as well as review of
documentation described above. The results of inspection will be presented to the SCPM and/or COP
and the project team associated with the process that was inspected.

APPENDIX A. HEALTH AND SAFETY PLAN
FORMS

INITIAL SITE-WIDE HEALTH & SAFETY PLAN | A-1
HEALTH AND SAFETY PLAN FORMS
1. Site-Wide Health & Safety Plan Review
2. Activity Hazard Analysis Form
3. Activity Hazard Analysis Preparatory Phase Training Log
4. Air Monitoring Log
5. BBP Exposure Plan Annual Training Information
6. BBP post-Exposure Evaluation
7. Calibration Log: Direct-Reading Monitoring Instrument
8. Daily Excavation Safety Checklist
9. Emergency Medical Notification Form
10. Hazardous Substance Inventory List
11. HBV Vaccination Declination
12. Injury/Illness Report Form
13. On-Site Vehicle Accident Report Form
14. Safety Inspection Report
15. Safety Meeting Attendance Roster
16. Site Control Log
17. Soil Classification Checklist
18. Tailgate Safety Meeting Record
19. Training Attendance Record

SITE-WIDE Health AND SAFETY PLAN REVIEW
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.
Date Name Signature Company

ACTIVITY HAZARD ANALYSIS (AHA)
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.

3. 1.
2. 1. 1.
2. 1.
3. •
3. 1. 1.

2.
4. 1.
5. 2. 1.
6. 3. 2.
7. 4. 3.

ACTIVITY HAZARD ANALYSIS (AHA) (CONTINUED)
Training Requirements and

Equipment to be Competent or Qualified Personnel Inspection Requirements
Used Name(s)
1. Training 1.
Qualified Personnel
2. Training 1.
Qualified Personnel
3. Training 1.
Qualified Personnel

ACTIVITY HAZARD ANALYSIS PREPARATORY PHASE TRAINING LOG
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.
Name Signature Company

AIR MONITORING LOG
Location on Site
Date:
Conducted By:
Page Number:
______ ______ ______ ______ ______

Time Location (____) (____) (____) (____) (____)
Legend:
VOC: volatile organic compound

PID: photoionization detector
FID: Flame ionization detector
LEL: lower explosive limit
O2: oxygen
mg/m3: milligrams per cubic meter
ppm: parts per million

BLOODBORNE PATHOGENS EXPOSURE PLAN ANNUAL TRAINING INFORMATION
Training on the following information is required annually for all persons trained in first aid or
cardiopulmonary resuscitation (CPR).
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.
1) Epidemiology and symptoms of bloodborne diseases
HIV
• HIV attacks the body’s ability to protect itself against disease

• Initially no visible signs of having the virus
• Most people with HIV develop AIDS (acquired immune deficiency syndrome)
• There is no licensed and approved vaccination for HIV
HBV and HBC - Signs and symptoms include flu-like symptoms:
• 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
• Virus lives outside the body only a few hours

• Four modes of transfer:
o Blood
o Semen
o Vaginal secretions
o Breast milk

HBV
• Up to 100 times easier to catch than HIV

• Unlike HIV, can live outside of body for several days
• Primarily found in the blood of infected individuals.
• HBV has also been detected in other bodily fluids including urine, saliva/nasopharyngeal fluids,
semen, and menstrual fluids
• Transmission of HBV is done most efficiently by percutaneous introduction (i.e., needlestick
injury).
• Sexual transmission is also possible, though inefficient.
• There is no cure for HBV
• There is a vaccination for HBV
HCV
• Up to 100 times easier to catch than HIV

• Unlike HIV, can live outside of body for several days
• Ways to contract HCV
o Long-term kidney dialysis
o Sex with multiple partners
o Tattooing or body piercing with shared needles or unsterilized equipment
o Intranasal cocaine use with shared straws
• There is no cure for HCV
• There is no vaccination for HCV.
How BBP Spread on the Job
• 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
• Available in the Site-Wide HASP

4) Methods for recognizing tasks and other activities that may involve exposure to blood and
OPIM
• Exposure may occur when providing first aid or CPR.

5) Use and limitations of exposure prevention or reduction methods, including engineering
controls, work practices, and PPE
• 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).

6) PPE types and their proper use, location, removal, handling, decontamination, disposal,
and basis for selection
• 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
• Very low risk vaccine

• Three doses over 6 months; must receive all three doses
• >79 percent effective
• Free to employees who administer first aid/CPR
• May decline vaccine (but must sign waiver); may receive vaccine later.
8) Appropriate actions in the event of an emergency involving blood or OPIM
• 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
• Documentation of the exposure route and exposure incident circumstances

• Identification and documentation of the source individual (unless identification is not feasible
or prohibited by law)
• Collection and testing of blood for HBV, HCV, and HIV serological status
• Post-exposure prophylaxis, when medically indicated, as recommended by the Vietnam
Ministry of Health or U.S. Public Health Service
• Counseling
• Evaluation of reported illness
11) Signs and labels and/or color-coding regulated waste containers or other containers of
blood or OPIM
• Plastic impermeable bag labeled “Biohazardous Waste” or with the international symbol and
the word “Biohazard.”

• Bags must be tied shut and placed in closable, leak-resistant and labeled containers that can
prevent leakage during all handling, storage, transport, shipping, and other activities.

I have read and understand the Site-Wide HASP Bloodborne Pathogens Exposure Control
Annual Training Information.
Date ____________________________________
Training conducted by ____________________________________________________
Location ________________________________________________________________
Employee Printed Name Signature

BLOODBORNE PATHOGEN POST-EXPOSURE EVALUATION
I. Exposed Person II. Exposure Source (if legally obtainable)
Name: Date of Birth: Name: Date of

Birth:
Street Address: Street Address:
City, State, Zip Code: City, State, Zip Code:
Telephone Work: Employer:

Home/Mobile:
Employer: Employer’s Street Address:
Personal Physician or Clinic: City, State, Zip Code:
III. Description of Incident Resulting in Exposure
Date of Incident (month/day/year): Time of Incident:

a.m. p.m.
Specific Description of Incident (include estimate of volume of fluid involved):
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

POST-EXPOSURE EVALUATION (CONTINUED)
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:
IV. Significant Exposure Certification by Physician
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.
A Hepatitis B vaccination is recommended for the exposed person: ☐ Yes ☐ No

The exposed person has received the Hepatitis B vaccination: ☐ Yes ☐ No
Physician’s Name (print): Physician’s Signature: Date Signed:
Business Telephone No.: ( ) Physician’s License No.:

Physician’s Business Address (street, city, state, zip code):

CALIBRATION LOG: DIRECT-READING MONITORING INSTRUMENT
Location on Site
Conducted By:
Instrument:
Date: Calibration Gas/Concentration:
Name:
Comments: Readings:
Name:
Comments: Readings:
Name:
Comments: Readings:
Name:
Comments: Readings:
Name:
Comments: Readings:

DAILY EXCAVATION SAFETY CHECKLIST
The Competent Person is required to make a daily inspection of excavations, adjacent areas, and
excavation protective systems for evidence of a situation that could result in possible cave-ins, indications
of failure of protective systems, hazardous atmospheres or other hazardous conditions. Inspections must
be completed prior to starting work and as needed through the shift.
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
Utilities Present? Company / Date Checked or Located

Electrical Yes / No
Gas Yes / No
Telephone Yes / No
Water Yes / No
Sewer Yes / No
Protective System Used? Describe

Sloping Yes / No
Benching Yes / No
Shoring Yes / No
Shielding or Barricade Yes / No

EMERGENCY MEDICAL NOTIFICATION FORM
Employee Name:
EMERGENCY NOTIFICATION INFORMATION
IN CASE OF EMERGENCY NOTIFY:

Name / Relationship / Telephone:
Name / Relationship / Telephone:
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:

HAZARDOUS SUBSTANCE INVENTORY LIST
SDS on Location and
File? Chemical or Product Name Manufacturer Container Type

HEPATITIS B VACCINE DECLINATION
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.
My employer, _________________________________________, has offered the HBV vaccine at no

charge to me. However, I decline HBV vaccination at this time. I understand that by declining the vaccine,
I continue to be at risk of acquiring Hepatitis B, a serious disease. I also understand that if in the future I
continue to have occupational exposure to blood or other potentially infectious materials and want to be
vaccinated with the HBV vaccine, I can receive the vaccination series at no charge to myself.
Employee Name (printed) Employee Signature Date
Supervisor Name (printed) Supervisor Signature Date
Copy to be retained in the employee’s secured medical surveillance file.

INJURY/ILLNESS REPORT FORM
INFORMATION REGARDING INJURED OR ILL EMPLOYEE

Name: Phone:
Home Address: Emergency Contact Person/Phone
Job Title Gender: M ☐ F ☐
Employer Employer Telephone
Supervisor Name Supervisor Telephone
INFORMATION ABOUT THE INCIDENT (TO BE COMPLETED BY THE EMPLOYEE)

Date of Incident: Time of Incident:
a.m. p.m. Time unknown

Time You Began Work: Were you hospitalized? Yes No
Dates:
Location of Incident
Was place of accident or exposure on the Bien Hoa Airbase Area remediation site?
Yes No
Location on the site:
What happened? Describe the incident in detail. Use additional pages if needed.
What vehicle, equipment, materials, and chemicals were you using?

What PPE were you using when the incident occurred?
What was your job assignment at the time of the incident?
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”.
Were you performing your regular job duties? Yes No

If no, describe the duties you were performing that were different from your usual job.
Did you receive training for the new duties? Yes No

Was special safety equipment supplied? Yes No
Describe the equipment:
Were you trained to use the safety equipment? Yes No
Did you use the safety equipment properly? Yes No
If no, please state why you did not use the safety equipment you were given.
Witnesses (Attach additional sheets as needed for other witnesses.)

1. Name
Company

Address
Phone
Eyewitness? Yes No Was a witness statement provided? Yes No
2. Name
Company
Address
Phone
3. Name
Company
Address
Phone
4. Name
Company
Address
Phone
5. Name
Company
Address
Phone
Name and company of person who received first report of injury:
Date of Initial Report

Time of Initial Report

TO BE COMPLETED BY CONTRACTOR SAFETY OFFICER
Was first aid administered on site? Yes No

Were emergency medical personnel or an ambulance called? Yes No
Was additional medical treatment required? Yes No First aid only
If Yes, provide the information below.
NAME OF PHYSICIAN OR HEALTH CARE PROFESSIONAL:
TELEPHONE:
Facility name and address:
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?

Additional comments and observations:

INJURED EMPLOYEE’S REVIEW
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.
Injured Employee Printed Name
Injured Employee Signature Date
Report prepared by
Title/Position
Company
Telephone
Signature Date

ON-SITE VEHICLE ACCIDENT INVESTIGATION FORM
Driver’s Name Vehicle License Number Year VIN
Driver / Vehicle 1
Driver’s License No. Vehicle Make Year Model Company vehicle?

Yes / No
Information
Company Name
Circle Areas
Of Vehicle 1 F R
Address
Damage
Passenger names (if any)
Accident Location (Address/Intersection/Area) Road Conditions

Accident Information
Weather Conditions
On site? Where on site? Other site traffic

Yes / No
Date of Accident Time of Accident Your Estimated Speed Other Vehicle Estimated Speed
a.m. p.m.
Police Report Made? Name and Address of Investigating Agency
Yes / No
Driver’s Name Vehicle License Number Year VIN
Driver’s License No. Vehicle Make Model Year No. of Passengers

Vehicle 2 Information
Home Telephone Work Telephone Registered Vehicle Owner
Driver’s Address Vehicle Owner’s Address Home Telephone
Work Telephone
Company Name/Address
Circle Areas
Of Vehicle 2 F R
Damage

Name Age Address Vehicle
No.
Describe Injuries
Injured Persons

No.
Describe Injuries

No.
Describe Injuries
Vehicle No. Name Address Witness?

Vehicle Passengers
Yes / No
Yes / No
Yes / No
Yes / No
Name Telephone Address

Witnesses
Other
Fully State How Accident Occurred (Give details, attach additional sheets if necessary)

Vehicle – Insert Number
Pedestrian
Direction before accident

Accident Details -
Direction after accident

- Diagram
Indicate N – S – E – W on compass at left

Description
Accident Details
Employee Name Employee Signature and Date
Supervisor Name Supervisor Signature and Date
Safety Officer Name Security Officer Signature and Date

VEHICLE ACCIDENT PROCEDURES
When an accident occurs, the driver must deal with immediate problems and gather and report accident
information to the Supervisor or Safety Officer in a timely manner.
When involved in an accident, you must take the following steps:
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.
2. Prevent additional accident.
Turn on the vehicle’s four-way flashers as the first warning signal.

Set out emergency warning devices
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.
Use a mobile phone or site radio to report the accident.

Provide as many details as possible, including location of the accident, number of vehicles involved
and number of people involved.
A driver should never leave the scene of an accident to notify law enforcement unless there is no
means of communication (such as cell phones) at the accident site.
5. Check for injuries. If anyone is hurt, seek medical assistance.
A driver or passenger trained in first aid procedures may provide assistance.
6. Document the accident.
Complete all information on the form.

Take photos of damages to vehicles.
Complete the diagram on the On-Site Vehicle Accident Report Form.

INITIAL SITE-WIDE HEALTH & SAFETY PLAN PAGE | A-0
SAFETY INSPECTION REPORT
Date / Time:
Location on Site:
Work Description:
OBSERVATIONS
Safety Conditions Requiring Corrective Corrective Action, Assignment, and

Action Completion Date
Project Manager:
Safety Inspector:
Distribution:

SAFETY MEETING ATTENDANCE ROSTER
Location on Site:
Date:
Topic:
Name Signature Company
Conducted By:
Signature:
Date:

SITE CONTROL LOG
Date / / Time:
Project Name: Dioxin Remediation Project at Bien Hoa Airbase

Project Location: Bien Hoa Airbase, Bien Hoa, Vietnam
Time
In Out Name Organization

SOIL CLASSIFICATION CHECKLIST
Date / Time Competent

Person
Soil Sample Location
Original Soil Classification (circle one) Soil Re-classification (circle one)
Stable / Type A / Type B / Type C Stable / Type A / Type B / Type C / No
Change
This checklist is completed by the Competent Person to document visual and manual soil classification tests used to
determine soil types present in an excavation. A separate analysis is performed on each layer of soil in the excavation
walls or if the excavation stretches over a distance where the soil type may change. If the properties, factors, or
conditions affecting the initial classification occur, the Competent Person shall evaluate the changes.
Particle Type
Condition ? Describe
Fine grained soil (cohesive) Yes / No
Coarse grained soil (sand/gravel) Yes / No
Water Conditions
Dry Yes / No
Wet/Surface Water/Submerged Yes / No
Other Visual Tests
Previously disturbed soil Yes / No
Layered systems that slope into
excavation Yes / No
Exposure to vibration Yes / No
Fissures/cracking/spalling Yes / No
Utility or underground structures Yes / No
Manual Soil Classification
Check applicable test(s)
Plasticity Dry Strength Thumb Pocket Shear Vane Drying
Penetration Penetrometer
Results

TAILGATE SAFETY MEETING
Project Name: Dioxin Remediation Project at Bien Hoa Airbase
Location: Bien Hoa Airbase, Bien Hoa, Vietnam Date
Site Activities Planned Today
Employee Questions or Comments
See next sheets for topics covered.
Attendees (use additional sheets as required)
Printed Name Signature

Attendees (use additional sheets as required)
Printed Name Signature
Meeting conducted by:
______________________________________ ____________________________________________
Name Title
_________________________________________
Signature

TAILGATE TRAINING CHECKLIST
Topic
Topic Details
Covered
Physical Hazards
Site Access Precautions
Potential Site Hazards

Site Characteristics
Observed Site Conditions
Biological Hazards
Other conditions
Physical hazards and injury prevention
Animal bites, stings, and poisonous plants
Hazards – General Discussions Heat Stress
Special Area Operations
Other hazards
Personal protective equipment
PPE Weather protective clothing
Other PPE Topics
Route to nearest medical facility
Identification of first aid providers available to assist
Emergency telephone numbers
Emergency Response Procedures for handling site emergency incidents
Incident reporting procedures
Incident investigation procedures
USAID requirements
Other emergency response topics

TAILGATE TRAINING CHECKLIST
Topic
Topic Details
Covered
Excavation and Trenching Safety
First aid kit
UXO Safety
Special Operations and Equipment
Working around heavy equipment
Review of local weather forecast

Weather Conditions
Emergency procedures for specific weather conditions
Other Safety Topics
Lessons Learned
Yesterday’s Site Operations
Select topics based on previous day’s operations or new information provided by USAID.

DIOXIN REMEDIATION PROJECT AT BIEN HOA AIRBASE
TRAINING ATTENDANCE RECORD
Training Location:
Date:
Topic
Method of Delivery Online – Verbal - Translator
Date Name Signature Company
Instructor Name:
Signature:
Date:
NOTE: Attach copy of any written handouts.

APPENDIX B. A&E HEALTH AND SAFETY
OFFICER AND LSECS RESUMES

INITIAL SITE-WIDE HEALTH & SAFETY PLAN PAGE | B-1
HEALTH AND SAFETY OFFICER
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.
CERTIFICATIONS AND TRAINING

Certified Instructional Trainer, Board of Certified Safety Professionals, since 1991. Certificate #CET-
13011
40-Hour Hazwoper Initial (1984, 2013) and current refresher training (2018)
8-Hour Hazwoper Manager/Supervisor (1984, 2013)
OSHA 30-Hour Construction Safety (2016)
Bloodborne Pathogen (2017, annual)
Confined Space (1996)
Office Ergonomics (2017, annual)
Cold Stress/Heat Stress Prevention (2017, annual)
Job Hazard Analysis (2017annual)
Fall Prevention and Ladder Safety (2017, annual)
Preventing Back Injury (2017, annual)
Preventing Slips, Trips, and Falls (2017, annual)
EXPERIENCE AND BACKGROUND

Ms. Black has over three decades’ experience in the evaluation of safety and health hazards in general
industry, construction, government, and military sectors, both nationally and internationally. She has
conducted site evaluations, site safety monitoring for uncontrolled hazardous waste sites, safety
compliance audits, safety training courses, and provided safety consultation for: site evaluation and cleanup
methodologies for uncontrolled hazardous waste sites; hazard communication programs, plans, and
procedures for hazard chemical use, storage, control, reporting, and training; air quality monitoring;
ergonomics; and overall compliance with federal and state OSHA Hazardous Materials regulations.
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.

In her position as Administrator for the Cardno Learning Network Americas Learning Management
System, she assigns training to 2,000 employees based on individual job descriptions and work assignments,
monitoring and reporting compliance on a weekly basis. She is also responsible for identifying training
needs, creating original courses and webinars to suit, and maintaining all course materials and compliance
data.
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

LEAD SAFETY AND ENVIRONMENTAL COMPLIANCE SPECIALIST
NOTE: LSECS Resume(s) to be provided.

APPENDIX C. LIST OF DESIGNATED
COMPETENT PERSONS

INITIAL SITE-WIDE HEALTH & SAFETY PLAN PAGE | C-1
LIST OF DESIGNATED COMPETENT PERSONS
Project Name: Dioxin Remediation at Bien Hoa Airbase Area Project
Bien Hoa, Vietnam
Project Location:
A&E Bien Hoa Contractor has designated the personnel below to perform as competent persons on this
Project.
Competent Person Description Applicability Competent Person

General Safety and Health Provisions (29 CFR 1926 Subpart C) Yes Danyelle Phillips
Occupational Health and Environmental Controls (29 CFR 1926 Subpart D) Yes Danyelle Phillips
Personal Protective and Life Saving Equipment (29 CFR 1926 Subpart E) Yes Danyelle Phillips
Fire Protection and Prevention (29 CFR 1926 Subpart F) Yes Danyelle Phillips and GVN
Signs, Signals, and Barricades (29 CFR 1926 Subpart G) TBD
Materials Handling, Storage, Use, and Disposal (29 CFR 1926 Subpart H) TBD
Hand and Power Tools (29 CFR 1926 Subpart I) TBD
Welding and Cutting (29 CFR 1926 Subpart J) TBD
Electrical (29 CFR 1926 Subpart K) TBD
Scaffolds (29 CFR 1926 Subpart L) TBD
Fall Protection (29 CFR 1926 Subpart M) Yes Danyelle Phillips
Helicopters, Hoists, Elevators, and Conveyors (29 CFR 1926 Subpart N) TBD
Motor Vehicles, Mechanized Equipment and Marine Operations (29 CFR
1926 Subpart O) NA
Excavations (29 CFR 1926 Subpart P) Yes TBD
Concrete and Masonry (29 CFR 1926 Subpart Q) TBD
Steel Erection (29 CFR 1926 Subpart R) TBD
Underground Construction, Caissons, Cofferdams, and Compressed Air (29
CFR 1926 Subpart S) NA
Demolition (29 CFR 1926) (Subpart T) TBD
Blasting and Use of Explosives (29 CFR 1926 Subpart U) NA
Electric Power Transmission and Distribution (29 CFR 1926 Subpart V) NA
Rollover Protective Structures; Overhead Protection (29 CFR 1926 Subpart
W) NA
Stairways and Ladders (29 CFR 1926 Subpart X) TBD
Commercial Diving Operations(29 CFR 1926 Subpart Y) NA
Toxic and Hazardous Substances (29 CFR 1926 Subpart Z) Yes Danyelle Phillips
Confined Spaces in Construction (29 CFR 1926 Subpart AA) NA
Cranes & Derricks in Construction (29 CFR 1926 Subpart CC) TBD

INITIAL SITE-WIDE HEALTH & SAFETY PLAN PAGE | C-2
APPENDIX D. ACTIVITY HAZARD
ANALYSES

INITIAL SITE-WIDE HEALTH & SAFETY PLAN PAGE | D-1
Activity/Work Task: General Site Activities Overall Risk Assessment Code (RAC) (Use highest code) M
Probability
“Probability” is the likelihood of causing an incident, near miss, or accident RAC Chart
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 L = Low Risk
1. Travel To/From Site 1. HEAVY traffic at all hours 1. Use passenger restraint systems at all times. H
2. Do not ride in or drive anything other than cars or trucks. Scooters
and other unconfined methods of travel are prohibited.
3. Use hired drivers who are familiar with the rules and regulations.
4. If self-driving, practice defensive driving techniques.
5. Ensure that the host will allow base access for the method of
transport used.
6. If walking along busy streets, pay careful attention to vehicles on all
sides. If possible, use hired transportation rather than walking.

2. Poorly controlled or regulated traffic 1. Use hired drivers who are familiar with the traffic patterns. H
patterns 2. If self-driving, practice defensive driving techniques.
3. Proceed at a pace that is safe and comfortable for you to maintain.
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.

3. 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 CSOimmediately.
10. Discuss precautions during Daily Tailgate meetings.
11. Identify the members of the team who are first aid/CPR certified.

4. Wildlife and Plant Hazards 1. Be watchful for and report the presence of wildlife. Wildlife includes H
feral dogs or cats; other mammals; biting or stinging insects; snakes
and other reptiles; and any other living creature that could pose a
hazard.
2. Assume that all snakes are poisonous and avoid contact.
3. Keep watch in the overhead vegetation for the presence of snakes and
biting insects.
4. Follow all recommended procedures in the event of a bite or sting.
5. Review the precautions and procedures during the Daily Tailgate
meeting.
6. Review the HASP for assistance in identifying wildlife concerns.
7. Avoid contact with any plants unless identified as “safe”.
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.

6. 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. Use operator restraint systems at all times.
3. Wear the appropriate hearing and eye protection.
4. Wear a high-visibility vest.
5. Do not walk behind any machine in operation.
6. Do not operate or ride on any heavy equipment unless trained and
certified to operate.
7. Stay upwind of equipment during earthmoving activities when soil is
dry and dusty.
8. Learn the appropriate hand or audible signals to stop operation in an
emergency.
3. Working in Site Operations 1. Maintaining clean and secure facilities 1. Check identity of new personnel on site to ensure proper L
Trailer(s) authorization.
2. Familiarize all team members with the trailer layout(s) and appropriate
use of facilities.
3. Create rotating schedule of cleaning personnel.
4. Remove trash/garbage at end of every workday.
5. Create appropriate and ergonomic workspaces for team members.
6. Check power, water, and sewer service daily.
7. Check all electrical outlets for functionality and appropriate power
connectors.
8. Keep walking surfaces clean and dry.
9. Remove trip hazards such as curled carpets, threshold transitions, and
door transitions.
10. Ensure adequate lighting.
11. Ensure adequate temperature control and ventilation.
12. Check security of locks on arrival and upon departure.
13. Remove insects, reptiles, and other wildlife.
14. Ensure screens on windows and doors are maintained to prevent
wildlife intrusion.

Used Name(s)
Travel To/From Site: Mobile Training 1. Passenger restraint system working properly and in good condition.
phone; passenger restraint Defensive Driving 2. Restraint system for every passenger.
systems 3. Driver identity.
Qualified Personnel 4. Condition of the vehicle to ensure it is safe to drive or ride in.
Anyone holding a current international driver’s
license or license required by Vietnam
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.

Activity/Work Task: Site Reconnaissance Overall Risk Assessment Code (RAC) (Use highest code) M
Probability
Reconnaissance includes non-invasive activities, such as site surveys “Probability” is the likelihood of causing an incident, near miss, or accident and is RAC Chart
and site walks with prospective contractors. identified as: Frequent, Likely, Occasional, Seldom or Unlikely.
“Severity” is the outcome/degree if an incident, near miss, or accident did occur and is E = Extremely High
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 “Hazard” on M = Moderate Risk
AHA. Annotate the overall highest RAC at the top of AHA. L = Low Risk
1. Visual surveys for 1. UXO 1. Prior to entering any new area on the site, request UXO clearance M
proposed haul road locations; land from the host or from the contractor.
surveying; contractor pre-bid site 2. Report any sightings of UXO.
walks; others TBD 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.

2. Wildlife and Plant Hazards 1. Request that new areas be swept for snakes in long grass or overhead H
in trees.
2. Be watchful for and report the presence of wildlife. Wildlife includes
feral dogs or cats; other mammals; biting or stinging insects; snakes
and other reptiles; and any other living creature that could pose a
hazard.
3. Work Uniform: Wear long sleeves and long pants with sturdy ankle
high hard-toed boots.
4. PPE Required: high-visibility safety vest; hard hat, hearing protection,
eye protection.
5. Assume that all snakes are poisonous and avoid contact.
6. Keep watch in the overhead vegetation for the presence of snakes
and biting insects.
7. Follow all recommended procedures in the event of a bite or sting.
8. Review the precautions and procedures during the Daily Tailgate
meeting.
9. Review the HASP for assistance in identifying wildlife concerns.
10. Avoid contact with any plants unless identified as “safe”.
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.

4. 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.
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.

6. 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.
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.

Used Name(s)
Proposed haul road Training 1. Routes to hospital with hired drivers.
locations; land surveying; PPE – Use and Maintenance 2. Adequate drinking water supply with individual drinking cups or bottles.
contractor pre-bid site First Aid/CPR/AED Training 3. New site work areas for hazards.
walks; others TBD: Site Evacuation Procedures 4. Cool-down and shaded areas.
First Aid Kit; AED; 5. PPE supplies.
appropriate PPE; UXO Qualified Personnel
contractor; drinking water Team members, subcontractors, vendors, and
supply; sunscreen; insect contractors pre-qualified to be on site.
repellent; canopies to
provide shade

Activity/Work Task: Site Characterization Activities Overall Risk Assessment Code (RAC) (Use highest code) M
Probability
For general precautions related to all site activities, refer to AHAs “Probability” is the likelihood of causing an incident, near miss, or accident and is RAC Chart
for “General Site Work” and “Non-Intrusive Site Activities”. identified as: Frequent, Likely, Occasional, Seldom or Unlikely.
“Severity” is the outcome/degree if an incident, near miss, or accident did occur and is E = Extremely High
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 “Hazard” on M = Moderate Risk
AHA. Annotate the overall highest RAC at the top of AHA. L = Low Risk

1. Soil Sampling 1. Exposure to contaminants in soil 1. Wear appropriate PPE as determined by the CSO, to include: Outer M
and inner chemical protective gloves; Full body disposable protective
clothing; Boot covers; and Full-face respirator with appropriate
cartridges OR half-face respirator with appropriate cartridges worn
under a full-face shield
2. Replace damaged PPE as soon as damage is discovered.
3. Do not touch or adjust respiratory protection unless in the
decontamination zone after gloves/hands are completely
decontaminated.
4. Follow the steps for the appropriate decontamination.
5. Eat, drink, or smoke only in designated clean areas AFTER
decontamination and removal of PPE.
6. Contain all decontamination fluids and materials for eventual disposal
or treatment.
7. For any monitoring instrumentation, cameras, or other electronic
equipment used during sampling, protect all surfaces from
contamination by covering with plastic bags.

2. Wearing PPE 1. Use the appropriate PPE and respiratory protection as determined by H
the CSO.
2. Acclimate to the heat gradually, increasing work shifts incrementally
until a maximum of four hours of work is tolerable.
3. Drink water and electrolyte fluids at every break after
decontamination.
4. Consume a minimum of four liters of fluids for every work shift.
5. Monitor yourself and teammates for signs of heat-related illness.
6. Stop work at the first signs of heat-related illness and proceed to the
decontamination area for treatment.
7. Use the proper size of full body cover, boots, and gloves to prevent
tripping or damage to PPE.
8. Maintain adequate supplies of PPE and respiratory protection in the
appropriate sizes.
9. Collect all used PPE and respirator cartridges and hold for disposal
pending results of analysis.
10. Use respirator cartridges for no more than one 8-hour work shift.
When removed from the mask, crush to signify the cartridge cannot
be reused.
11. Use duct tape to hold gloves to sleeves and boot covers to suit legs.
12. If needed, reinforce seams with duct tape to prevent tearing.

3. Decontamination 1. Remove soiled PPE in a manner that prevents contamination of skin, M
clothing, and hair.
2. Place used PPE and respirator cartridges in containers for eventual
disposal.
3. Decontaminate respirator as directed by manufacturer. Use
antibacterial soap and potable water rinse.
4. Wear clean surgical gloves when decontaminating respiratory
protection. To avoid soiling clothing due to splashing liquids, use a lab
apron or another clean disposable suit.
5. Wash hands and face before leaving the decontamination zone.
6. Decontaminate non-disposable sampling tools in separate wash
containers/basins. Do NOT decontaminate with respiratory
protection.
7. For disposable sampling tools, collect in a container and place in
decontamination zone with soiled disposable PPE. Do NOT leave at
sampling site.
8. For instrumentation used during sampling, remove plastic coverings
and decontaminate according to manufacturer’s instructions.
9. For non-disposable sampling tools, decontaminate as directed in the
Sampling Plan to prevent cross-contamination of samples.
10. Follow decontamination protocols included in HASP.
11. For sample handling protocols, refer to the Sampling Plan.
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.

2. Wearing PPE Refer to steps 1.2.1 thru 12 above. In addition: H
2. Breaks should be taken more frequently if wearing water repellent full
body cover due to lack of evaporation of perspiration.
3. Use cooling vests underneath disposable full body cover. Clean vests
as recommended by manufacturer.
3. Decontamination • Refer to steps 1.3.1 thru 11 above. M
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.
2. Wearing PPE • Refer to steps 1.2.1 thru 12 above. In addition: H


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.

1. When performing personal decontamination, notify decon assistants
that you have been handling potentially poisonous or irritant plants.
2. Request puncture-resistant and tear-resistant gloves and body cover if
working with plants with thorns or thistles.
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.
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.

1. When performing personal decontamination, notify decon assistants
that you have been handling fish and shellfish
2. Request puncture-resistant and tear-resistant gloves and body cover if
working with specimens with spines, bony protrusions, or teeth.
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.
sample containers.
3. Avoid stepping in spilled groundwater whenever possible.

2. Wearing PPE Refer to steps 1.2.1 thru 12 above. In addition: H
1. Breaks should be taken more frequently if wearing water
repellent full body cover due to lack of evaporation of
perspiration.
2. Use cooling vests underneath disposable full body cover. Clean

vests as recommended by manufacturer.
3. Decontamination Refer to steps 1.3.1 thru 11 above. M

Used Name(s)
1. Drinking water – Training 1. PPE and respiratory protection
outside of EZ SOPs for Working On or Around Water 2. Sampling tools/equipment decontamination effectiveness
2. Sampling tools Emergency Response for Man Overboard 3. Sample containers and coolers
3. Air monitoring 40-Hour Hazwoper Training 4. Buddy system
instrumentation if Training in sampling techniques 5. Proper use of PPE
required First aid/CPR for two members of the team
4. Sample containers,
coolers, ice Qualified Personnel
5. First aid kit TBD – based on types of sampling and media to
6. PPE, including cooling be sampled
vests and PFDs
7. Boats or rafts with
qualified operators

APPENDIX E. SUBCONTRACTOR LIST

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SUBCONTRACTOR LIST
Service Provided Subcontractor
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.

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APPENDIX F. PROJECT PERSONNEL
TRAINING INFORMATION

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NAME POSITION CERTIFICATION OR TRAINING DATE OF CERTIFICATE
REQUIREMENT LAST INCLUDED?
TRAINING
Andrew Sayers-Fay Chief of Party TBD (dependent on site work and use of
PPE)
Suzan Samara Deputy Chief of Party TBD (dependent on site work and use of
PPE)
Quang Mai Construction Manager TBD (dependent on site work and use of
PPE)
Thang Vu Lead Safety and Environmental TBD (dependent on site work and use of
Compliance Specialist PPE)
TBD Contractor Site Project TBD (dependent on site work and use of
Manager PPE)
TBD Contractor Safety Officer TBD (dependent on site work and use of
PPE)
TBD Sampling Technician TBD (dependent on site work and use of
PPE)

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APPENDIX G. BLOODBORNE PATHOGENS
EXPOSURE CONTROL PLAN

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BLOODBORNE PATHOGENS EXPOSURE CONTROL PLAN
This Bloodborne Pathogens Exposure Control Plan was developed in accordance with the BBP standard
as outlined in 29 CFR 1910.1030. The purpose of this exposure control plan is to minimize employee
occupational exposure to blood and other infectious body fluids.
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.
APPLICABILITY AND EXPOSURE DETERMINATION

The requirements of this Plan apply to all employees on the work site who may reasonably be anticipated
to have occupational exposure to blood or OPIM.
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.
ENGINEERING AND WORK PRACTICE CONTROLS

Whenever possible, engineering and work practice controls shall be implemented to eliminate or minimize
employee exposures. Such controls may include, but are not limited to, the following:
• Hand-washing supplies must be available at all work sites. At a minimum, antiseptic hand
cleaner with clean paper towels or antiseptic towelettes will be provided.
• Employees shall wash hands and exposed skin with soap and water or flush mucous
membranes immediately or as soon as feasible after contact with blood or OPIM.

• No eating, drinking, smoking, cosmetics or lip balm application, or handling of contact
lenses is allowed in areas with reasonable likelihood of occupational exposure to blood or
OPIM.
• In rare cases where employees may come across waste items contaminated with blood or
OPIM, care shall be taken to avoid potential contact.
• Any needles or sharp objects shall be placed in a puncture-resistant, labeled, leak-proof
container. Under no conditions shall needles or contaminated sharp objects be bent,
sheared, broken, or recapped.
All waste created during first aid administration, including PPE, shall be disposed of in a sealable waste bag
for disposal. All sanitary napkin and tampon disposal receptacles in restroom facilities shall be lined with
plastic bags that are removed and replaced daily. Because these items do not meet the definition of
regulated waste under the BBP standard and pose minimal risk of exposure, they can be disposed of in
the sealed plastic bags in regular waste containers.
PERSONAL PROTECTIVE EQUIPMENT

Employers on the site shall provide first aid and CPR providers with appropriate PPE at no cost. PPE may
include the following items:
• Gloves
• Ventilation devices such as mouthpieces, resuscitation bags, or pocket masks
• Face shields, eye protection, and body protection if needed to prevent exposure to OPIM
PPE shall be selected based on the potential exposure to blood or other OPIM. PPE is considered
appropriate if it does not permit blood or OPIM to pass through or reach the employee’s work clothes,
street clothes, skin, eyes, mouth, or mucous membranes under normal conditions and for the duration of
time it will be used. PPE shall be worn during any first aid response involving blood or OPIM.
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

used. Any reusable bin, pail, can, and similar receptacles that could become contaminated must be
inspected and decontaminated with a bleach solution as soon as possible when contamination is visible.
Clothing contaminated with blood or OPIM shall be bagged, labeled, and discarded as regulated waste.
REGULATED WASTE DISPOSAL

The handling, storage, treatment, and disposal of all regulated waste shall be conducted in accordance with
all applicable federal and local regulations. Proper handling of regulated waste is essential to prevent
unnecessary exposure to blood and OPIM. Regulated waste includes wastes in which blood or OPIM could
be released by pouring, dripping, squeezing, or flaking. Regulated waste must be placed in a bag, preferably
red or another bold color, labeled “Biohazardous Waste” or with the international symbol and the word
“Biohazard.” Bags must be tied shut and placed in closable, leak-resistant and labeled containers that
prevent leakage during all handling, storage, transport, shipping, and other activities. If the outside of the
container becomes contaminated, it must be placed in a secondary container meeting the same
specifications.
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 AND POST-EXPOSURE EVALUATION AND FOLLOW-UP

The A&E Bien Hoa Contractor or Project Contractor shall make available the HBV vaccination series and
post-exposure evaluation and follow-up to affected employees following an exposure incident. An
exposure incident includes a specific eye, mouth, other mucous membrane, broken skin, or parenteral
contact with blood or OPIM resulting from the performance of an employee’s duties. The HBV vaccination
and post-exposure evaluation and follow-up are discussed below.
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.
POST-EXPOSURE EVALUATION AND FOLLOW-UP

A confidential medical evaluation and follow-up shall be immediately provided to exposed employees
following the report of an exposure incident. The post-exposure evaluation and follow-up shall include
the following:
• Documentation of the exposure route and exposure incident circumstances;
• Identification and documentation of the source individual (unless identification is not feasible
or prohibited by law);
• Collection and testing of blood for HBV, HCV, and HIV serological status;
• Post-exposure prophylaxis, when medically indicated;

• Counseling; and
• Evaluation of reported illness.
The source individual’s blood shall be tested as soon as feasible after consent is obtained to determine
and document HBV, HCV, and HIV infection status. If the source individual is already known to be infected
with HBV, HCV, or HIV, the blood testing need not take place. The test results shall be made available to
the exposed employee, and any applicable laws and regulations regarding disclosure of identity and
infection status of the source individual will be complied with. Details of the exposure incident
investigation shall be documented on the “Post-Exposure Evaluation.” Copies of the completed form shall
be forwarded to the CSO and designated healthcare professional. Information provided to the healthcare
professional and the healthcare professional’s written opinion for follow-up is discussed below.
INFORMATION PROVIDED TO THE HEALTHCARE PROFESSIONAL

In the event of an exposure incident, the employer shall provide the following information to the
healthcare professional responsible for the employee’s HBV vaccination:
• 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.
HEALTHCARE PROFESSIONAL’S WRITTEN OPINION

Employees shall receive a copy of the evaluating healthcare professional’s written opinion within 15 days
of the completion of the evaluation. The opinion for HBV vaccination shall be limited to whether the
vaccination is indicated and if the employee has received such vaccination. The employee will be informed
of the results of the examination. During the evaluation, the employee will also be told about any medical
conditions that may result from exposure to blood or OPIM and that may require further evaluation or
treatment. All other findings or diagnoses shall remain confidential and shall not be included in the
healthcare professional’s written opinion.
INFORMATION AND TRAINING

All employees with the potential for occupational exposure to blood and OPIM will receive training at the
time of initial assignment to tasks during which occupational exposure might occur and at least annually
thereafter. Additional training will be provided when changes in tasks or procedures affect employee
exposure potential. The training program shall contain or address elements listed in “Bloodborne
Pathogen Exposure Control Plan Annual Training Information,” included in Appendix A.
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.

APPENDIX H. HAZARD COMMUNICATION
PROGRAM

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HAZARD COMMUNICATION PROGRAM
A Hazard Communication Program will be required from all contractors working on the Bien Hoa Airbase
Area Site. The A&E Bien Hoa Contractor LSECS will request from each CSO a hazardous substance
inventory list and copies of SDSs for hazardous substances present, stored, or used by facility personnel
and contractors in Project work areas. The Hazard Communication Program must include procedures to
establish, clearly designate, and communicate the potential hazards at the Project work areas using signage,
fencing, barricades, warning tape, and/or construction cones. At a minimum, signs will be posted at the
approved entry points and along the perimeter of each work area. Site personnel will be informed of the
hazardous substances they will be working with through Site-Wide HASP review and attendance at daily
safety meetings. Project hazard communication procedures shall be referred to for guidance and
requirements if hazardous chemical exposure is possible at the work site.
HAZARD COMMUNICATION STANDARD

In 2012, changes to the OSHA Hazard Communication Standard (HCS) (29 CFR 1910.1200) took effect,
bringing United States rules into alignment with the Globally Harmonized System (GHS) of Classification
and Labeling of Chemicals to better protect workers from hazardous chemicals produced in countries
around the world.
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.
GENERAL HAZARD COMMUNICATION REQUIREMENTS

The goal of Hazard Communication is to ensure that the hazards of chemicals present are evaluated, and
that information concerning their hazards is transmitted to employers and employees. This information is
to be transmitted by means of container labeling and other forms of warning, SDSs, and employee training.
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

who may be exposed under normal conditions of use or in a foreseeable emergency are able to react in
the appropriate manner.
WRITTEN HAZARD COMMUNICATION PROGRAM

Each employer at the site must develop, implement, and maintain a written Hazard Communication
Program. This written program must:
• describe labels and other forms of warning;

• describe the signage and materials used to clearly define the work site location;
• provide a list of hazardous chemicals known to be present and include an SDS for each;
• include employee information regarding hazards, work practices to avoid or minimize
exposure, and, where necessary, the appropriate PPE to prevent exposure;
• provide for employee training regarding the program and all of its elements;
• identify the hazards of non-routine tasks and how the employees will be informed of the
additional hazards; and
• identify hazards associated with chemicals contained in unlabeled containers in adjacent work
areas.
At multi-employer workplaces, the written program must identify methods to provide affected employees
of other employers who may be exposed with hazard communication information (e.g., SDS provision,
precautionary measures, and labeling system used).
LABELS AND OTHER FORMS OF WARNING

Chemical manufacturers, importers, distributors, and employers must use labels and other forms of hazard
warnings. As of June 1, 2015, the GHS requires that all labels have pictograms, a signal word, hazard and
precautionary statements, the product identifier, and supplier identification. Supplemental information can
also be provided on the label as needed. The pictograms used and their meanings are shown in the table
below.

CHEMICAL HAZARD LABELING INFORMATION
Carcinogen; Mutagenicity; Reproductive
Health Hazard: Toxicity; Respiratory Sensitizer; Target Organ
Toxicity; Aspiration Toxicity
Flammables; Pyrophorics; Self-Heating;

Flame: Emits Flammable Gas; Self-Reactives; Organic
Peroxides
Irritant (skin and eye); Skin Sensitizer; Acute

Toxicity; Narcotic Effects; Respiratory Tract
Exclamation Mark:
Irritant; Hazardous to Ozone Layer (Non-
Mandatory)
Gas Cylinder: Gases Under Pressure
Skin Corrosion/Burns; Eye Damage; Corrosive

Corrosion:
to Metals
Exploding Bomb: Explosives; Self-Reactives; Organic Peroxides
Flame Over Circle: Oxidizers
Environment (Non-Mandatory): Aquatic Toxicity
Skull and Crossbones: Acute Toxicity (fatal or toxic)
Chemical manufacturers, importers, distributors, and employers:
• 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;

• May use appropriate hazard warnings, or alternatively, words, pictures, symbols, or a
combination, to provide general information regarding chemical hazards as long as other
specific information is immediately available;
• May use signs, placards, process sheets, batch tickets, operating procedures, or other such
written materials instead of affixing labels to individual stationary containers, such as fuel
tanks, as long as the alternative method conveys the required label information;
• Are not required to label portable containers into which chemicals are transferred from
labeled containers, which are intended only for the immediate use of the employee who
performs the transfer;
• Must not remove or deface existing labels on incoming containers of hazardous chemicals,
unless the container is immediately remarked with the required information; and
• Must ensure that labels and other forms of warning are legible, in English, and prominently
displayed on the container, or readily available in the work area throughout the work shift
(can add other languages to English on label).
SAFETY DATA SHEETS

SDSs are a key tool in providing chemical hazard warnings to employees. Chemical manufacturers and
importers must develop and make available an SDS for each hazardous chemical they produce or import.
Employers must have an SDS in the workplace for each hazardous chemical that they use.
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 1: Identification includes product identifier; manufacturer or distributor name, address,

phone number; emergency phone number; recommended use; restrictions on use.
Section 2: Hazard(s) identification includes all hazards regarding the chemical; required label
elements.
Section 3: Composition/information on ingredients includes information on chemical ingredients;

trade secret claims.
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 9: Physical and chemical properties lists the chemical's characteristics.
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 12: Ecological information
Section 13: Disposal considerations
Section 14: Transport information
Section 15: Regulatory information
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.
HAZARD COMMUNICATION TRAINING

All employees at the work site must be provided with effective hazard communication information and
training on the hazards of chemicals present at the site to which they may be exposed. Training must be
provided at the time of initial assignment and whenever a new physical or health hazard is introduced into
the work area. Information and training may be designed to cover categories of hazards (e.g., flammability,
carcinogenicity) or specific chemicals.
All employees shall receive training including:
• label elements and SDS format;

• review of the Hazard Communication Program requirements;
• review of operations in work areas where hazardous chemicals are present;
• location and availability of the written Hazard Communication Program;
• discussion of the methods and observations to detect hazardous substances in work areas;
• description of the physical and health hazards of hazardous substances and protective
measures to be used; and
• review of the details of Hazard Communication Program and how to obtain and use hazard
warning information including SDSs and labels and other forms of warning.

APPENDIX I. ASSURED EQUIPMENT
GROUNDING CONDUCTOR
PROGRAM REQUIREMENTS

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ASSURED EQUIPMENT GROUNDING CONDUCTOR PROGRAM
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:
• Before first use;

• Before placing back in service following any repairs;
• Before equipment is used after any incident that can be reasonably suspected to have caused
damage (e.g., when a cord set is run over); AND
• At intervals not to exceed 3 months, except that cord sets and receptacles that are fixed and not
exposed to damage shall be tested at intervals not to exceed 6 months.
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.

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APPENDIX J. LIST OF DESIGNATED FIRST
AID RESPONDERS

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LIST OF DESIGNATED FIRST AID RESPONDERS
Project Name: Dioxin Remediation at Bien Hoa Airbase Area Project
Project Location: Bien Hoa, Vietnam
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.
Name First Aid/CPR/AED Training BBP Training

Danyelle Phillips 2018-04-10 2017-06-26
Ellen Graap Loth 2017-12-13 2017-10-11
Kenneth Swain 2017-07-11
Lynne Black 2019-06-28 2018-12-26
David Di Cesare 2017-06-06
Legend:
BBP: bloodborne pathogen

CPR: cardiopulmonary resuscitation
AED: automated external defibrillator

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APPENDIX K. PERSONAL PROTECTIVE
EQUIPMENT DONNING
PROCEDURES AND
PERSONNEL
DECONTAMINATION
PROCESS

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PERSONAL PROTECTIVE EQUIPMENT (PPE) DONNING PROCEDURE
A specific donning or “dress-up” sequence shall be developed as part of each contractor’s SHASP.
The sequence will be a progressive, systematic process, developed to maximize the protective
qualities of the PPE ensemble.
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:
• Impermeable disposable coverall

• Outer gloves
• Inner (surgical) gloves
• Disposable boot covers
• Duct tape
• Hard hat
• Respirator with appropriate cartridges
• OPTIONAL: contractor-supplied cotton coveralls to be laundered off site after every use.
NOTE: Respiratory protection will be assigned for the exclusive use of one worker and shall not be
shared.
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.

6. Hard hat. If coverall has a hood, pull it over the hard hat to hold it in place.
PERSONNEL DECONTAMINATION
Personnel leaving the Exclusion Zone (EZ) will be required to perform decontamination (decon)
prior to entering the Clean Zone (CZ) for breaks or at the end of the work shift. The sequence of
the steps, materials used, and methods for decontamination will vary depending on work tasks
performed, materials handled, type of personal protective equipment (PPE) and respiratory
protection used, and weather conditions.
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.

14. Re-check clothing and boots for signs of contamination. If clothing is soiled, request assistance
from decon technician to inspect clothing to determine whether it is “safe” to leave the CRZ.
15. Carry clean respirator and hard hat to showers or to CZ.
16. If showers and dressing rooms with lockers are provided, workers will shower with soap
and water before leaving the site. If contractor-provided inner coveralls are used, place the
used coverall in the container provided for laundering. Change into regular street clothes after
showering and before leaving the CRZ.
17. Store hard hat and respirator in area designated for clean storage.
18. Leave the CRZ as soon as all steps have been completed. Do not re-enter any areas to
retrieve dropped equipment or tools. If they are needed, request assistance from the decon
technician.
Sampling tools and sample containers will be handled and decontaminated prior to shipment from
the site to the laboratory. A decon sequence will be developed to prevent spread of contamination
from samples to the CZ. Sample container and tool decon will be conducted in such a way as to
prevent cross-contamination of sampled media.

APPENDIX L. DIOXIN MONITORING
INFORMATION

INITIAL SITE-WIDE HEALTH & SAFETY PLAN PAGE | L-1
SPECIMEN COLLECTION, PROCESSING AND STORAGE
PROTOCOLS FOR SERUM FOR DIOXINS (20-40 ML SERUM SAMPLE
SIZE)
BLOOD COLLECTION PROCEDURE

1. Have the following items on hand and available for use
a. Disposable gloves
b. Tourniquet
c. Alcohol disinfectant swabs
d. Gauze bandages
e. 21g butterfly needle or 21g Vacutainer straight needle (smaller needle may be required
for difficult collection)
f. Vacutainer needle holder
g. (Ten) 10 mL red top vacutainer tubes per participant – (glass, no serum separator gel)
provided by laboratory. Extra tubes will be provided to allow for a second centrifugation
of each sample (see Processing Section below).
h. Band-aid
i. Sharps disposal container for used needles
j. -20C Freezer for storage of serum samples
7. Tie the tourniquet onto the upper arm so that it can be quickly released with one hand.
8. Label each red top tube with the participant’s identification number, vacutainer number, time of
sampling and initials of sampler.
9. Swab the venipuncture area of the participant’s arm with alcohol swabs.
10. Wipe off excess alcohol with the gauze bandages.
11. Allow to air dry for 5 - 10 seconds.
12. Puncture the vein.
13. Push red top tube into the needle holder.
14. After blood flow is established, loosen the tourniquet.
15. Allow the vacutainer tubes to fill; red top tubes will fill to just above the paper label. Fill 10 tubes
for each participant.
16. Red tops should be allowed to clot upright in a rack.
17. Withdraw the needle and dispose of in the sharps disposal container.
18. Apply pressure on the venipuncture site and apply a bandage.
19. Make a photocopy of each participant’s identification document. The identification should be a
government issued document with a picture and signature. Photocopy both sides of the ID if
needed. This document should accompany the master sample collection sheet (see #15 below).
20. A master sample collection sheet should also be filled out during sample collection. The sample
collection sheet should have the participant’s name, address and assigned identification number,
number of vacutainers and the time of specimen collection. Note any problems with the
collection, i.e., low volume, etc. This master collection sheet (and copies of participants’ ID
documents) should not be shipped with the specimens to maintain patient confidentiality.

SERUM PROCESSING PROCEDURE
1. Materials and Equipment Needed per Participant
a. Disposable gloves
b. Two (2) Disposable glass pipettes (5¾ in with nominal volume 4.5 mL delivering
about 2.5 mL per aliquot) and one (1) disposable pipette bulbs (blue bulb fitting
pipette). Pipettes and bulbs are provided by laboratory. Use a new pipette and bulb
for each participant. Note a total of 10 pipette bulbs are supplied, this is one (1) per
participant and four (4) spare. Care must be taken to avoid aspirating the serum up
into the pipette bulb as this could cause sample cross-contamination. If this occurs
use a new bulb.
c. Two (2) amber glass bottles (each 40 mL volume) with Teflon lined screw on lids for
serum collection (provided by laboratory)
d. Labels for bottles (provided by laboratory).
e. Centrifuge
f. Freezer
2. Processing
a. After the red top tubes have been allowed to clot sufficiently (for a minimum of 30
minutes, 2 hours is preferred), place them in a centrifuge for 15 minutes at a
minimum speed of 2400 rpm. Note: If the clot appears to be adhered to the top of
the stopper, place a piece of gauze over the red top tube and loosen the stopper
until the clot is freed and falls back into the glass portion of the tube (placing the
tubes upright in a rack soon after collection will prevent the clot from adhering to
the stopper). Replace the stopper taking care not to touch the inside of the
stopper or glass tube.
b. Once the tubes have been centrifuged, place them upright in a rack. Follow this
procedure closely to maximize the amount of serum recovered from the red top
tube.
c. Using a disposable pipette, transfer all of the clear serum that is free of red cells from
each red top tube collected from a participant to one of the 40 mL glass bottles.
Take care not to disturb the red cell clot so that a maximum volume of clear serum
can be collected. Also take care to avoid aspirating the serum up into the pipette
bulb as this could cause sample cross-contamination. If this occurs use a new bulb.
Although the goal is to collect 40 to 50 mL of serum per participant, two glass bottles
are provided per participant so that each serum sample can be split into two (2)
portions, ensuring that the bottles are not overfilled and at risk of breaking during
freezing and shipping. Place a label identifying the specimen (identification number
only, not the participant’s name) on each glass bottle and label as (1 of 2) or (2 of 2)
accordingly. Ensure that at least one of the bottles has at least 25 mL of serum (just
over half full).
d. Stop collecting serum as soon as it starts to become mixed with red cells (becomes
red or cloudy). At this point any remaining liquid (red cells and serum mix) left in
the red top tubes should be transferred to a clean red top tube. Extra tubes and
labels are provided for this purpose (remember to label this tube with the
appropriate ID). Pull up any liquid out of the original red tops that can be accessed,
all the way down to the bottom of the tube between the clot and glass side of the
tube. It will appear very bloody but there will still be useable serum from this

mixture after a second centrifugation. All that should remain in the original red top
tube is the clot.
e. Centrifuge this red top tube containing the red cell/serum mix for 10 minutes and
transfer the clear serum to one of the glass bottles containing the clear serum
initially harvested. There should be a total of 3.5 to 5 mL of serum from each red
top when completed. Do not pull any of the red cells at the bottom of the tube
into the pipette. Slow and easy will ensure that the serum can be removed without
re-mixing the contents of the red top tube. If a substantial number of red cells are
re-mixed with the serum, transfer the serum to a clean red top tube and centrifuge
again to get rid of the cells. Discard all of the red top tubes into a sharps container
after the serum is removed.
f. Tighten the caps on the two (2) glass bottles, apply a custody seal (provided by
laboratory) to each bottle (cross the top of the lid and down the sides of the
bottle) and sign and date the seal. Store in a freezer until ready to ship.

CHAIN OF CUSTODY FORM
Complete the Chain of Custody (COC) form (provided by laboratory) indicating the identification code
for each specimen, the date, time of collection and the signature of the collector. The COC needs to be
filled out completely. The completed COC form must be shipped with the specimens (see instructions
below). It is not necessary for the participant to sign this form.
SHIPPING INSTRUCTIONS FOR SERUM SPECIMENS
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.

Complete the Commercial Invoice supplied. Sign, date it and include two (2) copies in the pouch with
the airbill and give a third copy to the courier. This is the document required for Customs Clearance.

USEPA 1613B
TYPICAL DETECTION LIMITS, METHOD DETECTION LIMITS, LOW CALIBRATION LIMITS, AND REPORTING LIMITS FOR
CHLORINATED DIOXINS AND FURANS
Instrument Type: High Resolution GC/MS

MDL Protocol: Federal Register 40 CFR Part 136, Appendix B, no iteration
Quantification: Linearity
Matrix SERUM
Units/Sample Size pg/g based on 40g sample
Default Extract Volume 10uL
LMCL based on High
Analyte Typical SDL MDL LMCL based on CS-1 RL1
Sensitivity CS-0.2
Dioxins
2,3,7,8-TCDD 0.005 0.0021 0.125 0.025 0.006
1,2,3,7,8-PECDD 0.013 0.0086 0.625 0.125 0.006
1,2,3,4,7,8-HXCDD 0.013 0.0083 0.625 0.125 0.006
1,2,3,6,7,8-HXCDD 0.013 0.0058 0.625 0.125 0.006
1,2,3,7,8,9-HXCDD 0.013 0.012 0.625 0.125 0.006
1,2,3,4,6,7,8-HPCDD 0.013 0.022 0.625 0.125 0.006
OCDD 0.013 0.055 1.250 0.250 0.006
LMCL based on High
Typical SDL MDL LMCL based on CS-1 RL1
Sensitivity CS-0.2
Furans
2,3,7,8-TCDF 0.005 0.0028 0.125 0.025 0.006
1,2,3,7,8-PECDF 0.013 0.0061 0.625 0.125 0.006
2,3,4,7,8-PECDF 0.013 0.0076 0.625 0.125 0.006
1,2,3,4,7,8-HXCDF 0.013 0.0079 0.625 0.125 0.006
1,2,3,6,7,8-HXCDF 0.013 0.0085 0.625 0.125 0.006
1,2,3,7,8,9-HXCDF 0.013 0.0066 0.625 0.125 0.006
2,3,4,6,7,8-HXCDF 0.013 0.0054 0.625 0.125 0.006
1,2,3,4,6,7,8-HPCDF 0.013 0.014 0.625 0.125 0.006
1,2,3,4,7,8,9-HPCDF 0.013 0.014 0.625 0.125 0.006
OCDF 0.013 0.033 1.250 0.250 0.006

HEALTH AND LIFESTYLE QUESTIONNAIRE

BLOOD SERUM DIOXIN ASSESSMENT
Employee Name
Case Number
Interviewer
Date/Time Interview began
Date/Time Interview Ended
Was questionnaire
completed?

Please provide your date of birth: / /
(DD)/ (MO) / (YYYY)
1. Health History
1.1 Gender Male Female
1.2 Height m cm
1.3 Weight kg
1.4 Have you lost weight in the past 12 Yes No
months?
1.5 How much weight did you lose? Kg
1.6 Have you gained weight in the past Yes No
12 months?
1.7 How much weight did you gain? Kg
FEMALES
1.8 How many times have you been pregnant in your life? Please include live births, stillborn,
aborted, miscarried, or ectopic/tubal pregnancies.
# Pregnancies None Don’t know
1.9 How many children did you give birth to? Please include only live births.
# Children None Don’t know
1.10 For each child, please provide the year of birth and an estimated number of months that your
child was breast-fed as the main source of nutrition.
If more than 6 children, please use the margins. If child was not breast-fed, record 0 months.
Child Name Birth Year (YYYY) Months breast-fed
1

1.11 Have any of your children had serious medical problems?
Yes No Don’t know
If yes, please describe:
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
Question Yes No Don’t

know
1.20 Do you have hemophilia or any other blood clotting
or bleeding disorder?
1.21 Have you received chemotherapy in the last 6
months?

Question Yes No Don’t
know
1.22 Are you currently taking medication to thin your
blood? This does not include aspirin.
1.23 Have you ever been diagnosed with anemia by a
health care professional?
1.24 Are you currently being treated for anemia?
1.25 Have you ever been diagnosed with malaria by a
1.26 Are you currently being treated for malaria?
1.27 Have you ever been diagnosed with dengue fever by
a health care professional?
1.28 Are you currently being treated for dengue fever?
1.29 Have you ever been diagnosed with Hepatitis by a
1.30 Are you currently being treated for Hepatitis?
1.31 Have you ever been diagnosed with HIV by a health
care professional?
1.32 Are you currently being treated for HIV?
1.33 Have you donated blood within the last 8 weeks?
1.34 Are you currently pregnant?
1.35 Have you breastfed a child within the last 6 months?

2. Residential/Address History
Please provide the addresses where you have lived since 1975. If you lived outside of Bien Hoa during that
time, please provide only the city, town, and province. Use margins for additional addresses and years.
2.1 Current address, including ward, commune, city and province.
When did you move here?

2.2 Previous address
From To
From To
From To
From To
From To
From To

3. Property Use
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

4. Work History
4.1 have you ever worked in waste disposal, including an incinerator, wastewater treatment, solid
waste/trash disposal or scrap metal collection?
Yes No Don’t Know
Comments
4.2 have you ever worked in a factory?
Yes No Don’t Know
Comments
4.3 Has your work ever involved spraying chemicals to kill weeds or plants?
Yes No Don’t Know
Comments
4.4 Have you ever worked in the paper industry?
Yes No Don’t Know
Comments
Have you ever worked in the production, formulation, use, or disposal of the following
chemicals:
4.5 Chlorophenol
Yes No Don’t Know
Comments
4.6 Agent Orange
Yes No Don’t Know
Comments
4.7 Vietnam era weedkillers other than Agent Orange, such as Agent Purple, Agent Pink, Agent
Blue, and Agent Green
Yes No Don’t Know
Comments
4.8 Other herbicides, weed killers, or brush killers
Yes No Don’t Know
Comments
4.9 PCP or pentachlorophenol
Yes No Don’t Know
Comments

4.10 2,4-D
Yes No Don’t Know
Comments
4.11 Tricholorophenol or its derivative, such as 2,4,5-T
Yes No Don’t Know
Comments
4.12 PCBs
Yes No Don’t Know
Comments
4.13 Have you ever worked at the Bien Hoa Airbase?
Yes No Don’t Know
Details
4.14 Were you ever exposed to a chemical spill or chemical accident while working at the Bien
Hoa Airbase?
Yes No Don’t Know
Comments
4.15 Were you ever exposed to any fire involving chemicals while working at the Bien Hoa
Airbase?
Yes No Don’t Know
Comments
4.16 Have you ever worked in any other factory or industry?
Yes No Don’t Know
Comments
4.17 Have you ever been exposed to a spill involving industrial chemicals in any other location?
Yes No Don’t Know
Comments
4.18 Have you ever been exposed to a fire involving industrial chemicals in any other location?
Yes No Don’t Know
Comments
4.19 Have you ever lived with someone who worked at the Bien Hoa Airbase?
Yes No Don’t Know

4.20 Did you live with them while they were working at the Bien Hoa Airbase?
Yes No Don’t Know
4.21 Did you serve in the military during the American War?
Yes No Don’t Know
Comments
4.22 Did you serve where Agent Orange and other defoliants were used?
Yes No Don’t Know
Comments
4.23 Did you personally handle or work with Agent Orange and/or other defoliants?
Yes No Don’t Know
Comments
Additional Comments

5. Fishing and Gardening
5.1 Have you ever gone fishing anywhere in Bien Hoa?
Yes No Don’t Know
When/Where?
5.2 Did you ever fish in the ponds/lakes on the Bien Hoa Airbase?
Yes No Don’t Know
When/Where?
5.3 Did you ever fish in Bien Hung Lake?
Yes No Don’t Know
Comments
5.4 Did you ever fish in Gate 2 Lake?
Yes No Don’t Know
Comments
5.5 Did you ever fish in the Dong Nai River?
Yes No Don’t Know
Comments
5.6 How many fish do you catch from the nearby lakes and river mentioned in questions 5.1 to
5.5?
0 1 2 3 4 5 5- 10- >20 Don’t
10 20 know
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

5.10 Did you ever harvest wood from Bine Hoa Airbase?
Yes No Don’t Know
Comments
5.11 Did you harvest lotus or other aquatic vegetables from Bien Hoa Airbase?
Yes No Don’t Know
Comments
5.12 Did you harvest ducks from the Bien Hoa Airbase?
Yes No Don’t Know
Comments
5.13 Did you harvest any other animals from Bien Hoa Airbase, such as frogs, birds, rats, snakes,
etc.?
Yes No Don’t Know
Comments
5.14 At which market do you purchase your food?
Yes No Don’t Know
Comments
5.15 Do you buy fish from local markets?
Yes No Don’t Know
Comments
5.16 Do you buy ducks from local markets?
Yes No Don’t Know
Comments

6. Food Consumption
6.1 Have you ever eaten fish caught anywhere in Bien Hoa?
Yes No Don’t Know
Comment
6.2 Have you ever eaten fish caught in the ponds/lakes on the Bien Hoa Airbase?
Yes No Don’t Know
Comments
6.3 Have you ever eaten fish caught in Bien Hung Lake?
Yes No Don’t Know
Comments
6.4 Have you ever eaten fish caught in Gate 2 Lake?
Yes No Don’t Know
Comments
6.5 Have you ever eaten fish caught in the Dong Nai River?
Yes No Don’t Know
Comments
6.6 What parts of the fish do you eat?
Muscle/Meat only Liver Stomach
Fat All parts
6.7 What other meat do you eat?
Beef Chicken Pork
Duck Other (specify)
6.8 What fruits and vegetables do you eat?
Lotus Bamboo Spinach
Gourds Other (specify)
6.9 Do you raise your own animals?
Yes No Don’t Know
List
6.10 Do you grow your own rice, vegetables, or fruits?
Yes No Don’t Know
List

7. Education
What was the highest grade or degree that you have completed?
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. Information and Outreach
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?

APPENDIX M. SHORT-FORM SUPPLEMENTAL
HEALTH AND SAFETY PLAN
FORMAT (NON-INTRUSIVE
SITE ACTIVITIES)

INITIAL SITE-WIDE HEALTH & SAFETY PLAN PAGE | M-1
Site Name: Bien Hoa Airbase Area Site Contact: Telephone:
Location: Bien Hoa, Vietnam Client Contact: Telephone:
Prepared By: Team Trigon Date: 23 May 2019 Date of Proposed Activities: 20 June 2019
Objectives: Site Type: Check as many as applicable.
USAID will conduct a Site Walk at the Bien Hoa Airbase Area for selected ☒ Active ☒ Industrial Waste ☐ Unknown
visitors to Inspect the Bien Hoa Airbase Interim measures Project area.
Activities include visual site reconnaissance in the Pacer Ivy and former ☐ Inactive ☒ Landfill ☒ Other (specify)
quarry areas of the Airbase only. No intrusive site activities will be Active military Airbase.
☒ Secure ☐ Confined space
conducted, and site reconnaissance will take place from vehicles or on
improved surfaces, such as compacted stone, concrete, or paved roadways.
☐ Unsecure ☒ Uncontrolled Waste
Site Description and History:
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.

Site Historical Practices:
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.
Waste Types: ☒ Liquid ☒ Solid ☒ Sludge ☐ Gas
Waste / Chemical ☐ Corrosive ☐ Oxidizer ☐ Flammable

Characteristics:
☒ Toxic ☒ Explosive ☐ Volatile ☐ Radioactive
☐ Reactive ☐ Inert ☒ Other: Arsenic (organic) – poison

Dioxin – potential carcinogen, mutagen, teratogen
Chemical / Health Hazards of Concern:

☐ Explosion or fire hazard – monitor with combustible gas ☒ Inorganic chemicals
meter
☐ Oxygen deficiency – monitor with oxygen meter ☒ Organic chemicals
☐ Landfill gases – monitor with methane and hydrogen sulfide ☒ Petroleum Hydrocarbons
meter
☐ Surface tanks ☐ Underground storage tanks
☐ Potential inhalation or skin absorption hazard that is ☐ Confined Space

immediately dangerous to life and health (IDLH)
Explosion or Fire Potential: ☐ High ☐ Medium ☒ Low ☐ Unknown

Radiological Hazards of Concern: NO KNOWN RADIOLOGICAL HAZARDS OF CONCERN
☐ Ionizing radiation (Radioactive materials, X-ray) ☐ Non-ionizing radiation (ultraviolet, lasers)
Safety Hazards of Concern During This Site Walk
☒ Heavy Equipment ☐ Buried utilities
☐ Confined Space Entry ☐ Overhead utilities
☐ Energized and rotating equipment (drill rig) ☐ Suspended loads
☐ Steam cleaning equipment ☐ Buried drums
☐ Excavations ☒ Work over or near water
☐ Welding or torch cutting (Hot work) ☐ Work from elevated platforms
☒ Sharp Objects ☐ Manual Lifting
☐ Compressed Gas Cylinder ☒ Traffic Control
☐ Lock-out Tag-out ☐ Forklift
☐ Hazardous energy sources ☒ Other (specify) Walking on/near an active runway
Physical Hazards of Concern: ☒ Vibration Aircraft
☒ Heat stress ☒ Noise
☐ Cold stress ☒ Solar (sunburn)
☒ Slips, trips, falls ☒ Unstable or steep terrain
☐ Illumination ☐ Other (specify) Contaminated dust
Biological Hazards of Concern: ☒ Snakes
☒ Poisonous plants ☒ Stinging insects (bees, wasps)
☒ Spiders ☒ Animals (feral dogs)
☐ Medical waste; blood; bodily fluids ☒ Ticks
Unexploded Ordnance: UXO in any areas to be accessed during the Site Walk has been cleared in advance by GVN/MND.

Photo-
Uncontrolled Chemical Highest Observed IDLH ionization
PEL/TLV Symptoms and Effects of Acute Exposure
Hazards Present at Site Concentration Level Potential
(eV)
Dioxin (as 2,3,7,8-TCDD) 110,000 ppt TEQ @ NA NA CARC NONE

30-60 cm bgs1
Arsenic 63 mg/kg2 0.002 5 mg/m3 CARC; poison NONE

mg/m3 (NIOSH)
(NIOSH-
C)
0.01
mg/m3
(OSHA)
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.
bgs = below ground surface PEL = Permissible exposure limit

CARC = Carcinogenic ppm = parts per million
eV = Electron volt ppt = parts per trillion
IDLH = Immediately dangerous to life or health TEQ = Toxic Equivalent
3
mg/m = Milligram per cubic meter TLV = Threshold limit value
NA = Not available

Field Activities Covered Under This Plan: (attach additional sheets if more than one task)
Task 1 Description Work Uniform
Type Primary Contingency Date of Activities
☐Intrusive Normal work clothing, Safety glasses, boot

boots, hi-visibility vest covers, hearing
☒Non-intrusive
protection
Site Personnel and Responsibilities (include

subcontractors):
Name, Affiliation Task # Responsibilities

Standard Operating Procedures (SOPs) – Task 1
Protective Equipment:
Task: ☒ 1 ☐ 2 ☐ 1. Site walk includes only non-intrusive activities. Participants will remain in
Work Uniform ☒ ☒ Other* ☐ Modified vehicles or on improved paved/graveled/hard-surfaced areas.
2. Standing water (puddles) are to be avoided to prevent slipping and
RESPIRATORY PROTECTIVE CLOTHING minimize spread of sludge/soil onto clothing and boots.
☒ Not needed ☐ Not needed
3. If conditions are windy, use eye protection to prevent injury by flying small
☐ APR: ☐ Tyvek® coveralls:
debris.
☐ Cartridge: ☐ Saranex® coveralls:
☐ Escape mask: ☐ Coveralls: 4. Do not enter any vegetation-covered areas or stand under trees or vines
☐ Other: ☒ Other: Hi-visibility vests. to prevent snakebite or contamination.
5. Treat all snakes as poisonous. Do not approach or attempt to handle.
HEAD AND EYE GLOVES
6. Do not approach or touch any stray animals, as they may carry parasites
☐ Not needed ☒ Not needed
and rabies.
☒ Safety glasses: See SOPs. ☐ Undergloves:
☐ Face shield: ☐ Gloves: 7. Check your skin for ticks during and after the site walk.
☐ Goggles: ☐ Overgloves: 8. Use mosquito/tick repellent prior to site entry.
☒ Hard hat: As required by host.
9. Report any injury to the identified CSO and LSECS immediately. Any break
☐ Other: in the skin will require attention. A first aid kit is available on site.
FIRST AID EQUIPMENT BOOTS 10. In the event of thunderstorms, site walk activities will be discontinued
☒ Standard First Aid kit ☐ Not needed immediately and shelter taken in vehicles or solid structures. DO NOT
☒ Portable eyewash ☒ Work boots: Hard-toed footware. take shelter under trees or open canopy structures.
☒ Overboots: See SOPs.
11. In the event of dusty conditions, personnel will remain in vehicles.
*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.

Site Maps
For Quarry Area

Details, see map at

Emergency Contacts Telephone
Police 113
Fire 114
Ambulance 115
Assistance 116
Bien Hoa Airbase Area Contact
Medical Emergency
Hospital Name: Dong Nai International Hospital
Hospital Address: * 1048A Pham Văn Thuan, Quarter 2, Tân Mai Ward, Bien Hoa City, Dong Nai Province
Hospital Telephone: Emergency: +84 251 3 840 840 General: +84 251 3 955 955
Ambulance Telephone: 115
Route to Hospital See next page for route map and directions.
USAID Team Members
Eileen Fanelli Mobile +84 (98) 7300806; Office +84 (24) 3935 2691
Anthony Kolb Mobile +84 (96) 2002758; Office +84 (24) 3935 2190
Phuc Nguyen Manh TBD
Cuong Nguyen Manh TBD
Team Trigon Personnel
Trigon Project Manager Sal Mansour Mobile: 058 6861 240
Site Safety Officer Kenneth Swain Mobile: +1 540 649 3584
HSE Director Lynne Black Mobile: +1 218 390 9909 Office: +1 434 422 4656
Additional Comments:
• Site Walk participants will not use or handle any hazardous chemicals or hazardous waste.
• A Safety Meeting to review the requirements of this HASP will be held and documented for Site Walk activities.
• All participants will follow all USAID, CSO, and LSECS directives and requirements.
• All injuries and incidents are to be reported to the CSO and LSECS.
Hospital Route Map Written Directions

NOTE: Individual site transportation is not available during
the conduct of reconnaissance activities. Use ambulance
service (115) or the provided transportation services, with
the following information noted to driver:
Dong Nai International

Hospital
Bệnh viện Quốc tế Hoàn Mỹ
Đồng Nai
1048A Phạm Văn Thuận, Tân
Mai, Thành phố Biên Hòa,
Đồng Nai, Vietnam
Note: This HASP, including this page, is to be available on site.

Short Form HASP Approvals
Dioxin Remediation at Bien Hoa Airbase Area
20 June 2019
A&E Bien Hoa Contractor Project Manager Date
A&E Bien Hoa Contractor LSECS Date
Contractor Safety Officer Date
Contractor PM Date

HASP Signature Form
(use additional sheets as necessary)
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.
Name Signature Date
Name Signature Date
Name Signature Date
Name Signature Date
Name Signature Date
Name Signature Date

HASP Signature Form (continued)
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.
Name Signature Date
Name Signature Date
Name Signature Date
Name Signature Date
Name Signature Date
Name Signature Date

Name Signature Date
Name Signature Date
Name Signature Date
Name Signature Date
Name Signature Date
Name Signature Date

Name Signature Date
Name Signature Date
Name Signature Date
Name Signature Date
Name Signature Date
Name Signature Date

ATTACHMENTS
Standard Operating Procedure (SOP) for Biohazards
Chemical Information for Dioxin and Arsenic
Personal Protective Equipment (PPE) Requirements
Standard Operating Procedure (SOP) for Before, During, and

After Site Walk

STANDARD OPERATING PROCEDURE (SOP)
FOR BIOHAZARDS

INITIALSITE-WIDE HEALTH & SAFETY PLAN PAGE | M-17
Standard Operating Procedure (SOP) for Biohazards
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.
This SOP discusses general precautions for working around:
Insects and arachnids;

Snakes; and
Animals.
The general precautions and emergency actions are from information on the following websites:
Centers for Disease Control and Prevention

(https://wwwnc.cdc.gov/travel/yellowbook/2018/select-destinations/vietnam);
International Association for Medical Assistance to Travelers
(https://www.iamat.org/country/vietnam/risk/zika-virus,
https://www.iamat.org/country/vietnam/risk/dengue,
https://www.iamat.org/country/vietnam/risk/chikungunya,
https://www.iamat.org/country/vietnam/risk/malaria, and
https://www.iamat.org/country/vietnam/risk/japanese-encephalitis);
U.S Library of Medicine, National Institutes of Health (Centipede sting treatment -
https://www.ncbi.nlm.nih.gov/pmc/articles/PMC4244901/);
Thailand Snakes section on Vietnam (https://www.thailandsnakes.com/southeast-asia-venomous-
snakes/vietnam-snakes-venomous-dangerous/);
World Health Organization (https://www.who.int/snakebites/treatment/en/);
Mayo Clinic (https://www.mayoclinic.org/first-aid/first-aid-snake-bites/basics/art-20056681 and
https://www.mayoclinic.org/first-aid/first-aid-animal-bites/basics/art-20056591);
Hub Pages Travel Site (https://hubpages.com/travel/Vietnam-Poisonous-Snakes-and-Venomous-
Spiders-and-other-Dangerous-Animals-and-Insects);

Insects and Arachnids
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
Bee or Wasp Stings
If stung by a bee or wasp:
Carefully remove the stinger (if present).

Wash thoroughly with soap and water.
Apply cold pack.
Use antidote kit if known to be allergic. Call for emergency assistance if symptoms appear.
Monitor for allergic reaction:
Extreme swelling;

Redness;
Pain;
Face, neck or tongue swelling;
Difficulty breathing.
Spider Bites
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.
Wash the bite area with soap and water.

Apply cold pack.
Monitor for allergic reaction.
Extreme swelling;
Redness;
Pain;
Request advanced medical care if symptoms persist.
Centipede Stings
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.
Wash the area with soap and water.

Apply hot water or hot compress to help deactivate the poison.
Follow hot pack with ice/cold pack.
• Monitor for allergic reaction.
o Extreme swelling;
Redness;
Pain;
Seek immediate advanced medical care for the pain or for secondary infection.
Mosquitoes
Mosquitoes in Vietnam are known to carry a variety of diseases, including:
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.

No known treatment or immunization.
Dengue
Peak transmission during the rainy season.
Flu-like symptoms, high fever, pain behind the eyes, muscle, joint, and bone pain, severe headache,
and red rash.
Chikungunya
Carriers typically found in and around urban and suburban dwellings.
Peak transmission during the rainy season.
Sudden onset high fever, severe muscle and joint pain, headache, fatigue, nausea, vomiting, and rash.
Joint pain can last for several months.
Malaria
Not active in the Bien Hoa Airbase Area at this time, but present in most rural areas in Vietnam.
Some strains are resistant to conventional drug treatment.
Requires pretreatment with antimalarial drugs before, during, and after visiting the area.
Japanese Encephalitis - Mosquito-Borne
Transmitted by evening-biting mosquitoes that have fed on infected wildlife.
High fever, severe headache, vomiting, diarrhea, fatigue and weakness. Some neurological
symptoms.
20-30% fatality rate.
No antiviral treatment available.
Immunization available.
Snakes
Of approximately 140 species of snakes identified in Vietnam, at least 37 are poisonous and potentially
harmful to humans, including:
38. Azemiops feae – Fea’s Viper

39. Bungarus candidus – Malayan Krait, Common Krait, Blue Krait, Javan Krait
40. Bungarus fasciatus – Banded Krait, Golden Banded Snake
41. Bungarus flaviceps – Red-headed Krait, Yellow-Headed Krait, Kinabalu Krait
42. Bungarus slowinskii – Red River Krait
43. Calliophis intestinalis – Banded Long-glanded Coral Snake, Brown Long-glanded Coral Snake
44. Calliophis maculiceps – Small-spotted Coral Snake
45. Calloselasma rhodostoma – Malayan Pit Viper
46. Daboia siamensis – Eastern Russell’s Viper, Daboia, Siamese Russell’s Viper
47. Deinagkistrodon acutus – Sharp-nosed Pit Viper, Hundred-pacer
48. Naja atra – Chinese Cobra, Taiwan Cobra, Formosan Cobra
49. Naja kaouthia – Monocellate Cobra, Thailand Cobra, Monacled Cobra
50. Naja siamensis – Thai Spitting Cobra
51. Ophiophagus hannah – King Cobra, Hamadryad, Jungle Cobra

52. Ovophis monticola – Mountain Pit Viper, Blotched Pit Viper,
53. Ovophis tonkinensis – Tonkin Pit Viper
54. Protobothrops cornutus – Horned Pit Viper, Fan-Si-Pan Horned Pit Viper
55. Protobothrops jerdonii – Jerdon’s Pit Viper, Bourret’s Pit Viper
56. Protobothrops mucrosquamatus – Chinese Habu, Taiwanese Pit Viper
57. Rhabdophis angeli – Angel’s Keelback
58. Rhabdophis callichroma –
59. Rhabdophis chrysargos – Speckle-bellied Keelback
60. Rhabdophis nigrocinctus – Green Keelback, Banded Keelback
61. Rhabdophis nuchalis – Hubei Keelback
62. Rhabdophis subminiatus – Red-necked Keelback, Heller’s Keelback
63. Sinomicrurus kelloggi – Kellog’s Coral Snake
64. Sinomicrurus macclellandi – Macclelland’s Coral Snake
65. Triceratolepidophis sieversorum – Three Horned-scaled Pitviper
66. Trimeresurus albolabris – White-lipped Green Pit Viper, White-lipped Pit Viper, White-lipped Tree
Viper
67. Trimeresurus gumprechti – Gumprecht’s Green Pit Viper
68. Trimeresurus macrops – Dark Green Pit Viper, Large-eyed Pit Viper
69. Trimeresurus popeiorum – Pope’s Pit Viper, Pope’s Green Pit Viper
70. Trimeresurus stejnegeri – Chinese Bamboo Pit Viper, Chinese Green Tree Viper
71. Trimeresurus truongsonensis – Quang Binh Pitviper
72. Trimeresurus vogeli – Vogel’s Green Pitviper, Vogel’s Pitviper
73. Tropidolaemus philippinensis – South Philippine Temple Pit Viper
74. Tropidolaemus wagleri – Wagler’s Pit Viper, Temple Pit Viper
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.

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:
Apply a tourniquet.
Cut or excise the area around the bite.
Use suction.
Apply poultices, ointments, or folk remedies to the bite.
Apply ice or heat to the wound site.
Administer medication, alcohol, or caffeine.
Treating medical personnel may prescribe acetaminophen (Paracetamol or Tylenol) for pain, which can
be extreme.
Dogs and Other Mammals
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.

First Aid for Animal Bites or Scratches
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.
• Wash the area thoroughly with soap and water.
• Apply antibiotic cream and cover with a clean bandage.
• Seek advanced medical care at the nearest hospital facility.

CHEMICAL INFORMATION FOR
DIOXIN AND ARSENIC

Chemical Information: Dioxin and Arsenic
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:
Safety Data Sheets (SDSs)

Dioxin 1746-01-6
Arsenic 7440-38-2
Additional information is available on the following websites:
US Environmental Protection Agency (USEPA)

USEPA Bulletin - Dioxin
USEPA Supporting Documents - Dioxin
USEPA Bulletin - Arsenic Compounds
National Institute for Occupational Safety and Health (NIOSH) Pocket Guide
NIOSH Pocket Guide - Dioxin
NIOSH Pocket Guide - Arsenic

PERSONAL PROTECTIVE EQUIPMENT
(PPE) REQUIREMENTS

Personal Protective Equipment (PPE) Requirements
For the Contractor Site Walk at the Bien Hoa Airbase Area, the following are examples of the PPE
required under this Site Walk HASP.
HARD-TOED FOOTWARE (WORK BOOTS)
HEARING PROTECTION (IF AIRCRAFT ARE ACTIVE)
HARD HAT (WORN AS REQUIRED BY HOST)

HI-VISIBILITY SAFETY VEST (WORN AS REQUIRED BY HOST)
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.
EYE PROTECTION (IN WINDY CONDITIONS)
BOOT COVERS (FOR WET OR MUDDY CONDITIONS)

STANDARD OPERATING PROCEDURE
(SOP) FOR BEFORE, DURING, AND
AFTER NON-INTRUSIVE SITE WALK

Standard Operating Procedures Before, During, and After Site Walk
BEFORE SITE WALK
• Attend the safety briefing presented by the CSO and LSECS.

• Read and sign the HASP.
• Ask questions if you are in doubt as to what to do.
• Have all required PPE ready on hand.
• Ensure your personal drinking water supply.
• Locate the first aid kit, hand sanitizers, and wound cleaning supplies.
• Be prepared with a clean change of clothing and shoes in the event that dusty or muddy
conditions are encountered.
• If dusty conditions are encountered, site walk may be postponed until conditions improve.
DURING THE SITE WALK
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.

AFTER THE SITE WALK
• 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.

FINAL SUPPLEMENTAL HEALTH & SAFETY

PLAN 3 MEDICAL SURVEILLANCE PROGRAM
ORIENTATION
APRIL 28, 2020

DISCLAIMER:
FINAL SUPPLEMENTAL HEALTH & SAFETY

PLAN 3 MEDICAL SURVEILLANCE
PROGRAM ORIENTATION

APRIL 28, 2020
PREPARED BY
USA
DISCLAIMER:
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

DRAFT SHASP–3: MEDICAL SURVEILLANCE ORIENTATION PROGRAM | i
RECORD OF REVISIONS
Revision Date Pages Revisions Approval
000 April 28, 2020 All Initial development/submittal USAID CO/COR

DRAFT SHASP–3: MEDICAL SURVEILLANCE ORIENTATION PROGRAM | ii
ACRONYMS AND ABBREVIATIONS
% percent
A&E Architecture and Engineering
CFR Code of Federal Regulations
CIT Certified Instructional Trainer
CO Contracting Officer
COP Chief of Party
COR Contracting Officer Representative
CSO Contractor Safety Officer
DCOP Deputy Chief of Party
EA Environmental Assessment
EM 385-1-1 USACE Safety and Health Requirements
Manual
LSECS Lead Safety and Environmental
Compliance Specialist
PCDD/F polychlorobenzodioxins and
polychlorodibenzofurans
PEL Permissible Exposure Limit (OSHA)
PPE Personal Protective Equipment
ppt Parts per trillion
SHASP Supplemental HASP
2,3,7,8-TCDD 2,3,7,8-Tetrachlorodibenzodioxin
TCDD 2,3,7,8-Tetrachlorodibenzodioxin
TEQ Toxicity Equivalent
U.S. United States
USAID U.S. Agency for International
Development
USACE U.S. Army Corps of Engineers
USEPA United Stated Environmental Protection
Agency

DRAFT SHASP–3: MEDICAL SURVEILLANCE ORIENTATION PROGRAM | iii
1 SIGNATURE SHEET
Dioxin Remediation at
Bien Hoa Airbase Area Project
SUPPLEMENTAL HEALTH & SAFETY PLAN 3 SIGNATURE PAGE
United States Agency for International Development

Contract Number: AID--OAA-I-15-00053
March 2020
Plan Prepared By:
Lynne Black, CIT

Health and Safety Officer; (434) 422-4656
Plan Submitted By:
Sal Mansour
Chief of Party
Plan Approval By:
Suzanne Johnson
Contracting Officer
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).

DRAFT SHASP–3: MEDICAL SURVEILLANCE ORIENTATION PROGRAM | 1-1
2 BACKGROUND INFORMATION
2.1 PROJECT INFORMATION AND BACKGROUND

Client: U.S. Agency for International Development (USAID)
Project Name: Dioxin Remediation at Bien Hoa Airbase Area Project (Project)
A&E Bien Hoa Contractor: Trigon Associates, Inc.
Contract Number: AID—OOAA-I-15-00053
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).
2.2 CONTAMINANT OF CONCERN

Dioxins are a group of toxic chemical compounds with similar chemical structures that are persistent
organic pollutants – meaning dioxins are toxic over many decades and do not break down easily. The
term “dioxin” or PCDD/F refers to a group of polychlorodibenzodioxins (PCDDs) and
polychlorodibenzofurans (PCDFs). PCDDs are comprised of 75 “congeners,” and PCDFs are
comprised of 135 congeners. A “congener” is a variant or configuration of a common chemical
structure. PCDDs and PCDFs are not commercial chemical products but are trace level byproducts

of combustion and several industrial chemical processes (including paper and pulp bleaching and
production of historical herbicides).
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 EXPOSURE ROUTES

There are three major site exposure routes for TCDD at the Bien Hoa Airbase Area: 1) dermal
(skin) contact, 2) inhalation, and 3) ingestion. The three exposure routes have various exposure
pathways. In addition, there are two main off-site exposure pathways of 1) ingestion of contaminated
food and 2) inhalation of background sources of combustion. These exposure routes and pathways
are discussed below. In addition, the (Revised) Draft Technical Memorandum Site Conceptual Model and
Data Gap Analysis presents the site conceptual model for the Bien Hoa Airbase Area and provides a
detailed description of exposure routes (USAID 2020).
3.1.1 DERMAL (SKIN) CONTACT

Dermal contact can result in dermal absorption which is the transport of a chemical from the skin or
eyes into the body. At the Bien Hoa Airbase Area, dermal exposure to dioxin contaminated materials
can occur via direct skin contact with contaminated soils, sediments, suspended sediments in surface
water, and groundwater or exposure through the eyes. Dermal exposure to dioxin contaminated
media is the most likely exposure pathway at the Bien Hoa Airbase Area due to the high frequency
that contaminated materials will be handled during excavation, treatment, and environmental

sampling. However, the hazards are limited by wearing appropriate personal protective equipment
(PPE) that protects against skin contact with contaminated soil, sediment, and water and eye exposure
and utilizing other mitigation measures. The minimum PPE requirements are detailed in Section 9.10
PPE Requirement Program of the Site-Wide HASP. Mitigation measure will vary based upon the activity
and more detail is provided in Section 9 Plans and Programs Required by the Safety Manual of the Site-
Wide HASP.
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.
3.1.4 OFF-SITE EXPOSURE ROUTES

The two major offsite exposure pathways are the ingestion of contaminated food sources and the
inhalation of background sources of combustion. Dioxin is a persistent organic pollutant that does
not break down easily and is absorbed and stored in fat and tissue. The lipophilic properties of dioxin
cause bioaccumulation in the food chain and exposure to those who consume contaminated food
sources. More than 90 percent (%) of dioxin exposure in humans worldwide is through food. Various
studies of food sources in the Bien Hoa Area have confirmed elevated levels of dioxin in food,
especially high fat foods like fish, pork, beef, chicken, and chicken eggs (Hatfield and VRTC 2009,
Hatfield and Office 33 2011; GVN/USAID 2016; Nguyen et al. 2018). In addition, dioxins are formed
as a result of background sources of combustion like burning trash containing plastics or chemicals,
cigarette smoke, and vehicle exhaust which can be inhaled as airborne particulate.

3.2 SYMPTOMS OF EXPOSURE
Symptoms of dioxin exposure vary based on the exposure route and concentration, duration, and
frequency of exposure. Short-term dermal (direct eye or skin contact) exposure of high
concentrations of dioxin can cause various eye and skin irritations including the following listed in
order of severity and exposure level:
• Skin and eye irritation,

• Allergic dermatitis (red, itchy rash),
• Chloracne (severe skin disease with lesions that resemble acne and blackheads and occur
mainly on the face and upper body), and
• Porphyria (skin itching and tenderness, swelling, nervous system disorders).
Short-term exposure of high concentrations of dioxin usually via ingestion may also cause the
following:
• 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.
4 MEDICAL SURVEILLANCE PROGRAM

A medical surveillance program will be required for all personnel working at the site while activities
are conducted that could lead to dioxin exposure. The medical surveillance programs will include
blood serum dioxin monitoring, general medical surveillance monitoring for other chemicals in
accordance with 29 CFR 1910.120, and a medical surveillance orientation program. Site activities with
the potential for dioxin exposure include intrusive activities as well as activities related to remedial
treatment operations. Project Contractors are responsible for developing and implementing a
contract-specific medical surveillance program for personnel who will be involved with site activities
with the potential for dioxin exposure. This will include the requirements detailed in Section 9.18.1
and 9.18.2 of the Site-Wide HASP and the requirements detailed in this SHASP.
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.
4.1 ACTIVITY HAZARDS AND LEVELS OF PPE

As described in Section 4.4 Pre-Task Safety and Health Analysis of the Site-Wide HASP, the first step in safety
and health planning for a new work activity is defining the types of work and associated risks. Activity
Hazard Analyses (AHAs) are tools to identify and define the work activities and associated tasks, identify
the sequence of work and specific anticipated hazards, and establish necessary control measures to
eliminated or reduce each hazard to an acceptable risk level. They also establish the minimum PPE required
for protection from hazardous materials.
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.
4.2 LEVELS OF MONITORING

Medical monitoring will be performed at three different levels of effort and intensity based on a
workers’ site activities and the frequency and duration of those activities. The three levels of medical
monitoring are described below.
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.
4.3 MEDICAL SURVEILLANCE PROGRAM REQUIREMENTS
4.3.1 EXAMINATION REQUIREMENTS AND FREQUENCY

The minimum required medical exams and frequencies are included in Section 9.18.1 Medical
Surveillance Program of the Site-Wide HASP. Tables 4-1 through 4-3 list the typical contents and
frequency of periodic exams for the different medical surveillance levels. Tables 4-1 and 4-3 include
additional exam elements at the bottom of the tables that may be included based on the Health and
Safety professional’s or attending physician/nurse practitioner’s recommendation due to the
employee’s work history.
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.
In addition, employees may receive supplemental medical monitoring examinations:

• As soon as possible if employee develops signs or symptoms of exposure;
• After any worksite injury;
• After an exposure incident;
• If serum dioxin levels exceed allowable limit: or
• At more frequent times if determined necessary by the examining occupational health physician.
TABLE 4-1. LEVEL 1 MEDICAL SURVEILLANCE EXAMINATIONS AND FREQUENCY
Examination Frequency
General Medical Questionnaire – Medical and Work  At start of assignment/employment
(Exposure) History  Annually
 At termination of employment or reassignment to a job
offsite
Work or Exposure History will be collected:
 Post exposure
 Post injury
 If symptoms of exposure develop
 If occupational health physician recommends
Physical Exam – including Visual Acuity and Audiometry  At start of assignment/employment
 Annually
Complete Blood Count (CBC)  At start of assignment/employment
 Annually
Sequential Multi-Channel Analysis (Comprehensive Metabolic  At start of assignment/employment
Panel)  Annually
Cardiopulmonary Function Testing  At start of assignment/employment
 Annually
Blood Serum Dioxin Analysis  Baseline - at start of assignment/employment
 Annually
offsite
 Post exposure
 Post injury
Health and Lifestyle Questionnaire – Blood Serum Dioxin  Baseline - at start of assignment/employment
Assessment
Additional Exam Elements – if requested by H&S Management or Occupational Health Physician
 Respirator Fit Test  RBC Cholinesterase  Serum Cholinesterase
 Blood Lead/ZPP  Urine Heavy Metal  Methemoglobin
 EKG  Tetanus/Diphtheria Vaccine  Cardia Stress Test

(Exposure) History  Annually
offsite
 Post exposure
 Post injury
 Annually
offsite
 Post exposure
 Post injury
Assessment

(Exposure) History  Every six months
offsite
 Post exposure
 Post injury
Physical Exam – including Visual Acuity and Audiometry  At start of assignment/employment
 Annually
Complete Blood Count (CBC)  At start of assignment/employment
 Annually
Sequential Multi-Channel Analysis (Comprehensive Metabolic  At start of assignment/employment
Panel)  Annually
Cardiopulmonary Function Testing  At start of assignment/employment
 Annually
 Every six months
offsite
 Post exposure
 Post injury
Assessment
Additional Exam Elements – if requested by H&S Management or Occupational Health Physician
 Respirator Fit Test  RBC Cholinesterase  Serum Cholinesterase
 Blood Lead/ZPP  Urine Heavy Metal  Methemoglobin
 EKG  Tetanus/Diphtheria Vaccine  Cardia Stress Test

4.3.2 MEDICAL SURVEILLANCE PROGRAM ORIENTATION TRAINING
Before participation in the medical surveillance program, medical surveillance program orientation
training must be provided to all participants including Level 1, Level 2, and Level 3 workers. Medical
surveillance orientation training must also be provided to occasional site workers that will be on site
during intrusive and/or remedial treatment operation activities for more than 30 days but not more
than 90 days (8 hours per day) per year and will remain outside of exclusion zones. Visitors to the
site will not be required to receive the medical surveillance program orientation training.
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.
4.4 BLOOD SERUM DIOXIN MONITORING

At the start of employment, all three levels of the medical surveillance program will have baseline
blood serum dioxin samples collected. The baseline blood serum results are extremely important as
they set each employee’s baseline blood serum dioxin concentration and establish a control level that
has not been affected by site activities. During employment, periodic blood serum dioxin samples will
be collected at varying frequencies based on an employee’s medical surveillance level designation.
The purpose of the periodic blood serum dioxin samples is to monitor the health of employees over
the course of the Project to ensure protective measures including PPE and site controls are
appropriate and being utilized properly by the employees. Exit samples will be collected from all three
levels of the medical surveillance program upon termination of employment or reassignment off site.
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).
4.4.1 ASSURANCE OF CONFIDENTIALITY

No identifying employee medical records will be retained on the site. Employees will be assigned a
unique identification number for tracking their results. This number shall be provided to the attending
occupational health physician, the analytical laboratory, Contractor Safety Officer (CSO), and the
A&E Bien Hoa Contractor Lead Safety and Environmental Compliance Specialist (LSECS). The

associated names will be retained only by the attending occupational health physician and the
employer. The anonymous dioxin blood serum results must be reported to the CSO and A&E Bien
Hoa Contractor LSECS on a monthly basis in electronic and tabulated format. The dioxin blood
serum results will be reported in the format included in Appendix C. The anonymous dioxin blood
serum results will be shared with USAID. USAID will compile and maintain the anonymous dioxin
blood serum results for the duration of the Project.
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.
4.4.2 BLOOD TEST RESULTS

4.4.2.1 COMMUNICATION
Blood serum dioxin results are private medical information. The occupational health physician will
provide the blood serum results in a letter directly to participants of the blood serum dioxin
monitoring via their personal email addresses or via US Mail or international mail carrier to
participants personal residences. The delivery method will be based on participants preferences.
Although company emails are not considered a private platform, if a participant approves the use of
company email as the method of conveyance of results, the occupational health physician will convey
the results in that manner. An example letter presenting the results of the blood serum dioxin testing
to the employee is included in Appendix E. A medical professional will be made available to the
employee to discuss their results at any time during blood serum dioxin monitoring.
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:

• Identification of which dioxin congener is the source of the elevated levels by comparing the
congener-specific concentrations to the 95th percentiles (if 2,3,7,8-TCDD is substantially elevated
compared to other congeners, this may indicate a site-related exposure),
o Dermal assessment
• Employee consultation with the examining occupational health physician to understand the
• 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,
o Dermal assessment
• Employee consultation with the attending occupational health physician to understand the
• 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.
In addition, the employee’s work habits will be assessed to ensure:

• PPE was used properly and consistently throughout Project assignment,
• Decontamination was performed before departure from the site,
• Worker did not enter the Project site unprotected in areas where PPE was required, and
• Other work habits did not contribute to the elevation of serum dioxin level.
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.

5 REFERENCES
GVN/USAID (CDM International, Inc. and Hatfield Consultants). 2016. Environmental Assessment of
Dioxin Contamination at Bien Hoa Airbase. May 3, 2016.
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.
Nguyen MH et al. 2018. Site-specific bioaccumulation of polychlorinated dibenzo-pdioxins and

polychlorinated dibenzofurans (PCDD/PCDFs) in mothers and their infants living in vicinity of Bien
Hoa Airbase, Southern 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.

APPENDIX A. MEDICAL SURVEILLANCE
PROGRAM ORIENTATION
TRAINING MATERIAL
MEDICAL
SURVEILLANCE
PROGRAM
ORIENTATION
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
12-Apr-21 MEDICAL SURVEILLANCE PROGRAM ORIENTATION 2

OUTLINE
• Health Risk Communication
• Risk Management
• Medical Surveillance Program
• Potential Exposure
• Dioxin Hazard Communication
• Frequently Asked Questions – Answers
MEDICAL SURVEILLANCE PROGRAM ORIENTATION

12-Apr-21 3
HEALTH RISK COMMUNICATION
• Introduction to Risk
• How a Health Risk is Determined
• Introduction to Health Risk Communication
• Health Risk
• Hazard Toxicity
12-Apr-21 MEDICAL SURVEILLANCE ORIENTATION PROGRAM 4

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

How a Health Risk is Determined

• Experts study an issue and determine there is a link between a hazard
and a health effect
• Hazard = smoking Linked Health Effect = lung cancer
to

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

Introduction to Health Risk Communication

• The exchange of information, advice, and opinions between experts
and people facing risks to their health
• Purpose = enable people at risk to make informed decisions to
protect themselves and loved ones
Community Health Community & Political

Issues, Local Context Preferences & Actions
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?

OUTLINE
• Risk Management

12-Apr-21 10
RISK MANAGEMENT
Project Objective
• Project Safety
Goal = Zero
Injury!
• Prevent/limit
exposure of
dioxin to levels
below those that
are likely to have
health effects

RISK MANAGEMENT
Project Objective HOW?

• Project Safety
Goal = Zero
Injury!
Making
• Prevent/limit
exposure of
Risk Visible
dioxin to levels
below those that
are likely to have
health effects

OUTLINE
• Risk Management

MEDICAL SURVEILLANCE PROGRAM
• Purpose
• Levels of Monitoring
– Level 1
– Level 2
– Level 3
– Occasional Site Workers
• Frequency of Examinations and Testing
• Action Limit for Blood Serum Dioxin Levels
• Assurance of Confidentiality
• Record Keeping and Data Management
– Anonymous Dioxin Blood Serum Results
– Occupational Health Physician

Purpose
• One requirement of Site-Wide Health & Safety Plan (HASP)
• Set limits so that worker health is not affected
• Monitoring to:
– Ensure effectiveness:
 Appropriate PPE;
 Appropriate site control measures; and
 Utilized properly by the employees.
– Know when to take corrective action

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.

Levels of Monitoring (continued)

• Level 1 – Wearing Level C PPE or more stringent >30 days a year
• Level 2 – Wearing Level D PPE (or no PPE) but onsite >90 days a year
• Level 3 – Wearing Level B PPE or more stringent >15 days a year
(workers with highest risk for dioxin exposure).
* Day = 8 hours.
Medical Surveillance Orientation – for Level 1, Level 2, Level 3, and
occasional site workers
Not monitored – site visitors, vendors, and delivery personnel

Levels of Monitoring (continued)

Occasional Site Workers
• Outside of exclusion zone
• On site more than 30 days/year, 8 hours/day but not more than 90 days

Frequency of Examinations and Testing

Level 1 and Level 2
• Baseline at start of assignment/employment
• Annual
• Exit at end of assignment/employment
Level 3
• Baseline at start of assignment/employment
• Every six months
• Exit at end of assignment/employment

Frequency of Examinations and Testing (continued)

Level 1, Level 2, and Level 3:
– Post exposure examination
– Post injury examination
– If symptoms of exposure develop
– If serum dioxin level exceeds allowable
– If occupational health physician recommends

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
• Other biological systems testing

• Cardiopulmonary function testing

Type of Examinations (continued)

Level 2 Examination:
• Baseline medical and work history questionnaire with updates
completed annually or as triggered by exposure or injury event
• Serum dioxin blood testing with Health / Lifestyle questionnaire

FREQUENTLY ASKED QUESTIONS
Why is “blood serum dioxin testing” used to assess
the amount of dioxins accumulated in the body?
• Dioxin level in blood serum is measured relative to the
blood lipid (fat) level
• Because dioxins are absorbed and stored in fatty tissues or
body fat
• Blood serum dioxin testing is less invasive than taking a
sample of body fat

12-Apr-21 23
Action Limit for Blood Serum Dioxin Levels

Project Action Limit for Blood Serum Dioxin is 30 picograms/gram
(pg/g lipid or parts per trillion) TEQ.
• TEQ = toxicity equivalents which standardizes toxicity of

dioxins/furans and dioxin-like substances to 2,3,7,8-
tetrachlorodibenzodioxin (2,3,7,8-TCDD)
• Part per trillion = one drop of water in an Olympic-sized swimming
pool

Are there levels of dioxins which are considered as
‘acceptable’ or ‘problematic’?
• There are no definitive levels of dioxins which are
considered ‘acceptable’ or ‘problematic’
• Different countries and jurisdictions have their own
guidelines for determining acceptable levels of dioxin in
human blood or other media (e.g., soil, food, breast milk,
etc.)
• Conservative action limit has been set for the Project that is
protective of human health:
– Project Action Limit for Blood Serum Dioxin = 30
picograms/gram of lipid (pg/g or parts per trillion) TEQ

12-Apr-21 25
What Happens if a Worker’s Blood Serum Dioxin Exceeds Action Limit?

• Employee will:
– Be restricted from performing intrusive work, or
– Stop working on the site.
• Consult with attending occupational physician
• Perform confirmation sampling
• Further blood testing to assess health conditions
• Review site activities & PPE procedures and take corrective actions

What Happens if a Worker’s Blood Serum Dioxin Increases Over Time?
• Small changes up to ± 20% can occur without indicating an issue
• Will identify which congeners are the source of elevated levels
– If 2,3,7,8-TCDD is substantially elevated, this may indicate a site-
related exposure
– Employee will:
 Be restricted from performing intrusive tasks, or
 Stop working on the site.
• Consult with attending occupational physician
Dioxin Blood Serum Action Limit of 30 pg/g

What Happens if a Worker’s Blood Serum Dioxin Increases Over Time?

(continued)
• Perform confirmation sampling
• Further blood testing to assess health conditions
• Review site activities & PPE procedures and take corrective actions
• A&E Bien Hoa Contractor will recommend changes for USAID
consideration in (sub)contractor activities and/or to the HASP
• (Sub)contractors will provide re-training in identified areas and closely
observe the worker for the first three (3) days on site after

How are the dioxin blood serum results interpreted?
• Individual dioxin results may vary and analytical method may
show up to 20% difference
• Influenced by a person’s blood chemistry and lipid content
at the time of sampling
• Lipid levels can change day-to-day or even meal-to-meal
• Most important consideration is changes in a
person’s blood serum dioxin levels over time
• Small changes up to ± 20% can occur without indicating an
issue
• If 2,3,7,8-TCDD is substantially elevated, this may indicate a
site-related exposure

12-Apr-21 29
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

Record Keeping and Data Management

• Anonymous dioxin blood serum results
– All results will be completely anonymous and stored only with the
employee identification number
• Occupational health physician will contact employee with…
– Results of analysis and
– Further action required, if any

OUTLINE
• Risk Management

POTENTIAL EXPOSURE
• Symptoms of Exposure
• Potential Exposure Scenarios
• Procedures – If Develop Symptoms
• Procedures – If Exposure Occurs

POTENTIAL EXPOSURE
Symptoms of Exposure
• Acute Exposure (high concentration, short duration)
– Onset of symptoms can take days to weeks
– Symptoms of acute exposure
 Skin and eye irritation
 Allergic dermatitis
 Chloracne
 Porphyria (skin itching and tenderness, swelling, nervous system
disorders)
 Gastrointestinal disturbances
• Long-term Exposure (low to any concentration, long duration)
– Impairment of the immune system, nervous system, endocrine system, and
reproductive function
– Cancer

POTENTIAL EXPOSURE
Routes
• Dermal Contact – direct skin contact with contaminated
media, contaminated media exposed to your eyes
• Inhalation – exposure to contaminated air or dust
• Ingestion – eating contaminated media

POTENTIAL EXPOSURE
Example Scenarios
• Failure of Personal Protective Equipment (PPE)
– During excavation of contaminated soil, respirator is not secured
properly, and you notice the seal is broken
– During sediment sampling in a submerged area, you notice water inside
your coveralls from a small tear
• Failure of Procedures
– During decontamination you make contact with external contaminated
surface of PPE
• Accidental Incident
– During excavation, the wind speed rises quickly, dust suppression
techniques fail, and the field office is exposed to contaminated dust

POTENTIAL EXPOSURE
Procedures – If Develop Symptoms
• Notify the task safety lead and your supervisor
• Notify the Lead Safety & Environmental Compliance Specialist
(LSECS) or the Health, Safety, and Environment (HSE) Officer
• Follow directions for additional blood testing and physician visits

POTENTIAL EXPOSURE
Procedures – If Exposure Occurs
• Notify the task safety lead and your supervisor
• Notify LSECS or the HSE officer
• Follow directions for additional blood testing and physician
visits
• Review site activities & PPE procedures and take corrective
actions

Why is dioxin dangerous?
• Toxic over many years, not water soluble, and does not
degrade easily
• Clings to soil/sediment and can be transported by surface
water downstream into sediments of surface water bodies
where it can enter the food chain
• Chemically stable and retained in human fatty tissue
• Alters cellular and chemical balances involved in bodily
functioning and reproductive processes
• Some health effects cannot be corrected or reversed
• Genetic effects may skip a generation and reappear in third
or subsequent generations
12-Apr-21 MEDICAL SURVEILLANCE PROGRAM ORIENTATION

39
What are the health effects?
• Dioxins are highly toxic and can cause cancer, reproductive
and developmental problems, damage to the immune system
and can interfere with hormones
• Short-term exposure of high levels may result in skin lesions
(chloracne, patchy darkening of the skin) and altered liver
function
• Long-term exposure is linked to impairment of the immune
system, developing nervous system, endocrine system, and
reproductive function

40
Are some groups more sensitive to the effects of dioxin
exposure than others?
• The developing fetus is the most sensitive to dioxin exposure
• Pregnant or nursing mothers
– Dioxin exposure can effect the developing fetus
– Dioxin is stored in breast milk due to the high fat content
• Children, including infants who are nursing, are more sensitive
because:
– Children and infants are smaller and receive higher dose of
chemical exposure per body weight
– Children and infants are more vulnerable to toxic
exposures as their body grows

12-Apr-21 41
OUTLINE
• Risk Management

DIOXIN HAZARD COMMUNICATION
• Dioxin 101
– Sources
– Properties
– Major Site Exposure Routes
– Off-site Exposure Routes

Dioxin 101 – Sources

2,3,7,8-TCDD
• Primary congener associated with Agent Orange and primary type of
dioxin at the Bien Hoa Airbase Area
• Not intentionally added; byproduct produced during manufacturing of
herbicides that were used in Agent Orange
• 2,3,7,8-TCDD has the chemical formula
of C₁₂H₄Cl₄O₂

Dioxin 101 – Properties

• Group of toxic chemical compounds with similar chemical structures
and biological effects
• A persistent organic pollutant that is toxic over many decades – does
not break down easily
• Absorbed and stored in fat and tissue – bioaccumulates in the food
chain
• Sticks to soil/sediment particles
• Not water soluble
• Not volatile

Dioxin 101 – Personal Exposure Routes

1) Dermal Contact – Exposure to dioxin concentrations in soils,
sediments, suspended sediment in surface water, and groundwater
can result via direct contact of contaminated media with skin


2) Inhalation – Dioxin concentrations in airborne particulate such as
windblown soil, dust, and ash
• Dust producing activities
• Excavation
• Transport of contaminated soil and sediment
• Intrusive activities (e.g., soil sampling, installing MWs, etc.)


3) Ingestion – Soil ingestion, or potentially contaminated drinking
water, can result in dioxin exposure to human and ecological
receptors
• No dioxin concentrations have been identified in drinking water
samples collected above the USEPA MCL or GVN discharge standard.
• Contaminated areas:
– Eating and smoking are not allowed
– Drinking water needs to be done without contacting contaminated
surfaces from hands, gloves, etc.

Dioxin 101 – Off-site Exposure Routes
Two major off-site exposure routes:
1) Ingestion - Dioxin exposure occurs primarily via ingestion of
contaminated food sources
– More than 90% of human dioxin exposure is through food
– High fat animal products like milk products, eggs, meat, and some
fish
2) Background Sources of Combustion
– Burning trash containing plastics or chemicals
– Cigarette smoke
– Vehicle exhaust

OUTLINE
• Risk Management

• Where do ‘background’ exposures of dioxins come

from?
• What are some of the non-site related ways that I can
be exposed to dioxins?
• What are dioxins?
• Why are dioxin concentrations reported as TEQ
concentrations?
• Is the level of harm the same for different dioxin
congeners?
• What is the lifespan of dioxin?

What are Dioxins?
• Group of toxic chemical compounds with similar chemical structures and
biological effects
• Generally stick to soil/sediment particles, not water soluble, and don’t break
down easily
• Absorbed and stored in fat and tissue and so bioaccumulate in the food chain
• Over 400 types of dioxin-related compounds – only 17 with significant
toxicity
• Three closely related families: 1) polychlorinated dibenzodioxins (PCDDs), 2)
polychlorinated dibenzofurans (PCDFs), and 3) Certain planar
polychlorinated biphenyls (PCBs)
• PCDDs and PCDFs are not commercial chemical products but are trace level
byproducts of combustion and several industrial chemical processes.
• Most toxic PCDD congener is 2,3,7,8-TCDD
• 2,3,7,8-TCDD is the primary congener associated with Agent Orange and
primary type of dioxin at the Bien Hoa Airbase Area

Why are dioxin concentrations reported as TEQ concentrations?
• Total dioxin concentrations of all congeners reported as 2,3,7,8-TCDD
toxicity equivalents (TEQ) using toxicity equivalent factors (TEF)
– Dioxins have different numbers and locations of chlorines
– Congener = variant or configuration of a common chemical structure
• Because the mechanism of toxicity is the same, TEFs can be used to
represent toxicity of a congener relative to 2,3,7,8-TCDD (the most
toxic)
– 2,3,7,8-TCDF has a TEF of 0.1 or 1/10 , so it is 10 times less toxic
than 2,3,7,8-TCDD
– A TEF value is assigned to each congener, multiplied by the
concentration of each congener, and then added together to express
the total dioxin concentration in TEQ
• TEQ concentrations can be directly compared with toxicity criteria,
screening levels, and regulatory requirements for 2,3,7,8-TCDD

53
Is the level of harm the same for different dioxin congeners?
• No, because the variability in chemical structure (number and location
of chlorines) affects a congener’s toxicity
• 2,3,7,8-TCDD is the most toxic
• Dioxins are most often found in mixtures in the environment which is
why measurements of TEQ are useful
• Level of harm depends on the type of dioxin(s), amounts present, type
of exposure and duration

54
Where do ‘background’ exposures of dioxins come from?
• Widely distributed in the environment at low concentrations from:
– Industrial processes: chemical manufacturing, chlorine
bleaching of pulp and paper
– Combustion: car emissions, waste incineration, burning of
trash, wood stoves, smoking cigarettes
– Natural sources: wildfires, volcanoes
• Dioxins are persistent and bioaccumulate (meaning dioxin
concentrations build up in the body over time)
• Most people have detectable limits in their tissues
• Background levels accumulate over a lifetime and persist for years –
even if no additional exposure (rate of degradation depends on
congener)

What are some of the non-site related ways that I can
be exposed to dioxins?
• More than 90% of human dioxin exposure is through food
• Dioxin contaminated high-fat foods: milk products, eggs,
meat, and some fish
• Burning trash containing plastics or chemicals
• Cigarette smoke
• Vehicle exhaust

12-Apr-21 56
What is the lifespan of dioxin?
• Measured in half-lives:
– time for concentration to
decrease to half of the
original amount.
• Depends on its location:
– In the environment depends on the type of soil and depth
– On the surface will be broken down by the sun in 1-3
years depending on conditions
– In subsurface soil and waterbody sediments can have a
half-life of more than 100 years
– In human body is 3-15 years, can be as high as 20 years
with the TCDD half life averaging 7 years

12-Apr-21 57
References
Biological Half Life:
• Milbrath et al. (2009). Apparent Half-Lives of Dioxins, Furans, and Polychlorinated Biphenyls as a
Function of Age, Body Fat, Smoking Status, and Breast-Feeding. Environ Health Persp. 117 417.
Toxicity Value Hierarchy:
• USEPA (2003). Human Health Toxicity Values in Superfund Risk Assessments. Washington, D.C., U.S.
Environmental Protection Agency.
PCDD/F Toxicological Profiles:
• ATSDR (1994).Toxicological Profile for 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.
Toxicity Equivalent Factors (TEF):
• Van den Berg, M., L. S. Birnbaum, et al. (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.
Threshold/Non-Threshold Approach to Carcinogen Risk Assessment:
• USEPA (1989). Risk Assessment Guidance for Superfund (RAGS):Volume 1 – Human HealthEvaluation
Manual (Part A). Office of Emergency and Remedial Response, U.S. Environmental Protection Agency.
• USEPA (2005). Guidelines for Carcinogen Risk Assessment, U.S. Environmental Protection Agency

References
Toxicological Values and Studies Relied Upon:
• JECFA (2002). Polychlorinated dibenzodioxins, polychlorinated dibenzofurans, and coplanar polychlorinated
biphenyls, Joint FAO/WHO Expert Committee on Food Additives WHO Food Additives Series 48.
• NTP (1982). Bioassay of 2,3,7,8-tetrachlorodibenzo-pdioxin for possible carcinogenicity (dermal) C. T.
Program. National Cancer Institute, Bethesda, MD, and National Toxicology Program, Research Triangle Park,
NC, National Toxicology Program.
• OEHHA (2011). Technical Support Document for Cancer Potency Factors Appendix B: Chemical-Specific
Summaries of the Information Used to Derive Unit Risk and Cancer Potency Values. Air Toxics Hot Spot
Program, Office of Environmental Health Hazard Assessment.
• OEHHA (2015). Guidance Manual for Preparation of Health Risk Assessments. Air Toxics Hot Spot Program,
Office of Environmental Health Hazard Assessment.
• USEPA (2012). 2,3,7,8-Tetrachlorodibenzo-p-dioxin (TCDD); CASRN 1746-01-6. Integrated Risk Information
System, U.S. Environmental Protection Agency.
• Baccarelli, A., S. M. Giacomini, et al. (2008). "Neonatal thyroid function in Seveso 25 years after maternal
exposure to dioxin." PLoS Med 5(7): e161.
• Mocarelli, P., P. M. Gerthoux, et al. (2008). "Dioxin exposure, from infancy through puberty, produces endocrine
disruption and affects human semen quality." Environ Health Perspect 116(1): 70-77.
• OEHHA (1999). Technical Support Document for the Derivation of Noncancer RELs Appendix D.3 Chronic
RELs and toxicity summaries using the previous version of the Hot Spots Risk Assessment guidelines. Air
Toxics Hot Spot Program, Office of Environmental Health Hazard Assessment.
• OEHHA (2014). Technical Supporting Document for Noncancer RELs Appendix D. Individual Acute, 8-Hour,
and Chronic Reference Exposure Level Summaries. Air Toxics Hot Spot Program, Office of Environmental
Health Hazard Assessment.
• Kociba, R. J., D. G. Keyes, et al. (1978). "Results of a two-year chronic toxicity and oncogenicity study of
2,3,7,8-tetrachlorodibenzo-p-dioxin in rats." Toxicol Appl Pharmacol 46(2): 279-303.
References
General Dioxin Resources:
• Centers for Disease Control and Prevention (CDC). 2017. National Biomonitoring Program, Chemical
Factsheets; Dioxins, Furans and Dioxin-Like Polychlorinated Biphenyls Factsheet. Available at
https://www.cdc.gov/biomonitoring/DioxinLikeChemicals_FactSheet.html. April.
• Environment Agency of Japan. 2000. Report on Tolerable Daily Intake (TDI) of Dioxins and Related
Compounds. Available at https://www.env.go.jp/en/chemi/dioxins/tdi_report.pdf. August.
• National Institute of Environmental Health Sciences (NIEHS). 2017. Dioxins. Available at
https://www.niehs.nih.gov/health/topics/agents/dioxins/index.cfm. August.
• New Zealand Ministry of Health. 2008. Serum Dioxin Testing Factsheet. Available at
https://www.health.govt.nz/system/files/documents/pages/dioxins-practitioners-serumtesting.pdf. June.
• The Aspen Institute. 2020.The Agent Orange in Vietnam Program. Available at
https://www.aspeninstitute.org/programs/agent-orange-in-vietnam-program/.
• United States Department of Veteran Affairs. 2017. Agent Orange. Available at
https://www.publichealth.va.gov/exposures/agentorange/index.asp.
• United States Environmental Protection Agency (USEPA). 2019. Learn about Dioxin. Available at
https://www.epa.gov/dioxin/learn-about-dioxin. July.
• World Health Organization (WHO). 2020. International Programme on Chemical Safety, Dioxins and
dioxin-like substances. Available at https://www.who.int/ipcs/assessment/public_health/dioxins/en/.

APPENDIX B. DIOXIN REFERENCE LIST
Dioxin References and Additional Background Information
Abad, E., J.J. Llerena, J. Sauló, J. Caixach, and J. Rivera. 2000. Comprehensive study on dioxin
contents in binder and anticaking agent feed additives. Organohalog Compd 46:439‐442.
ACC (American Chemistry Council). 2003. Interpreting the 2,3,7,8‐TCDD (Dioxin) CDC
Monitoring Data. Accessed at: http://www.dioxinfacts.org/dioxin_health/cdc/TCDDCombined.pdf
AEA (AEA Technology plc). 1999. Compilation of EU Dioxin Exposure and Health Data. Task 7 ‐
Ecotoxicology Report. Prepared for the European Commission DG Environment and the UK
department of the Environment Transport and the Regions (DETR). Report no. AEAT/EEQC/0016.
October.
Agency for Toxic Substances and Diseases Registry (ATSDR). 1994. Toxicological Profile for
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.
ATSDR. 2008. Public Health Statement for Chlorinated Dibenzo‐P‐dioxins (CDDs). In:
Encyclopedia of Earth. Eds. Cutler J. Cleveland (Washington, D.C.: Environmental Information
Coalition, National Council for Science and the Environment). [First published in the Encyclopedia
of Earth November 13, 2007; Last revised April 23, 2008; Retrieved July 8, 2009]. Accessed at:
http://www.eoearth.org/article/Public_Health_Statement_for_Chlorinated_Dibenzo‐
Pdioxins_(CDDs)
Aylward L.L., J.S. LaKind and S.M. Hays. 2008. Derivation of Biomonitoring Equivalent (BE) Values
for 2,3,7,8‐Tetrachlorodibenzo‐p‐Dioxin (TCDD) and Related Compounds: A Screening Tool for
Interpretation of Biomonitoring Data in a Risk Assessment Context. Journal of Toxicology and
Environmental Health, Part A, 71: 1499‐1508.
Baccarelli, A., S. M. Giacomini, et al.. 2008. "Neonatal thyroid function in Seveso 25 years after
maternal exposure to dioxin." PLoS Med 5(7): e161.
Centers for Disease Control and Prevention (CDC). 2017. National Biomonitoring Program,
Chemical Factsheets; Dioxins, Furans and Dioxin-Like Polychlorinated Biphenyls Factsheet.
Available at https://www.cdc.gov/biomonitoring/DioxinLikeChemicals_FactSheet.html. April.
Domingo, J.L., M. Schuhmacher, M.C. Agramunt, L. Muller, and F. Neugebauer. 2001. Levels of
metals and organic substances in blood and urine of workers at a new hazardous waste incinerator.
Int Arch Occup Environ Health 2001; 74:263–9.
Environment Agency of Japan. 2000. Report on Tolerable Daily Intake (TDI) of Dioxins and Related
Compounds. Available at https://www.env.go.jp/en/chemi/dioxins/tdi_report.pdf. August.

DRAFT SHASP–3: MEDICAL SURVEILLANCE ORIENTATION PROGRAM | B–1
Hansson, M., L. Barregard, G. Sallsten, B.G. Svensson, and C. Pappe. 1997. Polychlorinated dibenzo‐
pdioxin and dibenzofuran levels and patterns in polyvinylchloride and chloralkaliindustry workers.
Int Arch Occup Environ Health; 70:51–6.
Hansson, M., T. Grimstad and C. Pappe. 1995. Occupational exposure to polychlorinated dibenzo‐
pdioxins and dibenzofurans in a magnesium production plant. Occup Environ Med; 52:823–6.
Hatfield/Office 33. 2009. Comprehensive Assessment of Dioxin Contamination in Da Nang Airport,

Viet Nam: Environmental Levels, Human Exposure and Options for Mitigating Impacts. Hatfield
Consultants Ltd., North Vancouver, BC, Canada; Office 33, Ha Noi, Viet Nam. (Can be
downloaded from www.hatfieldgroup.com)
IARC (International Agency for Research on Cancer). 1997. IARC Monographs on the Evaluation of
Carcinogenic Risks to Humans. Volume 69: Polychlorinated Dibenzo‐para‐Dioxins and
Polychlorinated Dibenzofurans. World Health Organization. Lyon, France.
Iida, T., H. Hirakawa, T. Matsueda, S. Takenaka, M.L. Yu, and Y.L. Guo. 1999. Recent trend of
polychlorinated dibenzo‐P‐dioxins and their related compounds in the blood and sebum of Yusho
and Yu Cheng patients. Chemosphere; 38: 981–93.
IOM (Institute of Medicine). 1994. Veterans and Agent Orange ‐ Health effects of herbicides used in
Viet Nam. National Academy Press, Washington, D.C., 812 p.
Joint FAO/WHO Expert Committee on Food Additives (JECFA). 2002. Polychlorinated

dibenzodioxins, polychlorinated dibenzofurans, and coplanar polychlorinated biphenyls, Joint
FAO/WHO Expert Committee on Food Additives WHO Food Additives Series 48.
Kociba, R. J., D. G. Keyes, et al.. 1978. "Results of a two-year chronic toxicity and oncogenicity
study of 2,3,7,8-tetrachlorodibenzo-p-dioxin in rats." Toxicol Appl Pharmacol 46(2): 279-303.
Milbrath et al.. 2009. Apparent Half-Lives of Dioxins, Furans, and Polychlorinated Biphenyls as a
Function of Age, Body Fat, Smoking Status, and Breast-Feeding. Environ Health Persp. 117 417.
Mocarelli, P., P. M. Gerthoux, et al.. 2008. "Dioxin exposure, from infancy through puberty,
produces endocrine disruption and affects human semen quality." Environ Health Perspect 116(1):
70-77.
National Institute of Environmental Health Sciences (NIEHS). 2017. Dioxins. Available at

https://www.niehs.nih.gov/health/topics/agents/dioxins/index.cfm. August.
National Toxicology Program (NTP). 1982. Bioassay of 2,3,7,8-tetrachlorodibenzo-pdioxin for

possible carcinogenicity (dermal) C. T. Program. National Cancer Institute, Bethesda, MD, and
National Toxicology Program, Research Triangle Park, NC, National Toxicology Program.
New Zealand Ministry of Health. 2008. Serum Dioxin Testing Factsheet. Available at
https://www.health.govt.nz/system/files/documents/pages/dioxins-practitioners-serumtesting.pdf.
June.

Office of Environmental Health Hazard Assessment (OEHHA). 1999. Technical Support Document
for the Derivation of Noncancer RELs Appendix D.3 Chronic RELs and toxicity summaries using
the previous version of the Hot Spots Risk Assessment guidelines. Air Toxics Hot Spot Program,
Office of Environmental Health Hazard Assessment.
OEHHA. 2011. Technical Support Document for Cancer Potency Factors Appendix B: Chemical-
Specific Summaries of the Information Used to Derive Unit Risk and Cancer Potency Values. Air
Toxics Hot Spot Program, Office of Environmental Health Hazard Assessment.
OEHHA. 2014. Technical Supporting Document for Noncancer RELs Appendix D. Individual Acute,
8-Hour, and Chronic Reference Exposure Level Summaries. Air Toxics Hot Spot Program, Office
of Environmental Health Hazard Assessment.
OEHHA. 2015. Guidance Manual for Preparation of Health Risk Assessments. Air Toxics Hot Spot
Päpke, O., M. Ball and A. Lis. 1992. Various PCDD/PCDF patterns in human blood resulting from
different occupational exposures. Chemosphere; 25:1101–8.
Park, H., M.G. Ikonomou, H.S. Kim, JW. Choi, and Y.S. Chang. 2009. Dioxin and dioxin‐like PCB
profiles in the serum of industrial and municipal waste incinerator workers in Korea. Environment
International 35: 580‐587.
Schecter, A., L. Birnbaum, J.J. Ryan, and J.D. Constable. 2006. Dioxins: an overview. Environ Res
101: 419‐428.
Schecter, A.J., R. Malkin, O. Päpke, M. Ball, and P.W. Brandt‐Rauf. 1991. Dioxin levels in blood of
municipal incinerator workers. Med Sci Res; 19:331–2.
Srogi, K. 2008. Levels and congener distributions of PCDDs, PCDFs and dioxin‐like PCBs in
environmental and human samples: a review. Environ Chem Lett 6:1‐28.
The Aspen Institute. 2020. The Agent Orange in Vietnam Program. Available at
https://www.aspeninstitute.org/programs/agent-orange-in-vietnam-program/.
United States Department of Veteran Affairs. 2017. Agent Orange. Available at

https://www.publichealth.va.gov/exposures/agentorange/index.asp.
United States Environmental Protection Agency (USEPA). 1989. Risk Assessment Guidance for
Superfund (RAGS): Volume 1 – Human Health Evaluation Manual (Part A). Office of Emergency and
Remedial Response, U.S. Environmental Protection Agency.
USEPA. 2003. Human Health Toxicity Values in Superfund Risk Assessments. Washington, D.C.,
U.S. Environmental Protection Agency.
USEPA. 2005. Guidelines for Carcinogen Risk Assessment, U.S. Environmental Protection Agency

USEPA. 2012. 2,3,7,8-Tetrachlorodibenzo-p-dioxin (TCDD); CASRN 1746-01-6. Integrated Risk
Information System, U.S. Environmental Protection Agency.
USEPA. 2019. Learn about Dioxin. Available at https://www.epa.gov/dioxin/learn-about-dioxin. July.
Van den Berg, M., L. S. Birnbaum, et al.. 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.
World Health Organization (WHO). 2020. International Programme on Chemical Safety, Dioxins
and dioxin-like substances. Available at
https://www.who.int/ipcs/assessment/public_health/dioxins/en/.
WHO/EURO. 1998a. WHO revises the Tolerable Daily Intake (TDI) for dioxins. World Health
Organization, European Centre for Environment and Health; International Programme on Chemical
Safety. Organohalogen Compounds 38, 295.
WHO/EURO. 1998b. Assessment of the health risk of dioxins: re‐evaluation of the Tolerable Daily
Intake (TDI). World Health Organization, European Centre for Environment and Health;
International Programme on Chemical Safety. WHO Consultation, May 25‐29, 1998. Geneva,
Switzerland.

APPENDIX C. BLOOD SERUM DIOXIN
RESULT SUMMARY
Blood Serum Dioxin Sample Results - Monitoring
Baseline Periodic (Annual or Bi-annual) Exit
Level of
Employee Respiratory Estimated
2,3,7,8- Total 2,3,7,8- Total 2,3,7,8- Total Monitoring Job Description (include: Level of
ID Sample Date Lipid Sample Date Lipid Sample Sample Date Lipid Protection Days On-
TCDD TEQ TCDD TEQ TCDD TEQ (Level 1, 2, PPE, Sites worked at, Role)
Number ID Collected % ID Collected % Type ID Collected % Y/N Site
(ppt)1 (ppt)2 (ppt)1 (ppt)2 (ppt)1 (ppt)2 or 3)
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)

DRAFT SHASP–3: MEDICAL SURVEILLANCE ORIENTATION PROGRAM | C–1
Blood Serum Dioxin Sample Results – Post-Exposure
Baseline Most Recent Periodic (Annual or Bi-annual) Post-Exposure
Level of
Employee Job Description (include: Incident Description
2,3,7,8- Total 2,3,7,8- Total 2,3,7,8- Total Monitoring
ID Sample Date Lipid Sample Date Lipid Sample Sample Date Lipid Level of PPE, Sites worked at, (Locaton, Duration of
TCDD TEQ TCDD TEQ TCDD TEQ (Level 1, 2,
Number ID Collected % ID Collected % Type ID Collected % Role) Exposure, Type of Incident)
(ppt)1 (ppt)2 (ppt)1 (ppt)2 (ppt)1 (ppt)2 or 3)
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)

DRAFT SHASP–3: MEDICAL SURVEILLANCE ORIENTATION PROGRAM | C–2
APPENDIX D. CONSENT FORM FOR
BLOOD SAMPLING AND
ANALYSIS
CONSENT FORM FOR BLOOD SAMPLING AND ANALYSIS
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/Time of Unique Patient

ID Number YES / NO
Blood Draw
Assigned?

DRAFT SHASP–3: MEDICAL SURVEILLANCE ORIENTATION PROGRAM | D–1
APPENDIX E. FOLLOW-UP LETTER
[Clinic Logo]
[Date]
RE: Serum Dioxin Test Results

USAID Dioxin Remediation at Bien Hoa Airbase Area Project – Bien Hoa, Vietnam
Dear [Patient’s full name]:
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:
Concentration Detected Concentration Detected ACC 2003 Guideline

Chemical of Concern
(ppt. 2,3,7,8)
1
(ppt. Total TEQ)
2 (ppt. TEQ)
Baseline Total Dioxin [Result/Undetected] [Result/Undetected]
30
Follow‐Up Total Dioxin [Result/Undetected] [Result/Undetected]
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.
[Doctor prints name] [Doctor signs]
Print Name Signature
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)
JULY 17, 2020

SITE-WIDE ENVIRONMENTAL
MITIGATION AND MONITORING
PLAN (SWEMMP)

JULY 17, 2020
PREPARED BY
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
Table 1B Air Quality – Mitigation and Monitoring

Table 1B.1 ……. Non-Treatment Air Quality Monitoring Locations

SITE-WIDE ENVIRONMENTAL MITIGATION AND MONITORING PLAN (SWEMMP)
Table 1B.2 ……. Non-Treatment Air Quality Monitoring Parameters, Methods, Project Action Limits,
and Frequencies
Table 1B.3 ……. Treatment Air Emissions Monitoring Locations for TCH Treatment Plant
Table 1B.4 ……. Treatment Air Emissions Monitoring Parameters, Methods, Project Action Limits,
and Frequencies for TCH Treatment Plant – Emission Point (Stack)
Table 1B.5 ……. Treatment Air Emissions Monitoring Parameters, Methods, Project Action Limits,
and Frequencies for TCH Treatment Plant – Perimeter
Table 1C Ambient Noise/Vibration – Mitigation and Monitoring

Table 1C.1 ……. Ambient Noise/Vibration Monitoring Locations
Table 1C.2 ……. Ambient Noise/Vibration Monitoring Parameters, Methods, Project Action Limits,
and Frequencies
Table 1D GHG Emissions and Weather – Mitigation and Monitoring

Table 1D.1 ……. Weather Monitoring Location
Table 1D.2 ……. Weather Monitoring Parameters 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)

USAID STANDARD METADATA
PROJECT/ACTIVITY DATA*
Project/Activity Name: Dioxin Remediation at Bien Hoa Airbase Area Project

Geographic Location(s) (Country/Region): Bien Hoa, Dong Nai Province, Vietnam
Implementation Start/End Dates: 2 April 2020 (Start)/TBD (End)
Contract/Award Number: AID-OAA-I-15-00053
Ministry of National Defense / Air Defence - Air Force Command,
Implementing Partner(s): Architect and Engineering Services Contractor, Construction
Contractors
Tracking ID: TBD
Tracking ID/link of Related IEE: TBD
Tracking ID/link of Other, Related Analyses: TBD
ORGANIZATIONAL/ADMINISTRATIVE DATA*
USAID Vietnam Mission, Environment and Social Development

Implementing Operating Unit(s):
Office, Environmental Remediation Unit
Lead BEO Bureau: BEO Asia Bureau
Prepared by: Trigon Associates, LLC (A&E Bien Hoa Contractor)
Date Draft Prepared: April 13, 2020
Submitted by: TBD
Date Submitted: TBD
ENVIRONMENTAL COMPLIANCE REVIEW DATA*
Analysis Type: EMMP

Additional Analyses/Reporting Required: EMMR
*Standard metadata fields for the USAID Environmental Compliance Database (ECD) and planned
Development Information System (DIS).
DIOXIN REMEDIATION AT BIEN HOA AIRBASE AREA PROJECT | iv


ADS Automated Directives System
AMS Automated Measuring System
ARARs Applicable or Relevant and Appropriate Requirements
AWP Annual Work Plan
A&E Architect & Engineer
BMP Best Management Practice
CEM Continuous Emissions Monitor
CIL Climate Integration Lead
CLIN Contract Line Item Number
CO Carbon Monoxide
COD Chemical Oxygen Demand
COR Contracting Officer’s Representative
CQA Construction Quality Assurance
d Day
dB decibel
dBA Decibels A-weighted average
DONRE Department of Natural Resources and the Environment
DO Dissolved Oxygen
DQO Data Quality Objective
DU Decision Unit
ECD Environmental Compliance Database
EIA Environmental Impact Assessment
EMMP Environmental Mitigation and Monitoring Plan
EMMR Environmental Mitigation and Monitoring Report
ESS Environmental Scoping Statement
G2L Gate 2 Lake
GDWQ Guidelines for Drinking Water Quality
GHG Greenhouse Gas
kg kilogram
L liter
LTSA Long-term Storage Area
3
m Cubic Meters
MCL Maximum Contaminant Level
MEO Mission Environmental Officer
mg milligrams
MND Ministry of National Defence
NDAMN National Dioxin Air Monitoring Network
NOx Nitrogen Oxides
DIOXIN REMEDIATION AT BIEN HOA AIRBASE AREA PROJECT | v

Pb Lead
pg pico-gram
PMU Project Management Unit
ppq parts per quadrillion
REA Regional Environmental Administrator
RSL Regional Screening Level
SCM Site Conceptual Model
SO2 Sulfur Dioxide
SOW Statement of Work
SVOC Semi-volatile Organic Compound
SWPPP Storm Water Pollution Prevention Plan
TCH Thermal Conductive Heating
TDS Total Dissolved Solids
TSS Total Suspended Solids
ug microgram
USG United States Government
USEPA United States Environmental Protection Agency
VOC Volatile Organic Compound
VOHAP Volatile Organic Hazardous Air Pollutant
VRTC Vietnam Russia Tropical Center
WHO World Health Organization
DIOXIN REMEDIATION AT BIEN HOA AIRBASE AREA PROJECT | vi

1 PURPOSE
This Site-wide Environmental Mitigation and Monitoring Plan (SWEMMP) for the Dioxin
Remediation at Bien Hoa Airbase Area Project (Project) was 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 2 (CLIN 2), Task 2.3, Site-wide Environmental Monitoring and
Mitigation Plan.
The purpose of this SWEMMP is to document site-wide environmental mitigation

measures and monitoring actions to be implemented during Dioxin Remediation at
Bien Hoa Airbase Area Project (Project) activities to minimize the potential for negative
environmental impacts. This SWEMMP also prescribes minimum environmental
mitigation measures and monitoring actions to be incorporated into Activity-level
Environmental Mitigation and Monitoring Plans (EMMPs) developed for specific Project
activities.
1.1 BASIS OF EMMP

Environmental Mitigation and Monitoring Plans (EMMPs) are required for USAID-funded projects
under USAID Automated Directives System (ADS) 204, Environmental Procedures, when
documentation prepared in accordance with Title 22 of the Code of Federal Regulations (CFR)
Part 216 (22 CFR 216), Environmental Procedures, governs the USAID-funded project.
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.”
1.1.1 2016 ENVIRONMENTAL ASSESSMENT
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.
DIOXIN REMEDIATION AT BIEN HOA AIRBASE AREA PROJECT | 1

1.1.2 GVN ENVIRONMENTAL IMPACT ASSESSMENT
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
- Project Phase 2 - focusing on remediation of the Z1 Area at Bien Hoa Airbase.
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.
1.1.3 PROJECT IEE AND EMMP REQUIREMENTS
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.

EMMP and all Activity-level EMMPs with MND/ADAFC to reconcile the environmental
requirements of both governments before implementation.
1.2 USAID TEMPLATE EMMP

USAID developed an EMMP template as part of a broader USAID-wide initiative to harmonize
application of 22 CFR 216 and USAID ADS 204 environmental mitigation and monitoring
requirements and their implementation on all USAID projects. The USAID EMMP template serves
as a tool for translating applicable 2016 EA conditions and environmental mitigation measures
into specific implementable, and verifiably actions and that “an EMMP is an action plan that clearly
defines:
1. Mitigation measures. Actions that reduce or eliminate potential negative environmental

impacts resulting directly or indirectly from a particular project or activity, including environmental
limiting factors that constrain development.
2. Monitoring indicators. Criteria that demonstrate whether mitigation measures are suitable
and implemented effectively.
3. Monitoring/reporting frequency. Timeframes for appropriately monitoring the effectiveness

of each specific action.
4. Responsible parties. Appropriate, knowledgeable positions assigned to each specific action.
5. Field Monitoring/Issues. Field monitoring needs to be adequately addressed i.e. monitoring

dates, observations, issues identified and resolution.”
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.
1.3 SWEMMP ORGANIZATION

This SWEMMP for Dioxin Remediation at Bien Hoa Airbase Area Project activities has been
prepared in accordance with 22 CFR 216 and USAID ADS 204, to include the utilization of the
USAID EMMP template. Accordingly, this SWEMMP is organized as follows:
- Section 1, Purpose
- Section 2, Project/Activity Summary
- Section 3, Site-specific Information
- Section 4, Annual Reporting

- Section 5, Environmental Mitigation and Monitoring Plan for Project Activities
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.
A standard page for USAID metadata is included as a foreword to this document.
1.4 SWEMMP REVIEW AND AMENDMENT

EMMPs are living documents and it is incumbent on USAID to ensure that EMMPs are updated
and tailored as needed.
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.

2 PROJECT SUMMARY
As noted in Section 1, after the joint GVN/USAID EA, MND/ADAFC conducted an EIA for the
implementation of EA Alternative 4 in two Project phases (i.e., Phase 1 - remediation of the Pacer
Ivy Area; and Project Phase 2 - remediation of the Z1 Area). Project Phase 1 activities were
approved by GVN MND in Decision No. 3869/QD-BQP (MND 2019). Combined Project Phase
I and Phase II activities encompass the excavation and on-Airbase treatment of approximately
250,000 m3 of dioxin-contaminated soils and sediments, and the excavation and isolation in a
constructed on-Airbase storage facility of approximately 300,000 m3 of dioxin-contaminated soils
and sediments.
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;
- Excavation and isolation of approximately 150,000 m3 of dioxin-contaminated soils and

sediments with a concentration below 1,200 ppt but above 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 dioxin-contaminated wastewater and surface waters generated from Project

activities with concentrations exceeding permitted thresholds (MND 2019).
Phase II activities would address the remaining dioxin-contaminated soils and sediments.
2.1 PROJECT OWNER AND IMPLEMENTING AGENCIES

USAID is the implementing US government agency. The Project is managed by the USAD/Vietnam
Mission’s Environmental Remediation Unit.
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.
2.2 PROJECT ACTIVITIES AND POTENTIAL NEGATIVE ENVIRONMENTAL

IMPACTS
Project activities and their associated environmental aspects and potential impacts are addressed
by both the EA (MND/USAID 2016) and the EIA (MND/ADAFC 2019). While the EA did not
identify a preferred alternative, USAID has since reached agreement with the GVN to implement
EA Alternative 4. Since the GVN EIA evaluates this alternative in greater detail than the EA, the
structure of the GVN EIA will be used as the basis for organizing this SWEMMP. Throughout the
document differences will be noted between 22 CFR 216 requirements, the EA preliminary
conceptual EMMP, GVN EIA, and this SWEMMP.

EIA Chapter 3, Environmental Impact Assessment, outlines four primary Project activities and
discusses the associated environmental aspects and potential impacts:
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:
- Air Quality (dust, vehicle/equipment emissions, thermal treatment facility emissions);

- Water Quality (erosion, stormwater drainage to surface waters, process water discharges);
- Ambient Noise / Vibration (vehicle/equipment noise and vibration); and
- Greenhouse Gases (GHG) / Weather (vehicle/equipment emissions, GHG effect).
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).
2.3 ROLES AND RESPONSIBILITIES FOR SWEMMP IMPLEMENTATION

As a funding and US Government implementing agency, USAID is partnered with MND for
Project implementation. USAID has procured the services of an oversight contractor, i.e., A&E
Bien Hoa Contractor, to develop the Project Masterplan and to provide overall Project
engineering design, construction management, and related implementation support.
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

Contractors to prepare an Activity-level EMMP or direct the A&E Bien Hoa Contractor to assist
in developing such as part of contract requirements.
Each of these implementing organizations, i.e., the MND/ADAFC, USAID/Vietnam Mission,

USAID A&E Bien Hoa Contractor, and USAID Implementing Contractors, have assigned
responsibilities for environmental mitigation measures and monitoring actions contained in this
SWEMMP (Section 5).
2.4 ACTIVITY-LEVEL EMMPS

As noted, multiple Implementing Contractors will be executing Project activities on behalf of
MND/USAID. USAID will require that each of these Contractors implement Activity-specific
environmental mitigation measures and monitoring actions as part of their respective activities.
In accordance with the USAID Project IEE, USAID will document these measures and actions in
an Activity-level EMMP for all interim measures, civil works, treatment activities as described in
the USAID Project Appraisal Document. USAID, the A&E Bien Hoa Contractor, and the
Implementing Contractors will review all Activity-level environmental mitigation measures and
monitoring on a quarterly basis to assess the need for updates.
This SWEMMP prescribes minimum environmental mitigation measures and

monitoring actions to be applied to each activity (Section 5).
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).

3 SITE-SPECIFIC INFORMATION
Site-specific information relevant to the environmental conditions at Bien Hoa Airbase Area and
the execution of the Dioxin Remediation of the Bien Hoa Airbase Area Project is summarized
and presented in other Project documents. Most notably these documents include the Technical
Memorandum (TM) Site Conceptual Model (SCM) and Data Gaps Analysis (DGA) (USAID 2020),
Tabulated Summary of Applicable or Relevant and Appropriate Requirements (ARARs) (USAID
2020), Site-wide Sampling & Analysis Plan – Quality Assurance Project Plan (SAP-QAPP) (USAID
2020), and the Project Masterplan (still in development).
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.
- Off-Airbase dioxin contamination is primarily within soils/sediments located in land areas

adjacent to Pacer Ivy Area.
- Dioxin-contaminated soils/sediment have migrated from original source sites through

physical transport mechanisms, including storm water runoff during rain events, surface
water flow, wind erosion and deposition, and excavation and movement of contaminated
materials.
- 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 Site-wide SAP-QAPP (USAID 2020c) provides a comprehensive, site-specific planning

and guidance document for environmental sampling, field analysis, and environmental laboratory
analyses for all work to be conducted during Dioxin Remediation of the Bien Hoa Airbase Area
Project implementation. The Site-wide SAP-QAPP is applicable to USAID A&E Bien Hoa
Contractor and all Implementing Contractors who will be performing environmental
monitoring in accordance with this SWEMMP. The Site-wide SAP-QAPP is to be utilized during
field sampling and laboratory analyses to ensure that collected environmental monitoring data
meets specified data quality objectives (DQOs).

Several additional Project documents are relevant to the understanding of the scope of the
environmental mitigation measures and monitoring actions contained in this SWEMMP and the
execution of the Dioxin Remediation of the Bien Hoa Airbase Area Project. Most notably these
documents include the Initial Site-wide Health and Safety Plan (HASP) (USAID 2019),
Compendium of Standard Specifications (under development), and Construction Quality
Assurance (CQA) Plan (under development).
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.
The Compendium of Standard Specifications (Compendium) provides a set of standard

technical specifications specific to Project activities. The Compendium will serve as a basis for
design activities to ensure consistency in approach and quality of Project work activities as well
as to reflect best practices, to include green and sustainable practices. Relevant to the
environmental mitigation measures contained in this SWEMMP, the Compendium provides
specifications for: soil management, including excavation and stockpiling; use of clean fill
materials; reuse/replacement of treated soils; testing to confirm soil chemical, geotechnical, and
horticultural suitability for use; waste recycling and disposal; and site stabilization, including the
use of soil stabilization materials.
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.

4 ANNUAL REPORTING
Annual reporting on SWEMMP implementation progress is important and specifically addresses
the “Field Monitoring/Issues” aspect to USAID EMMPs (see Section 1.2) documenting mitigation
measures and monitoring actions, observations, and results, identified issues, and their resolution.
As noted above, SWEMMP implementation is to be discussed during quarterly USAID technical

review meetings with the USAID A&E Bien Hoa Contractor, and reviewed annually throughout
the duration of the Project in conjunction with the submission of AWPs. The USAID A&E Bien
Hoa Contractor is specifically assigned by USAID with “monitoring adherence to the SWEMMP
and Activity-level EMMPs” as a component of the A&E Bien Hoa Contractor’s daily construction
management and oversight activities.
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 SWEMMP implementation progress;

- Documentation of site-wide mitigation measures and monitoring actions;
- Discussion of site-wide observations and results;
- Summary of the effectiveness of the site-wide mitigation measures;
- Identification of Activity-level EMMPs developed by Implementing Contractors;
- Discussion of Activity-level EMMP implementation progress, mitigation measures, monitoring
actions, and associated observations and results;
- Summary of the effectiveness of the Activity-level mitigation measures;
- Discussion of problems, issues or concerns with respect to SWEMMP implementation,
resolution, and lessons learned; and
- Recommendations for revisions to mitigation measures or monitoring actions.
- 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.

5 SWEMMP TABLES WITH DETAIL
This section provides site-wide environmental mitigation measures and monitoring actions that
are to be implemented during Project activities to minimize the potential for negative
environmental impacts. Measures are presented in the USAID EMMP tabular format organized by
category of potential negative impact (Water Quality, Air Quality, Ambient Noise/Vibration,
GHG Emissions/Weather) and the EIA Project activities (Preparation, Construction, Remediation
Operations, and Environmental Restoration).
As noted, multiple Implementing Contractors will be executing Project activities and

implementing Activity-specific environmental mitigation measures and monitoring actions. Nearly
all construction activities are anticipated to take place during the dry season. As a result,
monitoring locations are chosen based upon the prevailing environmental conditions during the
dry season. If this changes during the life of the Project, additional monitoring locations may be
needed and this SWEMMP will be updated (e.g., if the treatment contractor is able to operate
during the rainy season).
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.
5.1 WATER QUALITY

Water quality encompasses the mitigation and monitoring of potential negative impacts to surface
water quality (including stormwater) and groundwater quality resulting from Project activities and
addresses the discharge of process waters.
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 EIA (e.g. daily monitoring of turbidity); however, USAID is also proposing not to monitor
several water parameters mentioned in the EIA because such parameters cannot be plausibly
linked to proposed Project activities (e.g., coliforms or mercury). Also, USAID will not monitor
water quality in several ponds on the airbase as these will be dewatered before excavating the
contaminated sediment and will not receive effluent from other remediation activities. Thus,
water quality will not be impacted in these ponds by remediation activities.
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.
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 determine Bien Hoa Airbase surface water drainage pathways and
storm water drainage patterns and supplement this SWEMMP.
5.2 AIR QUALITY

Air quality encompasses the mitigation and monitoring of potential negative impacts to air quality
resulting from Project activities and addresses the emission of air pollutants from stationary
sources.
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.

Figure 1B shows site-wide air quality monitoring locations. AIR1 was chosen to be a background
reference site that will be largely unaffected by Project activities and is at the administrative center
of the Airbase. AIR2, AIR3, AIR4, AIR6, and AIR7 are downwind of potentially significant Project
activities. AIR3 and AIR7 are upwind of nearby residents outside of the Airbase. AIR5 is located
downwind of urban activities and upwind of Project activities.
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.
5.3 AMBIENT NOISE / VIBRATION

Ambient noise / vibration encompasses the mitigation and monitoring of potential negative
impacts with respect to noise and vibrations resulting from Project activities.
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.
5.4 GREENHOUSE GASES (GHG) EMISSIONS / WEATHER

Greenhouse gas (GHG) / weather encompass the mitigation and monitoring of GHG emissions
resulting from Project activities and the monitoring of weather at the Bien Hoa Airbase Area.
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

will be real-time with data recorded for duration of the Project. The A&E Bien Hoa Contractor
will implement a system for notifying Implementing Contractors of current or pending weather
events (e.g., increasing wind speed, changing wind direction).
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.

6 REFERENCES
GVN/USAID (CDM International, Inc. and Hatfield Consultants). 2015. Environmental
Assessment of Dioxin at Bien Hoa Airbase, Environmental Scoping Statement. March 13, 2015.

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. 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.
Ministry of Natural Resources and Environment (MONRE). 2019. Approval of Environmental

Impact Assessment Report, the Dioxin Remediation at Bien Hoa Airbase Area Project. March 25,
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.

TABLES
TABLE 1A WATER QUALTY – MITIGATION AND MONITORING
TABLE 1B AIR QUALITY – MITIGATION AND MONITORING
TABLE 1C AMBIENT NOISE/VIBRATION – MITIGATION AND MONITORING
TABLE 1D GHG EMISSIONS AND WEATHER – MITIGATION AND MONITORING

TABLE 1A. WATER QUALITY – MITIGATION AND MONITORING
POTENTIAL MONITORING LOCATION,

MONITORING
SUB-ACTIVITY NEGATIVE WATER MITIGATION MEASURES FREQUENCY, AND RESPONSIBLE PARTIES
INDICATOR
QUALITY REPORTING
Preparation and Construction
Site-wide Detrimental Establish pre-construction surface water quality conditions (baseline) and Tables 1A.1 and 1A.2; Tables 1A.1 and 1A.2; USAID A&E Bien Hoa Contractor
Monitoring Changes from initiate site-wide surface water quality (stormwater) monitoring.
Baseline Conditions
Establish pre-construction groundwater quality conditions (baseline), install Tables 1A.3 and 1A.4 Tables 1A.3 and 1A.4 USAID A&E Bien Hoa Contractor
additional groundwater monitoring wells (as needed), and initiate site-wide
groundwater monitoring.
Activity-level Detrimental Activity-level EMMPs and SWPPPs will include surface water quality Tables 1A.1 and 1A.2; Tables 1A.1 and 1A.2; Implementing Contractor, or A&E
Monitoring Changes from (stormwater) monitoring when appropriate. Minimum monitoring Bien Hoa Contractor as directed by
Baseline Conditions parameters and frequencies are specified in the referenced tables. USAID
Activity-level EMMPs will include groundwater monitoring when Tables 1A.3 and 1A.4 Tables 1A.3 and 1A.4 Implementing Contractor, or A&E
appropriate. Minimum monitoring parameters and frequencies are specified Bien Hoa Contractor as directed by
in the referenced tables. USAID
Clearing Site and Erosion, Runoff, Erosion/sediment control best management practices (BMPs), inspection, Compliance with Monitoring, inspection, and Implementing Contractor;
Excavating Sedimentation and maintenance as per Project Site-wide SWPPP, Activity-level SWPPP, SWPPP. reporting in accordance USAID A&E Bien Hoa Contractor
Contaminated and/or Activity-level EMMP. with SWPPP. Construction Manager (CM)
Soils/Sediments Excavation is to be done according to an Excavation Plan; surface water oversight
controls and diversionary structures are to be constructed to divert water
around active excavations; excavation activities are to occur during the dry
season to the extent practical to minimize potential for erosion, runoff, and
sedimentation.
Decontamination water can be applied to the area if any residual soil
present is of the same concentration and erosion outside that area can be
prevented.
Contact with Contact with groundwater is to be minimized during excavation; Compliance with Monitoring, inspection, and Implementing Contractor;
Groundwater and dewatering systems are to be used to minimize groundwater seepage into SWPPP. reporting in accordance USAID A&E Bien Hoa Contractor
Potential for excavations. with SWPPP. CM oversight
Contamination
Dewatering of Discharge to Surface Discharges to groundwater prohibited. Tables 1A.1 and 1A.2 Tables 1A.1 and 1A.2 Implementing Contractor;
Contaminated Water (Drainage Intermittent discharge only after testing and confirmation of compliance. USAID A&E Bien Hoa Contractor
Soils/Sediments Waters from CM oversight
Decontamination water can be applied to the area if any residual soil
Contaminated present is of the same concentration and erosion outside that area can be
Soils/Sediments) prevented.
Discharges to surface waters must meet QCVN 08:2015/BTNMT, National
Technical Regulation on Surface Water Quality.
DIOXIN REMEDIATION AT BIEN HOA AIRBASE AREA PROJECT TABLES 1

MONITORING
INDICATOR
QUALITY REPORTING
Transporting Runoff, Spill or Soil/sediment transport practices as per Project Site-wide SWPPP, Activity- Compliance with Monitoring, inspection, and Implementing Contractor;
Contaminated Release Potential level SWPPP, and/or Activity-level EMMP. SWPPP. reporting in accordance USAID A&E Bien Hoa Contractor
Soils/Sediments Exposed soils/sediments are to be covered during transportation to avoid with SWPPP. CM oversight
reduce spillage; transport vehicles are to remain on designated haul routes;
transport vehicles are to abide by Airbase speed limits; rinsing/cleaning of
transport vehicles is to occur at designated area(s) after each vehicle trip.
Stockpiling/Placing Erosion, Runoff, Erosion/sediment control BMPs, inspection, and maintenance as per Project Compliance with Monitoring, inspection, Implementing Contractor;
of Contaminated Sedimentation Site-wide SWPPP, Activity-level SWPPP, and/or Activity-level EMMP. SWPPP. and reporting in USAID A&E Bien Hoa Contractor
Soils/Sediments Contaminated soils/sediments are to be stockpiled or placed only in accordance with SWPPP. CM oversight
designated storage areas or soil staging areas; stockpiled soils/sediments are
to be managed to prevent erosion or stormwater runoff; stockpiled
soils/sediments are to be covered daily.
Constructing Erosion, Runoff, Erosion/sediment control BMPs, inspection, and maintenance as per Project Compliance with Monitoring, inspection, Implementing Contractor;
Storage Areas Sedimentation Site-wide SWPPP, Activity-level SWPPP, and/or Activity-level EMMP during SWPPP. and reporting in USAID A&E Bien Hoa Contractor
construction. accordance with SWPPP. CM oversight;
MND/ADAFC oversight (LTSA)
Constructing Erosion, Runoff, Erosion/sediment control BMPs, inspection, and maintenance as per Project Compliance with Monitoring inspection, and Implementing Contractor;
TCH Treatment Sedimentation Site-wide SWPPP, and Activity-level SWPPP, and/or Activity-level EMMP SWPPP. reporting in accordance USAID A&E Bien Hoa Contractor
Plant during construction. with SWPPP. CM oversight
Rinsing/Cleaning Process Water Discharges to groundwater prohibited. Tables 1A.5 and 1A.6 Tables 1A.5 and 1A.6 Implementing Contractor;
of Equipment and Discharge (Rinse Intermittent discharge only after testing and confirmation of compliance. USAID A&E Bien Hoa Contractor
Vehicles Water from Decontamination water can be applied to the area of excavation if any CM oversight
Cleaning Activities) residual soil present is of the same concentration and erosion outside that
area can be prevented.
Discharges to surface waters to meet QCVN 40:2011/BTNMT, National
Technical Regulation on Industrial Wastewater and TCVN 9737:2013
Dioxin Discharge Standards from the Treatment Activities for the Dioxin
Contaminated Sites requirements.
Rinsing/cleaning of transport vehicles is to occur at designated areas after
each trip event.
Refueling of Spill or Release Refueling of equipment and vehicle practices as per Project Site-wide Compliance with Monitoring, inspection, Implementing Contractor;
Equipment and Potential SWPPP, Activity-level SWPPP, and/or Activity-level EMMP to mitigate SWPPP. and reporting in USAID A&E Bien Hoa Contractor
Vehicles potential for spill or release to ground or surface waters. accordance with SWPPP. CM oversight
Refueling is only to be done in designated areas; refueling during
precipitation events is to be avoided; fuels are to be stored in appropriate
containers marked as to their contents; containers are to be securely
closed when not transferring fuel to/from the container.

MONITORING
INDICATOR
QUALITY REPORTING
Storing Materials Spill or Release Storage and inspection practices as per Project Site-wide SWPPP, Activity- Compliance with Monitoring, inspection, Implementing Contractor;
and Wastes Potential level SWPPP, and/or Activity-level EMMP to minimize potential for spill or SWPPP. and reporting in USAID A&E Bien Hoa Contractor
release to ground or surface waters. accordance with SWPPP. CM oversight
Liquid materials and wastes with water-endangering properties are to be
stored in securely closed containers on impervious surfaces with a means of
secondary containment sufficient for at least 110% of the largest container.
Remediation Operations
Site-wide Detrimental Changes Continue site-wide surface water and groundwater monitoring. Tables 1A.1 and 1A.2; Tables 1A.1 and 1A.2; USAID A&E Bien Hoa Contractor
Monitoring from Baseline Tables 1A.3 and IA.4 Tables 1A.3 and 1A.4
Conditions
Activity-level Detrimental Changes Continue Activity-level surface water and groundwater monitoring. Tables 1A.1 and 1A.2; Tables 1A.1 and 1A.2; Implementing Contractor, or A&E
Monitoring from Baseline Tables 1A.3 and IA.4 Tables 1A.3 and 1A.4 Bien Hoa Contractor as directed by
Conditions USAID
Operating Storage Process Water Discharges to groundwater prohibited. Tables 1A.5 and 1A.6 Tables 1A.5 and 1A.6 Implementing Contractor;
Areas Discharge Intermittent discharge only after testing and confirmation of compliance. USAID A&E Bien Hoa Contractor
(Leachate, Decontamination water can be applied to the area of excavation if any CM oversight;
Condensation) residual soil present is of the same concentration and erosion outside that MND/ADAFC oversight (LTSA)
area can be prevented.
Discharges to surface waters from operating storage areas are to meet
QCVN 40:2011/BTNMT, National Technical Regulation on Industrial
Wastewater and TCVN 9737:2013 Dioxin Discharge Standards from the
Treatment Activities for the Dioxin Contaminated Sites requirements.
Storage areas are to be constructed in accordance with MND/ADAFC
approved designs and operated accordingly.
Operating TCH Process Water Discharges to groundwater prohibited. Tables 1A.5 and 1A.6 Tables 1A.5 and 1A.6 Implementing Contractor;
Treatment Plant Discharge Discharges to surface waters from the TCH treatment facility to meet USAID A&E Bien Hoa Contractor
(Leachate, QCVN 40:2011/BTNMT, National Technical Regulation on Industrial CM oversight
Condensation) Wastewater and TCVN 9737:2013 Dioxin Discharge Standards from the
Treatment Activities for the Dioxin Contaminated Sites requirements.
TCH Treatment Plant to be constructed in accordance with MND/ADAFC
Degradation of For construction and operation of the proposed thermal conductive Compliance with Monitoring, inspection, and Implementing Contractor, or A&E
Groundwater heating (TCH) Treatment Plant, a minimum of three groundwater Activity-level EMMP. reporting in accordance Bien Hoa Contractor as directed by
monitoring wells, triangulating the facility, are to be installed and with Activity-level EMMP. USAID
monitored on a quarterly (4 times/year) basis (in accordance with QCVN
24:2017/BTNMT) as part of the associated Activity-level EMMP.
Stockpiling/Placing Erosion, Runoff, Same as for Stockpiling/Placing of Contaminated Soils/Sediments above. As per above. As per above. Implementing Contractor;
of Treated Sedimentation USAID A&E Bien Hoa Contractor
Soils/Sediments CM oversight

MONITORING
INDICATOR
QUALITY REPORTING
Storing Materials Spill or Release Same as for Storing Materials and Wastes above. As per above. As per above. Implementing Contractor;
and Wastes Potential USAID A&E Bien Hoa Contractor
CM oversight
Environmental Restoration
Site-wide Detrimental Changes Continue site-wide surface water and groundwater monitoring. Tables 1A.1 and 1A.2; Tables 1A.1 and 1A.2; USAID A&E Bien Hoa Contractor
Monitoring from Baseline Tables 1A.3 and IA.4 Tables 1A.3 and 1A.4
Conditions
Activity-level Detrimental Changes Continue Activity-level surface water and groundwater monitoring. Tables 1A.1 and 1A.2; Tables 1A.1 and 1A.2; Implementing Contractor, or A&E
Monitoring from Baseline Tables 1A.3 and IA.4 Tables 1A.3 and 1A.4 Bien Hoa Contractor as directed by
Conditions USAID
Grading/Backfilling Erosion, Runoff, Erosion/sediment control BMPs as per Project Site-wide SWPPP, Activity- Compliance with Monitoring, inspection, and Implementing Contractor;
Sedimentation level SWPPP, and/or Activity-level EMMP. SWPPP. reporting in accordance USAID A&E Bien Hoa Contractor
with SWPPP. CM oversight
Revegetating Site Erosion, Runoff, Erosion/sediment control BMPs as per Project Site-wide SWPPP, Activity- As per above. As per above. Implementing Contractor;
Sedimentation level SWPPP, and/or Activity-level EMMP. USAID A&E Bien Hoa Contractor
CM oversight

Table 1A.1 Surface Water Quality Monitoring Locations
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

Table 1A.2 Surface Water Quality Monitoring Parameters, Methods, Project Action Limits, and Frequencies
MONITORING FREQUENCY WHEN POTENTIAL

PROJECT ACTION
PARAMETER TEST METHOD PROJECT ACTION LIMIT REFERENCE IMPACT FROM ACTIVE PROJECT
LIMIT
CONSTRUCTION ACTIVITY 1
pH Field Monitor 6 to 8.5 QCVN 08-MT:2015/BTNMT Weekly
Turbidity Field Monitor Baseline NA Daily
Oil/grease Method 1664 0.3 mg/L QCVN 08-MT:2015/BTNMT
TSS Method 160.2 20 mg/L QCVN 08-MT:2015/BTNMT
Weekly
COD Method 410.4 10 mg/L QCVN 08-MT:2015/BTNMT
Total Phenols Method 604 0.005 mg/L QCVN 08-MT:2015/BTNMT
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.

Table 1A.3 Groundwater Quality Monitoring Locations
LOCATION
DESCRIPTION
REFERENCE
MW1 (Existing) Monitoring Well 1
MW8 (New Installation) Monitoring Well 8
See Figure 1A

Table 1A.4 Groundwater Quality Monitoring Parameters, Methods, Project Action Limits, and Frequencies

PROJECT ACTION
PARAMETER TEST METHOD PROJECT ACTION LIMIT REFERENCE IMPACT FROM ACTIVE PROJECT
LIMIT
pH Field Monitor 5.5 to 8.5 QCVN 09-MT:2015/BTNMT
Total Dioxin Method 1613B Baseline NA
Arsenic Method 6020A 0.05 mg/L QCVN 09-MT:2015/BTNMT
Monthly
Total Phenol Method 604 0.001 mg/L QCVN 09-MT:2015/BTNMT
2,4-D Method 8151 0.07 mg/L USEPA MCL
2,4,5-T Method 8151 0.009 mg/L WHO GDWQ
NOTES:
QCVN 09-MT:2015/BTNMT, National Technical Regulation on Ground Water Quality
USEPA MCL – US Environmental Protection Agency (USEPA) Maximum Contaminant Level (MCL) for 2,3,7,8-TCDD in drinking water is 30 parts per quadrillion.
WHO GDWQ – World Health Organization (WHO) Guidelines for Drinking-water Quality (GDWQ)
NA – not applicable
– EIA Table 5.3 water quality parameters COD, Ammonium N, Ferric, Coliform, Lead, Mercury, Cadmium, Chrome (VI), and Chrome (III) and EIA Table 5.7 with identical water quality
parameters not included. These are not groundwater quality parameters of concern with respect to monitoring Project activities. There are no GVN surface water quality regulations
for 2,4-D and 2,4,5-T.
– 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.

Table 1A.5 Process Water Quality Monitoring Locations
LOCATION REFERENCE DESCRIPTION

Point of Discharge
When there is reasonable potential to impact surface water quality
(to be determined)
Downstream Surface
When there is reasonable potential to impact surface water quality, at the
Water Location
Table 1A.1 location that is downstream of the point of discharge
(to be determined)

Table 1A.6 Process Water Quality Monitoring Parameters, Methods, Project Action Limits, and Frequencies
PROJECT ACTION MONITORING FREQUENCY WHEN POTENTIAL

PARAMETER TEST METHOD LIMIT FOR PROJECT ACTION LIMIT REFERENCE IMPACT FROM ACTIVE PROJECT
DISCHARGE 1 CONSTRUCTION ACTIVITY 2
pH Field Monitor 5.5 to 9 QCVN 40:2011/BTNMT
Turbidity Field Monitor Surface water baseline NA
QCVN 40:2011/BTNMT
Oil and grease Method 1664 10 mg/L
Upon Initial Discharge
TSS Method 160.2 100 mg/L QCVN 40:2011/BTNMT
COD Method 410.4 150 mg/L QCVN 40:2011/BTNMT Weekly (for continuing discharges)
Total Phenols Method 604 0.5 mg/L QCVN 40:2011/BTNMT
Total Dioxin Method 1613B 10 pg TEQ/L TCVN 9737:2013
Arsenic Method 6020A 0.1 mg/L QCVN 40:2011/BTNMT
2,4-D Method 8151 0.07 mg/L USEPA MCL
2,4,5-T Method 8151 0.009 mg/L WHO GDWQ
NOTES:
QCVN 40:2011/BTNMT, National Technical Regulation on Industrial Wastewater, column B values (discharged into water sources not serving as potable water supply)
USEPA MCL – US Environmental Protection Agency (USEPA) Maximum Contaminant Level (MCL) for 2,3,7,9-TCDD in drinking water is 30 parts per quadrillion.
WHO GDWQ - World Health Organization (WHO) Guidelines for Drinking-water Quality (GDWQ)
1 Downstream surface water location – will use Project Action Limit from Table 1A.2.
– EIA Section 5.2.2 references B values. Proposed is more stringent
– EIA Table 5.3 water quality parameters DO, BOD5, Nitrate, Total P, Total N, Ammonium N, Ferric, Animal and Vegetable Oils/Fats, Mineral Oil/Fat, Chlorine, Coliform, Mercury,
Cadmium, Chrome (VI), and Chrome (III) and EIA Table 5.7 with identical water quality parameters as well as not included. These are not water quality parameters of concern with
respect to process waters expected from Project activities, e.g., discharges from vehicle and equipment cleaning or sediment dewatering. There are no GVN surface water quality
regulations for 2,4-D and 2,4,5-T.
– 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; EIA Section 5.2.4. references
semi-annual [2 times/year] monitoring frequency for environmental restoration phase. Proposed is more frequent.

TABLE 1B. AIR QUALITY – MITIGATION AND MONITORING
POTENTIAL
NEGATIVE MONITORING MONITORING AND
SUB-ACTIVITY MITIGATION MEASURES RESPONSIBLE PARTIES
AIR QUALITY INDICATOR REPORTING FREQUENCY
IMPACT
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.

POTENTIAL
IMPACT
Constructing Dust; Storage areas are to be constructed in accordance with MND/ADAFC Same as above. Same as above. Implementing Contractor;
Storage Areas Vehicle/Equipment approved designs. USAID A&E Bien Hoa
Exhaust Emissions Same as described for Clearing Site and Excavating Contaminated Contractor CM oversight;
Soils/Sediments above. MND/ADAFC oversight (LTSA)
Constructing Dust; TCH Treatment Plant to be constructed in accordance with MND/ADAFC Same as above. Same as above. Implementing Contractor;
TCH Treatment Vehicle/Equipment approved designs. USAID A&E Bien Hoa
Plant Exhaust Emissions Same as described for Clearing Site and Excavating Contaminated Contractor CM oversight
Soils/Sediments above.
Storing Materials Vapor Emissions Containers are to be kept closed except when transferring material or Visual monitoring. Daily. Implementing Contractor;
and Wastes wastes to/from the containers. USAID A&E Bien Hoa
Contractor CM oversight
Site-wide Detrimental Changes Continue site-wide ambient air quality monitoring. Tables 1B.1 and 1B.2 Tables 1B.1 and 1B.2 USAID A&E Bien Hoa
Monitoring from Baseline Contractor
Conditions
Activity-level Detrimental Changes Continue site-wide ambient air quality monitoring. Tables 1B.1 and 1B.2 Tables 1B.1 and 1B.2 Implementing Contractor, or
Monitoring from Baseline A&E Bien Hoa Contractor as
Conditions directed by USAID
Operating Plant Emissions Air emissions from the TCH Treatment Plant to meet QCVN Tables 1B.3 and 1B.4 Tables IB.3 and 1B.4 Implementing Contractor;
Treatment Plant 19:20089/BTNMT, National Technical Regulation on Emission of Inorganic USAID A&E Bien Hoa
Substances and Dusts, and other ARARs. Minimum monitoring locations, Contractor CM oversight
frequency, and monitoring parameters for the TCH facility are specified in
Tables 1B.3. and IB.4.
TCH Treatment Plant to be constructed in accordance with MND/ADAFC
Stockpiling/Placing Dust; Same as described for Clearing Site and Excavating Contaminated Same as above. Same as above. Implementing Contractor;
of Treated Vehicle/Equipment Soils/Sediments above. USAID A&E Bien Hoa
Soils/Sediments Exhaust Emissions Contractor CM oversight
Storing Materials Vapor Emissions Same as described for Storing of Materials and Wastes above. Same as above. Same as above. Implementing Contractor;
and Wastes USAID A&E Bien Hoa
Site-wide Detrimental Changes Continue site-wide ambient air quality monitoring. Tables 1B.1 and 1B.2 Tables 1B.1 and 1B.2 USAID A&E Bien Hoa
Monitoring from Baseline Contractor
Conditions
Activity-level Detrimental Changes Continue site-wide ambient air quality monitoring. Tables 1B.1 and 1B.2 Tables 1B.1 and 1B.2 Implementing Contractor, or
Monitoring from Baseline A&E Bien Hoa Contractor as
Conditions directed by USAID

POTENTIAL
IMPACT
Grading/Backfilling Dust; Same as described for Clearing Site and Excavating Contaminated Same as above. Same as above. Implementing Contractor;
Vehicle/Equipment Soils/Sediments above. USAID A&E Bien Hoa
Exhaust Emissions Contractor CM oversight
Revegetating Site Dust; Same as described for Clearing Site and Excavating Contaminated Same as above. Same as above. Implementing Contractor;
Vehicle/Equipment Soils/Sediments above. USAID A&E Bien Hoa
Exhaust Emissions Contractor CM oversight

Table 1B.1 Non-Treatment Air Quality Monitoring Locations and Occurrence
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)
AIR4 Project Office

Project Duration
AIR5 Upwind of Airbase near Z1-09
AIR6 Downwind of Z1 Area

When Project activities in the area
Downwind of Northeast Area/Upwind of Tan (or anticipated during the month/quarter)
AIR7
Phong Ward
See Figure 1B

Table 1B.2 Non-Treatment Air Quality Monitoring Parameters, Methods, Project Action Limits, and Frequencies

PROJECT ACTION LIMIT
PARAMETER TEST METHOD PROJECT ACTION LIMIT IMPACT FROM ACTIVE PROJECT
REFERENCE
Automated Measuring 200 µg/m3 24-hour mean;
Total Dust QCVN 05:2013/BTNMT Continuous
System (AMS) 100 µg/m3 annual mean
Baseline or 150 µg/m3 24-hour
PM10 AMS mean; QCVN 05:2013/BTNMT Weekly
50 µg/m3 annual mean
Total Dioxin Method TO-9A Baseline or 0.6 TEQ pg/m3 TCVN 10843:2015 Monthly
3
Baseline or 22 µg/m 1-hour
Benzene Method TO-15 QCVN 06:2009/BTNMT Every two months
mean; 10 µg/m3 annual mean
NOTES:
QCVN 05:2013/BTNMT, National Technical Regulation on Ambient Air Quality
TCVN 10843:2015, Air Quality – Maximum Concentration of Dioxin in Ambient Air
1 Potential Impact – Samples only collected when there is active Project construction activity occurring, or anticipated to occur, upwind of the monitoring location.
– EIA Table 5.5 references 23 total locations; selected seven non-treatment locations are reasonable and appropriate regarding proximity/downwind of proposed Project activities and
providing adequate monitoring coverage.
– EIA Table 5.4 monitoring parameters for ‘Dust’ are Suspended Dust and PM10. Proposed are PM2.5 and PM10 as inhalable and respirable dust, which are standards for human health
exposure, are better indicators of potential dioxin exposure.
– EIA Section 5.2.2 references quarterly [4 times/year] monitoring frequency based on Circular No. 24/2017/TT-BTNMT. Proposed is more frequent at appreciably fewer locations.

Table 1B.3 Treatment Air Emissions Monitoring Locations for TCH Treatment
Plant
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

Table 1B.4 Treatment Air Emissions Monitoring Parameters, Methods, Project Action Limits, and Frequencies for
TCH Treatment Plant – Emission Point (Stack)
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)
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
260 µg/m3 24-hour mean;
Styrene Method TO-15 QCVN 06:2009/BTNMT
1,000 µg/m3 1-hour mean;
Toluene Method TO-15 QCVN 06:2009/BTNMT
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)
USEPA Regional Screening Levels (RSLs) – Users Guide. November 2019
– Actual air emissions monitoring locations dependent on facility configuration; upon final design, this SWEMMP may be amended as warranted (see Section 1.4).

Table 1B.5 Treatment Air Emissions Monitoring Parameters, Methods, Project Action Limits, and Frequencies for
TCH Treatment Plant – Perimeter
MONITORING FREQUENCY
PROJECT ACTION LIMIT
WHEN POTENTIAL IMPACT
PARAMETER TEST METHOD (HOURLY AVERAGES, EXCEPT AS PROJECT ACTION LIMIT REFERENCE
FROM ACTIVE PROJECT
NOTED)
Automated
Baseline or 150 µg/m3 24-hour mean;
PM10 Measuring System QCVN 05:2013/BTNMT
(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
260 µg/m3 24-hour mean;
Styrene Method TO-15 QCVN 06:2009/BTNMT
1,000 µg/m3 1-hour mean;
Toluene Method TO-15 QCVN 06:2009/BTNMT
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
USEPA Regional Screening Levels (RSLs) – Users Guide. November 2019
– Actual air emissions monitoring locations dependent on facility configuration; upon final design, this SWEMMP may be amended as warranted (see Section 1.4).

TABLE 1C. AMBIENT NOISE AND VIBRATION – MITIGATION AND MONITORING
POTENTIAL
NEGATIVE
MONITORING MONITORING AND
SUB-ACTIVITY AMBIENT NOISE MITIGATION MEASURES RESPONSIBLE PARTIES
INDICATOR REPORTING FREQUENCY
AND VIBRATION
IMPACT
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
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.

POTENTIAL
NEGATIVE
SUB-ACTIVITY AMBIENT NOISE MITIGATION MEASURES RESPONSIBLE PARTIES
AND VIBRATION
IMPACT
Site-wide Ambient Noise; Continue 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; Continue Activity-level ambient noise and vibration monitoring. Tables 1C.1 and 1C.2 Tables 1C.1 and 1C.2 Implementing Contractor, or A&E
Monitoring Vibration Bien Hoa Contractor as directed by
USAID
Operating Storage Ambient Noise; Same as described for Clearing Site and Excavating Contaminated Soils/Sediments Same as above. Same as above. Implementing Contractor;
Areas Vibration above. USAID A&E Bien Hoa Contractor
Storage areas are to be constructed in accordance with MND/ADAFC approved CM oversight
designs and operated accordingly.
Operating Ambient Noise; Same as described for Clearing Site and Excavating Contaminated Soils/Sediments Same as above. Same as above. Implementing Contractor;
Treatment Plant Vibration above. USAID A&E Bien Hoa Contractor
TCH Treatment Plant to be constructed in accordance with MND/ADAFC CM oversight
Stockpiling/Placing Ambient Noise; Same as described for Clearing Site and Excavating Contaminated Soils/Sediments Same as above. Same as above. Implementing Contractor;
of Treated Vibration above. USAID A&E Bien Hoa Contractor
Site-wide Detrimental Changes Continue 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 from Baseline
Conditions
Activity-level Detrimental Changes Continue Activity-level ambient noise and vibration monitoring. Tables 1C.1 and 1C.2 Tables 1C.1 and 1C.2 Implementing Contractor;
Monitoring from Baseline USAID A&E Bien Hoa Contractor
Conditions CM oversight
Grading/Backfilling Ambient Noise; Same as described for Clearing Site and Excavating Contaminated Soils/Sediments Same as above. Same as above. Implementing Contractor;
Vibration above. USAID A&E Bien Hoa Contractor
CM oversight
Revegetating Site Ambient Noise; Same as described for Clearing Site and Excavating Contaminated Soils/Sediments Same as above. Same as above. Implementing Contractor;
Vibration above. USAID A&E Bien Hoa Contractor
CM oversight

Table 1C.1 Site-wide Ambient Noise/Vibration Monitoring Locations
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

Table 1C.2 Ambient Noise/Vibration Monitoring Parameters, Methods, Project Action Limits, and Frequencies
PROJECT
PARAMETER/
TEST METHOD ACTION PROJECT ACTION LIMIT REFERENCE MONITORING FREQUENCY
TIME PERIOD
LIMIT
Noise
Monthly when there is construction

6am to 9pm Noise Monitor 70 dBA
activity occurring in this area of the
QCVN 26:2010/BTNMT
airbase or anticipated to occur during
9pm to 6am Noise Monitor 55 dBA the month (12 times/year).
Vibration
Vibration Monthly when there is construction

6am to 6pm 75 dB
Monitor activity occurring in this area of the
QCVN 27:2010/BTNMT
Vibration airbase or anticipated to occur during
6pm to 6am Background the month (12 times/year).
Monitor
dB – decibels
dBA – decibels A-weighted average
QCVN 26:2010/BTNMT, National Technical Regulation on Noise, limits for Normal areas
QCVN 27:2010/BTNMT, National Technical Regulation on Vibration, maximum limits on vibration acceleration in construction, limits for Usual areas
Circular No. 24/2017/TT-BTNMT for monitoring frequency
– EIA Table 5.5 references 23 locations
– EIA Sections 5.2.1, 5.2.2, and 5.2.4 reference quarterly [4 times/year] monitoring frequency for planning, construction, and environmental restoration phases. Proposed is more frequent.

TABLE 1D. GREENHOUSE GAS (GHG) EMISSIONS AND WEATHER – MITIGATION AND MONITORING
POTENTIAL
NEGATIVE
SUB-ACTIVITY GHG EMISSIONS/ MITIGATION MEASURES RESPONSIBLE PARTIES
WEATHER
IMPACT
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.

POTENTIAL
NEGATIVE
SUB-ACTIVITY GHG EMISSIONS/ MITIGATION MEASURES RESPONSIBLE PARTIES
WEATHER
IMPACT
Constructing TCH GHG Emissions Same as described for Clearing Site and Excavating Contaminated Same as above. Same as described for Clearing Implementing Contractor;
Treatment Plant 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.
Site-wide Weather Conditions Continue site-wide weather monitoring. Tables ID.1 and ID.2. Tables 1D.1 and 1D.2. USAID A&E Bien Hoa
Operating Storage GHG Emissions Same as described for Clearing Site and Excavating Contaminated Same as above. Same as above. Implementing Contractor;
Areas Soils/Sediments above. USAID A&E Bien Hoa
Storage areas are to be constructed in accordance with MND/ADAFC Contractor CM oversight
Operating GHG Emissions Same as described for Clearing Site and Excavating Contaminated Same as above. Same as above. Implementing Contractor;
Treatment Plant Soils/Sediments above. USAID A&E Bien Hoa
TCH Treatment Plant to be constructed in accordance with MND/ADAFC Contractor CM oversight
Consideration should be given to preferential fuel sources from a
reduction of GHG emissions perspective, e.g., using natural gas, propane,
or electricity for TCH, vice gasoline, diesel, kerosene, or heating oil.
Stockpiling/Placing GHG Emissions Same as described for Clearing Site and Excavating Contaminated Same as above. Same as above. Implementing Contractor;
of Treated Soils/Sediments above. USAID A&E Bien Hoa
Soils/Sediments Contractor CM oversight
Site-wide Weather Conditions Continue site-wide weather monitoring. Tables ID.1 and ID.2. Tables 1D.1 and 1D.2. USAID A&E Bien Hoa
Grading/Backfilling GHG Emissions Same as described for Clearing Site and Excavating Contaminated Same as above. Same as above. Implementing Contractor;
Soils/Sediments above. USAID A&E Bien Hoa
Revegetating Site GHG Emissions Same as described for Clearing Site and Excavating Contaminated Same as above. Same as above. Implementing Contractor;
Soils/Sediments above. USAID A&E Bien Hoa

Table 1D.1 Site-wide Weather Monitoring Locations
LOCATION
DESCRIPTION
REFERENCE
WEATHER1 Weather Station at Project Office
See Figure 1D
Table 1D.2 Weather Monitoring Parameters and Frequency
PARAMETER MONITORING FREQUENCY

Temperature
Relative Humidity
Wind Speed
Continuous (real-time)
Wind Direction
Precipitation
Barometric Pressure
– EIA Table 5.4 references temperature, humidity, and wind velocity only. Proposed is more comprehensive.
– EIA Table 5.5 references 23 locations; EIA Section 5.2.2 references quarterly [4 times/year] monitoring frequency.
Proposed is continuous, i.e., more frequent at single weather station.

FIGURES
FIGURE 1A WATER QUALITY MONITORING LOCATIONS
FIGURE 1B AIR QUALITY AND WEATHER MONITORING LOCATIONS
FIGURE 1C AMBIENT NOISE/VIBRATION MONITORING LOCATIONS

FIGURE 1A WATER QUALITY MONITORING LOCATIONS
DIOXIN REMEDIATION AT BIEN HOA AIRBASE AREA PROJECT FIGURES 1

FIGURE 1B AIR QUALITY AND WEATHER MONITORING LOCATIONS

FIGURE 1C NOISE AND VIBRATION MONITORING LOCATIONS

ANNEX
SITE-WIDE STORMWATER POLLUTION PREVENTION PLAN

SITE-WIDE STORMWATER POLLUTION

PREVENTION PLAN (SWPPP)
JULY 17, 2020

SITE-WIDE STORMWATER
POLLUTION PREVENTION PLAN
(SWPPP)

JULY 17, 2020
PREPARED BY
USA
DISCLAIMER
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

TABLES
Table 1. Soil Compostion and Physical Characteristics............................................................................ 5
Table 2. Implementing Organization Roles and Responsibilities .......................................................... 10
Table 3. Project Stormwater Management Team .................................................................................... 11
Table 4. Stormwater Pollutant Sources ..................................................................................................... 13
Table 5. Best Management Practices ........................................................................................................... 19
Table 6. Good Housekeeping Practices. .................................................................................................... 21
Table 7. Site-Wide Stormwater Quality Monitoring Locations. .......................................................... 24
Table 8. Stormwater Quality Monitoring Parameters, Methods, Project Action Limits, and
Frequencies. ................................................................................................................................... 26
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


ADAFC Air Defence – Air Force Command
ARAR Applicable or Relevant and Appropriate Requirement
AWP Annual Work Plan
CASQA California Stormwater Quality Association
cm centimeter
CM Construction Manager
COD Chemical Oxygen Demand
COR Contracting Officer’s Representative
DGA Data Gaps Analysis
DQO Data Quality Objective
DU Decision Unit
EMMP Environmental Mitigation and Monitoring Plan
GHP Good Housekeeping Practice
ha hectare
kg kilogram
km kilometer
L liter
LLC Limited Liability Corporation
LSECS Lead Safety and Environmental Compliance Specialist
LTSA Long-term Storage Area
m meters
3
m cubic meters
mg milligrams
NPDES National Pollutant Discharge Elimination System
MONRE Ministry of Natural Resources and Environment
OWS Oil-water Separator
pg picogram
PMU Project Management Unit
QAPP Quality Assurance Project Plan
SAP Sampling and Analysis Plan

TCDD tetrachlorodibenzo-para-dioxin
TM Technical Memorandum
ug microgram
US United States
USDOT United States Department of Transportation
WBS Work Breakdown Structure
WMS Weather Monitoring Station
DIOXIN REMEDIATION AT BIEN HOA AIRBASE AREA PROJECT | iv

1 INTRODUCTION
This Site-Wide Storm Water Pollution Prevention Plan (Site-wide SWPPP) has been
developed for the Dioxin Remediation at Bien Hoa Airbase Area Project (Project) 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 2 (CLIN 2), Task 2.6, Site-Wide Storm
Water Pollution Prevention Plan for Dioxin Remediation at Bien Hoa Airbase Area Project.
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.
1.2 DOCUMENT ORGANIZATION

This Site-wide SWPPP has been developed in conformance with United States (US) Environmental
Protection Agency (USEPA) guidance, e.g., Developing your Stormwater Pollution Prevention
Plan, a Guide for Construction Sites (USEPA 2007), as well as applicable industry best practices
such as those published by the California Stormwater Quality Association (CASQA) in the
CASQA Stormwater Best Management Practice Handbook Portal: Construction (CASQA 2009).
This Site-wide SWPPP is organized as follows:
- 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.

1.3 REVIEW AND AMENDMENT
This Site-wide SWPPP must be reviewed by the USAID A&E Bien Hoa Contractor, annually in
conjunction with the development of the Activity Annual Work Plan (AWP) and review of the
SWEMMP, and in consideration of Project plans, designs, and stormwater inspection and
discharge monitoring and results. This Site-wide SWPPP must be updated with amendments as
warranted.
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.
1.4 SWPPP AVAILABILITY

This Site-wide SWPPP and any amendments must be maintained and available for review at the
USAID Project Office location during normal business hours. See also Section 7.4, Recordkeeping.
1.5 SITE CHARACTERISTICS
1.5.1 CLIMATE AND PRECIPITATION
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 1. ANNUAL AND SEASONAL RAINFALL AT BIEN HOA STATION IN YEARS 1994–2019.
FIGURE 2. MONTHLY RAINFALL AT BIEN HOA STATION IN YEARS 1994–2019.
FIGURE 3. RAINY DAYS PER MONTH AT BIEN HOA STATION IN YEARS 1994–2019.

FIGURE 4. WEATHER MONITORING LOCATION AT PROJECT FIELD OFFICE

1.5.2 GEOLOGY AND SOIL CHARACTERISTICS
Geology at Bien Hoa Airbase is documented in a geologic/hydro-geologic investigation report

(Dekonta 2014) and in the EA (GVN/USAID 2016).
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.
TABLE 1. SOIL COMPOSTION AND PHYSICAL CHARACTERISTICS
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
Sediment 47.2 36.6 16.1 0.1 4.1 4.79 6,500
Pacer Ivy Soil 80.2 12.6 0.2 7.0 5.1 5.40 9,100
Southwest Soil 67.3 18.3 11.7 2.7 21.0 6.95 8,800
Z1 Soil 43.4 35.5 21.1 0.0 4.4 5.21 2,700
Soil 45.2 23.6 30.7 0.5 5.4 5.03 1,900

1GVN/USAID 2016
1.5.3 TOPOGRAPHY AND DRAINAGE
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

determine Bien Hoa Airbase surface water drainage pathways and storm water drainage patterns
and supplement this Site-wide SWPPP.
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.

FIGURE 5. TOPOGRAPHY OF BIEN HOA AIRBASE (2009 SURVEY DATA).
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.
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.

2 STORMWATER MANAGEMENT
USAID is the implementing US government agency. The project is managed by the USAD/Vietnam
Mission. The COR is part of the Environmental Remediation Unit within the Environmental and
Social Development Office within the Mission.
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.
2.1 IMPLEMENTING ORGANIZATION ROLES AND RESPONSIBILITIES

As a funding and US Government implementing agency, USAID has partnered with MND to
support Project implementation. USAID has procured the services of an oversight contractor,
i.e., A&E Bien Hoa Contractor, to develop the Project Masterplan and to provide overall Project
engineering design, construction management, and related implementation support. The
construction management support includes the development of this Site-wide SWPPP and the
implementation of those portions assigned to the A&E Bien Hoa Contractor.
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.
Each of these implementing organizations, i.e., USAID, USAID, MND/ADAFC Project

Management Unit (PMU), A&E Bien Hoa Contractor, and USAID Implementing Contractors, have
assigned roles and responsibilities for stormwater management. These roles and responsibilities
are summarized in Table 2, Implementing Organization Roles and Responsibilities.

TABLE 2. IMPLEMENTING ORGANIZATION ROLES AND RESPONSIBILITIES
IMPLEMENTING
STORMWATER MANAGEMENT ROLE(S) AND RESPONSIBILITY(IES)
ORGANIZATION
USAID Project Project Owner/Lead Implementing Organization

Management Unit Stormwater management responsibilities include ensuring overall that Project remedial construction
(PMU) activities are conducted by the Implementing Organizations in a manner that is compliant with Project
ARARs and consistent with the established Project plans, to include this Site-wide SWPPP.
USAID A&E Bien Oversight Contractor

Hoa Contractor Stormwater management responsibilities include: implementing portions of this Site-wide SWPPP as
assigned to USAID A&E Bien Hoa Contractor; reviewing USAID Implementing Contractors’ Activity-
level SWPPPs on behalf of USAID for conformance with this Site-wide SWPPP; providing
Construction Manager (CM) and Lead Safety and Environmental Compliance Specialist (LSECS)
oversight of Implementing Contractors Activity-level SWPPP implementation; reviewing and
evaluating inspection, discharge monitoring, and maintenance records from USAID Implementing
Contractors to monitor negative impacts to stormwater quality resulting from Project remedial
construction activities; and reviewing this Site-wide SWPPP at least annually and amending as
appropriate.
USAID Executing Contractors

Implementing Stormwater management responsibilities include implementing stormwater pollution prevention
Contractors procedures in conformance with this Site-wide SWPPP that are specific to the Implementing
Contractor’s activities.
2.2 ACTIVITY-LEVEL STORMWATER POLLUTION PREVENTION

As noted, each Implementing Contractor who is executing Project activities on behalf of
MND/USAID must implement stormwater pollution prevention procedures that address
Activity-specific potential source(s) of storm water pollution, site-wide erosion and sediment
controls, BMPs, GHPs, inspection, maintenance and recordkeeping measures, and training.
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.
2.3 STORMWATER MANAGEMENT TEAM

Each of the Project implementing organizations has designated an individual to fulfill the
organization’s roles and responsibilities with respect to Site-wide SWPPP implementation. These
individuals are collectively listed in Table 3 and effectively comprise the Project Stormwater
Management Team.
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.

TABLE 3. PROJECT STORMWATER MANAGEMENT TEAM
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)
Sal Mansour +84.58.686.1240 (mobile)

USAID A&E Bien Hoa Chief of Party (COP) [email protected] (email)
Contractor Quang Trieu Mai +84.903.511.779 (mobile)
Construction Manager (CM) [email protected] (email)
First Interim David Liu +1.626.470.2441 (office)

Measures Contractor Project Manager +1.626.617.7389 (mobile)
[email protected]
Bobby Bobo Contractor Site +84.90.191.7452 (mobile)

Superintendent +1.865.387.6517 (US)
Contractor (Variable) Contractor Project Manager (CPM) (Variable)

3 POTENTIAL SOURCES OF STORMWATER POLLUTION
Potential sources of stormwater pollution resulting from the planned Project remedial
construction activities are identified and documented in this section. The identification of
potential sources of stormwater pollution supported the development of the Site-wide erosion
and sediment controls (Section 4), BMPs (Section 5), and GHPs (Section 6), as well as provide
minimum sources for inclusion in Activity-level SWPPPs as appropriate. Allowable stormwater
and non-stormwater discharges during Project remedial construction activities are also
documented in this section.
3.1 PROJECT ACTIVITIES

MND/ADAFC conducted an EIA outlining two phases of the Project, i.e., Phase 1 - remediation
of the Pacer Ivy Area; and Project Phase 2 - remediation of the Z1 Area. Project Phase 1 activities
were approved by GVN MND in Decision No. 3869/QD-BQP (MND 2019). MND describes
Project Phase 1 activities in Decision No. 3869/QD-BQP as:
• 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;
• Excavation and on-Airbase isolation of ~150,000 m3 of dioxin-contaminated soils and

sediments with a concentration below 1,200 ppt but above MND land-use thresholds in a
constructed storage facility; and
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.
3.2 STORMWATER POLLUTANT SOURCES

Potential sources of pollutants that could affect the quality of stormwater discharges resulting
from site-wide Project remedial construction activities are listed in Table 4.

Dioxin as a Stormwater Pollutant
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.
As noted previously, Section 7, Inspection, Maintenance and Recordkeeping Measures, describes

the required baseline and routine monitoring of turbidity, TSS, and 2,3,7,8-TCDD to specifically
address dioxin as a potential stormwater pollutant.
TABLE 4. STORMWATER POLLUTANT SOURCES
POTENTIAL STORMWATER POLLUTANTS
PESITCIDES, HERBICIDES3
SEDIMENT (DIOXIN)
OTHER CHEMICALS
FLOATING SOLIDS
DIESEL, GASOLINE
HEAVY METALS2
OIL, GREASE
NUTRIENTS
PROJECT ACTIVITY1
Clearing, Grading Site X X X X X X X
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
Constructing Storage Areas X X X X X X X
Constructing TCH Treatment Plant X X X X 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

3.3 ALLOWABLE STORMWATER DISCHARGES
Typical stormwater discharges from Project remedial construction activities include the following:
• Stormwater discharges associated with construction activities;

• Stormwater discharges from earth-disturbing activities associated with the excavation of
contaminated soils and sediments and the grading/leveling of staging areas, stockpiling areas,
access roads and haul roads; and
• Stormwater discharges from support activities provided the activities are directly related to
the construction activities and do not continue to operate beyond the completion of the
construction activities.
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.
3.4 ALLOWABLE NON-STORMWATER DISCHARGES

Non-stormwater discharges associated with Project remedial construction activities are generally
prohibited; however, the following non-stormwater discharges are allowed, provided that these
discharges avoid areas of exposed soils, or, in the case of landscape irrigation and water used to
control dust, do not result in runoff:
1) Discharges from emergency fire-fighting activities;

2) Fire hydrant flush water;
3) Landscape irrigation;
4) Water used to wash vehicles and equipment, provided that there is no discharge of soaps,
solvents, or detergents used for such purposes;
5) Water used to control dust;
6) Potable water including uncontaminated water line flush water;
7) External building washdown, provided soaps, solvents, and detergents are not used, and
external surfaces do not contain hazardous substances (e.g., lead-based paint, or paint or
caulk containing polychlorinated biphenyls);
8) Pavement wash waters, provided spills or leaks of toxic or hazardous substances have not
occurred (unless all spilled material has been removed) and where soaps, solvents, and
detergents are not used.
9) Uncontaminated air conditioning or compressor condensate;
10) Uncontaminated, non-turbid discharges of ground water or spring water;
11) Foundation or footing drains where flows are not contaminated with process materials such
as solvents or contaminated ground water; and
12) Construction dewatering and vehicle washing waters water that are discharged in
accordance with the SWEMMP.

All allowable non-stormwater discharges are to be minimized to the greatest extent practical
during Project remedial construction activities and specifically identified in Activity-level SWPPPs
and/or EMMPs.
4 EROSION AND SEDIMENT CONTROLS

USAID implementing contractors must implement erosion and sediment controls during Project
remedial construction activities. Erosion and sediment controls are primarily structural controls
that minimize surface erosion, scouring, and sedimentation from stormwater runoff by:
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;
3) Minimizing the amount of soil exposed during remedial construction activities;
4) Minimizing the disturbance of steep slopes;
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;
7) Minimizing soil compaction and preserve topsoil; and
8) Ensuring stabilization of disturbed areas after clearing, grading, excavating, or other land
disturbing activities have ceased.
4.1 MINIMUM EROSION AND SEDIMENT CONTROLS

The following erosion and sediment controls at the minimum must be implemented site-wide
during Project remedial construction activities:
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:
a. Provide and maintain an undisturbed natural buffer of at least 15 meters; or
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.
3) Direct stormwater runoff whenever feasible to vegetated areas and maximize

stormwater infiltration and filtering to reduce pollutant discharges.

4) Install perimeter controls (e.g., filter berms, silt fences, vegetative strips, and temporary
diversionary dikes) at the Project site in areas that will receive stormwater pollutant
discharges.
5) Minimize sediment track-out by vehicles and construction equipment:
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.
6) Manage soil/sediment stockpiles and land clearing debris piles:
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.
8) Minimize steep slope disturbances (defined as 15 percent [%] or greater in grade).
9) Minimize soil compaction in areas where final vegetative stabilization is to occur or

infiltration practices are to be installed:
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:
a. Situate the basin outside of natural buffers;
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

d. Use velocity dissipation devices at inlets and outlets.
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:
a. The requirement to initiate stabilization is triggered as soon as the construction work on

the respective portion of the site is temporarily ceased and will not resume for 14 or
more days, or as soon as it is known that construction work is permanently ceased, or
sooner based on weather forecast.
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
b. Implement permanent non-vegetative stabilization measures (e.g., rip-rap, gravel, gabions,

and geotextiles) to provide effective cover.
4.2 REPRESENTATIVE DESIGNS FOR EROSION AND SEDIMENT CONTROLS

Representative designs for erosion and sediment controls in metric units (USDOT 2020) are
included with this Site-wide SWPPP as an Attachment. Representative designs are included for
the following controls:
• Temporary Inlet Protection

• Straw Bales
• Sediment Traps
• Temporary Diversion Channels
• Temporary Erosion Control Berms, Slope Drains and Lined Waterways
• Silt Fences
• Check Dams
• Check Dams Moderate Grades
• Check Dams with Rolled Erosion Control Product
• Temporary Diversion Berms
• Sediment Filter Bags
• Sediment Wattles
• Fiber Rolls
• Stabilized Construction Exits
• Gabion Baskets
• Gabion Faced Walls
• Placed Riprap at Culvert Outlets

A Compendium of Standard Specifications (Compendium) has been developed to provide a set
of standard technical specifications specific to Project remedial and construction activities (USAID
2020). The Compendium serves as the basis for design to ensure consistency in approach and
quality of Project work activities as well as to reflect best practices, including green and sustainable
practices. Relevant to the erosion and sediment control measures prescribed by this Site-wide
SWPPP, the Compendium contains specifications for:
• soil management, including excavation and stockpiling;

• use of clean fill materials;
• reuse/replacement of treated soils;
• testing to confirm soil chemical, geotechnical, and horticultural suitability for use;
• waste recycling and disposal; and
• site stabilization, including the use of soil stabilization measures such as wattles, silt fencing,
and synthetic/natural tackifiers.
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.

5 BEST MANAGEMENT PRACTICES
Stormwater Best Management Practices (BMPs) are work practices that minimize the potential
for discharge of pollutants resulting from Project remedial construction activities. USAID
implementing contractor must implement stormwater BMPs during Project remedial
construction activities. BMPs differ from erosion and sediment controls presented in Section 4 in
that BMPs are predominantly construction and engineering practices rather than structures and
address a broader range of stormwater quality concerns.
Required minimum BMPs specific to particular construction activities are listed in Table 5. These
BMPs are organized by Project activity.
TABLE 5. BEST MANAGEMENT PRACTICES
PROJECT ACTIVITY BEST MANAGEMENT PRACTICE
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.
Dewatering of • Discharge of visible floating solids or foam is prohibited.

Soils/Sediments
• An oil-water separator (OWS) or other suitable filtration device must be used to remove
oils and grease.
• Discharges must meet QCVN 40:2011/BTNMT, National Technical Regulation on
Industrial Wastewater and TCVN 9737:2013 Dioxin Discharge Standards from the
Treatment Activities for the Dioxin Contaminated Sites requirements (as per SWEMMP).
Transporting • Exposed soils/sediment in vehicles must be covered during transportation to reduce

Soils/Sediments spillage.
• Transport vehicles must remain on designated haul routes and abide by Airbase speed
limits.
• Where soil/sediment has been tracked-out onto paved roads or other impervious surfaces,
the deposited sediment must be removed by the end of the business day via sweeping,
shoveling, or vacuuming surfaces.
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.

PROJECT ACTIVITY BEST MANAGEMENT PRACTICE
• An effective means of minimizing discharges of pollutants (e.g., directing equipment/vehicle
wash waters to a sediment basin or trap, or filtering wash waters using bags or sand filters)
must be provided.
• Soaps, solvents, or detergents must not be used.
• Discharges must meet QCVN 40:2011/BTNMT, National Technical Regulation on
Industrial Wastewater and TCVN 9737:2013 Dioxin Discharge Standards from the
Treatment Activities for the Dioxin Contaminated Sites requirements (as per SWEMMP).
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.

6 GOOD HOUSEKEEPING PRACTICES
Good housekeeping is the overall practice of maintaining all Project work areas neat and ensuring
that all materials, supplies, and storage containers are organized and stored in a manner that
prevents contact of stormwater pollutants with rainwater and/or otherwise reduces or eliminates
the potential for stormwater pollution. These common work practices are termed Good
Housekeeping Practices (GHPs). Good housekeeping practices (GHPs) are to be implemented
during Project remedial construction activities.
USAID implementing contractors must implement the GHPs specific to their construction
activities listed in Table 6.
TABLE 6. GOOD HOUSEKEEPING PRACTICES.
CATEGORY GOOD HOUSKEEPING PRACTICE
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.
Materials Storage - Material handling equipment must not be overloaded.

- Materials must be stored inside a building, under a roof, or in a covered
manner to the greatest extent practical.
- Materials must be stored in appropriate and well-labeled containers.
- Containers must be closed securely when not transferring materials.
- Material storage areas must have sufficient aisle space.
Vehicles/Equipment - Vehicles/equipment must have routine maintenance scheduled and

performed regularly.
- Vehicles/equipment must be checked routinely for and correct any leaks.

7 INSPECTION, MAINTENANCE AND RECORDKEEPING
MEASURES
USAID will require implementation by implementing contractors and/or the A&E Bien Hoa of
site-wide stormwater inspection, maintenance of controls, and recordkeeping measures during
Project remedial construction activities. Stormwater inspection measures include visual
inspection and stormwater discharge monitoring that includes baseline and routine monitoring.
7.1 VISUAL INSPECTIONS

In accordance with USAID direction, the A&E Bien Hoa Contractor and/or USAID Implementing
Contractors must visually inspect the following Project locations relevant to stormwater with
ongoing remedial construction activities, at a minimum, once every seven (7) calendar days, or
once every fourteen (14) calendar days and within twenty four (24) hours prior to and post the
occurrence of a storm event of one (1) centimeter (cm) or greater precipitation.
• 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.
Visual inspections must be conducted to:
• 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;

• Check for signs of erosion and sedimentation; and
• Document the visual quality of stormwater (when discharges are occurring).
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).
Records of stormwater visual inspections must be signed by the inspector.
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.
7.2 DISCHARGE MONITORING

Stormwater discharge monitoring is a requirement of this Site-wide SWPPP.
Site-wide stormwater discharge monitoring is required to establish pre-construction surface

water quality conditions (baseline) as well as to provide routine monitoring of stormwater quality
during Project remedial construction activities. Baseline monitoring activities are defined in the
SWEMMP.
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.

Heavy metals, diesel, gasoline, and nutrients are all controllable factors that are not anticipated
to routinely occur in stormwater from Project activities. Inspection of BMPs and GHPs will be
the primary monitoring method for these potential pollutants. The remaining pollutants either
pre-exist in the soil and sediment to be disturbed during remedial activities at levels of concern
(arsenic, dioxins, phenols, 2,4-D, and 2,4,5-T) are indicative of a class of potential Project
stormwater pollutants (e.g., oil/grease and COD) or can affect the impact of pollutants being
monitored (e.g., pH, turbidity, and TSS). Table 7 and Figure 6 present the site-wide stormwater
discharge monitoring locations for the remaining potential pollutants USAID will require activity-
level monitoring in each of those locations when potentially impacted by project activities and
document these requirements in the Activity-level EMMP.
TABLE 7. SITE-WIDE STORMWATER QUALITY MONITORING LOCATIONS.
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.

FIGURE 6. SURFACE WATER/STORMWATER MONITORING LOCATIONS

TABLE 8. STORMWATER QUALITY MONITORING PARAMETERS, METHODS, PROJECT ACTION
LIMITS, AND FREQUENCIES.
MONITORING FREQUENCY WHEN

PROJECT
TEST PROJECT ACTION LIMIT POTENTIAL IMPACT FROM ACTIVE
PARAMETER ACTION
METHOD REFERENCE PROJECT CONSTRUCTION
LIMIT
ACTIVITY 1
pH Field Monitor 6 to 8.5 QCVN 08-MT:2015/BTNMT Weekly
Turbidity Field Monitor Baseline NA Daily
Oil/grease Method 1664 0.3 mg/L QCVN 08-MT:2015/BTNMT
TSS Method 160.2 20 mg/L QCVN 08-MT:2015/BTNMT
COD Method 410.4 10 mg/L QCVN 08-MT:2015/BTNMT Weekly
Total 0.005
Method 604 QCVN 08-MT:2015/BTNMT
Phenols mg/L
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).
7.3 EROSION AND SEDIMENT CONTROLS MAINTENANCE

Erosion and sediment controls are critical to the prevention of contaminant migration and the
protection of receiving waters. Erosion and sediment controls must be inspected (see Section
7.1), maintained, and repaired as needed to assure continued performance of their intended
functions. Maintenance will vary according to site conditions. USAID implementing contractors
must conduct maintenance regularly and whenever a visual inspection (formal or informal)
identifies a maintenance need.

Required erosion and sediment control maintenance measures include:
• 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:
• Identification of control and location;

• Brief description of maintenance performed;
• Name of individual(s) conducting maintenance; and
• Date of maintenance.
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:
• SWPPP and amendments (see Section 1.4);

• Delegation of stormwater responsibilities in writing (as applicable, see Section 2.3);
• Weather conditions (see Section 4.1);
• Dates when major land disturbing activities (e.g., clearing, grading excavating) occur in an area
(see Section 4.4);
• Dates when construction activities are either temporarily or permanently ceased in an area
(see Section 4.4);
• Dates when an area is either temporarily or permanently stabilized (see Section 4.4);
• Visual inspection records (see Section 7.1);
• Discharge monitoring records (see Section 7.2);

• Erosion and sediment control maintenance records (see Section 7.3); and
• Training records (see Section 8).

8 TRAINING
All individuals assigned with stormwater management responsibilities or otherwise responsible
for implementing the requirements of this Site-wide SWPPP must be trained on potential
stormwater pollutants, erosion and sediment controls, BMPs, GHPs, and inspection, maintenance
and recordkeeping measures.
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.

9 REFERENCES
CASQA. 2009. Stormwater Best Management Practice Handbook Portal: Construction.
November 2009.
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
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.
USDOT. 2020. US Department of Transportation, Federal Highway Administration, Office of

Federal Lands Highway, https://flh.fhwa.dot.gov/resources/standard/. March 2020.
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).

ATTACHMENTS
REPRESENTATIVE DESIGNS FOR EROSION AND SEDIMENT

CONTROLS
TEMPORARY INLET PROTECTION
STRAW BALES
SEDIMENT TRAPS
TEMPORARY DIVERSION CHANNELS
TEMPORARY EROSION CONTROL BERMS, SLOPE DRAINS AND LINED WATERWAYS
SILT FENCES
CHECK DAMS
CHECK DAMS MODERATE GRADES
CHECK DAMS WITH ROLLED EROSION CONTROL PRODUCT
TEMPORARY DIVERSION BERMS
SEDIMENT FILTER BAGS
SEDIMENT WATTLES
FIBER ROLLS
STABILIZED CONSTRUCTION EXITS
GABION BASKETS
GABION FACED WALLS
PLACED RIPRAP AT CULVERT OUTLETS


(SUPPORT DOCUMENT)
DECEMBER 28, 2020


(SUPPORT DOCUMENT)

SEPTEMBER 10, 2020
PREPARED BY
USA
DISCLAIMER
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

FINAL MASTERPLAN – VOLUME 2 | i
RECORD OF REVISIONS
REVISION DATE PAGES SUMMARY OF REVISIONS APPROVAL
Initial development/submittal
000 May 4, 2020 All of Draft Implementation MND and USAID COR
Masterplan.
001 August 10, 2020 All Final Masterplan (Revised) MND and USAID COR

FINAL MASTERPLAN – VOLUME 2 | ii
% percent
°C degrees Celsius
ADAFC Air Defence-Air Force Command
AMST Academy of Military Science and Technology
BRA Baseline Risk Assessment
COPC Chemical of Potential Concern
DONRE Dong Nai Department of Natural Resources and Environment
DU Decision Unit
EMP Environmental Management Plan
GHG Greenhouse Gases
HI Hazard Index
IUR Inhalation Unit Risks
LTSA Long-Term Storage Area
m2 square meter
m3 cubic meter
mg/L milligram per liter
MIS Multiple Increment Sampling
MOI Memorandum of Intent
MONRE Ministry of Natural Resources and Environment
PCB polychlorinated biphenyl
PCDD/F polychlorinated dibenzo-p-dioxins and dibenzofurans
ppm parts per million
PeCDD 1,2,3,7,8-Pentachlorodibenzo-P-dioxin
RfC Reference Concentrations
RfD Reference Dose
SF Slope Factors
SI Site Investigation
TCDD 2,3,7,8-Tetraclorodibenzo-P-dioxin
TEQ Toxic Equivalency
U.S. United States

FINAL MASTERPLAN – VOLUME 2 | iii
8 HISTORICAL BACKGROUND
This section provides descriptions of the historical efforts addressing dioxin contamination at the Bien
Hoa Airbase (Airbase) Area.
8.1 BIEN HOA AIRBASE AREA ENVIRONMENTAL ASSESSMENT

In 2016, the U.S. Agency for International Development (USAID) collaborated with the Government
of Vietnam (GVN) to conduct an environmental assessment (EA) of contamination in the Bien Hoa
Airbase Area. The EA estimated the volume of contaminated soils and sediments in the range of
408,500 to 495,300 cubic meters (m3). The estimated distribution of soil and sediment contamination
is 95 percent (%) within the Airbase itself and the remaining portion of contamination to reside outside
the boundaries of the Airbase.
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.
8.2 OTHER USAID AND GVN EFFORTS ADDRESSING DIOXIN CONTAMINATION

In addition to this Project, and the risk reduction measures already implemented (Volume 1,
Section 5.1), USAID and GVN have conducted other efforts to understand and prepare to address
dioxin contamination at the Bien Hoa Airbase Area. These efforts include:
• 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

• Vetiver grass project initiated in 2014 by Vietnam Institute of Geosciences and Mineral Resources
and funded by the Ministry of Natural Resources and Environment (MONRE). The project entailed
the experimental planting of Vetiver grass on 300 square meters (m2) of Pacer Ivy Area for the
purpose of mitigating dioxin contamination. As reported at a 2015 conference, the project
achieved initial successful results, in that the Vetiver demonstrated its ability to absorb and process
dioxin in soil. Dioxin concentration in soil in the grass plot experiments tended to decrease
compared to the non-grass plot. The data generated from this effort led the project team to
conclude that the Vetiver grass can grow well on poor quality and moderately chemical-/dioxin-
contaminated soil and that its use in phytostablization should be further evaluated to determine if
it can be replicated on a larger scale at Bien Hoa Airbase.
• 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.
8.3 ENVIRONMENTAL IMPACT ASSESSMENT AND PROJECT APPROVAL

In 2019, the Ministry of National Defence (MND) and ADAFC conducted and developed the Report
of Environmental Impact Assessment (EIA) for the Dioxin Remediation at Bien Hoa Airbase Area
Project based on the expected implementation of EA Alternative 4. The EIA provides additional data
on water, air, and soil quality. It also includes the additional contaminated areas that DONRE identified
and were described in Section 8.2.
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:
• Phase 1 duration from 2019 through 2025;
• 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

• Treat all dioxin-contaminated wastewater and surface water with concentrations exceeding the
allowable thresholds.
9 SITE CONCEPTUAL MODEL, DATA GAPS ANALYSIS,

BASELINE RISK ASSESSMENT
The A&E Bien Hoa Contractor prepared a Technical Memorandum (TM) for the Site Conceptual
Model and Data Gaps Analysis (SCM/DGA) to understand historical dioxin contamination at the Bien
Hoa Airbase Area and the potential for future migration of contamination. This TM includes an
evaluation of the sufficiency of existing data, established a SCM for the Bien Hoa Airbase Area,
identified and determined the criticality of data gaps, and recommended site investigations (SI) and
other evaluation activities to resolve critical data gaps.
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.
9.1 SITE CONCEPTUAL MODEL AND DATA GAPS ANALYSIS

The SCM/DGA 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. The purpose of the SCM/GA is to:
• Advance a SCM to guide development and implementation of the Dioxin Remediation of

the Bien Hoa Airbase Area Project (Project) Implementation Masterplan;
• 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.

9.2 BASELINE RISK ASSESSMENT
This BRA includes a hazard identification, toxicity assessment, exposure assessment, exposure
scenario (current conditions), and risk characterization.
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.
Further details are provided in Annex 7, Baseline Risk Assessment.
10 APPLICABLE RELEVANT AND APPROPRIATE

REQUIREMENTS
The A&E Bien Hoa Contractor developed a Tabulated Summary of Applicable or Relevant and
Appropriate Requirements (ARARs) for USAID that outlined the process implemented to define the
ARARs and presented the proposed list of ARARs for the Project. In order to develop plans for
remediation, it was necessary to agree upon a set of ARARs, specifying the acceptable concentrations
of contaminants in the environment and acceptable methods for remediation. These standards are
the basis for defining the level of cleanup required, treatment goals and objectives, volume of material
to be treated, and waste classifications for disposal, among others.
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.

ARARs approved by USAID and ADAFC are the source for regulatory guidance, establishment of
goals, and definition of criteria applicability for Project activities. 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, and in
turn the Project goals and implementation practices, as applicable.
The Tabulated Summary of ARARs, including further details on their development, is provided in
Annex 5.

ANNEX 5 – TABULATED APPLICABLE AND RELEVANT OR
APPROPRIATE REQUIREMENTS

TABULATED SUMMARY OF
APPLICABLE OR RELEVANT AND
APPROPRIATE REQUIREMENTS
AUGUST 10, 2020

TABULATED SUMMARY OF APPLICABLE

OR RELEVANT AND APPROPRIATE
REQUIREMENTS

AUGUST 10, 2020
PREPARED BY
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
DIOXIN REMEDIATION AT BIEN HOA AIRBASE AREA

| i
SUMMARY OF APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
ADAFC Air Defence Air Force Command
Airbase Bien Hoa Airbase
dscm dry standard cubic meter
ENV Environmental
GEN Gender
m3 Cubic Meters
MCLG Maximum Contaminant Level Goa
mg/L milligram per liter
mm millimeter
ng nanogram
ng/kg nanogram per kilogram
NESHAP National Emissions Standards for Hazardous Air Pollutants
NPDWR National Primary Drinking Water Regulations
OHS Occupational Health and Safety
ppm parts per million
TBC To Be Considered
TCDD 2,3,7,8-tetrachlorodibenzo-p-dioxin
TEQ Toxic Equivalency
US United States
USG United States Government

| ii
EXECUTIVE SUMMARY
The Dioxin Remediation at Bien Hoa Airbase Area Project undertaken by the United States Agency
for International Development (USAID) in collaboration with the Government of Vietnam (GVN) will
remediate dioxin contamination that resulted from the storage, handling, and leakage of Agent Orange
during and after the Vietnam War. A project of this depth, breadth, and level of complexity demands
that the implementers establish a comprehensive understanding of and strategies for adherence to
relevant laws, regulations, and standards. This Draft Tabulated Summary of Applicable or Relevant and
Appropriate Requirements (ARARs) outlines the evaluation process implemented for the review of
the laws, regulations, and standards pertaining to the specific dioxin remediation program needs at the
Airbase and surrounding area and the development of the ARARs list for the Project.
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.

| iii
1 INTRODUCTION
This Draft Tabulated Summary of Applicable or Relevant and Appropriate Requirements (ARARs) (ARARs
Summary) was developed by the USAID/Vietnam Architect–Engineer Services for Dioxin Remediation at
Bien Hoa Airbase Area Contractor (A&E Bien Hoa Contractor) for the United States 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 (Contract Line Item Number 1), Task 1.4, Identify
Applicable or Relevant and Appropriate Requirements. The efforts outlined in this report are in support
of the Dioxin Remediation at Bien Hoa Airbase Area Project (the Project).
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.
2.1 TYPES OF ARARS

ARARs typically fall in one of three categories:
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

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toxic equivalency (TEQ) values that relate to TCDD, which is assigned a unit value of one. TCDD happens
to be the predominate dioxin congener in Agent Orange.
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.
2.2 ARAR RELEVANCY

Part of the ARARs review process involves determining the relevancy of the laws, regulations, and
standards. There are three categories of relevancy:
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.
2.3 ARAR APPLICATION

Once the Project ARARs list is approved, Project goals, procedures, and outcomes will comply with the
selected ARARs or meet one of the following conditions:
• Action taken is only part of a total remediation that will attain ARARs upon completion;
• Compliance with ARAR will result in greater risk;
• Compliance with ARAR is technically impractical from an engineering perspective;
• Remedial action selected will attain a standard of performance that is equivalent to the ARAR; and
• Inconsistent application of standard.

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3 PURPOSE
The purpose of this ARARs Summary is to outline the process implemented to define the ARARs, as well
as present the list of ARARs developed for the Project. The Project is a multimillion-dollar clean-up project
with the goal of remediating the dioxin contaminated soils and sediments in and around the Airbase Area.
The first phase of the Project is to develop a Masterplan to finalize the remedial approach and select the
preferred treatment technology(ies) for dioxin remediation.
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.
4 ARARS IDENTIFICATION METHODOLOGY

This Section defines the complete process from initial ARAR identification through final USAID approval.
The step-wise process for defining and refining Project ARARs, along with the participants anticipated to
be involved in each step, is summarized in the below table. The participants and their associated roles
include:
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.

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Stakeholders – GVN organizations and agencies participating in the Project Masterplan development
process (e.g., the Ministry of National Defence (MND), Ministry of Environment and Natural Resources,
the Ministry of Science and Technology, etc.) through the series of five Masterplan Roadmap meetings.
STEPS ACTIVITIES PARTICIPANTS
1 Identify potential requirements A&E Bien Hoa Contractor
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
4.1 STEP 1 – IDENTIFICATION AND ACQUISITION

The first step towards developing the list of “Applicable” or “Relevant and Appropriate” requirements for
consideration was to review the laws, regulations, and standards referenced in the joint 2016 USAID-
GVN report “Environmental Assessment of Dioxin Contamination at Bien Hoa Airbase” (EA) and the
GVN Environmental Impact Assessment (EIA) prepared for the Vietnam MND by New Technology
Institute in February 2019. Between the EA and the EIA, approximately 90 laws, regulations, and guidelines
from both the US and Vietnam were referenced. These references served as the initial source of
requirements identified for consideration for inclusion in the ARARs list. The A&E Bien Hoa Contractor
identified ARARs across each of the categories described in Section 2.1.
4.2 STEP 2 – EVALUATION

The identification necessitated, in many cases, acquisition of electronic copies of the laws, regulations, and
standards anticipated to have importance within the context of the Project. In the second step, the A&E
Bien Hoa Contractor evaluated them for their applicability and relevance to the Project. As both the EA
and EIA were directly related to the assessment of dioxin contamination at the Airbase Area, many of the
references in those documents were presumed to be applicable. Through the process of acquiring the
documents from the initial list, additional requirements were identified as potentially “Relevant and
Appropriate” and “To Be Considered”, and efforts were directed toward determining the importance of
the requirements in the context of the Project.
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.

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While the evaluation process completed to date deemed some of the requirements to be of lesser
importance at this stage of Project progression, it also generated a list of several key decision making
ARARs for detailed evaluation. Table 5-1 presents the details of these requirements and the associated
actions anticipated to be taken with respect to the remedial approach in utilizing the proposed ARARs.
The ARARs considered at this stage to be key to the Project progression, as described in section 6, relate
to the following aspects of the Project:
1. Cleanup levels for contaminated soil and sediment;

2. Soil and sediment treatment goals and objectives;
3. Waste classifications for disposal;
4. Criteria for material disposition and reuse/replacement on site;
5. Surface water quality and stormwater monitoring;
6. Evaluation of land parcels for long-term storage area;
7. Treatment of discharge and control of emissions; and
8. Monitoring of ambient air and water quality.
4.3 STEP 3 – REFINE ARARS

After completion of the initial list of documents, step three was to refine the list, by eliminating the laws,
regulations, and standards that were determined not applicable to the existing Project conditions. The list
of documents included in the initial ARARs list was provided to the SMEs for evaluation. Each SME assessed
the laws and regulations listed to determine relevancy and compare the strictness of the similar laws and
regulations to determine which provided the strictest requirements with respect to the criteria
considered in Step 2.
4.4 STEP 4 – STAKEHOLDER REVIEW

Step four included coordination between the USAID, ADAFC, the A&E Bien Hoa Contractor Team, SMEs,
and the GVN Project Masterplan stakeholders. During Masterplan Roadmap Meeting 2 in November 2019,
stakeholders were asked to review the ARARs information prepared by the A&E Bien Hoa Contractor
to assess completeness of the list, and identify any requirements that have been amended or updated
more recently than the versions listed.
4.5 STEP 5 – STAKEHOLDER FEEDBACK

Ahead of Masterplan Roadmap Meeting 3, the A&E Bien Hoa Contractor consolidated Stakeholder
feedback and 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.
4.6 STEP 6 – FINAL APPROVED ARARS

Final feedback from the stakeholders was addressed as directed by USAID, modifications made to the
ARARs list as needed, and the final list of ARARs for the Project provided to USAID and ADAFC as part

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of the draft and final Implementation Masterplan for review and approval. The approved ARARs list will
serve as the source for regulatory guidance and establishment of goals, and it will define the criteria to
serve as the basis for design of subsequent Project activities.
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).

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TABLE 5-1. POTENTIAL ARARS
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.

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ACTIVITY 2: SOIL AND SEDIMENT TREATMENT GOALS AND OBJECTIVES (A = Applicable R&A = Relevant & Appropriate)
NO. CITATION TITLE DATE ORIGIN DESCRIPTION ACTION A or R&A

4 Decision Document On Approval of the 6 GVN MND Project approval and assigns Utilize the treatment requirement of A
No. 3869/QD-BQP Investment Project and September ADAFC as the project owner. Establishes <100 ppt TEQ, This represents the
the Plan for Selection of 2019 scope of Phase 1 work (2019 to 2025) to lowest of the limits established for
the Contractor for excavate based on land use, treat about the land use categories anticipated
"Dioxin Remediation in 150,000 m3 to below 100 ppt dioxin for future development of Bien Hoa
Bien Hoa Airbase–Phase TEQ, and safely isolate/store about Airbase.
1" 150,000 m3 of soil and sediment that is Utilize the maximum storage
below 1,200 ppt dioxin TEQ. Tentatively threshold of 1,200 ppt TEQ. Location
approves TCH technology and approves of storage area north of the runway.
the storage location as north of the
runway.
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.

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ACTIVITY 3: WASTE CLASSIFICATION FOR DISPOSAL (A = Applicable R&A = Relevant & Appropriate)
6 QCVN 07: 2009/BTNMT National Technical 2009 GVN Hazardous waste threshold values for: Utilize the hazardous waste A
Regulation on inorganic constituents including arsenic; threshold values for waste
Hazardous Waste organic constituents including dioxin and classification.
Thresholds dioxin-like compounds; as well as the Utilize the sampling procedures and
hazardous waste characteristics: analytical methods to determine if
ignitability, alkalinity, and acidity. levels of waste constituents exceed
Regulation specifies the appropriate hazardous waste thresholds to
sampling procedures and analytical classify wastes as hazardous or
methods for waste classification. The nonhazardous. Based on the waste
regulation is applicable to individuals and classification, determine the
organizations generating, collecting, appropriate disposal options for the
transporting, storing, treating, landfilling, specific wastes, (e.g., soils, sediments,
and disposing of waste; state management vegetation, and investigation-derived
agencies, sampling and analysis units, and wastes).
individuals and organizations conducting
activities related to waste.
– Total Dioxin: Basic Absolute Content =

0.1 ppm; Leaching Concentration = 0.005
mg/L
– Arsenic: Basic Absolute Content = 40
ppm; Leaching Concentration = 2 mg/L

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ACTIVITY 4: CRITERIA FOR MATERIAL REUSE/REPLACEMENT ON SITE (A = Applicable R&A = Relevant & Appropriate)
7 QCVN National Technical 2012 GVN Regulation defines seven land use R&A
45:2012/BTNMT Regulation on Allowed types and provides a limit on dioxin Utilize a maximum of 100 ppt TEQ for
Limits of Dioxin in Soils allowable in soils as follows for the treated material to be reused in formerly
protection of human health and the contaminated areas. This represents the
environment. The lowest applicable lowest of the limits established for the land
land use for the Project is: use categories anticipated for future
– Land Use: No. 2 Forest land, land development of Bien Hoa Airbase. Apply
for perennial trees: Maximum other screening criteria related to soil
Allowable Limit: 100 ng/kg TEQ (ppt condition and content (e.g., exclusion of
TEQ) debris such as wood, asphalt, concrete,
metal, plastic) sized larger than gravel.
8 QCVN National Technical 2017 GVN To protect waterbodies with Utilize the dioxin limit for imported R&A
43:2017/BTNMT Regulation on Sediment aquaculture, the allowable limit for backfill material (not treated material).
Quality dioxin is 21.5 ng/kg TEQ (ppt TEQ). Apply other screening criteria related to
Sediment is defined as material soil condition and content (e.g.,
particles located at a depth of not exclusion of debris such as wood,
more than 15 cm from the bottom asphalt, concrete, metal, plastic) sized
surface of the water, the particles larger than gravel.
with size of smaller than 2 mm or
passing through a sieve with 2 mm
diameter hole (U.S. # 10 sieve).
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)

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ACTIVITY 5: SURFACE WATER QUALITY AND STORMWATER MONITORING (A = Applicable R&A = Relevant & Appropriate)

12 QCVN 08-MT: National Technical 21 GVN Regulation defines the Maximum Utilize the A1 surface water Maximum A
2015/BTNMT Regulation on Surface December Permissible Limits for surface water Permissible Limits for determining
Water Quality 2015 quality parameters. The regulation whether groundwater or surface water
also defines the appropriate analytical related to Project activities can be
methods for surface water analyses. released as surface water. Pertinent
The regulation classifies surface water Project activities would include
into four categories: A1, A2, B1, and dewatering (groundwater) during
B2. excavation operations and dewatering
A1 – Used for supplying domestic (surface water) ponds and other surface
water (after being commonly treated) water bodies.
or conserving aquatic animals and Utilize the A1 surface water Maximum
plants. The following are A1 Permissible Limits for stormwater
Maximum Permissible Limits of note: monitoring and to determine when
pH: 6 to 8.5 mitigation actions need to be taken to
Total Suspended Solids: 20 mg/L prevent stormwater runoff.
Arsenic: 0.01 mg/L Utilize the A2, B1, and B2 for other
applications, as appropriate.
13 NĐ80/2014/NĐ-CP Decree on the drainage 8 June 2014 GVN Article 20. Management of rainwater R&A
and treatment of drainage systems and use of rainwater The Project will incorporate
wastewater 1. The management of rainwater these requirements into
drainage system: engineering designs and the
a) The management of drainage of implementation of the
rainwater is managing the constructed Stormwater Pollution Prevention
works; Plan.
b) The networks of sewers, channels,
manholes must be dredged, repaired
and maintained periodically;
c) A procedure for managing and
operating the rainwater drainage
system; and
d) Plans for the development of the
drainage network.
14 TCVN 9737:2013 Dioxin Limits in 2013 GVN R&A
Wastewater and Waste The wastewater discharge Consider using the wastewater
Gas Discharges from standard for dioxin from standard for dioxin until the
Residual Dioxin treatment is 10 pg TEQ/Ll. baseline in surface water is
Remediation There is no surface water established.
standard for dioxin.

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ACTIVITY 6: EVALUATION OF LAND PARCELS FOR LONG-TERM STORAGE OF LOW-LEVEL
(A = Applicable R&A = Relevant & Appropriate)
CONTAMINATION MATERIAL
15 Decree No. Decree on Management 24 April GVN Decree provides requirements for Utilize the decree to determine A
38/2015/ND-CP of Waste and 2015 hazardous waste treatment and storage requirements for hazardous waste
Discarded Materials facilities and responsibilities of Ministries. treatment as a “licensed waste
treatment facility”.
16 Joint Circular No. Joint Circular Guiding 18 January GVN Circular provides guidance in selecting For solid waste utilize the standards R&A
01/2001/TTLT/BKH the Regulations on 2001 locations for building and operating solid and for non-solid waste (e.g.,
CNMT-BXD Environmental waste landfills. This does not apply to vegetation) consider the standards to
Protection for the hazardous waste facilities. determine setbacks, with respect to
Selection of Location, Provides the following set back ranges of housing and groundwater resources in
for the Construction large burial sites with respect to delta and order to determine useable area and
and Operation of, Solid midland population clusters ultimately design and storage capacity.
Waste Burial Sites Airports, industrial zones – 2,000 to 300 m
5 households > 300 m
Underground water > 100 m
17 United States USEPA Guide for 2003 USG Guide provides ranges of state-required Utilize the setbacks established across R&A
Environmental Industrial Waste setbacks for solid waste landfills, in regards state (US) regulatory requirements for
Protection Agency, Management to multiple features as well as most establishing storage are evaluation
2003. Guide for common values across the state criteria not addressed in Joint Circular
Industrial Waste regulations. 01/2001/TTLTBKHCNRIT-BXD. The
Management ranges of setbacks will provide a
Waste Management Range of minimum distances from features: framework for applying professional
Protecting Land, Groundwater – 1 to 15 ft (5 feet is most judgment based on site-specific
Groundwater, common) conditions.
Surface Water, Air Property Boundaries – 20 to 600 ft
Drinking Water Wells – 500 to 1320 ft
Public Water Supply – 400 to 5280 ft
Surface Waterbody – 100 to 2000 ft

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ACTIVITY 7: TREATMENT OF DISCHARGE AND CONTROL EMISSIONS (A = Applicable R&A = Relevant & Appropriate)

18 TCVN 9737:2013 Dioxin Limits in 2013 GVN The wastewater discharge standard for (1) Utilize the standard (or baseline) for R&A
Wastewater and dioxin from treatment is 10 pg TEQ/Ll. dioxin in process water and wastewater
Waste Gas Discharges discharged from the treatment plant.
from Residual Dioxin (2) Utilize the requirement to develop
Remediation work practices and engineering
controls and to develop emission
monitoring procedure for dioxin
treatment activities.
19 QCVN National Technical 28 GVN Maximum values of pollution parameters of Utilize the requirements for pH, oil and A
40:2011/BTNMT Regulation on December industrial wastewater being discharged into grease, TSS, COD, total phenols, and
Industrial Wastewater 2011 receiving waters. arsenic for process water and
– pH range: 5.5 to 9 wastewater discharged from the
– Oil and grease: 10 mg/L treatment plant.
– TSS: 100 mg/L
– COD: 150 mg/L
– Total phenols: 0.5 mg/L
– Arsenic: 0.1 mg/L
This Regulation is applicable to organizations
and individuals involved in the discharge of
industrial wastewater into receiving waters.
20 QCVN National Technical 16 GVN Maximum allowable concentration of dusts Utilize the requirements for total dust A
19:2009/BTNMT Regulation on November and inorganic substances entered into at the treatment plant stack. If a
Industrial Emission of 2009 ambient air, applies to individuals and thermal oxidizer is part of the
Inorganic Substances organizations carrying out activities related treatment train, use the requirements
and Dusts to the sending of the industrial emission for CO, SO2, and NOx
containing dusts and inorganic substance
into ambient air. Using a Kp=1 and Kv = 0.6
at 25°C and 760 mm mercury:
– Total dust: 120 mg/Nm3
– CO: 1,000 mg/Nm3
– SO2: 500 mg/Nm3
– NOx (as NO2): 850 mg/Nm3
21 TCVN 10843:2015 Ambient Air Quality - 2015 GVN Supervision and assessment of ambient air Utilize this standard (or baseline) for R&A
Maximum Dioxin quality. treatment plant emissions of dioxin and
Concentration in The maximum dioxin concentration in develop work practices and engineering
Ambient Air ambient air is 0.6 pg-TEQ/m3. controls and to develop/refine ambient
air monitoring procedures.

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22 QCVN National Technical 25 October GVN Utilize the requirements for total dust A
05:2013/BTNMT Regulation on 2013 This Regulation applies to supervision and PM10 (or baseline) during
Ambient Air Quality and assessment of ambient air quality. excavation activities. Use the PM10
– Total dust: 24 hour mean: 200 requirement around the treatment
µg/m3. Annual mean: 100 µg/m3 plant perimeter.
– PM10: 24 hour mean: 150 µg/m3.
Annual mean: 50 µg/m3
23 QCVN 06: National Technical 07 October GVN Utilize the arsenic limit during A
2009/BTNMT Regulation on 2009 Regulation prescribes the permissible excavation activities. Utilize the
Hazardous Substances maximum concentrations of hazardous requirement to inform the selection
in Ambient Air substances in air, including but not and design for implementation of
limited to: treatment technologies and to develop
Arsenic (compounds) emissions control strategies for all
Average duration: 1 hour, Permissible Project operations.
concentration: 0.03 micrograms per
cubic meter (μg/m3)
Average duration: Year, Permissible
concentration 0.005 μg/m3
24 QCVN National Technical 16 GVN Utilize the requirement to inform the A
26:2010/BTNMT Regulation on Noise December This Regulation prescribes the selection and design for implementation
2010 maximum noise limits in areas where of excavation activities and treatment
humans live and work (permissible technologies.
noise limits, in decibels).
– 6 am to 9 pm: 70 dBA
– 9 pm to 6 am: 55 dBA
25 QCVN National Technical 2010 GVN Utilize the requirement to inform the A
27:2010/BTNMT Regulation on This Regulation prescribes the selection and design for implementation
Vibration maximum limits on the levels of of excavation activities and treatment
vibration acceleration in areas where technologies.
humans live and work.
– 6 am to 6 pm: 75 dB
– 6 pm to 6 am: background
The vibration in this Regulation is the
vibration created by humans,
regardless of the sources of vibration
and their positions.

| 14
(A = Applicable R&A = Relevant &
ACTIVITY 8: MONITORING OF AMBIENT AIR AND WATER QUALITY
Appropriate)
26 QCVN 06: National Technical 07 October GVN Permissible maximum concentrations of Utilize the maximum A
2009/BTNMT Regulation on Hazardous 2009 hazardous substances in air, including but concentrations for benzene
Substances in Ambient not limited to: during excavation activites.
Air – Arsenic. 1 hour mean: 0.03 micrograms Utilize the maximum
per cubic meter (μg/m3). Annual mean: concentrations for benzene,
0.005 μg/m3 styrene, toluene, and xylene
– Benzene. 1 hour mean: 22 μg/m3. during treatment.
Annual mean: 10 μg/m3
– Styrene. 1 hour mean: 260 μg/m3.
– Toluene. 1 hour mean: 1,000 μg/m3.
– Xylene. 1 hour mean: 1,000 μg/m3.
27 QCVN 09-MT National Technical 21 December GVN Maximum value of groundwater quality Utilize the maximum allowable A
2015/BTNMT Regulation on 2015 parameters. values in groundwater for pH,
Groundwater Quality – pH range: 5.5 to 8.5 arsenic, and total phenol. Utilize
– Arsenic: 0.05 mg/L the specified methods.
– Total phenol: 0.001 mg/L
It applies to assess and supervise the
quality of groundwater resource based on
the different uses.
28 Circular No. Circular on 01 September GVN There are two primary sections that apply Utilize the monitoring A
24/2017/TT-BTNMT Environmental 2017 to the Project: frequencies as the minimum
Monitoring Techniques 1.) Techniques for monitoring requirements for the Project.
environmental components on a periodic
basis, including: outdoor air, noise and
vibration; inland surface water;
groundwater; wastewater; exhaust gases;
soil; sediment.
2.) Quality assurance and quality control
in periodic environmental monitoring

| 15
6 ARARS IN THE CONTEXT OF PROJECT PROGRESSION
This ARARs Summary captures the approach and thought process that went into the Identification
and Evaluation of ARARs and reports on the progress of developing the list of ARARs. The A&E Bien
Hoa Contractor was able to find many of the requirements referenced in the Assessment Reports, as
well as a number of other potentially relevant regulations, as indicated in Table 5-1. However, one
challenge encountered during the process of Identification and Evaluation of ARARs was the
unavailability of official English translations of some Vietnamese regulations and standards. The A&E
Bien Hoa Contractor has enlisted a translator to provide English translations of Vietnamese
requirements that were found only in their original version, and the efforts will continue to locate
references to identify and evaluate ARARs and to keep USAID informed of emerging and newly
identified requirements so that they may be evaluated with respect to their relevancy to the Project.
6.1 STAKEHOLDER ENGAGEMENT

As the approved ARARs are a cornerstone of Project development, it was important for all Project
stakeholders to engage at this phase of the Project. Input from stakeholders was received for the
following:
• Masterplan Roadmap Meeting 2 and Draft ARARs Review
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.
• Masterplan Roadmap Meeting 3 Participation
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.
6.2 ARARS REVISIONS

Stakeholder input was collected through email correspondence, as well as discussions during
Meeting 3. The list of ARARs was then updated to reflect stakeholder input and circulated for final
approval as part of the draft and final Implementation Masterplan. Once approved by USAID, the
ARARs will be used by the A&E Bien Hoa Contractor to establish and summarize the aspects of the
Project listed in section 4.2, which include but are not limited to contaminated soil and sediment
cleanup levels and goals and objectives for treatment of soil and sediment.

| 16
As the project proceeds, the Approved ARARs list may continue to evolve as new information arises.
If new site conditions are encountered, the ARARs list will be assessed to determine if new
requirements need to be added. Similarly, if new or amended regulations or standards are
promulgated, the identification and acquisition of these additional requirements will be assessed and
the list updated, as agreed upon by the Project stakeholders.

| 17
ANNEX 6 – SITE CONCEPTUAL MODEL AND DATA GAPS
ANALYSIS

ARCHITECT-ENGINEER SERVICES FOR DIOXIN REMEDIATION
AT BIEN HOA AIRBASE AREA PROJECT
FINAL TECHNICAL MEMORANDUM SITE

CONCEPTUAL MODEL AND DATA
GAPS ANALYSIS
AUGUST 10, 2020

ARCHITECT–ENGINEER SERVICES FOR DIOXIN
REMEDIATION AT BIEN HOA AIRBASE AREA PROJECT
FINAL TECHNICAL
MEMORANDUM SITE CONCEPTUAL
MODEL AND DATA GAP ANALYSIS

AUGUST 10, 2020
PREPARED BY
USA
DISCLAIMER
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
A–E SERVICES FOR DIOXIN REMEDIATION AT BIEN HOA AIRBASE AREA PROJECT | i
FINAL TM SITE CONCEPTUAL MODEL AND DATA GAPS ANALYSIS
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
A–E SERVICES FOR DIOXIN REMEDIATION AT BIEN HOA AIRBASE AREA PROJECT | ii
RECORD OF REVISIONS
PAG SUMMARY OF
REVISION DATE APPROVAL
ES REVISIONS
001 March 6, 2020 All (Revised) Draft TM USAID COR
002 August 10, 2020 All Final TM USAID COR
A–E SERVICES FOR DIOXIN REMEDIATION AT BIEN HOA AIRBASE AREA PROJECT | iii
AMST Academy of Military Science and Technology
ASTM American Society for Testing and Materials
bgs below ground surface
BHL Bien Hung Lake
bw body weight
bw/d body weight per day
cm Centimeter
CIFA Canadian Food Inspection Agency
COC Contaminant of Concern
d Day
DONRE Department of Natural Resources and the Environment
DU Decision Unit
ESS Environmental Scoping Statement
EU European Union
G2L Gate 2 Lake
GIS Geographic Information System
kg kilogram
m3 Cubic Meters
MIS Multi-Increment® Sampling
PAD Project Appraisal Document
Pb Lead
pg pico-gram
ppq parts per quadrillion
QAPP Quality Assurance Project Plan
SAP Sampling and Analysis Plan
SWEMMP Site-wide Environmental Monitoring and Mitigation Plan
A–E SERVICES FOR DIOXIN REMEDIATION AT BIEN HOA AIRBASE AREA PROJECT | iv
TDS Total Dissolved Solids
ug/L micrograms per liter
UNDP United Nations Developmental Programme
US United States
A–E SERVICES FOR DIOXIN REMEDIATION AT BIEN HOA AIRBASE AREA PROJECT | v
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
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).
• Dioxin exposure routes are identified as dietary exposure/ingestion, inhalation of fugitive

airborne particulate (dust), dermal absorption (direct contact), and soil/sediment ingestion.
• Dietary exposure/ingestion of contaminated food sources is the most significant exposure

route due to the bioaccumulation and biomagnification of dioxin in a variety of foods.
• Sensitive receptors are identified as off-Airbase adults/children, on-Airbase personnel, on-

Airbase residents, terrestrial animals, and aquatic animals. The greatest exposures have been
document in those with the longest residency with long-term/chronic exposure to food or
activities involving dermal contact (e.g., long-term residents engaging in these behaviors and
certain types of non-human organisms with the highest sensitivity (bottom feeding fish, soil
eating chickens)).
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:
• Physical and basic chemical properties of soils and sediments;
• Groundwater/aquifer characteristics;
• Topography at a scale to design excavations;
• 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;
• Nature and extent of arsenic contamination in soils and sediments;
• 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
• Subsurface utilities and structure locations.
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.
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:
• Summarize existing site data (Section 2);
• 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.
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.
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).
3.1 SITE DEFINITION AND SETTING

The Bien Hoa Airbase is 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. The
surrounding Wards are densely populated, with most of the land used for private residences,
commercial and industrial facilities, and the associated transportation infrastructure. Areas not
occupied by residential communities or urban infrastructure are used for the raising of livestock
(e.g., chickens), aquaculture (fish, ducks), and/or cultivation of foods and products for sale (e.g.,
vegetables, rubber trees). Bien Hoa City has a population of approximately 1.35M person (Dong
Nai Statistical Office 2019). The Bien Hoa Airbase 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. Figure 1 shows the Bien Hoa Airbase and proximity to the surrounding population. It
also identifies the eight main areas of the Airbase.
ADAFC reports a working population of up to 2,200 persons on the Airbase, including

approximately 1,200 persons residing on the Airbase (GVN/USAID 2016). The Bien Hoa Airbase
is an active airbase with ADAFC military training activities and operations being conducted. In
addition to military 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).
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/)
FIGURE 1 BIEN HOA AIRBASE AREA
FIGURE 2 BIEN HOA AIRBASE AREA 2009 TOPOGRAPHY AND DRAINAGE AREAS
FIGURE 3 HISTORICAL 1968 TOPOGRAPHIC AND INFRASTRUCTURE MAP
3.2 SOURCES OF CONTAMINATION AND DISTRIBUTION
3.2.1 DIOXIN AS A CONTAMINANT
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).
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.
The EA identified three known dioxin source areas on the Airbase.
• 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.
FIGURE 4 IDENTIFIED DECISION UNITS WITH LAND USE
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
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).
3.2.5 DRINKING WATER SAMPLING RESULTS
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.
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.
3.2.7 DONRE OFF-AIRBASE SAMPLING PROGRAM RESULTS
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:
1. DONRE-A1: An total area of approximately 36,824 m2 of contaminated soils (reported with

a maximum of 4,992 ppt dioxin in soils), excluding the area of the Airbase, occupied by 75
households (residences) in Buu Log Ward, referred to by DONRE as “Residential Area 5.”
Sampling was conducted in select locations within the larger area;
FIGURE 5 DONRE OFF-AIRBASE SAMPLING AND RESULTS
(FINAL TM SITE CONCEPTUAL MODEL AND DATA GAPS ANALYSIS
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).
3.2.8 CONTAMINATION SUMMARY AND INITIAL RECOMMENDATIONS
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.
FIGURE 6 DONRE OFF-AIRBASE AREAS IDENTIFIED WITH ELEVATED DIOXIN CONCENTRATIONS
FIGURE 7 SURFACE DIOXIN CONCENTRATIONS AT BIEN HOA AIRBASE AREA
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.
3.3 MIGRATION PATHWAYS AND EXPOSURE ROUTES

Migration pathways and exposure routes for dioxin in contaminated soils and sediments at Bien
Hoa Airbase (secondary sources) are well documented in available data and information resulting
from past GVN, USAID, and other organizations efforts.
3.3.1 MIGRATION PATHWAYS
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
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.
3.3.2 EXPOSURE ROUTES
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.
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
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).
3.4 SENSITIVE RECEPTORS

A receptor is an ecological entity exposed to the contaminant. Receptors include human
receptors (adults, children, and elderly) and ecological receptors (any living organism other than
humans). Adverse effects of dioxin exposure have been established following releases of dioxins
into human and natural environments or food supplies (Birnbaum 1994). In addition, studies of
wildlife, as well as domestic and laboratory animals, have furthered the understanding of potential
adverse outcomes of exposure (Birnbaum 1994).
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.
3.4.1 OFF-AIRBASE ADULTS (PARTICULARLY WOMEN OF CHILD-BEARING AGE) AND

CHILDREN.
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
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).
3.4.2 ON-AIRBASE PERSONNEL AND ON-AIRBASE RESIDENTS.
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).
3.4.3 REMEDIAL WORKERS
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.
3.4.4 TERRESTRIAL AND AQUATIC ANIMALS.
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.
concentrations. Consumption of these organisms leads to biomagnification and represents a
significant human exposure pathway for dioxin.

In summary, past storage, handling, and disposal activities have resulted in contaminated soils and
sediments which have become secondary source of dioxin exposure at the Airbase. Based on
historical and recent sampling efforts, dioxin concentrations exceeding GVN-approved land use
standards for dioxin limits were observed in soil and sediment samples at the Z1 Area, Southwest
Area, and Pacer Ivy Area, and other areas to a lesser extent.
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.
RELEASE AND RECEPTORS
EXPOSURE
TRANSPORT PATHWAYS
MECHANISMS
Surface Water Contact with
Runoff / Contaminated
Erosion Surface Water
Wind Erosion / Contact with

DIOXIN
SOURCES IN Atmospheric Airborne
Deposition Particles / Dust
Soil
Bioaccumulation Consumption of
in Terrestrial / Contaminated
Aquatic Animals Food
Disturbance / Contact with

Excavation / Soil Particles
Movement of Soils
Surface Water Contact with

Runoff / Contaminated
Erosion Surface Water
Sediment
Bioaccumulation Consumption of
in Terrestrial / Contaminated
Aquatic Animals Food
Flow / Consumption of
Groundwater Movement of Contaminated
Groundwater Drinking Water
KEY
– Significant exposure pathway
– Insignificant exposure pathway
– Incomplete exposure pathway
FIGURE 8 DIAGRAM FOR SITE CONCEPTUAL MODEL
FIGURE 9 ILLUSTRATIVE SITE CONCEPTUAL MODEL
TABLE 1 SUMMARY OF BIEN HOA AIRBASE SCM ELEMENTS
KEY SITE DEFINITION AND SIGNIFICANT DIOXIN IDENTIFIED DIOXIN POTENTIAL

SETTING CHARACTERISTICS MIGRATION PATHWAYS EXPOSURE ROUTES RECEPTORS
Pacer Ivy and Z1 areas are Storm Water Runoff Dietary Exposure / Off-Airbase Adults and
significant secondary sources Ingestion Children (particularly near
Pacer Ivy)
Multiple drainage pathways Surface Water Flow Inhalation of Fugitive On-Airbase Personnel
from Pacer Ivy to Airborne Particulates
residential areas
Off base contamination is mostly Wind Erosion and Dermal Absorption On-Airbase Residents
adjacent to Pacer Ivy Deposition
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.
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.
4.1 ORGANIZATION OF IDENTIFIED DATA GAPS

Data gaps identified via the analysis were organized into categories related to the four major
elements of the SCM to provide decision makers with a better understanding of the value of
addressing the data gaps. An additional category ‘Other’ was used to group data gaps that are
considered outside of the four SCM categories but relevant to completion of the Project, (e.g.,
utility locations).
• Site Definition and Setting

• Sources of Contamination and Distribution
• Migration Pathways and Exposure Routes
• Receptors
• Other (Excavation Planning, Containment System Design, Technology Evaluation)
4.2 DETERMINATION OF CRITICALITY

A determination was made as to which data gaps are considered to be ‘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.
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)?
• 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?
4.3 RECOMMENDATIONS FOR RESOLUTION

Recommendations are made for site investigation (SI) and other evaluation activities to resolve
the critical data gaps. Some recommended SI and evaluation activities, in part or in whole, have
been initiated by the A&E Bien Hoa Contractor. When this is the case, it is indicated in the table
under the “Recommended SI and Evaluation Activities” column. Table 2 identifies those data gaps
determined to be critical and briefly describes the recommended SI and evaluation activity to
resolve each of the identified critical data gaps. All the recommended activities are dependent on
completing UXO clearance on and off the Airbase.
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
SCM
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 Containment Structure
SCM
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
√ 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
SCM
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
√ 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
SCM
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.
√ 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:
√ Health and Safety of Site Workers
√ Design of LTSA Containment Structure
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.

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
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).
• Dioxin exposure routes are identified as dietary exposure/ingestion, inhalation of fugitive

airborne particulate (dust), dermal absorption (direct contact), and soil/sediment ingestion.
• Dietary exposure/ingestion of contaminated food sources is the most significant exposure

route due to the bioaccumulation and biomagnification of dioxin in a variety of foods.
• Sensitive receptors are identified as off-Airbase adults/children, on-Airbase personnel, on-

Airbase residents, terrestrial animals, and aquatic animals. The greatest exposures have been
document in those with the longest residency with long-term/chronic exposure to food or
activities involving dermal contact (e.g., long-term residents engaging in these behaviors and
certain types of non-human organisms with the highest sensitivity (bottom feeding fish, soil
eating chickens)).
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.
5.2 CRITICAL DATA GAPS

Data gaps in available data and information guided by the SCM that were determined to be critical
and recommended for resolution are found in Table 2. These should be addressed early in
Masterplan implementation and include:
• Physical and basic chemical properties of soils and sediments;
• Groundwater/aquifer characteristics;
• Topography at a scale to design excavations;
• 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;
• Nature and extent of arsenic contamination in soils and sediments;
• 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
• Subsurface utilities and structure locations.
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.
5.3 NEXT ACTIONS FOR CRITICAL DATA GAP RESOLUTION

The appropriate USAID, GVN, and other Stakeholders need be engaged to review the critical
data gaps and recommended SI and evaluation activities. Priority should be given to those data
gaps determined to be critical for the more near-term Project activities, i.e., land area turnover,
establishing baselines, evaluation of remedial alternatives, design of treatment and containment
systems, and excavation planning. With respect to the resolution of critical data gaps, it is
expected that SI and Evaluation Workplan(s) would be developed by the A&E Bien Hoa
Contractor as appropriate to these data gap(s) providing a detailed approach and timeline for
resolving the data gap(s). 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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in breast milk in a hot spot of dioxin contamination in Vietnam.
Nguyen XQ, Ngo XN, Hoang QK, Nquyen QH, Nguyen TB, and Nguyen TD. 2005. Assessment
of Biodiversity and Water Quality of the Bien Hung Lake, Dong Nai Province.
Office 701. 2018. Establishing of Office of the Standing Board of National Steering Committee on
Overcoming Post-war Consequences of Unexploded Ordnance and Toxic Chemicals in Vietnam.
QCVN. 2012. QCVN 45:2012, National technical regulation on allowed limits of dioxin in soils.
QCVN. 2017. QCVN 43:2017/BTNMT National technical regulation on quality of sediment.
World Bank. 2011. Vietnam Country Gender Assessment.
World Health Organization. 2010. Exposure to Dioxins and Dioxin-like Substances a Major Public
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.
ANNEX 7 – BASELINE RISK ASSESSMENT

FINAL TECHNICAL MEMORANDUM

AUGUST 10, 2020



AUGUST 10, 2020
PREPARED BY
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
4.4 PCB 1260 21
4.5 LEAD 22
FINAL TECHNICAL MEMORANDUM BASELINE RISK ASSESSMENT
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
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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ADAFC Air Defense - Air Force Command
ADD Average daily dose
As Arsenic
ATSDR Agency for Toxic Substances and Disease Registry
BW Body weight
cm Centimeter
CSF Cancer Slope Factor
d Day
DU Decision Unit
EC Exposure concentration
EFH Exposure Factors Handbook
EPC Exposure Point Concentration
EU European Union
EVSA Excess Volume Stockpile Area
g gram
G2L Gate 2 Lake
GIS Geographic Information System
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
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
SA Skin surface area
SAF Soil adherence factor
TCDD 2,3,7,8-Tetrachlorodibenzo-p-dioxin
TCDF 2,3,7,8-Tetrachlorodibenzofuran
TDI Tolerable Daily Intake
TEF Toxic Equivalency Factor
UCL Upper confidence limit
ug/L micrograms per liter
UNDP United Nations Development Programme
US United States
VEA Vietnam Environment Administration
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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).
SELECTION OF CHEMICALS OF POTENTIAL CONCERN (COPC)
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.
POTENTIAL EXPOSED POPULATIONS
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.
RESULTS & CONCLUSIONS
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.
The purpose of this TM BRA is to:
• 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).
2 SITE BACKGROUND
2.1 GENERAL DESCRIPTION AIRBASE AND SURROUNDING AREA

The Bien Hoa Airbase is located in Bien Hoa City, Dong Nai Province. 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. The surrounding Wards are densely populated, with most of the land used for private residences,
commercial and industrial facilities, and the associated transportation infrastructure. As of 2018, the
province had an average population of approximately three million people, with a population density of
approximately 526 people per km2 (GSO 2018). Bien Hoa city is characterized by industrial activity,
rapid urbanization, and reduced land allocation for agricultural uses (GVN/USAID 2016).
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).
2.2 SUMMARY OF HISTORICAL CONTAMINATION AT SITE
2.2.1 USE OF AGENTS ORANGE, WHITE, AND BLUE

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. Agents Pink, Green, Purple, and Orange all contained 2,4,5-trichlorophenoxyacetic acid, or
2,4,5-T, in their formulations and were all contaminated to some extent with 2,3,7,8-tetrachlorodibenzo-
p-dioxin, or TCDD, which was formed during the manufacture of 2,4,5-T (IOM 2014). Agent Blue
contained cacodylic acid, and organic arsenic compound (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/USAID 2016).
Approximately 4.4 million gallons of Agent Orange, 2.1 million gallons of Agent White, and 720,000
gallons of Agent White were stored in tanks on the Bien Hoa Airbase, and it was reported that other
Ranch Hand herbicides were used on the Airbase (GVN/USAID 2016). In 1971, all remaining Agent
Orange and Ranch Hand-related material from South Vietnam, including Bien Hoa Airbase, was
consolidated, re-drummed, and sent to Johnston Atoll in the central Pacific Ocean (Young 2009).
FIGURE 2-1 BIEN HOA AIRBASE AREA
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.
Additional information on select past study methods is available in Section 3.1.
2.3 ENVIRONMENTAL STANDARDS FOR PCDD/FS

A number of international bodies have established guidelines, limits, or recommendations for dioxins in
environmental media, including soil. Vietnam has established two major regulations pertaining to dioxins in
soil and sediment – TCVN 8183:2009 and QCVN 45:2012/BTNMT.
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.
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
ZI-2; ZI-3; ZI-5; ZI-6; Z1-7; Z1-8; Z1-11; Z1-13; Z1-16

SW-1; SW-2; SW-3; SW-4; SW-6; SW-7; SW-8
Urban Residential 300
PI-10; PI-11; PI-12; PI-13; PI-14
Soil SE-1; SE-2
ZI-1; ZI-4; ZI-12; ZI-17

ZT-1; ZT-2; ZT-3; ZT-4; ZT-5; ZT-6; ZT-7
Industrial 1200
PI-1; PI-2; PI-3; PI-4; PI-5; PI-6; PI-7; PI-8; PI-9
NE-1; NE-2; NE-3; NE-4; NE-5
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
FIGURE 2-2 LAND USE AT BIEN HOA AIRBASE AREA
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.
2.5 CURRENT AREAS OF CONTAMINATION

The Dong Nai Department of Natural Resources and the Environment (DONRE) conducted dioxin
monitoring for soil, sediments, and groundwater at several locations around the Airbase between 2005 and
2016 and shared their results to ADAFC in 2019. Three additional off-Airbase areas with elevated dioxin
concentrations in soils and sediments were identified as follows:
• DONRE-A1 – An total area of approximately 36,824 m2 of contaminated soils (reported with a

maximum of 4,992 ppt dioxin in soils), excluding the area of the Airbase, occupied by 75 households
(residences) in Buu Log Ward, referred to by DONRE as “Residential Area 5.” Sampling was conducted
in select locations within the larger area;
• 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.
FIGURE 2-3 SURFACE DIOXIN CONCENTRATIONS AT THE BIEN HOA AIRBASE AREA
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.
3.1 AVAILABLE DATA SETS

For this risk assessment, data from several different data sets from multiple sampling programs consisting
of soil, sediment, groundwater, biota tissue, and breast milk data were reviewed; these data sources,
used to evaluate potential exposures, are summarized and described below. Results of dioxin analyses
for all of the studies discussed below were reported in TEQ, characterized by WHO TEFs as described
by Van den Berg et al. (2006) (Van den Berg, Birnbaum et al. 2006, GVN/USAID 2016). A summary of
each data set with respect to the number of samples collected from each site area and environmental
media, the analysis method used for dioxins/furan, and a general description of the sampling methodology
is presented in Appendix A, Table A-1.
3.1.1 HATFIELD AND 10-80 DIVISION (2006)

In January of 2006, Hatfield Consultants (Hatfield) and the Vietnam Ministry of Health (10-80 Division)
reported the results of an investigation of Agent Orange/dioxin soil and sediment hot spots in southern
Vietnam (Hatfield and 10-80 Division 2006). Phase I of the study identified potentially contaminated sites
with the potential to pose a risk to human health, and Phase II of the study confirmed Phase I sites
through field sampling. Overall, 36 samples were taken at the Bien Hoa Airbase between March 29 and
April 1, 2005, though some initial sampling took place in March of 2004 (Hatfield and 10-80 Division
2006).
3.1.2 HATFIELD AND VRTC (2009)

In June of 2009, Hatfield Consultants and the Vietnam-Russia Tropical Center (VRTC) reported the
results of an investigation of soil and sediment aimed at assessing the impacts of dioxin on human and
ecological health to support clean-up and capacity building activities (Hatfield and VRTC 2009).
3.1.3 HATFIELD AND OFFICE 33 (2011)

In August of 2011, Hatfield Consultants and the Office of the National Steering Committee 33 of
Vietnam’s Ministry of Natural Resources and Environment (Office 33) reported the findings of an
environmental and human health assessment of dioxin contamination at Bien Hoa Airbase, which
consisted of the re-publication of two Hatfield studies led by the 10-80 Division of Vietnam’s Ministry
of Health in 2004-2005 and Vietnam-Russia Tropical Centre of the Ministry of National Defense in 2008,
as well as the results of a 2010 study implemented by Office 33 (Hatfield and Office 33 2011). Included
in the report are the results of a soil, sediment, and biota sampling scheme. Details on how these samples
were collected and analyzed are presented in the Hatfield and Office 33 (2011) report.
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
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).
3.1.4 VEA AND MONRE (2012)

At the time of assessment, the full Vietnam Environmental Agency (VEA) and Ministry of Natural
Resources and Environment (MONRE) report, A preliminary report on additional assessment on dioxin
contamination at new AO/Dioxin contaminated areas in Bien Hoa and Phu Cat Airbase (VEA and MONRE
2012), was not available in English. Therefore, these data are reported based on the summary in
Environmental Assessment of Dioxin Contamination at Bien Hoa Airbase, which reported select results from
the VEA and MONRE sampling scheme.
3.1.5 VRTC (2013A,B)

At the time of assessment, the full VRTC reports, Analysis Results Identifying the concentration of toxic
substance of PCDD/PCDF and dl-PCB in samples (Annex 1 contract HĐ-BQLDA/2012/30) (VRTC
2013) and Analysis Results Identifying the concentration of toxic substance of PCDD/PCDF in samples
(VRTC 2013), were not available in English. Data from these reports were not included in summary data
tables characterizing dioxin contamination in the Environmental Assessment of Dioxin Contamination
at Bien Hoa Airbase report (GVN/USAID 2016) and were therefore not incorporated in this assessment.
3.1.6 DEKONTA (2014)

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).
3.1.7 TUYET-HAHN ET AL. (2015)

Tuyet-Hanh et al. (2015) assessed the health risk of exposure to dioxin/furans through foods for local
residents living in seven wards surrounding Bien Hoa and Da Nang airbases – Trung Dung, Tan Phong,
and Buu Long wards in Bien Hoa City, as well as An Khe, Hoa Khe, Chinh Gian and Thanh Khe Tay
wards in Da Nang City (Tuyet-Hanh, Minh et al. 2015). Regarding Bien Hoa, food samples were collected
from households in the three wards, a Tan Phong local market located between Tan Phong and Trung
Dung, a Trung Dung local market, Gate 2 Lake and Bien Hung Lake located near Trung Dung, and Dau
Lake and two markets located between Buu Long and the Dong Nai River (Tuyet-Hanh, Minh et al.
2015). In 2013 food samples were collected and a food frequency survey was administered (Tuyet-Hanh,
Minh et al. 2015).
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
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).
Seventeen 2,3,7,8-substituted PCDD/Fs congeners were quantified using mass spectrometry/gas

chromatography; results were reported as total TEQ, which was calculated using WHO TEFs as
described by Van den Berg et al. (2006) (Van den Berg, Birnbaum et al. 2006, Tuyet-Hanh, Minh et al.
2015).
3.1.8 GVN/USAID (2016)

The GVN and USAID completed Environmental Assessment of Dioxin Contamination at Bien Hoa Airbase in
May 2016 (GVN/USAID 2016) to meet the requirements of Title 22 of the U.S. Code of Federal
Regulations, Part 216. Samples were collected November through December 2014 as well as March
through April 2015 using a comprehensive sampling methodology known as multi-increment sampling
(MIS) (GVN/USAID 2016). A total of more than 1,400 samples were collected, which included more
than 1,300 composite soil and sediment samples for potential dioxin analysis and 100 samples of soil,
sediment, groundwater, and biota for various chemical and/or physical property testing (GVN/USAID
2016). Over 700 samples of soil, sediment, groundwater, and biota were analyzed (GVN/USAID 2016).
It was not specified how TEQ was calculated.
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).
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.
3.2 SELECTION OF CHEMICALS OF POTENTIAL CONCERN

Baseline risk assessments assess potential impacts to human health prior to or in absence of remedial
action. The purpose of this section is to streamline and identify chemicals that may pose harm to human
health, in lieu of evaluating all chemicals detected at or near the Airbase.
3.2.1 IDENTIFICATION OF CHEMICALS OF POTENTIAL CONCERN IN SOIL AND SEDIMENT

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 toxicity (USEPA 1989). Chemicals detected in soil and
sediment in each area were screened as follows:
• 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.
3.2.2 IDENTIFICATION OF CHEMICALS OF POTENTIAL CONCERN IN GROUNDWATER

Maximum concentrations of chemicals in groundwater were compared to USEPA MCLs. If an MCL did
not exist for a chemical, the maximum concentration was compared to the USEPA Residential Tap
Water RSL. Any chemical that exceeded its respective screening level was automatically considered a
Chemical of Concern and will be further considered in the BRA. Based on this the only COPCs in
groundwater are dioxins/furans and lead.
3.3 DATA SUMMARY

Soil, sediment, biota, diet, and groundwater data were tabulated and summary statistics developed for
each analyte including the minimum and maximum detected values, the arithmetic mean, and the
frequency of detection. For soil, data were summarized in the following three depth groupings, which
are based on potential exposures of the receptors identified in the Exposure Assessment: 1) surface soil,
2) subsurface soil, and 3) all soil. The results of the data summarization are provided in Table 3-1 for
dioxins/furans and in Table 3-2 for other confirmed COPCs.
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
Soil 28 100% 238 0.8 3440 ppt TEQ 22 ppt

ZT Area
Groundwater 1 100% 0.8 0.8 0.8 pg/L TEQ 30 pg/L
Soil 128 100% 135 0.7 1510 ppt TEQ 22 ppt
Z1 Area Sediment 6 100% 739 245 1579 ppt TEQ 22 ppt
Soil 65 100% 4325 6.8 111000 ppt TEQ 22 ppt

Southwest Area
Groundwater 1 100% 18 18 18 pg/L TEQ 30 pg/L
Southeast Area Soil 4 100% 41.9 31.8 64.5 ppt TEQ 22 ppt
Soil 97 100% 786 0.8 11400 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
Soil 16 100% 384 3.8 1020 ppt TEQ 22 ppt

Northeast Area
Sediment 45 100% 171 9.8 1300 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
Bien Hung Lake Area Sediment 1 100% 83 83 83 ppt TEQ 22 ppt

a Bolded values indicate RSL or MCL exceedance
TABLE 3-2 DATA SUMMARY FOR OTHER COPCS
DETECTION MEAN MINIMUM MAXIMUM CONCENTRATION INDUSTRIAL RSL /

COPC AREA MEDIUM
FREQUENCY CONCENTRATION CONCENTRATION CONCENTRATIONA UNIT USEPA MCL
Groundwater 100% 0.36 0.36 0.36 µg/L 10 µg/L

ZT Area
Soil 100% 3.7 3.7 3.7 mg/kg 3 mg/kg
Soil 100% 11.02 3.6 29 mg/kg 3 mg/kg
Z1 Area Sediment 100% 15 15 15 mg/kg 3 mg/kg
Southwest Soil 100% 15.4 6.2 25 mg/kg 3 mg/kg

Area Groundwater 100% 5 5 5 µg/L 10 µg/L
Soil 100% 20.77 3.7 63 mg/kg 3 mg/kg
Pacer Ivy
Arsenic Sediment 100% 20 20 20 mg/kg 3 mg/kg
Area
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
ZT Area Soil 100% 5.2 5.2 5.2 mg/kg 800 mg/kg

Soil 100% 13.53 9.5 30 mg/kg 800 mg/kg
Z1 Area Sediment 100% 17 17 17 mg/kg 800 mg/kg
Lead Groundwater - 0.16 0.16 0.16 µg/L 15 µg/L
Southwest Soil 100% 39.33 35 46 mg/kg 800 mg/kg

Area Groundwater - 32.46 0.121 64.8 µg/L 15 µg/L
Soil 100% 30.94 6.6 95 mg/kg 800 mg/kg
DETECTION MEAN MINIMUM MAXIMUM CONCENTRATION INDUSTRIAL RSL /
COPC AREA MEDIUM
FREQUENCY CONCENTRATION CONCENTRATION CONCENTRATIONA UNIT USEPA MCL
Pacer Ivy Sediment 100% 57 57 57 mg/kg 800 mg/kg

Area Groundwater - 21.31 21.31 21.31 µg/L 15 µg/L
Northeast
Soil 100% 16 16 16 mg/kg 800 mg/kg
Area
Gate 2
Lake
Bien Hung
Lake
a Bolded values indicate RSL or MCL exceedance
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.
4.1 HIERARCHY FOR SELECTING TOXICOLOGICAL CRITERIA

In accordance with recommendations outlined by USEPA (2003), the following hierarchy of sources was
considered in selecting toxicological criteria for this BRA:
• Tier 1: USEPA’s IRIS

• Tier 2: USEPA’s Provisional Peer Reviewed Toxicity Values (PPRTVs) from the Office of Research
and Development/National Center for Environmental Assessment/Superfund Health Risk Technical
Support Center
• Tier 3: Other Toxicity Values, including USEPA and non-USEPA sources. Such sources include the
Agency for Toxic Substances and Disease Registry (ATSDR) minimal risk levels, USEPA’s Health
Effects Assessment Summary Tables, California Environmental Protection Agency values, and other
sources that are current, transparent and publicly available, and have been peer reviewed.
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).
4.2.1 NONCARCINOGENIC EFFECTS

4.2.1.1 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
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 CARCINOGENIC EFFECTS

Under standard USEPA risk assessment procedures, toxicological criteria derivation and selection reflect
the conservative assumption that there is no threshold dose for carcinogenic effects; however, it has
been recognized that some carcinogens follow a nonlinear, threshold response in which a level of
exposure exists at which there is no increased risk of cancer within the exposed population (USEPA
1989, USEPA 2005).
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
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.

4.3.1.1 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 three 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).
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).

4.3.2.1 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).
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
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 PCB 1260

Polychlorinated biphenyls, or PCBs, are a class of synthetic organic compounds in which two to ten
chlorine atoms are attached to a biphenyl molecule (ATSDR 2000). PCBs were produced commercially
and marketed worldwide for use in closed and open-end applications (ATSDR 2000). Many commercial
PCB mixtures are known by a trade name, Aroclor, and have a distinguishing suffix number which
identifies the degree of chlorination. For example, Aroclor 1260 indicates that the PCB mixture contains
approximately 60% chlorine by weight.

4.4.1.1 ORAL
IRIS provides a chronic 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 1260 as it is highly
chlorinated and is therefore likely to have comparable toxicity. This value was derived from a study on
female rhesus monkeys, which identified a LOAEL of 5 x 10-3 mg/kg-day based on eye exudate,
inflammation and/or prominence of the eyelid Meibomian glands, and particular changes in finger and
toe nails (Tryphonas, Hayward et al. 1989, Tryphonas, Luster et al. 1991a, Tryphonas, Luster et al.
1991b, Arnold, Bryce et al. 1993a, Arnold, Bryce et al. 1993b, USEPA 1994). A cumulative uncertainty
factor of 300 was applied to the data, including a factor of three to adjust from subchronic to chronic
exposure (USEPA 1994). Therefore, removing the UF of three yields a subchronic reference dose of 6
x 10-5 mg/kg-day.
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.

4.4.2.1 ORAL
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, derived from laboratory studies which identified
liver cancers in rats exposed to PCB mixtures; the slope factor selected is based on data for Aroclors
1254 and 1260 (Brunner, Sullivan et al. 1996, USEPA 1996). Following EPA recommendation, the highest
of these CSFs, rounded to two (mg/kg-day)–1, was selected as the upper-bound CSF for evaluating food-
chain exposures, sediment or soil ingestion, and dermal contact exposures associated with high risk and
high persistence PCBs (USEPA 1996).
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.
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).
4.6 SUMMARY OF TOXICOLOGICAL CRITERIA

A summary of cancer toxicological criteria for all COPCs is provided in Table 4-1.
TABLE 4-1 CANCER TOXICOLOGICAL CRITERIA
COPC VALUE UNIT VALUE TYPE SOURCE TIER
2.3 pg/kg-bw/day Provisional Tolerable Daily Intake JECFA 3
2,3,7,8-TCDD (mg/kg-day)-1 Oral Cancer Slope Factor OEHHA 3

130,000
38 (µg/m3)-1 Inhalation Unit Risk OEHHA 3
1.5 (mg/kg-day)-1 Oral Cancer Slope Factor IRIS 1

Arsenic (inorganic)
0.0043 (µg/m3)-1 Inhalation Unit Risk IRIS 1
2 (mg/kg-day)-1 Oral Cancer Slope Factor IRIS 1

PCB 1260
2 (mg/kg-day)-1 Inhalation Slope Factor IRIS 1
A summary of noncancer toxicological criteria for all COPCs is provided in Table 4-2.
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
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.
5.1 EXPOSURE SCENARIOS

One potential exposure scenario was explored for the risk assessment characterizing current Airbase
settings:
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.
5.2 POTENTIALLY EXPOSED POPULATIONS

Multiple potential receptor groups were assumed for this risk assessment, preliminarily identified in the
site conceptual site model (SCM). It is important to note that the identified receptors are hypothetical,
and represent segments of the target population, rather than actual people.
• 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.
5.3 EXPOSURE PATHWAYS
The potentially exposed populations and exposure pathways are summarized in Table 5-1 and
described below.
5.3.1 DIRECT CONTACT EXPOSURE TO SOIL/SEDIMENT

Direct contact exposure to soil and sediment can occur through ingestion, dermal contact, particulate
inhalation, and inhalation of air emissions from treatment.
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.
5.3.2 EXPOSURE TO GROUNDWATER

COPCs present in groundwater can result in exposure to human receptors via direct ingestion. Ingestion
of groundwater represents an exposure pathway for any persons ingesting groundwater from the
Airbase, including local residents and resident Airbase personnel and families.
5.3.3 INDIRECT/DIETARY EXPOSURE

COPC exposure occurs to human receptors via ingestion of contaminated food sources. Given the
difficulties of enforcing aquaculture bans, it is likely that dietary exposure/ingestion has resulted in
significant COPC exposure 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 2011,
GVN/USAID 2016). These studies confirmed that an important exposure route for dioxin was through
consumption of fish and other aquatic organisms on the Airbase and the surrounding area.
5.3.4 INFANT INGESTION OF BREAST MILK

COPCs may be transferred from mother to infant via breastfeeding. 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 2011). These results confirmed that an important exposure route for
dioxin was through consumption of breastmilk from lactating women on the Airbase and the surrounding
area.
TABLE 5-1 IDENTIFICATION OF POTENTIALLY EXPOSED POPULATIONS AND PATHWAYS
POTENTIALLY EXPOSED POPULATIONS EXPOSURE MEDIA POTENTIAL EXPOSURE PATHWAY
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
Surface Soil Soil Ingestion
(0-1 ft BGS) Dermal Contact with Soil

Current and Future Nonresident Airbase
Personnel (adult, >18 years) Particulate Inhalation
Sediment Ingestion
Sediment
Dermal Contact with Sediment
Groundwater Groundwater Ingestion
5.4 EXPOSURE CALCULATIONS
5.4.1 EXPOSURE POINT CONCENTRATIONS

Overall, the exposure point concentration (EPCs) 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 DU
then the maximum concentration was used. Also, if the sample size for the data set was less than three,
the maximum concentration was also used. For values reported below the limit of detection, one half
of the detection limit was used.
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.
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:
EPCair = 95% UCL soil concentration X PEF
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.
5.4.1.5 BREAST MILK

The 95% UCLs were calculated from the breast milk data presented in Hatfield and Office 33 (2011)
using the USEPA (2016) program ProUCL 5.1.
5.4.2 DOSE EQUATIONS

5.4.2.1 DIRECT CONTACT EXPOSURE
Direct contact exposure can occur through soil/sediment dermal contact, soil/sediment ingestion,
groundwater ingestion, dermal contact with groundwater, particulate inhalation, incidental surface water
ingestion, and dermal contact with surface water.
Soil/sediment dermal contact was quantified according to the following equation:
𝑬𝑬𝑬𝑬𝑬𝑬𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔/𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔 × 𝑪𝑪𝑪𝑪 × 𝑬𝑬𝑬𝑬 × 𝑬𝑬𝑬𝑬 × 𝑨𝑨𝑨𝑨 × 𝑺𝑺𝑺𝑺 × 𝑨𝑨𝑨𝑨𝑨𝑨

𝑨𝑨𝑨𝑨𝑨𝑨/𝑳𝑳𝑳𝑳𝑳𝑳𝑳𝑳 =
𝑩𝑩𝑩𝑩 × 𝑨𝑨𝑨𝑨
Where:
ADD = Average Daily Doses for non-carcinogens (milligram per kilogram per day,
mg/kg-day)
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)
Soil/sediment ingestion was quantified according to the following equation:
𝑬𝑬𝑬𝑬𝑬𝑬𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔/𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔 × 𝑪𝑪𝑪𝑪 × 𝑬𝑬𝑬𝑬 × 𝑬𝑬𝑬𝑬 × 𝑰𝑰𝑰𝑰

Where:
ADD = Average Daily Doses for non-carcinogens (mg/kg-day)
EPCsoil/sediment = Exposure point concentration for COPC in soil or sediment (mg/kg)
CF = Conversion factor (10-6 kg/mg)
IR = Soil ingestion rate (mg/day)
Groundwater ingestion was quantified according to the following equation:
𝑬𝑬𝑬𝑬𝑬𝑬𝒈𝒈𝒈𝒈𝒈𝒈𝒈𝒈𝒈𝒈𝒈𝒈𝒈𝒈𝒈𝒈𝒈𝒈𝒈𝒈𝒈𝒈 × 𝑬𝑬𝑬𝑬 × 𝑬𝑬𝑬𝑬 × 𝑰𝑰𝑰𝑰

Where:
EPCgroundwater = Exposure point concentration for COPC in groundwater (mg/L)
IR = Groundwater ingestion rate (L/day)
Dermal contact with groundwater was quantified according to the following equation:
𝑫𝑫𝑫𝑫𝒆𝒆𝒆𝒆𝒆𝒆𝒆𝒆𝒆𝒆 × 𝑬𝑬𝑬𝑬 × 𝑬𝑬𝑬𝑬 × 𝑬𝑬𝑬𝑬 × 𝑺𝑺𝑺𝑺

Where:
DAevent = Dermally Absorbed Dose per event (mg/cm2-event)
EV = Events per day (events/day)
SA = Skin Surface Area (cm2)
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:
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)
Particulate inhalation exposure concentrations for non-carcinogenic chemicals (ECnc) and

exposure concentrations for carcinogenic chemicals (ECc) were calculated as follows since for the
inhalation pathway, a “dose” is not calculated per se. Rather, an exposure concentration (EC) is
calculated that represents a time-weighted average (TWA) concentration derived from a measured
or modeled exposure point concentration (EPC) in air that has been adjusted based on the
characteristics of the exposure scenario being evaluated (USEPA 2009).
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)
EF = Exposure frequency for inhalation (days/year)
ET = Exposure time (hours/day)
AT = Averaging time for carcinogens (number of hours in 70 years)
Incidental surface water ingestion, during swimming or wading, was quantified according to the
following equation:
𝑬𝑬𝑬𝑬𝑬𝑬𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔 × 𝑬𝑬𝑬𝑬 × 𝑬𝑬𝑬𝑬 × 𝑬𝑬𝑬𝑬 × 𝑰𝑰𝑰𝑰

Where:
ET = Exposure time (hrs/day)
IR = Surface water ingestion rate (L/hr)
Dermal contact with surface water, during swimming or wading, was quantified according to the
following equation:

Where:
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:
ET = Exposure Time (hrs/event)
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:
𝑬𝑬𝑬𝑬𝑬𝑬𝑫𝑫𝑫𝑫𝑫𝑫𝑫𝑫 × 𝑪𝑪𝑪𝑪 × 𝑬𝑬𝑬𝑬 × 𝑬𝑬𝑬𝑬 × 𝑰𝑰𝑰𝑰 × 𝑭𝑭𝑭𝑭

Where:
EPCDiet = Exposure point concentration for COPC in diet (mg/kg)
CF = Conversion factor (0.001 kg/g)
IR = Dietary ingestion rate for the food item (gram per day [g/day])
FI = Fraction ingested (0 to 1, unit less)
5.4.2.3 INFANT INGESTION OF BREAST MILK

Infant ingestion of breast milk, from mothers living on or near the Airbase who consume local foods,
was quantified according to the following equation:
𝑬𝑬𝑬𝑬𝑬𝑬𝒎𝒎𝒎𝒎𝒎𝒎𝒎𝒎 × 𝑬𝑬𝑬𝑬 × 𝑬𝑬𝑬𝑬 × 𝑰𝑰𝑰𝑰 × 𝑨𝑨𝑨𝑨𝑨𝑨

Where:
EPCmilk = Exposure point concentration for COPC in breastmilk (mg/L)
IR = Dietary ingestion rate for breastmilk (L/day)
ABS = Oral absorption factor (unit less)
5.4.3 EXPOSURE PARAMETERS

The purpose of this section is to summarize the parameters used in estimating exposure and calculating
risk. A summary of all exposure parameters by exposure scenario is provided in Appendix A, Table A-
9.
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
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.
5.4.3.1 VIETNAMESE POPULATION-SPECIFIC EXPOSURE PARAMETERS

Vietnamese population-specific exposure parameters were investigated for body weight, skin surface
area, and local diet ingestion rates.
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
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.
5.4.3.2 USEPA DEFAULT EXPOSURE PARAMETERS

The remaining exposure parameters (exposure duration, exposure time, exposure frequency, averaging
time, and ingestion rates) were based on the USEPA recommended default exposure parameters for
residential exposure scenarios for adults and children and for worker exposure scenarios (USEPA 2014).
All exposure parameters can be found 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).
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).
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.
6.1 CALCULATION OF RISK AND HAZARD
6.1.1 NONCANCER HAZARD INDEX

Non-cancer hazards will be characterized using the hazard quotient approach (USEPA 1989). An HQ
of less than one indicates that the average daily dose for a particular chemical of concern is below the
level associated with a toxic effect (USEPA 1989).
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).
For inhalation exposures, the hazard quotient is calculated as follows:
𝑬𝑬𝑬𝑬𝒏𝒏𝒏𝒏
𝑯𝑯𝑯𝑯 =
𝑹𝑹𝑹𝑹𝑹𝑹
Where:
ECnc = Exposure concentration for non-carcinogenic chemicals (mg/m3)

RfC = Reference concentration (mg/m3)
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:
𝐻𝐻𝐻𝐻 = 𝐻𝐻𝐻𝐻1 + 𝐻𝐻𝐻𝐻2 + ⋯ + 𝐻𝐻𝐻𝐻𝑛𝑛
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.
6.1.2 CANCER HAZARD INDEX

As discussed in the toxicity assessment, some chemicals, such as dioxins, act through a non-linear mode
of action, indicating that a threshold dose must be reached before a carcinogenic effect may occur.
Because of this, in parallel to the carcinogenic risk the carcinogenic potential is estimated using a hazard
metric similar to that described for noncancer hazards.
For exposure to carcinogens, the hazard quotient is calculated as follows:
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.
6.1.1 INCREMENTAL LIFETIME 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.
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:
𝑰𝑰𝑰𝑰𝑰𝑰𝑰𝑰 = 𝑳𝑳𝑳𝑳𝑳𝑳𝑳𝑳 × 𝑺𝑺𝑺𝑺
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:
𝑰𝑰𝑰𝑰𝑰𝑰𝑰𝑰 = 𝑰𝑰𝑰𝑰𝑰𝑰 × 𝑬𝑬𝑬𝑬𝑪𝑪
Where:
IUR = Inhalation unit risk (microgram per cubic meter [µg/m3])-1

ECC = Exposure concentration for carcinogens (µg/m3)
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 RISK AND HAZARDS UNDER BASELINE CONDITIONS

This section presents the baseline risk assessment results for baseline conditions by medium; estimates
are provided separately for nonresident Airbase personal and for local residents/resident Airbase
personnel and their families. Depending on the COPC and its mode of toxicity, hazards are quantified
with one or more of the following: noncancer hazard index, cancer hazard index, and/or increased
lifetime cancer risks. Summaries of estimated noncancer hazard indices, cancer hazard indices, and
increased lifetime cancer risks for all populations, COPCs, and media are provided at the end of this
section.
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:
• ZI Area: 0.1 (ZI-012) – 171 (ZI-03);

• ZT Area: 0.2 (ZT-05) – 61 (ZT-02);
• SW Area: 0.8 (SW-04) – 441 (SW-01);
• PI Area: 0.3 (PI-07) – 187 (PI-02);
• NF Area: 0.4 (NF-03) – 6.6 (NF-04);
• NE Area: 0.2 (NE-01) – 21 (NE-02); and
• SE Area: 0.7 (SE-01) – 1.3 (SE-02).
Cancer HIs for local residents’ and Airbase residents’ exposure to soil in all Areas and DUs are
presented in Appendix A, Table A-10. Only one Area yielded an HI below one; all other Areas yielded
HIs greater than one. The overall Area HIs ranged from 0.4 in the Southeast Area and 1.9 in the
Northern Forest Area to 56 in the Southwest Area and 17 in the Pacer Ivy Area. Each Area contained
at least two DUs with an HI less than one; the list below reflects the range of DU HIs within each Area
whose land use is listed as Urban Residential or Forest Land in Table 2-1. The cancer hazard values
reported reflect child receptors, as their HIs exceed those for adult receptors.
• ZI Area: 0.04 (ZI-12) – 52 (ZI-03);

• ZT Area: 0.1 (ZT-05) – 19 (ZT-02);
• 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.
• ZI Area: 2x10-6 (ZI-12) – 2x10-3 (ZI-03);

• ZT Area: 4x10-6 (ZT-04) – 8x10-4 (ZT-02);
• SW Area: 1x10-5 (SW-04) – 6x10-3 (SW-01);
• PI Area: 4x10-6 (PI-107) – 3x10-3 (PI-02);
• NF Area: 5x10-6 (NF-03) – 9x10-5 (NF-04);
• NE Area: 3x10-6 (NE-01) – 3x10-4 (NE-02); and
• SE Area: 1x10-5 (SE-01) – 2x10-5 (SE-02).
6.2.1.1.2 NONRESIDENT AIRBASE PERSONNEL

Noncancer HIs for nonresident Airbase personnel exposure to soil in all Areas and DUs under baseline
condition are presented in Appendix, Table A-11. All Areas with available data had HIs greater than one
except the Northern Forest and Southeast Areas. Each Area included at least two DUs with an HI less
than one; ranges of DU HIs for each Area are listed below. All values reported were for adult receptors
and for DUs with listed as having an Industrial Land Use in Table 2-1.
• ZI Area: 0.02 (ZI-12) – 18 (ZI-03);

• ZT Area: 0.02 (ZT-05) – 6.6 (ZT-02);
• SW Area: 0.1 (SW-04) – 47 (SW-01);
• PI Area: 0.03 (PI-07) – 20 (PI-02);
• NF Area: 0.04 (NF-03) – 0.7 (NF-04);
• NE Area: 0.02 (NE-01) – 2.2 (NE-02); and
• SE Area: 0.1 (SE-01) – 0.1 (SE-02).
Cancer HIs for nonresident Airbase personnel exposure to soil in all Areas and DUs under baseline
conditions are presented in Appendix A, Table A-11. Four Areas yielded HIs below the threshold of
one; all other Areas with available data yielded HIs greater than one. The overall Area HIs ranged from
0.04 in the Southeast Area and 0.2 in the Northern Forest Area to 6.0 in the Southwest Area. Each Area
included at least two DUs with an HI less than one; the list below reflects the range of DU HIs within
each Area for DUs whose land use is listed as Industrial in Table 2-1. All values reported were for adult
receptors.
• 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.
• ZI Area: 5x10-7 (ZI-12) – 6x10-4 (ZI-03);

• ZT Area: 7x10-7 (ZT-05) – 2x10-4 (ZT-02);
• SW Area: 3x10-6 (SW-04) – 2x10-3 (SW-01);
• PI Area: 1x10-6 (PI-07) – 7x10-4 (PI-02);
• NF Area: 1x10-6 (NF-03) – 2x10-5 (NF-04);
• SE Area: 3x10-6 (SE-01) – 5x10-6 (SE-02).
6.2.1.2 OTHER COPCS
Total noncancer HIs for local residents and Airbase residents’ exposure to soil under baseline conditions
are presented in Appendix A, Table A-12 and demonstrate that among all Areas with available data,
three Areas yielded HIs less than one. The Area total HIs ranged from 0.2 in the site background and
ZT Area to 2.7 in the Pacer Ivy Area. Arsenic-specific HIs ranged from 0.2 in the site background and
ZT Area to 2.1 in the Pacer Ivy Area; only one HI (0.6) associated with Aroclor 1260 was calculated
with available data for the Pacer Ivy Area. If the site background HI for arsenic is subtracted from the
HIs for the other site areas, the HI for the ZT area is at or below background and the HIs for the other
areas range from 0.3 (Northeast Area) to 1.9 (Pacer Ivy Area). The values reported reflect HIs for
children; all child receptor HIs exceed those for child receptors.
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).
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
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.
• ZI Area: 8.0 (ZI-09) – 30 (ZI-10);

• PI Area: 1.0 (PI-21) – 67 (PI-15);
• NW Area: 1.5 (NW-02) – 8.7 (NW-04);
• NE Area: 0.5 (NE-10) – 26 (NE-07); and
• Outside Airbase: 1.7 (BHL-01) – 3.4 (G2L-01).
Cancer hazard indices for local residents’ and Airbase residents’ exposure to sediment in all Areas and
DUs with available data are presented in Appendix A, Table A-14 and demonstrate that all Areas with
available data yielded HIs greater than one except outside the Airbase. The overall Area HIs ranged
from 0.5 and 1.0 outside the Airbase to 13 in the Pacer Ivy Area. Each area except the ZI Area included
at least one DU with an HI less than one. The ranges of DU HIs within each area are presented below.
All values reported were for child receptors.
• ZI Area: 2.5 (ZI-09) – 19.2 (ZI-10);

• PI Area: 0.2 (PI-21) – 21 (PI-15);
• NW Area: 0.4 (NW-02) – 2.7 (NW-04);
• NE Area: 0.2 (NE-10) – 8.0 (NE-07); and
Increased lifetime cancer risk for local residents’ and Airbase residents’ exposure to sediment in all
Areas and DUs for which data were available under baseline conditions is presented in Appendix A,
Table A-14. All Areas evaluated for local/Airbase residents yielded ILCRs greater than 1x10-6; specifically,
only one Area had an ILCR within the risk range of 1x10-6 to 1x10-4. The overall Area ILCRs ranged
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.
• ZI Area: 1x10-4 (ZI-09) – 4x10-4 (ZI-10);

• PI Area: 7x10-6 (PI-21) – 9x10-4 (PI-15);
• NW Area: 2x10-5 (NW-02) – 1x10-4 (NW-04);
• Outside Airbase: 2x10-5 (BHL-01) – 5x10-5 (G2L-01).

Noncancer hazard indices for nonresident Airbase personnel exposure to sediment in all Areas and DUs
with available data under baseline conditions are presented in Appendix A, Table A-15. One Area yielded
an HI below the threshold of one; all other Areas with available data yielded HIs greater than one. The
overall Area HIs ranged from 0.8 in the Northwest Area to 4.8 in the Pacer Ivy Area. Four Areas
included at least one DU with an HI less than one; the list below reflects the range of DU HIs within
each Area. All values reported were for child receptors.
• ZI Area: 0.9 (ZI-09) – 3.3 (ZI-10);

• PI Area: 0.06 (PI-21) – 7.3 (PI-15);
• NW Area: 0.2 (NW-02) – 0.9 (NW-04);
• NE Area: 0.1 (NE-10) – 2.8 (NE-07); and
Cancer HIs for nonresident Airbase personnel exposure to soil in all Areas and DUs with available data
under baseline conditions are presented in Appendix A, Table A-15. Four Areas yielded HIs below one;
all other Areas yielded HIs greater than one. The overall Area HIs ranged from 0.1 outside the Airbase
to 1.5 in the Pacer Ivy Area. Each Area contained at least two DUs with HIs less than one; the list below
reflects the range of DU HIs within each Area. All values reported were for child receptors.
• ZI Area: 0.3 (ZI-09) – 1.0 (ZI-10);

• PI Area: 0.02 (PI-21) – 2.2 (PI-15);
• NW Area: 0.05 (NW-02) – 0.3 (NW-04);
• NE Area: 0.02 (NE-10) – 0.9 (NE-07); and
Increased lifetime cancer risk for nonresident Airbase personnel exposure to sediment in all Areas and
DUs for which data were available under baseline conditions is presented in Appendix A, Table A-15.
All Areas evaluated for nonresident personnel yielded ILCRs greater than 1x10-6; specifically, three Areas
had an ILCR within the risk range of 1x10-6 to 1x10-4. The overall Area ILCRs ranged from 6x10-6 outside
the Airbase to 2x10-4 in the Pacer Ivy Area. The ranges of DU ILCRs within each Area are presented
below.
• ZI Area: 3x10-5 (ZI-09) – 1x10-4 (ZI-10);

• PI Area: 2x10-6 (PI-21) – 2x10-4 (PI-15);
• NW Area: 5x10-6 (NW-02) – 3x10-5 (NW-04);
• Outside Airbase: 6x10-6 (BHL-01) – 1x10-5 (G2L-01).
6.2.2.2 OTHER COPCS

Total noncancer hazard indices 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, arsenic-specific, and Aroclor 1260-specific
HIs below the threshold of one. The Area total HIs ranged from 0.05 in the Northwest Area and 0.2 in
the site background to 1.0 in the Pacer Ivy Area. Arsenic-specific HIs ranged from 0.05 in the Northwest
Area and 0.2 in the site background to 0.9 in the Pacer Ivy Area; only one HI (0.04) associated with
Aroclor 1260 was calculated with available data for the Pacer Ivy Area. The values reported reflect HIs
for children; all child receptor HIs exceed those for adult receptors.
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
available data for the Pacer Ivy Area.

Total noncancer hazard indices 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. All Areas yielded total, arsenic-specific, and Aroclor 1260-specific HIs below the
threshold of one. Total and arsenic-specific HIs ranged from 0.005 in the Northwest Area and 0.03 in
the site background to 0.1 in the Pacer Ivy Area. Only one HI (0.005) associated with Aroclor 1260 was
calculated with available data for the Pacer Ivy Area. All values reported were for adult receptors.
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.
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.
6.2.3.2 OTHER COPCS

Noncancer arsenic-specific hazard indices for local residents and Airbase residents’ exposure to
groundwater under baseline conditions are presented in Appendix A, Table A-19. The HI for the site
background was not able to be calculated; all other Areas with available data yielded HIs less than one.
The Area HIs ranged from 0.1 in the ZT Areas and 0.9 in the Southwest Area. All values reported reflect
HIs for children; all child receptor HIs exceeded those for adult receptors.
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.
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.
6.2.5 BASELINE CONDITIONS OVERALL

6.2.5.1 LOCAL AND AIRBASE RESIDENTS
Table 6-1 through Table 6-6 summarize the noncancer HIs, cancer HIs, and ILCRs for all chemicals and
exposure pathways for local residents, resident Airbase personnel and their families, and nonresident
Airbase personnel by area.
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.
TABLE 6-1 NONCANCER HAZARD INDEX SUMMARY FOR LOCAL RESIDENTS AND RESIDENT AIRBASE PERSONNEL AND THEIR FAMILIES
PCDD/FSA OTHER COPCSA OVERALL

SITE AREA
SOIL SEDIMENT GROUNDWATER DIET TOTAL SOIL SEDIMENT GROUNDWATER TOTAL TOTAL
Z1 Area 29 30 0.1 NA 59 1.4 0.7 0.8 2.9 62

ZT Area 45 NA 0.1 NA 45 0.2 NA 0.1 0.2 45
Southwest Area 184 NA 1.3 NA 185 1.2 NA 0.9 2.0 187
Pacer Ivy Area 57 44 1.6 NA 103 2.7 1.0 0.8 4.5 108
Northwest Area 6.2 7.5 NA NA 14 NA 5E-02 NA 5E-02 14
Northern Forest Area 20 NA NA NA 20 NA NA NA NA 20
Northeast Area 20 10 NA NA 30 0.5 NA NA 0.5 31
Southeast Area 1.3 NA NA NA 1.3 NA NA NA NA 1.3
Bien Hung Lake NA 1.7 NA NA 1.7 NA 0.5 NA 0.5 2.2
Gate 2 Lake NA 3.4 NA NA 3.4 NA 0.3 NA 0.3 3.6
SITEWIDE 48 18 0.8 246 312 1.0 0.4 0.6 2.0 314
a Bolded values indicate a hazard index above the threshold of one
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
TABLE 6-3 INCREASED LIFETIME CANCER RISK SUMMARY FOR LOCAL RESIDENTS AND RESIDENT AIRBASE PERSONNEL AND THEIR FAMILIES
PCDD/FS A OTHER COPCS A

SITE AREA OVERALL
SOIL SEDIMENT GROUNDWATER DIET TOTAL SOIL SEDIMENT GROUNDWATER TOTAL TOTAL
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
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
PCDD/FSA OTHER COPCSA

SITE AREA OVERALL
SOIL SEDIMENT TOTAL SOIL SEDIMENT TOTAL TOTAL
Z1 Area 3.1 3.3 6.3 0.1 0.1 0.2 6.6
ZT Area 4.8 NA 4.8 2E-02 NA 0.0 4.8
Southwest Area 20 NA 20 0.1 NA 0.1 20
Pacer Ivy Area 6 4.8 11 0.3 0.1 0.4 11
Northwest Area NA 0.8 0.8 NA 5E-03 5E-03 0.8
Northern Forest Area 0.7 NA 0.7 NA NA NA 0.7
Northeast Area 2.2 1.1 3.3 0.1 NA 0.1 3.3
Southeast Area 0.1 NA 0.1 NA NA NA 0.1
Bien Hung Lake NA 1.7 1.7 NA 0.1 0.1 1.7
Gate 2 Lake NA 3.4 3.4 NA 3E-02 3E-02 3.4
SITEWIDE 5 2.2 7 0.1 4E-02 0.2 7
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
TABLE 6-6 INCREASED LIFETIME CANCER RISK SUMMARY FOR NONRESIDENT AIRBASE PERSONNEL
PCDD/FSA OTHER COPCSA OVERALL

SITE AREA
SOIL SEDIMENT TOTAL SOIL SEDIMENT TOTAL TOTAL
Z1 Area 1E-04 1E-04 2E-04 2E-05 1E-05 3E-05 2E-04

ZT Area 2E-04 NA 2E-04 3E-06 NA 3E-06 2E-04
Southwest Area 6E-04 NA 6E-04 2E-05 NA 2E-05 7E-04
Pacer Ivy Area 2E-04 2E-04 4E-04 3E-05 2E-05 5E-05 4E-04
Northwest Area NA 3E-05 3E-05 NA 8E-07 8E-07 3E-05
Northern Forest Area 2E-05 NA 2E-05 NA NA NA 2E-05
Northeast Area 7E-05 3E-05 1E-04 8E-06 NA 8E-06 1E-04
Southeast Area 5E-06 NA 5E-06 NA NA NA 5E-06
Bien Hung Lake NA 6E-06 6E-06 NA 9E-06 9E-06 1E-05
Gate 2 Lake NA 1E-05 1E-05 NA 5E-06 5E-06 2E-05
SITEWIDE 2E-04 6E-05 2E-04 1E-05 6E-06 2E-05 2E-04
aBolded values indicate an increased lifetime cancer risk below 1 x 10-4; bolded italicized values indicate an increased lifetime
cancer risk above 1 x 10-5
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.
6.3.1 HAZARD IDENTIFICATION

For the hazard identification, the following uncertainties and assumptions had a significant impact on the
results of the risk 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.
6.3.2 TOXICITY ASSESSMENT

For the toxicity assessment, the following uncertainties and assumptions had a significant impact on the
• 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.
6.3.3 EXPOSURE ASSESSMENT

For the exposure assessment, the following uncertainties and assumptions had a significant impact on
the results of the risk assessment:
• 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
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..
6.3.4 RISK CHARACTERIZATION

For the risk characterization, the following uncertainties and assumptions had a significant impact on the
• 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.
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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APPENDIX A
ADDITIONAL FIGURES AND TABLES
TABLE A-1 SUMMARY OF DIOXIN/FURAN DATA SETS USED
ENVIRONMENTAL NUMBER ANALYSIS

REPORT SITE AREA SAMPLING SUMMARY
MEDIA OF SAMPLES METHOD
Samples were collected from various locations on and

Soil All Area 16 HR-GCMS around the Airbase, including lakes, natural vegetation,
Hatfield and 10-80 Division (2006) grazing areas/wetlands, gardens, streams, agriculture fields,
fish pond, Dong Nai River, and the marsh southwest of the
Sediment All Areas 20 HR-GCMS
base (Hatfield and 10-80 Division 2006).
Samples were taken from areas including the southwest
Pacer Ivy and Z1 ‘newly discovered’ corner, southwest airbase corner
Soil 114 HR-GCMS (Pacer Ivy area at the runway), Z1 area (‘hot spot’ area),
Areas
and ponds/lakes surrounding the Z1 area; the Pacer Ivy site
Hatfield and VRTC (2009) included a concrete yard, a buffer zone leading to ditches,
and small creeks and ponds (Hatfield and VRTC 2009). Soil
Pacer Ivy and Z1 samples were collected from depths between 0-10 cm, 10-
Sediment 11 HR-GCMS
Areas 30 cm and 30-60 cm (maximum 100 cm) (Hatfield and
VRTC 2009).
Soil Pacer Ivy Area 23 HR-GCMS
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).
Northern Area 5 HR-GCMS

Fish tissue samples (muscle, fat, eggs, or whole fish) were
collected in November 2010 from lakes and ponds inside
and outside the Bien Hoa Airbase, including Mr. San Lake,
Biota All Areas 53 HR-GCMS Northeastern Perimeter Lake, Mr. Quy Lake, Mr. Binh
Lake, Gate 2 Lake, Mr. Hoc Lake, Gate 2 Market, Bien Hoa
Market, Z1 Lake, Bien Hung Lake, and Pacer Ivy Lake
(Hatfield and Office 33 2011).
Blood samples were collected, and serum was analyzed

from all eligible donors (Hatfield and Office 33 2011).
Blood samples were collected from males (N = 37) and
Human Serum All Areas 42 HR-GCMS females (N = 5) of ages ranging from 38 to 61, who were
currently working within Bien Hoa Airbase premises or
had worked there in the past (Hatfield and Office 33
2011).
Hatfield and Office 33 (2011) Breast milk samples were collected from volunteer donors
[continued] from Trung Dung ward (n=18), Tan Phong ward (n=2),
Tan Tien ward (n=1), and Hoa An ward (n=1) (Hatfield
and Office 33 2011). Donors were asked to donate 15 to
50 cc of breast milk; milk was manually extruded by each
Breast Milk All Areas 22 HR-GCMS
individual mother directly into a sample jar. Of the 22
breast milk donors, twelve were breastfeeding their first
infant (primiparous females), eight were feeding their
second infant, and two were with their third infant
(Hatfield and Office 33 2011).
One hundred thirty soil samples were collected from
VEA and MONRE (2012) Soil Pacer Ivy Area 111 Unknown
Pacer Ivy, of which 111 were analyzed (GVN/USAID 2016).
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
Dekonta (2014) Groundwater All Areas 6 Unknown
(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.
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 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
Tuyet-Hahn et al. (2015) Food All Areas 46 HR-GCMS
‘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)
Z1 Area 132 HR-GCMS

ZT Area 28 HR-GCMS
Southwest Area 86 HR-GCMS
Soil Pacer Ivy Area 219 HR-GCMS
Northern Forest Area 16 HR-GCMS
Northeast Area 21 HR-GCMS Samples were collected November through December
2014 as well as March through April 2015 using a
Southwest Area 4 HR-GCMS
comprehensive sampling methodology known as multi-
Z1 Area 17 HR-GCMS increment sampling (MIS) (GVN/USAID 2016). A total of
more than 1,400 samples were collected, which included
Pacer Ivy Area 62 HR-GCMS more than 1,300 composite soil and sediment samples for
GVN/USAID (2016)
Sediment Northwest Area 28 HR-GCMS potential dioxin analysis and 100 samples of soil, sediment,
groundwater, and biota for various chemical and/or
Northeast Area 52 HR-GCMS physical property testing (GVN/USAID 2016). Over 700
samples of soil, sediment, groundwater, and biota were
Offsite Lake Area 4 HR-GCMS
analyzed (GVN/USAID 2016). It was not specified how
Groundwater All Areas 14 HR-GCMS TEQ was calculated.
Z1 Area 1 HR-GCMS
Pacer Ivy Area 3 HR-GCMS
Biota Northwest area 6 HR-GCMS
Northeast Area 8 HR-GCMS
Offsite Lake Area 3 HR-GCMS
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
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
95%
STANDARD CONFIDENCE
DEVIATION STUDENT T
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-08 1753.3 1238.3 4.0 3040.0 2.4 3210.3 4452.1 3040.0 Maximum
PI-10 892.0 895.8 4.0 2220.0 2.4 1946.1 2844.4 2220.0 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
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-04 166.3 137.2 4.0 349.0 2.4 327.7 465.3 327.7 Arithmetic
95%
STANDARD CONFIDENCE
DEVIATION STUDENT T
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-04 550.8 214.8 4.0 706.0 2.4 803.5 1018.9 706.0 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
TABLE A-3 PCDD/F ALL SOIL DEPTHS EXPOSURE POINT CONCENTRATIONS BY DECISION UNIT IN PPT
95%
DECISION STANDARD CONFIDENCE
MEAN OF MAXIMUM CONFIDENCE CONFIDENCE POINT CONCENTRATION
UNIT DEVIATION STUDENT T
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
95%
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
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
95%
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
TABLE A-4 PCDD/F SURFACE SEDIMENT EXPOSURE POINT CONCENTRATIONS BY DECISION UNIT IN PPT
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
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-08 166.5 80.7 4.0 223.0 2.4 261.4 342.4 261.4 Arithmetic
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-12 181.3 56.3 4.0 259.0 2.4 247.4 303.8 247.4 Arithmetic
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
TABLE A-5 PCDD/F ALL DEPTHS SEDIMENT EXPOSURE POINT CONCENTRATIONS BY DECISION UNIT IN PPT
95%
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
95%
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
TABLE A-6 PCDD/F GROUNDWATER EXPOSURE POINT CONCENTRATIONS BY SITE AREA IN PG/L
ARITHMETIC CHEBYSHEV 95%

95%
NUMBER 95% UPPER UPPER PCDD/F EXPOSURE EXPOSURE POINT
STANDARD CONFIDENCE
SITE AREA MEAN OF MAXIMUM CONFIDENCE CONFIDENCE POINT CONCENTRATION
DEVIATION STUDENT T
STATISTIC
MEAN MEAN
Overall 7.1 9.8 6.0 21.4 2.9 15.2 24.6 15.1 Arithmetic
Z1 0.8 0.0 3.0 0.9 2.9 0.9 0.9 0.9 Maximum
ZT 0.8 NC 1.0 0.8 NC NC NC 0.8 Maximum
SW 18.0 NC 1.0 18.0 NC NC NC 18.0 Maximum
PI 21.4 NC 1.0 21.4 NC NC NC 21.4 Maximum
TABLE A-7 PCDD/F DIETARY EXPOSURE POINT CONCENTRATIONS BY ITEM IN PPT
ARITHMETIC CHEBYSHEV 95%

95%
NUMBER 95% UPPER UPPER EXPOSURE POINT
STANDARD CONFIDENCE EXPOSURE POINT
DIET ITEM MEAN OF MAXIMUM CONFIDENCE CONFIDENCE CONCENTRATION
DEVIATION STUDENT T CONCENTRATION
SAMPLES LIMIT OF THE LIMIT OF THE TYPE
STATISTIC
MEAN MEAN
Chicken 51.8 NC 3.0 95.0 NC NC NC 95.0 Maximum
Duck 13.9 NC 2.0 19.6 NC NC NC 19.6 Maximum
Chicken eggs 18.5 NC 2.0 29.7 NC NC NC 29.7 Maximum
Duck Eggs 15.7 NC 1.0 15.7 NC NC NC 15.7 Maximum
Fish 24.8 27.7 9.0 68.3 1.9 42.0 65.1 65.1 Chebyshev
Snails 65.6 5.6 2.0 69.5 6.3 90.5 82.8 69.5 Maximum
Vegetables 0.5 NC 5.0 1.0 NC NC NC 1.0 Maximum
Rice 0.0 NC 1.0 0.0 NC NC NC 0.0 Maximum
TABLE A-8 OTHER COPC EXPOSURE POINT CONCENTRATIONS BY SITE AREA AND ENVIRONMENTAL MEDIA
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
Arsenic Surface Soil NE 3.1 NC 1 3.1 NC NC NC 3.1 Maximum

Arsenic Surface Soil PI 22.1 23.1 5 63.0 2.1 44.2 67.2 44.2 Arithmetic
Arsenic Surface Soil SW 15.4 9.4 3 25.0 2.9 31.3 39.1 25.0 Maximum
Arsenic Surface Soil Z1 17.0 10.5 3 29.0 2.9 34.6 43.3 29.0 Maximum
Arsenic All Soil NE 3.1 NC 1 3.1 NC NC NC 3.1 Maximum
Arsenic All Soil PI 20.8 20.6 7 63.0 1.9 35.9 54.7 35.9 Arithmetic
Arsenic All Soil SW 15.4 9.4 3 25.0 2.9 31.3 39.1 25.0 Maximum
Arsenic All Soil Z1 11.0 9.4 6 29.0 2.0 18.8 27.8 27.8 Chebyshev
Arsenic All Soil ZT 3.7 NC 1 3.7 NC NC NC 3.7 Maximum
Arsenic All Soil LTSA 19.4 16.6 12 63 1.8 28.0 40.3 40.3 Chebyshev
Aroclor 1260 Surface Soil PI 234.3 484.8 5 1100.0 2.1 696.6 1179.4 696.6 Arithmetic
Aroclor 1260 All Soil PI 234.3 484.8 5 1100.0 2.1 696.6 1179.4 696.6 Arithmetic
Arsenic Sediment PI 20.0 NC 1 20.0 NC NC NC 20.0 Maximum
Arsenic Sediment Z1 15.0 NC 1 15.0 NC NC NC 15.0 Maximum
Arsenic Sediment BHL 11.0 NC 1 11.0 NC NC NC 11.0 Maximum
Arsenic Sediment G2L 5.7 NC 1 5.7 NC NC NC 5.7 Maximum
Arsenic Groundwater PI 4.8 NC 1 4.8 NC NC NC 4.8 Maximum
Arsenic Groundwater Z1 3.2 3.0 3 6.5 2.9 8.3 10.8 6.5 Maximum
Arsenic Groundwater ZT 0.4 NC 1 0.4 NC NC NC 0.4 Maximum
Arsenic Groundwater SW 5.0 NC 1 5.0 NC NC NC 5.0 Maximum
Lead Groundwater PI 21.3 NC 1 21.3 NC NC NC 21.3 Maximum
Lead Groundwater Z1 2.7 3.3 3 6.4 2.9 8.3 11.0 6.4 Maximum
Lead Groundwater ZT 0.0 NC 1 0.025 NC NC NC 0.025 Maximum
Lead Groundwater SW 64.8 NC 1 64.8 NC NC NC 64.8 Maximum
Conc. = concentration
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
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 - - -
Sediment
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 - - -
Sediment
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 -
Contact with
Adult (>18 yrs) 49.1 350 - 10 3650 days - - 3559 0.07 -
Sediment
Nonresident Adult (>18 yrs) 49.1 250 - 25 9125 days - - 2584 0.12 -
Child (1-6 yrs) 14.5 350 - 5 1825 days 0.78 L/day - - -
Groundwater Groundwater
Resident Adolescent (7-18 yrs) 22.8 350 - 11 4015 days 2.5 L/day - - -
Ingestion
Adult (>18 yrs) 49.1 350 - 10 3650 days 2.5 L/day - - -
DAY/ MG/CM2-
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 - -
Child (1-6 yrs) 14.5 50 2 5 1825 days 0.50 L/hr - - -

Incidental
Resident Adolescent (7-18 yrs) 22.8 50 2 11 4015 days 0.50 L/hr - - -
Ingestion
Surface Adult (>18 yrs) 49.1 25 1 10 3650 days 0.50 L/hr - - -
Water Child (1-6 yrs) 14.5 50 2 5 1825 days - - 6500 - -
Dermal -
Resident Adolescent (7-18 yrs) 22.8 50 2 11 4015 days - 8960 - -
Contact
Adult (>18 yrs) 49.1 25 1 10 3650 days - - 14800 - -
Child (1-6 yrs) 14.5 365 - 5 1825 days 5.94 g/day - - -

Consumption g/day
Resident Adolescent (7-18 yrs) 22.8 365 - 11 4015 days 9.31 - - -
of Chicken
Adult (>18 yrs) 49.1 365 - 10 3650 days 20.1 g/day - - -
Consumption g/day
of Duck
g/day
Child (1-6 yrs) 14.5 365 - 5 1825 days 4.49 - - -
Consumption
of Chicken Resident Adolescent (7-18 yrs) 22.8 365 - 11 4015 days 7.04 g/day - - -
Local Diet Eggs
Consumption g/day
of Duck Eggs
Consumption g/day
of Fish
Adult (>18 yrs) 49.1 365 - 10 3650 days 64.9 g/day C- - -
Consumption
Resident
of Snails Adolescent (7-18 yrs) 22.8 365 - 11 4015 days 7.09 g/day - - -
DAY/ MG/CM2-
YEAR DAY
Consumption g/day
Local Diet of Vegetables
Adult (>18 yrs) 49.1 365 - 10 3650 days 168 g/day - - -
(continued)
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
TABLE A-10 SOIL EXPOSURE RISK/HAZARD FROM PCDD/FS FOR LOCAL RESIDENTS AND RESIDENT
AIRBASE PERSONNEL AND THEIR FAMILIES
CHILD NONCANCER CHILD CANCER INCREASED LIFETIME

DECISION UNIT
HAZARD INDEXA HAZARD INDEXA CANCER RISKB
ZI AREA
Z1 Overall 29 8.7 4E-04
ZI-01 31 9.3 4E-04
ZI-02 27 8.2 4E-04
ZI-03 171 52 2E-03
ZI-04 5.1 1.5 7E-05
ZI-05 2.0 0.6 3E-05
ZI-06 13 3.9 2E-04
ZI-07 5.0 1.5 7E-05
ZI-08 2.2 0.7 3E-05
ZI-11 2.5 0.8 3E-05
ZI-12 0.1 0.04 2E-06
ZI-13 8.8 2.7 1E-04
ZI-16 46 14 6E-04
ZI-17 0.3 0.1 4E-06
ZT AREA
ZT Overall 45 14 6E-04
ZT-01 1.0 0.3 1E-05
ZT-02 61 19 8E-04
ZT-04 0.3 0.1 4E-06
ZT-05 0.2 0.1 3E-06
ZT-06 0.5 0.1 6E-06
ZT-07 2 1 2E-05
SOUTHWEST AREA
SW Overall 184 56 2E-03
SW-01 441 134 6E-03
SW-02 141 43 2E-03
SW-03 35 10.6 5E-04
SW-04 0.8 0.3 1E-05
SW-06 1.4 0.4 2E-05
SW-07 13 3.9 2E-04
SW-08 1.2 0.4 2E-05
PACER IVY AREA
PI Overall 57 17 8E-04
PI-01 4 1.1 5E-05
PI-02 187 57 3E-03
PI-03 0.5 0.1 6E-06
PI-04 5 1 7E-05
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
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
b 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
TABLE A-11 SOIL EXPOSURE RISK/HAZARD FROM PCDD/FS FOR NONRESIDENT AIRBASE PERSONNEL
NONCANCER HAZARD CANCER HAZARD INCREASED LIFETIME CANCER

DECISION UNIT
INDEXA INDEXA RISKB
ZI AREA
Z1 Overall 3.1 0.9 1E-04
ZI-01 3.3 1.0 1E-04
ZI-02 2.9 0.9 9E-05
ZI-03 18 5.6 6E-04
ZI-04 0.5 0.2 2E-05
ZI-05 0.2 0.1 7E-06
ZI-06 1.4 0.4 5E-05
ZI-07 0.5 0.2 2E-05
ZI-08 0.2 0.1 8E-06
ZI-11 0.3 0.1 9E-06
ZI-12 2E-02 5E-03 5E-07
ZI-13 0.9 0.3 3E-05
ZI-16 4.9 1.5 2E-04
ZI-17 3E-02 9E-03 1E-06
ZT AREA
ZT Overall 4.8 1.5 2E-04
ZT-01 0.1 3E-02 3E-06
ZT-02 6.6 2.0 2E-04
ZT-04 3E-02 1E-02 1E-06
ZT-05 2E-02 7E-03 7E-07
ZT-06 0.1 2E-02 2E-06
ZT-07 0.2 0.1 6E-06
SOUTHWEST AREA
SW Overall 20 6.0 6E-04
SW-01 47 14 2E-03
SW-02 15 4.6 5E-04
SW-03 3.7 1.1 1E-04
SW-04 0.1 3E-02 3E-06
SW-06 0.2 5E-02 5E-06
SW-07 1.4 0.4 4E-05
SW-08 0.1 4E-02 4E-06
PACER IVY AREA
PI-01 0.4 0.1 1E-05
PI-02 20 6 7E-04
PI-03 0.1 2E-02 2E-06
PI-04 0.5 0.2 2E-05
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
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
risk above 1 x 10-5
TABLE A-12 SOIL EXPOSURE RISK/HAZARD FROM OTHER COPCS FOR LOCAL RESIDENTS AND RESIDENT
CHILD NONCANCER HAZARD INDEXA INCREASED LIFETIME CANCER RISKB

AREA
AROCLOR AROCLOR
ARSENIC TOTAL ARSENIC TOTAL
1260 1260
Background 0.2 NA 0.2 2E-05 NA 2E-05
Z1 1.4 NA 1.4 9E-05 NA 9E-05
ZT 0.2 NA 0.2 1E-05 NA 1E-05
SW 1.2 NA 1.2 8E-05 NA 8E-05
PI 2.1 0.6 2.7 1E-04 4E-06 1E-04
NE 0.5 NA 0.5 3E-05 NA 3E-05
risk above 1 x 10-5
TABLE A-13 SOIL EXPOSURE RISK/HAZARD FROM OTHER COPCS FOR NONRESIDENT AIRBASE
PERSONNEL
NONCANCER HAZARD INDEXA INCREASED LIFETIME CANCER RISKB

AREA
ARSENIC AROCLOR 1260 TOTAL ARSENIC AROCLOR 1260 TOTAL
Background 3E-02 NA 3E-02 4E-06 NA 4E-06
Z1 0.1 NA 0.1 2E-05 NA 2E-05
ZT 2E-02 NA 2E-02 3E-06 NA 3E-06
SW 0.1 NA 0.1 2E-05 NA 2E-05
PI 0.2 0.1 0.3 3E-05 1E-06 3E-05
NE 0.1 NA 0.1 8E-06 NA 8E-06
risk above 1 x 10-5
TABLE A-14 SEDIMENT EXPOSURE RISK/HAZARD FROM PCDD/FS FOR LOCAL RESIDENTS AND RESIDENT
CHILD NONCANCER CHILD CANCER HAZARD INCREASED LIFETIME CANCER

DECISION UNIT
HAZARD INDEXA INDEXA RISKB
ZI AREA
Z1 Overall 30 9.2 4E-04
ZI-09 8 2.5 1E-04
ZI-10 30 9.2 4E-04
PACER IVY AREA
PI-15 67 21 9E-04
PI-16 16 5.0 2E-04
PI-17 24 7.2 3E-04
PI-18 22 7 3E-04
PI-19 1 0.2 9E-06
PI-20 62 19 8E-04
PI-21 1 0.2 7E-06
NORTHWEST AREA
NW Overall 7.5 2.3 1E-04
NW-01 2.0 0.6 3E-05
NW-02 1.5 0.4 2E-05
NW-03 7.1 2.1 9E-05
NW-04 8.7 2.7 1E-04
NORTHEAST AREA
NE-06 1.4 0.4 2E-05
NE-07 26 8.0 4E-04
NE-08 5.3 1.6 7E-05
NE-09 9 2.8 1E-04
NE-10 0.5 0.2 7E-06
NE-11 2.5 0.8 3E-05
NE-12 5.0 1.5 7E-05
NE-13 1.6 0.5 2E-05
NE-14 0.7 0.2 1E-05
NE-15 4.5 1.4 6E-05
OUTSIDE AIRBASE
BHL-01 1.7 0.5 2E-05
G2L-01 3.4 1.0 5E-05
risk above 1 x 10-5
TABLE A-15 SEDIMENT EXPOSURE RISK/HAZARD FROM PCDD/FS FOR NONRESIDENT AIRBASE
PERSONNEL

DECISION UNIT
ZI AREA
Z1 Overall 3.3 1.0 1E-04
ZI-09 0.9 0.3 3E-05
ZI-10 3.3 1.0 1E-04
PACER IVY AREA
PI Overall 4.8 1.5 2E-04
PI-15 7.3 2.2 2E-04
PI-16 1.8 0.5 6E-05
PI-17 2.5 0.8 8E-05
PI-18 2.4 0.7 8E-05
PI-19 0.07 0.02 2E-06
PI-20 6.7 2 2E-04
PI-21 0.06 0.02 2E-06
NORTHWEST AREA
NW Overall 0.8 0.2 3E-05
NW-01 0.2 0.1 7E-06
NW-02 0.2 5E-02 5E-06
NW-03 0.8 0.2 2E-05
NW-04 0.9 0.3 3E-05
NORTHEAST AREA
NE-06 0.2 5E-02 5E-06
NE-07 2.8 0.9 9E-05
NE-08 0.6 0.2 2E-05
NE-09 1.0 0.3 3E-05
NE-10 0.1 2E-02 2E-06
NE-11 0.3 0.1 9E-06
NE-12 0.5 0.2 2E-05
NE-13 0.2 0.1 5E-06
NE-14 0.1 2E-02 3E-06
NE-15 0.5 0.1 2E-05
OUTSIDE AIRBASE
BHL-01 1.7 0.1 6E-06
G2L-01 3.4 0.1 1E-05
risk above 1 x 10-5
TABLE A-16 SEDIMENT EXPOSURE RISKS/HAZARD FROM OTHER COPCS FOR LOCAL RESIDENTS AND RESIDENT AIRBASE PERSONNEL AND
THEIR FAMILIES

DECISION UNIT
Background 0.2 NA 0.2 2E-05 NA 2E-05
Z1 0.7 NA 0.7 5E-05 NA 5E-05
PI 0.9 4E-02 1.0 6E-05 3E-07 6E-05
NW 5E-02 NA 5E-02 3E-06 NA 3E-06
BHL-01 0.5 NA 0.5 3E-05 NA 3E-05
G2L-01 0.3 NA 0.3 2E-05 NA 2E-05
b 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
TABLE A-17 SEDIMENT EXPOSURE RISK/HAZARD FROM COPCS FOR NONRESIDENT AIRBASE PERSONNEL
NONCANCER HAZARD INDEXA INCREASED LIFETIME CANCER RISKB

DECISION UNIT
Background 3E-02 NA 3E-02 4E-06 NA 4E-06
Z1 0.1 NA 0.1 1E-05 NA 1E-05
PI 0.1 5E-03 0.1 2E-05 7E-08 2E-05
NW 5E-03 NA 5E-03 8E-07 NA 8E-07
BHL-01 0.1 NA 0.1 9E-06 NA 9E-06
G2L-01 3E-02 NA 3E-02 5E-06 NA 5E-06
b 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
TABLE A-18 GROUNDWATER EXPOSURE RISK/HAZARD FROM PCDD/FS FOR LOCAL RESIDENTS AND
RESIDENT AIRBASE PERSONNEL AND THEIR FAMILIES

DECISION UNIT
ZI Area 0.1 2E-02 3E-06
ZT Area 0.1 2E-02 3E-06
Southwest Area 1.3 0.4 6E-05
Pacer Ivy Area 1.6 0.5 8E-05
risk above 1 x 10-5
TABLE A-19 GROUNDWATER EXPOSURE RISK/HAZARD FROM OTHER COPCS FOR LOCAL RESIDENTS
AND RESIDENT AIRBASE PERSONNEL AND THEIR FAMILIES

DECISION UNIT
ARSENIC ARSENIC
Background NA NA
Z1 0.8 2E-04
ZT 0.1 1E-05
SW 0.9 2E-04
PI 0.8 2E-04
risk above 1 x 10-5
TABLE A-20 DIETARY EXPOSURE RISK/HAZARD FROM PCDD/F FOR LOCAL RESIDENTS AND RESIDENT

DIETARY ITEM
Chicken 56 17 2E-03
Duck 11 3.5 4E-04
Chicken Eggs 13 3.9 4E-04
Duck Eggs 6.9 2.1 2E-04
Fish 123 37 4E-03
Snails 31 9.4 1E-03
Vegetables 4.9 1.5 2E-04
Rice 0.4 0.1 1E-05
Total Diet 246 75 8E-03
Infant Ingestion of Breast Milk 75 23 2E-04
risk above 1 x 10-5
ANNEX 8 – TECHNICAL MEMORANDA
– LONG-TERM STORAGE AREA SUMMARY RISK

ASSESSMENT
– TECHNOLOGY EVALUATION AND

RECOMMENDED TREATMENT METHODS
– PROJECT MATERIAL DISPOSITION APPROACH

LONG-TERM STORAGE AREA SUMMARY

RISK ASSESSMENT
MAY 28, 2020

Architect–Engineer Services for Dioxin
Remediation at Bien Hoa Airbase Area
Project
LONG-TERM STORAGE AREA SUMMARY

RISK ASSESSMENT
US Agency for International Development

MAY 28, 2020
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
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
2.3 ARSENIC 3
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
A–E SERVICES FOR DIOXIN REMEDIATION AT BIEN HOA AIRBASE AREA PROJECT
LONG-TERM STORAGE AREA SUMMARY RISK ASSESSMENT | i
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
LONG-TERM STORAGE AREA SUMMARY RISK ASSESSMENT | ii
ADAFC Air Defense - Air Force Command
As Arsenic
BW Body weight
cm Centimeter
d Day
DU Decision Unit
EFH Exposure Factors Handbook
EPC Exposure Point Concentration
EVSA Excess Volume Stockpile Area
g gram
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
ng nanogram
Pb Lead
PCB Polychlorinated biphenyl
PCDD Polychlorinated dibenzodioxins
PCDF Polychlorinated dibenzofurans
pg picogram
RfC Reference Concentration
RfD Reference Dose
SWTF Surface water transport factors
TCDD 2,3,7,8-Tetrachlorodibenzodioxin
TCDF 2,3,7,8-Tetrachlorodibenzofuran
TEF Toxic Equivalency Factor
UCL Upper confidence limit
ug microgram
LONG-TERM STORAGE AREA SUMMARY RISK ASSESSMENT | iii
US United States
LONG-TERM STORAGE AREA SUMMARY RISK ASSESSMENT | iv
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.
Key proposed LTSA design elements include:
• 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
As part of this evaluation, the following exposure pathways were evaluated:
• Groundwater Ingestion and Dermal Contact with Groundwater: COPCs present

in the LTSA may leach into groundwater and can result in exposure to human receptors via
drinking water ingestion or dermal contact with groundwater during bathing or showering
(and washing dishes or fruits/vegetables). These exposure pathways are complete for any
persons living on the Airbase, including local residents and resident Airbase personnel and
families.
• 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
LONG-TERM STORAGE AREA SUMMARY RISK ASSESSMENT | v
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).
LONG-TERM STORAGE AREA SUMMARY RISK ASSESSMENT | vi
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.
Key proposed LTSA design elements include:
• 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.
LONG-TERM STORAGE AREA SUMMARY RISK ASSESSMENT | 1
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.
2.1 HIERARCHY FOR SELECTING TOXICOLOGICAL CRITERIA

In accordance with recommendations outlined by USEPA (2003), the following hierarchy of sources
was considered in selecting toxicological criteria:
• Tier 1: USEPA’s IRIS

• Tier 2: USEPA’s Provisional Peer Reviewed Toxicity Values (PPRTVs) from the Office of
Research and Development/National Center for Environmental Assessment/Superfund
Health Risk Technical Support Center
• Tier 3: Other Toxicity Values, including USEPA and non-USEPA sources. Such sources
include the Agency for Toxic Substances and Disease Registry (ATSDR) minimal risk levels,
USEPA’s Health Effects Assessment Summary Tables, California Environmental Protection
Agency values, and other sources that are current, transparent and publicly available, and
have been peer reviewed.
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
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).

Under standard USEPA risk assessment procedures, toxicological criteria derivation and selection
reflect the conservative assumption that there is no threshold dose for carcinogenic effects;
however, it has been recognized that some carcinogens follow a nonlinear, threshold response in
which a level of exposure exists at which there is no increased risk of cancer within the exposed
population (USEPA 1989, USEPA 2005).
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).
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
3.1 EXPOSURE PATHWAYS

As part of this evaluation, the following exposure pathways were evaluated:
• Groundwater Ingestion and Dermal Contact with Groundwater: Dioxins/furans and

arsenic present in the LTSA may leach into groundwater and can result in exposure to human
receptors via drinking water ingestion or dermal contact with groundwater during bathing or
showering (and washing dishes or fruits/vegetables). These exposure pathways are complete for
any persons living on the Airbase, including local residents and resident Airbase personnel and
families. While currently groundwater from this portion of the airbase is not routinely utilized
for such purposes by local residents, the risk of future use of groundwater for this purpose
exists.
• 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.
3.2 SOURCE CONTAMINATION IN THE LTSA

For the evaluation of the LTSA, the PCDD/F exposure point concentration (EPC) was set equal to
1,200 ppt, which is the highest TEQ concentration allowed in the material placed in the LTSA. For
arsenic, an EPC based on the 95% UCLs for the soil and sediment data for those DUs identified for
remediation was calculated using the USEPA (2016) program ProUCL 5.1.
3.3 GROUNDWATER AND SURFACE WATER TRANSPORT ASSUMPTIONS

This assessment utilized the same methodology to estimate dioxin/furans and arsenic
concentrations in groundwater and surface water as used for the assessment of the Excess Volume
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.
3.4 GROUNDWATER TRANSPORT

This assessment estimates groundwater concentrations (GWBien Hoa) for PCDD/F (pg/L) and arsenic
(µg/L) by assuming this water is extracted from a well 50 m downgradient from the LTSA. These
concentrations are calculated using the following equation:
𝑮𝑮𝑮𝑮𝑩𝑩𝑩𝑩𝑩𝑩𝑩𝑩 𝑯𝑯𝑯𝑯𝑯𝑯 = 𝑮𝑮𝑮𝑮𝑮𝑮𝑮𝑮 × 𝑺𝑺𝑺𝑺𝑺𝑺𝑺𝑺𝑩𝑩𝑩𝑩𝑩𝑩𝑩𝑩 𝑯𝑯𝑯𝑯𝑯𝑯
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.
3.5 SURFACE WATER TRANSPORT

This assessment estimates surface water concentrations (SWBien Hoa) for PCDD/F (pg/L) and arsenic
(µg/L) by assuming this water is from a pond near the LTSA. These concentrations are calculated
using the following equation:
𝑺𝑺𝑺𝑺𝑩𝑩𝑩𝑩𝑩𝑩𝑩𝑩 𝑯𝑯𝑯𝑯𝑯𝑯 = 𝑺𝑺𝑺𝑺𝑺𝑺𝑺𝑺 × 𝑺𝑺𝑺𝑺𝑺𝑺𝑺𝑺𝑩𝑩𝑩𝑩𝑩𝑩𝑩𝑩 𝑯𝑯𝑯𝑯𝑯𝑯
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.
3.6 ESTIMATION OF FISH CONCENTRATIONS

This assessment estimates any future fish concentrations associated with the surface water
concentrations from transport from the LTSA (FISHBien Hoa) for PCDD/F (mg/kg) and arsenic
(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:
𝑭𝑭𝑭𝑭𝑭𝑭𝑭𝑭𝑩𝑩𝑩𝑩𝑩𝑩𝑩𝑩 𝑯𝑯𝑯𝑯𝑯𝑯 = 𝑩𝑩𝑩𝑩𝑩𝑩 × 𝑺𝑺𝑺𝑺𝑩𝑩𝑩𝑩𝑩𝑩𝑩𝑩 𝑯𝑯𝑯𝑯𝑯𝑯
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.
3.7 DOSE EQUATIONS
3.7.1 GROUNDWATER INGESTION

The potential exists for each receptor to ingest groundwater from the site. The doses associated
with ingestion were quantified according to the following equation:
𝑬𝑬𝑬𝑬𝑬𝑬𝒈𝒈𝒈𝒈𝒈𝒈𝒈𝒈𝒈𝒈𝒈𝒈𝒈𝒈𝒈𝒈𝒈𝒈𝒈𝒈𝒈𝒈 × 𝑬𝑬𝑬𝑬 × 𝑬𝑬𝑬𝑬 × 𝑰𝑰𝑰𝑰

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)
IR = Groundwater ingestion rate (L/day)
BW = Body weight (kilogram [kg])
3.7.2 DERMAL CONTACT WITH GROUNDWATER

The potential exists for each receptor to come into dermal contact with groundwater during bathing
or showering. The doses associated with dermal contact were quantified according to the following
equation:
ADD = Average Daily Doses for non-carcinogens (mg/kg-d)

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
DAevent = Dermally Absorbed Dose per event (mg/cm2–event)

EPCsurfacewater = Exposure point concentration for COPC in groundwater (mg/L)
ET = Exposure Time (hrs/day)
3.7.3 INCIDENTAL SURFACE WATER INGESTION

The potential exists for each receptor to incidentally ingest surface water during swimming or
wading. The doses associated with incidental ingestion were quantified according to the following
equation:
𝑬𝑬𝑬𝑬𝑬𝑬𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔 × 𝑬𝑬𝑬𝑬 × 𝑬𝑬𝑬𝑬 × 𝑬𝑬𝑬𝑬 × 𝑰𝑰𝑰𝑰

𝑨𝑨𝑫𝑫𝑫𝑫/𝑳𝑳𝑳𝑳𝑳𝑳𝑳𝑳 =

EPCsurfacewater = Exposure point concentration for COPC in surface water (mg/L)
IR = Surface water ingestion rate (L/hr)
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:


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
DAevent = Dermally Absorbed Dose per event (mg/cm2–event)

EPCsurfacewater = Exposure point concentration for COPC in surface water (mg/L)
3.7.4 FISH CONSUMPTION

The potential exists for local residents and resident airbase personnel and their families to
consume fish that may have been in surface water that was impacted by leaching or surface
runoff from the LTSA. The doses associated with fish consumption were quantified according to
the following equation:
𝑭𝑭𝑭𝑭𝑭𝑭𝑭𝑭𝑩𝑩𝑩𝑩𝑩𝑩𝑩𝑩𝑩𝑩𝑩𝑩𝑩𝑩 × 𝑪𝑪𝑪𝑪 × 𝑬𝑬𝑬𝑬 × 𝑬𝑬𝑬𝑬 × 𝑰𝑰𝑰𝑰


EPCDiet = Exposure point concentration for COPC in diet (mg/kg)
CF = Conversion factor (0.001 kg/g)
IR = Fish consumption rate (gram per day [g/day])
3.8 EXPOSURE PARAMETERS

The purpose of this section is to summarize the parameters used in estimating exposure and
calculating risk. A summary of all exposure parameters is provided in Table 1. 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). 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.
3.8.1 VIETNAMESE POPULATION-SPECIFIC EXPOSURE PARAMETERS
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.
SKIN SURFACE AREA

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). 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). For the evaluation of the
LTSA, 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 Table 1.
LOCAL FISH INGESTION RATES

Local diet ingestion rates were presented in the Tuyet-Hanh et al. (2015) study which included daily
consumption rates of meat, seafood, eggs, vegetables, and rice for adults in the Southeastern region
of Vietnam. Specifically, for the LTSA evaluation, the daily fish consumption rates for fresh water fish
were used for adults. 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 are presented in Table 1.
3.8.2 USEPA DEFAULT EXPOSURE PARAMETERS

The remaining exposure parameters were based on the USEPA recommended default exposure
parameters for residential exposure scenarios for adults and children (USEPA 2014). All exposure
parameters can be found in Table 1.
EXPOSURE DURATION
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).
GROUNDWATER AND SURFACE WATER INGESTION

OSWER default ingestion rates for resident drinking water ingestion were selected for the
groundwater ingestion pathway. The OSWER resident default drinking water ingestion rates were
selected for both the child and adult local residents and airbase residents and their families. The
adult resident drinking water rate was selected for the adolescent age group for the groundwater
ingestion pathway (USEPA 2014). For the LTSA evaluation, the USEPA (2011) default value for
incidental surface water ingestion for all age groups of 0.05 L/hr was used.
3.8.3 CHEMICAL-SPECIFIC EXPOSURE PARAMETERS
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
4.1 HAZARDS AND RISK FINDINGS

Table 2 presents the noncancer hazards for each age group, Table 3 presents the cancer hazards,
and Table 4 presents increased lifetime cancer risks associated with groundwater, groundwater as
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
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.
4.2 UNCERTAINTY ASSESSMENT

There is uncertainty associated with the estimation of the groundwater and surface water
concentrations that were derived from the evaluation of the EVSA at the Danang site to
characterize potential groundwater and surface water impacts from the LTSA at the Bien Hoa site.
The primary uncertainty relates to the differences in soil and groundwater properties between
Danang and Bien Hoa that will affect the potential for groundwater and surface water impacts from
the LTSA. Once site-specific data on the movement of water from the LTSA to groundwater and
surface water become available, this uncertainty may be reduced significantly. Based on the hazard
and risk calculations for this scenario, there is at least a 30-fold margin of safety in these estimates.
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.
JECFA (2002). Polychlorinated dibenzodioxins, polychlorinated dibenzofurans, and
coplanar polychlorinated biphenyls, Joint FAO/WHO Expert Committee on Food
Additives WHO Food Additives Series 48.
Lien, N. M. (1998). Compilation of Anatomical, Physiological and Metabolic Characteristics for a

Reference Vietnamese Man, Viet Nam National Atomic Energy Commission.
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.
Tuyet-Hanh, T. T., N. H. Minh, L. Vu-Anh, M. Dunne, L. M. Toms, T. Tenkate, M. H. Thi and F.

Harden (2015). "Environmental health risk assessment of dioxin in foods at the two most
severe dioxin hot spots in Vietnam." Int J Hyg Environ Health 218(5): 471-478.
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.
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 (2011). Exposure Factors Handbook, U.S. Environmental Protection Agency.
USEPA (2012). 2,3,7,8-Tetrachlorodibenzo-p-dioxin (TCDD); CASRN 1746-01-6. I. R. I. System,

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.
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
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
SURFACE WATER Adolescent Hazard Index 7E-08 3E-05 1E-03 1E-03 3E-05 3E-06 3E-03 3E-03 6E-05
ALL PATHWAYS Adolescent Hazard Index 4E-05 2E-04 1E-03 1E-03 2E-03 5E-06 3E-03 5E-03 2E-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
TABLE 3. SUMMARY OF CANCER HAZARD FROM LTSA
PCDD/Fs
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
SURFACE WATER Adolescent Hazard Index 2E-08 8E-06 5E-04 5E-04
ALL PATHWAYS Adolescent Hazard Index 1E-05 7E-05 5E-04 6E-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
TABLE 4. SUMMARY OF NONCANCER HAZARD, CANCER HAZARD, AND INCREASED LIFETIME CANCER RISK FROM LTSA
All
PCDD/Fs Arsenic
Chemicals
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
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
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

TECHNOLOGY EVALUATION AND
JUNE 1, 2020
ARCHITECT–ENGINEER SERVICES FOR DIOXIN REMEDIATION

TECHNOLOGY EVALUATION AND
US Agency for International Development

June 1, 2020
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 ................................................................................................. 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
FINAL TM – TECHNOLOGY EVALUATION AND RECOMMENDED TREATMENT METHODS
ARAR Applicable or Relevant and Appropriate Requirements
C Celsius
GAC Granular Activated Carbon
GFH Granular Ferric Hydroxide
IPTD In Pile Thermal Desorption
kg Kilogram
m Meters
M Million
m3 Cubic Meters
MCD Mechano-Chemical Destruction
MCS Matrix Constituent Separator
MPPE Modified Polyphenylene Ether
NAPL Non-Aqueous Phase Liquids
NOX Nitrogen Oxide
POPS Persistent Organic Pollutants
QCVN National Technical Regulation
TCVN Technical Committee of Vietnam (National Technical Standards)
TEQ Toxic Equivalents
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.
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.
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.
2.1 2016 BIEN HOA REMEDIAL TECHNOLOGIES EVALUATION

An environmental assessment of dioxin contamination at Bien Hoa Airbase was conducted in 2016
and is referred to here as the “2016 EA” (USAID 2016). The 2016 EA evaluated 22 remedial
technologies to address dioxin in soil at the Airbase. These technologies were screened with the
following three criteria:
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).
2.2 TECHNOLOGY REVIEW AND ADVANCEMENTS SINCE RELEASE OF THE EA

Since publication of the EA in 2016, there has been on-going efforts to review possible treatment
technologies. Some efforts have involved further evaluation of technologies originally eliminated from
consideration in the EA and others have been focused on further evaluation of technologies identified
for further consideration.
2.2.1 SOIL WASHING
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.
SHIMIZU SOIL WASHING PILOT TEST

In 2019, Shimizu, a Japanese firm, conducted a soil washing pilot test at the Bien Hoa Airbase to
demonstrate its effectiveness. It utilized a water-based process for physical separation of dioxin from
soil (Shimizu 2019). The results indicated that soil washing could not achieve the desired treatment
(≤100 ppt dioxin) as only one of 23 analytical samples of washed soil had a dioxin concentration less
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.
ECOSPEARS SOIL WASHING

To evaluate the potential to use a different liquid to produce different results, USAID also assessed an
approach developed by the remediation technology firm, ecoSPEARS. ecoSPEARS performs soil
washing, utilizing a two-stage organic solvent-based technology for soil washing. There is currently
insufficient data to suggest that ecoSPEARS’ soil washing technology can destroy dioxins at the range
of concentrations measured in soils and sediments at the Airbase to MND-approved limits. Therefore,
ecoSPEARS’ soil washing technology also confirmed the original conclusion of the 2016 EA to eliminate
soil washing from further consideration.
SOIL WASHING WITH PHOTOLYSIS

This technology has been proposed as an alternative to presumptive thermal remedies for the
remediation of sites with large-scale dioxin-impacted soils. Conceptually, this approach takes advantage
of the transport of particles to which dioxins are adsorbed, although dioxins themselves are
hydrophobic and tightly bound to soils. Dioxins tend to be strongly sorbed to the fine-grained material
within the soil matrix, and particularly the soil organic fraction. Bench testing demonstrated that 90ºC
water resulted in particle extraction comparable with a 100ºC solution of sodium hydroxide.
However, extraction varied significantly with soil type, wherein extraction was optimal in soils
containing less weathered organic matter. The most effective bench test was for a soil with 6%
relatively new organic matter where only 20% dioxins remained in soil following extraction.
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.
2.2.2 TCH TECHNOLOGY
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.
MATRIX CONSTITUENT SEPARATOR (MCS)

MCS is an ex situ TCH process that involves application of infrared heat to contaminated soils,
followed by subsequent recovery of targeted chemical constituents, based on the principles of
convection, conduction, radiant heating, air stripping, and vacuum extraction.
Thermodyne Technologies performed an MCS pilot test with soil from Bien Hoa to further confirm
the effectiveness of TCH on the soil conditions at the site. Results of the testing demonstrated the
MCS effectively reduced dioxin concentrations from above 15,000 ppt to below 2 ppt. This pilot test
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.
TERRATHERM IN-PILE THERMAL DESORPTION (IPTDTM) – KOREA.

Early in 2020, TerraTherm Asia performed IPTD at a pilot scale on dioxin impacted soils at a former
U.S. military base outside Seoul, South Korea utilizing horizontal heaters that reportedly simplified
construction, saved on materials, and improved the overall heating process. Using this design, IPTD
was employed to reach end dioxin concentrations 200 times lower than the 50 ppt goal for the specific
site. This result further confirms the 2016 EA conclusion that TCH remains a viable technology.
TERRATHERM ASIA HEATED BOX PILOT TESTING – BIEN HOA.

Early in 2020, TerraTherm Asia performed a heated box pilot test to evaluate the effectiveness in
destroying high concentration dioxins in soil from Bien Hoa Airbase. The heated box is a form of
TCH wherein soil is placed within a large insulated box, rather than an engineered concrete pile, which
is then heated to evaporate water, then further heated to desorb and remove dioxins. Off-gas is
directed through a thermal oxidizer for dioxin destruction.
A total of 45 m3 of saturated soil, consisting of silty clay filter cake from soil washing with 20 percent
organics, was placed in the box. Initial dioxin concentrations in the soil ranged from 8,000 to 20,000
nanograms-toxic equivalents per kilogram (ng-TEQ/kg) with an average concentration of 14,000 ng-
TEQ/kg. Nine horizontal heaters with boosted (hotter) ends were installed within the soil in the box.
The heaters were turned off at 50 days (less than the planned 21 days for dioxin treatment at or above
the target treatment temperature) based in part on favorable interim soil sample results, but also as
related to cease work requirements stemming from the COVID-19 virus. Final soil sample results
indicated 1.97 ng-TEQ/kg dioxins (30-point composite sample) as compared with the treatment goal
of 100 ng-TEQ/kg. At present, the final report for this work has not been issued as the team is waiting
for laboratory results for dioxins from off-gas sampling.
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
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:
• Bag house filters,

• Selective catalytic reduction (SCR) catalysts,
• Catalytic destruction and filter materials, and
• Electron irradiation processes.
Waste incinerator plants employ bag filters outfitted with activated carbon injection or fixed bed
carbon filters to meet dioxin emission criteria. SRC-catalysts are often employed for use in NOx
reduction but are also known to effectively destroy dioxins. Calco Environmental Engineering
commercialized ceramic filters that are extremely resistant to high temperatures/corrosion and are
employed for continuous removal of particulates in flue gas. Also, Gore and Associates proposed the
use of catalytic filters (REMEDIA D/F) wherein dioxins/furans in exhaust pass through a membrane
resulting in the instantaneous destruction of dioxins/furans yielding byproducts including CO2, H2O
and HCL (acid likely requires additional treatment as with scrubber).
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.
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.
3.1 TREATMENT TECHNOLOGY SELECTION PROCESS

At the subsequent Masterplan Roadmap Meeting No. 3, stakeholders agreed to apply the USAID
proposed two-stage selection process. The first stage involves screening each potential technology for
compliance with those agreed criteria identified as “critical.” For the technologies satisfying these
critical criteria, the second stage involves comparing technology options to the remaining non-critical
evaluation criteria, based on a rating system developed with stakeholder input. The consolidated list
of first stage screening and second stage evaluation criteria is included in Appendix 1.
3.2 STAGE 1: SCREENING CRITERIA

Stakeholders agreed on nine critical criteria in seven major categories. If a technology failed any one
of these, it was rejected from further consideration and therefore did not move into the second stage
of the process. The nine screening criteria included several sub-criteria under the following five (out
of seven) major categories. There were no critical criteria in category 4 (sustainability) or category 6
(residual risks):
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)
Cost
• Within budget (5B)
Acceptance
• GVN stakeholder acceptance (7A)
3.3 STAGE 2: EVALUATION CRITERIA

For the technologies passing all the screening criteria, it was agreed to evaluate remaining technologies
against the criteria listed below, by assigning them a rank of 1 – 3 (1 being least favorable and 3 being
most favorable). Then the rank was to be multiplied by the weight factor listed below, to calculate an
overall score for each technology. The process was designed, such that the technology with the highest
score would represent the recommended remedial technology. The criteria in category 1 (general)
were all identified as critical and addressed in Stage 1.
CATEGORY/CRITERIA WEIGHT FACTOR

Effectiveness
• Reducing dioxin mass (2A) 20%
• Consistent results per technology (2C) 7%
Implementability
• Ability to operate in dry and rainy seasons and tropical storms (3C) 7%
• Sensitivity to physical properties of soil and sediment (3D) 4%
• Availability of sufficient power/energy supply (3E) 2%
• Technology commercialized for POPS or have been tested on site (3F) 5%
• Ability to control the technology and easy to operate (3G) 6%
Sustainability
• Minimization of consumption of resources (4A) 9%
Cost
• Estimate of probable cost (5A) 11%
Residual Risks
• Minimization of byproducts (6A) 10%
• Need for LTM of ICs following implementation (6B) 8%
• Risk of explosion during treatment (6C) 5%
Acceptance
• Community acceptance (7B) 6%
100%
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.
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.
4.3 PLASMA ARC AND PYROLYSIS

Although plasma arc and pyrolysis technology is mature and established, it is anticipated that it cannot
be implemented in a cost-effective manner due to projected high energy and waste stream treatment
costs. This technology creates a thermal plasma field by applying a large electric current through an
oxygen-deficient gas, with the resistivity of the gas resulting in temperatures of 3,000°C or higher.
Cost data presented in the 2016 EA for this technology, however, indicated that the cost could be
approximately $4,000 per metric ton. Assuming a soil density of approximately 1.5 metric tons/m3,
the estimated cost to treat 408,500 m3 of soil would be approximately $2,451M. The excessive costs
associated with plasma arc and pyrolysis fail the budget criteria and result in an unfavorable assessment
by the GVN stakeholders, as well.
4.4 BASE CATALYZED DESORPTION

Although base catalyzed desorption is a mature and established technology, it is anticipated that it
cannot be implemented cost-effectively, due to high energy and waste stream treatment costs. In base
catalyzed desorption, dioxin is desorbed from contaminated soil using heat and sodium bicarbonate
to form a dioxin-contaminated condensate. The condensate is mixed with sodium hydroxide,
hydrocarbons, and other reagents, causing a reaction that dechlorinates the dioxin. The process also
generates large quantities of waste that would require management by methods such as landfilling,
recycling, and/or reuse. In 2018, costs for base catalyzed decomposition in combination with thermal
desorption were found to be between $2,320 – 5,205 per tonne. (USAID 2018). The high costs and
waste handling requirements were considered unacceptable by the GVN for the Da Nang Airport
remediation project and are assumed to be unacceptable for this project as well.
4.5 SUPERCRITICAL AND SUBCRITICAL WATER TREATMENT

Water in a supercritical state (above 374°C and 22 megapascals pressure) can be used to facilitate
oxidation of organics. Similarly, subcritical water (heated above 100°C and pressurized into a liquid)
can be used to extract dioxin from soils and sediments. However, both of these processes must be
performed in the aqueous phase, which means all soil would have to be mixed with very large quantities
of water to dissolve or suspend all solids requiring treatment. The treated soil would then have to be
dewatered and dried before being reused or otherwise managed—with the extracted water also likely
requiring treatment for residual soil particles.
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
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.
4.6 GAS-PHASE CHEMICAL REDUCTION

Gas-phase chemical reduction mixes hydrogen gas with chlorinated organic compounds, such as PCBs,
at temperatures above 850°C and low pressure, yielding methane, hydrogen chloride, and minor
amounts of other low molecular-weight hydrocarbons. Although this process has demonstrated
effectiveness, the gas-phase chemical reduction process is known to have high reagent needs, low
throughput, high-energy costs, and a high degree of complexity. Previous studies for this project
estimated a cost for gas-phase chemical reduction to be $1,539 per metric ton, which did not include
contractor overhead and profit, or capital and decommissioning costs. Consequently, this technology
was not expected to be cost-competitive with other technologies. The excessive costs associated with
gas-phase chemical reduction fail the budget criteria and result in an unfavorable assessment by the
GVN stakeholders, as well.
4.7 MECHANO-CHEMICAL DESTRUCTION (MCD)

MCD is discussed in this section since it was originally identified as a viable technology in the 2016 EA.
However, as a result of assessing MCD against the screening criteria, it failed five of the nine criteria
in this assessment. MCD is a reasonably quick process, does not require the use of toxic or expensive
chemicals, has low energy requirements, and reportedly can achieve destruction/removal efficiencies
up to 99.99% for PCDD/Fs. However, the scalability of this approach has been a notable limitation
for application to sites with large volumes of impacted soil. Moreover, a 2012 study performed by
UNDP (Cook 2015) found that the effectiveness of the process was sensitive to dioxin concentrations
in the feed soil such that optimal destruction/removal efficiencies were not reliably achievable. These
current limitations of this technology suggest that it may not be as cost effective as anticipated and
treated soils may not ultimately be reusable if dioxin concentrations remain above acceptable limits.
These issues with effectiveness and related concerns of the GVN stakeholders result in the elimination
of further consideration of MCD as a viable technology for the Bien Hoa Airbase.
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.
TABLE 5-1. STAKEHOLDER QUESTIONS REGARDING TCH TECHNOLOGY
# 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.
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.
6.1 STAGE TWO EVALUATION OF TCH OPTIONS

While TCH is the selected remedial treatment technology, there are a number of ways this technology
can be configured including:
• Ex situ or in situ applications;

• Large constructed ex situ pile(s) or smaller container treatment approach(es);
• Standard vapor extraction or higher vacuum;
• High-temperature in-pile destruction or lower-temperature desorption, followed by off-gas
treatment;
• Vapor treatment via thermal oxidizer or granular activated carbon (GAC);
• Various primary power sources, including fuel (kerosene/diesel) or electric; and/or
• Various leachate/condensate treatment options.
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.
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
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.
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
USEPA. 2010. Reference Guide to Non-combustion Technologies for Remediation of Persistent

Organic Pollutants in Soil, Second Edition.
APPENDICES
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
Tính hiệu quả

Effectiveness
2A. Giảm lượng dioxin 20% 5% 25% 30% 20% 20%

2.A. Reducing Dioxin Mass
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
2C. Xử lý tới các ngưỡng nền cho dioxin 5% 5% Có/Không 0%

2C. Treat to background levels for dioxin Yes/No
2D. Xử lý dioxin phải triệt để theo QCVN & TCVN

2D. Treatment of dioxin must be completely as QCVN & TCVN Có/Không 0% Có/Không Có/Không Có/Không
Yes/No Yes/No Yes/No Yes/No
2E. Chất thải tồn dư phải được xử lý/tiêu hủy hoàn toàn (không phát sinh chất gây nhiễm) 5% Có/Không Có/Không Có/Không Có/Không
2E. By-products must be completely treated/destroyed (don't create other contaminants) Yes/No Yes/No Yes/No Yes/No
2F. Công nghệ sử dụng tất cả phương án xử lý phải nhất quán

5% 5% Có/Không 10% 7%
2F. Consistent results per technology
Yes/No
Tính khả thi

Implementability
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
3G. Khả năng kiểm soát công nghệ và dễ vận hành

8% 5% 5% 5% 6%
3G. Ability to control the technology and easy to operate
Tính bền vững

Sustainability
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
5B. Trong phạm vi kinh phí 10% Có/Không 0% Có/Không Có/Không

5B. Within budget Yes/No Yes/No Yes/No
Rủi ro tồn dư (khó khăn)

Residual Risks (challenges)
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
6C. Rủi ro cháy nổ trong quá trình xử lý 2% 13% 2% 5% 5%

6C. Risk of expolosion during treatment
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
7.B. Chấp thuận từ cộng đồng 5% 5% Có/Không 7% 5% 6%

7.B. Community Acceptance Yes/No
TỔNG
100% 100% 100% 100% 100% 100%
TOTAL
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.
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.
Uses strong electric fields to cause molecular disassociation, at non-elevated

NON-THERMAL PLASMA temperatures, and induce formation of radicals and degradation of dioxin.
Process by which biological plant growth and respiration induces dioxin removal from
PHYTOREMEDIATION and/or degradation in soils and sediments
MYCOREMEDIATION Relies on fungal growth and respiration to degrade dioxin.
Note:
Basic descriptions summarized from 2016 Environmental Assessment
APPENDIX 3. OUTPUT FROM REMEDIAL TREATMENT TECHNOLOGIES SCREENING
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
LANDFILLS, SOLIDIFICATION, AND IN SITU VITRIFICATION
- Temporarily eliminates exposure risk - Effective for wide range of dioxin - Process relatively quick, but likely -Less expensive as compared with Stakeholders likely to prefer more No full-scale demonstrations
to dioxin impacted soils by vitrifying concentrations in soil/sediment requires treatment of small volumes at more pernanent solutions permanent solution for dioxin impacted soil
(melting) the soil containing dioxins, - Melts soil to contain dioxins, but does a time - Applicatiion of more expensive, but identified, and questionable
thus preventing leaching or other not result in destruction of dioxins - May alter soil characteristics if used more permanent technologies may be long term effectiveness
routes of exposure - Potential need for long-term on- site that are outside of better investment
VITRIFICATION - Potential long-term risks for this remediation on processed soil geotechnical requirements for - UNDP (2009b) reports ex situ
X process that does not result in X - Past examplers where was not X development X system development (90 ton per day), X X
permanent destruction of dioxins successful (UNDP 2009a) - During Danang Airport EA, no full- but very expensive due to energy
scale examples identified, and no requirements -
similar recent work identified $700 per cubic meter (BEM 2007)
INCINERATION AND THERMAL DESORPTION METHODS
- For excavated soils, exposure - Effective for high dioxin Scalable for large volumes of soil Costs associated with incineration are Stakeholders may not accept - While demonstrated for full-
pathways to soil/sediment will be concentrations in soil Estimate 8-years for alternative expected to be greater than those generation of waste products (fly scale treatment of dioxin-
eliminated - Can achieve up to 99.9999% - Rotary kiln capable of processing associated with TCH technologies. As ash/bottom ash), and potential impacted soil, is one of the
- Capable of meeting dioxin limits for destruction efficiency 8,100 m3 per month presented in the 2016 EA, the pollution in exhaust most expensive technologies,
soil/sediment - Potential generation of toxic residuals Equates to 29 months of operation for incineration of the base soil volume of results in fly ash and bottom
• - Risks associated with generation of ash • (solid, liquid, and gas) • Pacer Ivy Area targeted to receive 408,500 m3 was estimated to cost ash that requires management,
INCINERATION requiring stabilization/disposal - ineffective if high water content in 236,100 m3 under this alternative $666M. Based on a soil density of 1.5 and would require natural gas
- Risks associated with potential exhaust soils (must operate in dry season) Requires natural gas to operate (no tonne/m3, this equates to an estimated (no current natural gas supply
from incinerator natural gas service currently in these X unit cost of $1,087 per tonne. X X to the Airbase)
- Generates the highest greenhouse gas areas) - On-site incineration were found to
emissions of any technology - Need to consider altered range from $649 – 4,967 per tonne
geochemical properties of soil as (USAID 2018).
applicable for reuse
- Exposure risk to dioxins in fly ash - Hydrothermal treatment (300 C) of - Not applied at full-scale For soil treatment, not expected to be Stakeholders unlikely to accept Not applicable for full-scale
significantly reduced fly ash in a solution of sodium cost effective base on need to process technology not proven at field scale treatment of dioxin-impacted
Capable of meeting ARARs hydroxide and methanol was effective sois into and out of the aqueous phase soil
HYDROTHERMAL in reducing dioxins in fly ash from for treatment
TREATMENT (mostly 1100 ng/g to 0.45 ng/g total dioxins.
for fly ash) X X - One study for soil treatment X X X X
reported reduction from 1,100 ng/g
total dioxins to
0.45 ng/g (Kulkarni 2008 and Ma 1997)
- Exposure risk from dioxins in fly ash Typically applied for fly ash, not soil - Not applied at full-scale - Developing technology as applied to Stakeholders unlikely to accept Not applicable for full-scale
reduced but not eliminated - Most effective at very low dioxin dioxins that may provide cost effective technology not proven at field scale treatment of dioxin-impacted
Possibly can meet ARARs concentrations treatment of fly ash soil
- May be more effective on less - low maintenance and low
chlorinated dioxins (TCDD) with lesser temperatures reduce costs
NON-THERMAL removal of more chlorinated PCDD/Fs no requirement for auxiliary fuel
PLASMA - DRE for TCDD shown to be 81% in
(for fly ash) X X one test X X X X
- One study reported 81% DRE for
total dioxin in fly ash resulting from
incineration (Oda 2006)
TREATMENT
FOR DIOXINS IN
SOIL/SEDIMENT
- 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
PHYSICAL SEPARATION METHODS (SOIL WASHING)

SOIL WASHING/ - For excavated soils, exposure - Applicable for moderate - Not applied for large volumes of Costs likely high associated with use Community unlikely to accept use of Not demonstrated for full-
LIQUIFIED-GAS pathways to soil/sediment will be concentrations of dioxins dioxin- impacted soil of liquified gas for treatment of large large volumes of liquified gas in the scale application for the
EXTRACTION largely eliminated 98% RE observed using propane moderately fast process volumes of dioxin-impacted soil process treatment of dioxin-impacted
- Capable of meeting dioxin limits for - Reportedly less effective for soils with - No known full-scale applications soil
soil/sediment higher fractions of silt./clay and that have addressing dioxin-impacted soils with •
- Risks associated withhandling waste high organic content (BEM 2007) concentrations observed at the Airbase
solvent generated during - Results in wastewater stream requiring - Best implemented during dry season
X implementation X additional treatment X where water content of soil is minimal X X
- Short term exposure risk associated
with handling of liquified gas
STEAM - Exposure risk likely to remain in -Primarily tested for PCB-impacted soil Not tested for full-scale application for Cost efficient based on use of Stakeholder likely to reject technology Not demonstrated for full-
DISTILLATION partially treated soils - Testing for dioxin-impacted soil high dioxin-impacted soil remediation moderate temperatures and that has not been demonstated at full- scale application for the
- Short term exposure risk from RE for DCDD, but low DE (30%) for maintenance of soil properties scale application and that has treatment of dioxin-impacted
generation of concentrated dioxin tetra- through octa-CDD/Fs allowing reuse demonstrated poor dioxin treatment soil
waste that requires disposal - Results suggest only loosely bound and efficiency
Unlikely to meet ARARs readily accessiible dioxins were removed
- One study reported 95% DRE for
DCDD in soil
X X - Generates dioxin concentrate that X X X X
requires disposal
TREATMENT
FOR DIOXINS IN
SOIL/SEDIMENT
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
TREATMENT
TECHNOLOGY FOR X Reject FINDINGS AND
DIOXINS IN
SOIL/SEDIMENT
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
TREATMENT
DIOXINS IN
SOIL/SEDIMENT
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
TREATMENT
DIOXINS IN
SOIL/SEDIMENT
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
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
2A. Giảm lượng dioxin

20% 3 0.60
2.A. Reducing Dioxin Mass
2F. Công nghệ sử dụng tất cả phương án xử lý
phải nhất quán 7% 3 0.20
2F. Consistent results per technology
Tính khả thi
Implementability
3.C. Khả năng hoạt động trong mùa khô và mưa
3.C. Ability to Operate in Dry and Rainy Seasons and 7% 2 0.14
tropical storms
3D. Tính nhạy cảm đối với lý tính của đất và trầm
tích
4% 2 0.08
3D. Sensitivity to physical properties of soil and
sediment
3E. Cần xem lại sự có sẵn của nguồn cung cấp đủ
điện/năng lượng
2% 2 0.04
3E. Should consider the availability of sufficient
power/energy supply
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 5% 2 0.11
3F. Treatment technology should be commercialized
for POPS or have been tested on site
3G. Khả năng kiểm soát công nghệ và dễ vận
hành
6% 2 0.12
3G. Ability to control the technology and easy to
operate
Tính bền vững
Sustainability
4.A. Giảm thiểu tiêu thụ nguồn nguyên nhiên liệu

9% 2 0.18
4.A. Minimization of Consumption of Resources
Chi phí
Cost
5.A. Dự kiến chi phí khả dĩ

11% 2 0.23
5.A. Estimate of Probable Cost
Rủi ro tồn dư (khó khăn)

Residual Risks (challenges)
6.A. Giảm thiểu phát thải tồn dư

10% 2 0.20
6.A. Minimization of Byproducts
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
7.B. Chấp thuận từ cộng đồng

6% 3 0.17
7.B. Community Acceptance
TỔNG
100% 2.45
TOTAL
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.
ASSUMPTION LESSON LEARNED FROM DANANG AIRPORT REMEDIATION

Pilot Testing
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.
Needs to be addressed prior to full scale implementation. Elevated levels of

Arsenic
arsenic were found and needed to be dealt with.
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.
Compounds with a low odor threshold resulted in complaints from

Compounds below threshold would not surrounding communities. Conducted measuring, provided fact sheet,
create issues. presented data and afterwards odor began to dissipate as treatment had
burned off VOCs.
There were not accurate assumptions about the off-gas concentration

Off gas assumptions
estimations. Need to have a better handle on these.
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.
• 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:
• 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.
WASTE GENERATION, MATERIAL REUSE, AND DEMOBILIZATION

While safe and effective destruction of dioxin is the primary goal, the creation and handling of secondary
waste streams should be considered, including:
• 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.
PROJECT MATERIAL DISPOSITION

APPROACH
AUGUST 31, 2020

DISCLAIMER
DIOXIN REMEDIATION
PROJECT MATERIAL DISPOSITION

APPROACH

AUGUST 31, 2020

USA
DISCLAIMER
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

PROJECT MATERIAL DISPOSITION APPROACH
1 INTRODUCTION
Many different materials and equipment will be used throughout the Project. Some materials are on the
Airbase already, e.g., excavated soil, 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.
The Environmental Remediation at Danang Airport Project was the first of its kind in Vietnam, and one
of the largest conducted worldwide. As a result, there were no defined criteria/action levels established
for safe reuse of materials with residual dioxin concentrations below the Government of Vietnam (GVN)
thresholds for hazardous waste. There were no licensed dioxin hazardous waste disposal facilities in
Vietnam (other than the project activities). Nor were there defined processes in place to guide the
disposition of materials. The United States Agency for International Development (USAID), its
Implementing Contractors, and GVN counterpart, Air Defense Air Force Command (ADAFC), worked
together to define these items. The following builds on that experience, including the need to identify
disposition issues early on, and summarizes the approach, disposition categories, materials types, and
threshold criteria for final disposition for the Dioxin Remediation at Bien Hoa Airbase Area Project.

2 APPROACH
This disposition approach incorporates the following objectives: prevent and minimize waste, consider
material source to prevent and minimize waste disposed on the airbase, and maximize safe reuse. To
achieve this the following considerations will be made throughout the Project.
– Waste prevention and minimization
• Design to use materials that are resistant to contamination and/or amenable to cleaning;
• Intermediate waste should be treatable by thermal conductive heating (TCH), if cleaning is not
practicable;
• Minimize packaging and waste generation;
• Limit repeated handling; and
• Prevent spills through proper maintenance and minimize impacts with secondary containment.
– Material source consideration
• Materials imported to the Project area must be reused or disposed of off the airbase to the
maximum extent practicable; and
• After waste prevention and minimization, existing material within Project boundaries can be
disposed on the airbase. This may include vegetation debris, uncontaminated construction
debris, and non-hazardous material with dioxin and/or arsenic below levels of concern.
– Safe reuse maximization
• Consider cleaning procedures for materials in final designs. Procedures should be developed
before materials are used. This is of particular concern for materials in contact with high dioxin
concentrations during treatment; and
• Establish disposition categories and the applicable action levels.
2.1 DISPOSITION CATEGORIES

As shown in Figure 1, the following three disposition categories are established:
– 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.
– 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.

2.2 MATERIAL TYPES
Three material types are established that take into consideration the material’s condition and potential
disposition (Figure 1). 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. .
– 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.

3 RESIDUAL CONTAMINATION ACTION LEVELS
For the Danang Project, USAID researched international regulatory limits that could be used as action
levels and evaluated possible sampling methods to safely manage equipment or materials leaving the site
(CDM Smith 2017). The proposed residual contamination action levels were presented to ADAFC in a
letter dated 06/14/17. ADAFC submitted the plan to Vietnam Ministry of Natural Resources and the
Environment (MONRE) for approval in December 2017. For the Bien Hoa Project, USAID proposes
similar action levels. The proposed dioxin action levels are (changes from Danang are noted):
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.
3.3 MATERIAL DISPOSITION PLANS

A wide range of materials will be used to implement the Project. 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.
3.4 REQUIRED DISPOSITION PROCEDURES

USAID will require all Material Disposition Plans to use the following procedures:
1. The Implementing Contractor must decontaminate the material (if necessary and possible).
2. The Architect & Engineering Services/Construction Management Contractor or the Implementing
Contractor will sample the material and determine the residual dioxin and arsenic contamination.
3. If the dioxin or arsenic contamination exceeds targeted action levels, Steps 1 and 2 may be repeated.
4. USAID will provide split samples collected in Step 2 to ADAFC for independent analyses within three
(3) weeks of notification. In the event of any discrepancies, USAID and ADAFC will agree on a plan
of action in a timely manner, e.g., reanalysis, resampling, additional cleaning, etc.
5. The Implementing Contractor must prepare a Material Disposition Letter (MDL) for all items
remaining on the Airbase or leaving the Airbase and submit to USAID and ADAFC for review and
approval. The MDL must include: an identification code linking it to the master list; description and
quantity of the item; proposed destination, including licenses and permits for disposal facilities;
estimated scrap value (if applicable); and, residual dioxin and arsenic test results.
6. Prior to moving any material offsite, the Implementing Contractor must identify the items to ADAFC’s
representative or designee, who cross-checks the items with the approved MDL.
7. Finally, the Implementing Contractor disposes of the material in accordance with the approved MDL
under the supervision of USAID’s Architect & Engineering Services/Construction Management
Contractor.
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.

ANNEX 9 – THE PROJECT’S ACRONYMS AND ABBREVIATIONS

PROJECT ACRONYMS & ABBREVIATIONS
APRIL 2, 2020
PROJECT ACRONYMS &

ABBREVIATIONS

APRIL 2, 2020
PREPARED BY
USA
DISCLAIMER
CONTENTS
CONTENTS i
UPDATES ii
PREAMBLE 1
ACRONYMS & ABBREVIATIONS 1
ARCHITECT-ENGINEER FOR DIOXIN REMEDIATION AT BIEN HOA AIRBASE AREA PROJECT

PROJECT ACRONYMS & ABBREVIATIONS | i
UPDATES
UPDATE DATE PAGES SUMMARY OF UPDATES APPROVAL
000 April 2, 2020 All Project Acronyms & Abbreviations USAID COR

PROJECT ACRONYMS & ABBREVIATIONS | ii
PREAMBLE
This document provides a list of acronyms and abbreviations intended for use in the Dioxin
Remediation at Biên Hòa Airbase Area Project. This is a living document, subject to updates
with time, with the goal of obtaining stakeholders’ comments and including all Project related
terminologies.
ACRONYMS & ABBREVIATIONS

Project Acronyms & Abbreviations are listed in both English and Vietnamese languages with
linguistically equivalent descriptions. The list is alphabetized by acronym/abbreviation.
NO ENGLISH DESCRIPTION VIETNAMESE DESCRIPTION

1. °C degrees Celsius °C độ C
2. °F degrees Fahrenheit °F độ F
3. µg/L micrograms per liter µg/L microgam trên lít
2,4,5-trichlorophenoxyacetic 2,4,5-trichlorophenoxyacetic acid
4. 2,4,5-T 2,4,5-T
acid (chất diệt cỏ)
2,4- dichlorophenoxyacetic chất 2,4- dichlorophenoxyacetic
5. 2,4-D 2,4-D
acid acid
6. 3D three-dimensional 3D 3 chiều
temperature, time and nhiệt độ cháy, thời gian cháy và độ
7. 3T 3T
turbulance trộn lẫn với oxy
8. 95UCL 95% upper confidence level 95UCL giới hạn tin cậy trên 95%
9. Ǻ angstrom Ǻ angstrom
10. A&E Architect & Engineer TV&TK Tư vấn & Thiết kế
11. A&E Contractor Trigon Associates, LLC. Nhà thầu TV&TK Trigon Associates, LLC.
Assistant Administrator,
12. AA/M AA/M Trợ lý Hành chánh, Cục quản lý
Bureau for Management
13. ABS dermal absorption from soil ABS hấp thụ qua da từ đất
fraction of contaminant
tỷ lệ chất gây nhiễm hấp thụ qua da
14. ABSd absorbed dermally ABSd
(không thứ nguyên)
(dimensionless)
fraction of contaminant
tỷ lệ chất gây nhiễm hấp thụ qua
15. ABSGI absorbed in gastrointestinal ABSGI
đường ruột (không thứ nguyên)
tract (dimensionless)
16. AC alternating current AC dòng điện xoay chiều
17. ACC American Chemistry Council ACC Hội đồng Hóa chất Hoa Kỳ
18. ACF Agricultural Credit Facility ACF Cơ sở Tín dụng nông nghiệp
19. ACI American Concrete Institute ACI Viện Nghiên cứu bê tông Hoa Kỳ
20. ACR Activity Completion Report ACR Báo cáo Hoàn thành hoạt động
Air Defense - Air Force Bộ Tư lệnh Phòng không – Không
21. ADAFC BTLPK-KQ
Command quân
22. ADB Asian Development Bank ADB Ngân hàng Phát triển Á châu
Implementation Plan
23. Addendum Addendum Phụ lục Kế hoạch thực hiện
Addendum
Hệ thống Chỉ thị tự động, Hệ thống
24. ADS Automated Directives System ADS
Quy định bắt buộc
automated external
25. AED AED máy sốc tim tự động
defibrillator
adherence factor of soil to skin hệ số bám dính đất vào da
26. AF AF
(mg/cm2-event) (mg/cm2-lần)
Air Force Center for Trung tâm Không lực Kỹ thuật Môi
27. AFCEE AFCEE
Environmental Excellence trường

PROJECT ACRONYMS & ABBREVIATIONS | 1
28. AHA Activity Hazard Analysis AHA Phân tích Mối nguy trong hoạt động
Quy định Đấu thầu mua sắm của
29. AIDAR USAID Acquisition Regulation AIDAR
USAID
American Industrial Hygiene Hiệp hội Vệ sinh công nghiệp Hoa
30. AIHA AIHA
Association Kỳ
31. Airbase Biên Hòa Airbase Sân bay Sân bay Biên Hòa
Administrative Management
32. AMS AMS Nhân sự Quản lý hành chánh
Staff
Academy of Military Science
33. AMST VKHCNQS Viện Khoa học công nghệ quân sự
and Technology
American National Standards
34. ANSI ANSI Viện Tiêu chuẩn quốc gia Hoa Kỳ
Institute
35. AO agent orange AO chất da cam
36. AOWG Agent Orange Working Group AOWG Nhóm Đối thoại chất da cam
Asia-Pacific Economic Tổ chức Hợp tác kinh tế Châu Á -
37. APEC APEC
Cooperation Thái Bình Dương
38. APR Annual Project Report APR Báo cáo Năm
39. APS Annual Program Statement APS Báo cáo Chương trình năm
40. AQC air quality control AQC kiểm soát chất lượng không khí
Applicable, Relevant, and Các Quy định và tiêu chuẩn phù
41. ARARs ARARs
Appropriate Regulations hợp, các Quy định cần áp dụng
42. ARV antiretroviral (drugs) ARV kháng virus (thuốc)
American Society of Civil
43. ASCE ASCE Hiệp hội Kỹ sư xây dựng Hoa Kỳ
Engineers
Association of Southeast Asia
44. ASEAN ASEAN Hiệp hội các quốc gia Đông Nam Á
Nation
45. asl above sea level asl trên mực nước biển
American Society of
46. ASME ASME Hiệp hội Kỹ sư cơ khí Hoa Kỳ
Mechanical Engineers
47. AST aboveground storage tank AST bồn chứa nổi
Hội Kiểm định – vật liệu Hoa Kỳ,
American Society for Testing
48. ASTM ASTM Hiệp hội Thí nghiệm và vật liệu Hoa
and Materials Kỳ
49. AT averaging time (days) AT thời gian trung bình (ngày)
Agency for Toxic Substances Cục Quản lý đăng ký chất độc hại
50. ATSDR ATSDR
and Disease Registry và bệnh tật Hoa Kỳ
51. AWP Annual Workplan AWP Kế hoạch Thực hiện năm
tiêu chí chất lượng môi trường
52. AWQC ambient water quality criteria AWQC
nước xung quanh
53. BA bioavailability BA sinh khả dụng
best available control công nghệ kiểm soát tốt nhất sẵn
54. BACT BACT
technology có
công nghệ kiểm soát tốt nhất sẵn
best available technique/best
55. BAT/BEP BAT/BEP có/Biện pháp xử lý môi trường tối
environmental practice ưu
56. BBP blood-borne pathogen BBP mầm bệnh truyền qua đường máu
57. BCD base-catalyzed decomposition BCD phân hủy xúc tác base
58. BCF bioconcentration factor BCF hệ số tích tụ sinh học
59. BEO Bureau Environmental Officer BEO Nhân viên Môi trường Cục
60. BEO Bureau Environment Officer BEO Trưởng ban Môi trường Cục
61. bgs below ground surface bgs dưới mặt đất
62. BHC benzene hexachloride BHC benzene hexachloride
63. BHL Biên Hùng Lake HBH Hồ Biên Hùng
thông lệ quản lý tối ưu, thực hành
64. BMP best management practice BMP
quản lý tối ưu
nhu cầu oxy sinh học, nhu cầu
65. BOD biological oxygen demand BOD
dưỡng khí sinh học

66. BPM beats per minute BPM nhịp trên phút
67. BRA baseline risk assessment BRA Đánh giá rủi ro nền
68. BT body temperature BT thân nhiệt
benzene, toluene, benzene, toluene, ethylbenzene,
69. BTEX BTEX
ethylbenzene, and xylene and xylene
70. btos below top of sediment btos dưới lớp mặt trầm tích
71. BTU British thermal unit BTU Đơn vị nhiệt Anh
British thermal unit per cubic
72. BTU/cubic ft BTU/cubic ft Đơn vị nhiệt Anh trên feet khối
foot
73. BTV baseline threshold value BTV giá trị ngưỡng nền
74. bw body weight bw trọng lượng cơ thể
75. bw/d body weight per day bw/d trọng lượng cơ thể trên ngày
compression, cooling, and
76. C3 C3 nén, làm lạnh và ngưng tụ
condensation
77. CAA Clean Air Act CAA Luật Không khí sạch
Civil Aviation Administration of Cục Hàng không dân dụng Việt
78. CAAV CAAV
Vietnam Nam
79. CARC carcinogenic CARC gây ung thư
Center on Analytical Services Trung tâm Dịch vụ phân tích thí
80. CASE CASE
and Experimentation nghiệm
California Stormwater Quality Hiệp hội Chất lượng mước mưa
81. CASQA CASQA
Association California
82. Cat-Ox catalytic oxidizer Cat-Ox oxy hóa có xúc tác
83. CB chlorobenzenes CB chlorobenzenes
84. CBC complete blood count CBC huyết đồ
85. CC Chemical Command BTLHH Bộ Tư lệnh Hóa học
86. CC Communication Component CC Hợp phần Truyền thông
Communications & Capacity Phụ trách Truyền thông & xây dựng
87. CCBM CCBM
Building Manager năng lực
88. CDC Centers for Disease Control CDC Trung tâm Kiểm soát dịch bệnh
Country Development and Chiến lược Phát triển hợp tác quốc
89. CDCS CDCS
Cooperation Strategy gia
Community Driven Chương trình Phát triển dựa vào
90. CDD CDD
Development cộng đồng
Community Development
91. CDO CDO Chuyên viên Phát triển cộng đồng
Officer
United Nations Convention on Công ước Liên hợp quốc về Xóa bỏ
92. CEDAW the Elimination of CEDAW mọi hình thức phân biệt đối xử đối
Discrimination against Women với phụ nữ
center point between thermal tâm điểm giữa các giếng gia nhiệt
93. Centroid Centroid
conductive heating wells truyền dẫn nhiệt
Comprehensive Environmental Luật Ứng phó, bồi thường, chịu
94. CERCLA Response, Compensation, and CERCLA trách nhiệm môi trường toàn diện
Liability Act Hoa Kỳ
Research Centre for
Trung tâm Nghiên cứu công nghệ
95. CETASD Environmental Technology and CETASD
môi trường và phát triển bền vững
Sustainable Development
96. CF conversion factor CF hệ số quy đổi
Committee for the Ủy ban quốc gia vì sự tiến bộ của
97. CFAW CFAW
Advancement of Women phụ nữ Việt Nam
Canadian Food Inspection
98. CFIA CFIA Cục Giám định thực phẩm Canada
Agency
99. cfm cubic foot per minute cfm foot khối trên phút
Code of Federal Regulations, Bộ luật các Quy định Liên bang
100. CFR CFR
United States Hoa Kỳ

Community Health Extension
101. CHEWs CHEWs Nhân viên Y tế cộng đồng
Workers
102. CLIN contract line item number CLIN số hạng mục hợp đồng
103. CM Construction Manager CM Chỉ huy trưởng công trường
104. cm centimeter cm xentimét
Contractor Construction
105. CMC CMC Quản lý thi công của Nhà thầu
Management
106. CMU concrete masonry unit CMU khối vữa bê tông
107. CO Contracting Officer CO Chuyên viên Hợp đồng
carbon dioxide (chemical
108. CO2 CO2 carbon dioxide (công thức hóa học)
formula)
109. CO2e carbon dioxide equivalent CO2e carbon dioxide tương đương
110. COC Chemical of Concern COC Hóa chất quan ngại
111. COC Chain of Custody COC Chuỗi lưu ký
112. COD chemical oxygen demand COD nhu cầu ôxy hóa học
113. COP Chief of Party COP Chủ nhiệm Dự án
Contaminant of Potential
114. COPC COPC Chất gây nhiễm tiềm ẩn quan ngại
Concern
Contracting Officer's
115. COR COR Đại diện Chuyên viên Hợp đồng
Representative
116. CP Communication Plan CP Kế hoạch Truyền thông
carcinogenic polynuclear
117. cPAH cPAH hydrocarbon thơm đa nhân
aromatic hydrocarbons
Contractor Performance Báo cáo Đánh giá thực hiện của
118. CPARs CPARs
Assessment Reports Nhà thầu
Committee for Population,
119. CPFC UBDSGĐTE Ủy ban Dân số, gia đình và trẻ em
Family and Children
120. CPM Contractor Project Manager CPM Giám đốc Dự án Nhà thầu
121. CPR cardiopulmonary resuscitation CPR hồi sức tim phổi
Comprehensive Poverty
Chiến lược giảm nghèo và tăng
122. CPRGS Reduction and Growth CPRGS
trưởng toàn diện
Strategy
Construction Quality Đảm bảo chất lượng thi công (Kế
123. CQA CQA
Assurance (Plan) hoạch)
Construction Quality Control Kế hoạch Quản lý chất lượng thi
124. CQCP CQCP
Plan công
125. CRC collision-reaction cell CRC cell va chạm-phản ứng
Contamination Reduction
126. CRZ CRZ Vùng khử nhiễm
Zone
127. CS Communications Specialist CS Chuyên gia Truyền thông
128. CS carbon steel CS thép carbon
129. CSF concentration safety factor CSF hệ số an toàn nồng độ
Construction Specification
130. CSI CSI Viện Kỹ thuật xây dựng (Hoa Kỳ)
Institute (U.S.)
131. CSO Contractor Safety Officer CSO Chuyên viên An toàn Nhà thầu
Chương trình Chiến lược đối tác
132. CSP Country Strategy Program CSP
quốc gia
133. CTE central tendency exposure CTE phơi nhiễm điển hình, phổ biến
Center for Technology of Trung tâm Công nghệ xử lý môi
134. CTET TTCNXLMT
Environmental Treatment trường
concentration of the non- nồng độ các loại hóa chất không
135. Cu Cu
ionized species (mg/l) ion hóa (mg/l)
136. CV coefficient of variation CV hệ số biến động
chemical concentration in nồng độ hóa chất trong nước
137. Cw Cw
water (mg/cm3) (mg/cm3)

138. CY cubic yard CY yard khối
139. CZ Clean Zone CZ Vùng sạch
140. D&B Design/Build (contract) D&B Thiết kế & Thi công (Hợp đồng )
141. D&H dig and haul D&H Đào xúc & Vận chuyển
dermal absorbed dose (mg/kg- liều lượng hấp thụ qua da (mg/kg-
142. DAD DAD
day) ngày)
Designated Agency Safety and Chuyên viên phụ trách An toàn và
143. DASHO DASHO
Health Official (USAID) sức khỏe
Department of Army Security Cục Bảo vệ an ninh quân đội (Việt
144. DASP CBVANQĐ
Protection (Vietnam) Nam)
decibel, trọng số A; đơn vị đo âm
145. dBA decibels, A-weighted dBA
thanh
146. DCA dichloroethane DCA dichloroethane
147. DCE dichloroethene DCE dichloroethene
148. DCOP Deputy Chief of Party DCOP Phó chủ nhiệm Dự án
149. DCR Design Change Record DCR Hồ sơ Thay đổi thiết kế
Department of Defense Ban An toàn vật liệu nổ Bộ Quốc
150. DDESB DDESB
Explosive Safety Board phòng
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

175. DOFA Department of Foreign Affairs SNV Sở Ngoại vụ (Việt Nam)
Department of Natural Sở Tài nguyên và môi trường (Việt
176. DONRE STNMT
Resources and Environment Nam)
177. DOT Department of Transportation SGTVT Sở Giao thông vận tải (Việt Nam)
178. DPE Dual-phase extraction DPE Thu hồi hai pha
Department of Planning and
179. DPI CKHĐT Cục Kế hoạch và đầu tư (BQP)
Investment (MND)
Department of Planning &
180. DPI SKHĐT Sở Kế hoạch & Đầu tư
Investment
Mục tiêu bảo đảm chất lượng dữ
181. DQO Data Quality Objective DQO
liệu
destruction and removal
182. DRE DRE năng suất tiêu hủy
efficiency
Hydrocarbon dầu mỏ bay hơi (C10-
183. DRO diesel range organics DRO
C28)
184. DS decontamination station DS trạm khử nhiễm
effective diffusion coefficient of
hệ số khuếch tán hiệu dụng của
185. Dsc the chemical through the Dsc
hóa chất qua lớp sừng
stratum corneum
186. dscm dry standard cubic meter dscm mét khối chuẩn khí khô
direct fired thermal desorption Đơn nguyên khử bám nhiệt, đốt
187. DTDU DTDU
unit trực tiếp
188. DU Decision Unit DU Đơn nguyên/Đơn vị lấy mẫu
Center for Environmental
Trung tâm Quan trắc môi trường,
Monitoring, Vietnam
189. DXL DXL Phòng thí nghiệm Dioxin Tổng cục
Environment Administration Môi trường
Dioxin Laboratory
190. EA Environmental Assessment ĐM Đánh giá Môi trường
environmental
191. EA/R EA/R đánh giá/xử lý môi trường
assessment/remediation
192. EBCT empty bed contact time EBCT Thời gian tiếp xúc xử lý (nước)
193. ECAC estimated cost at completion ECAC dự toán hoàn thành
Excavation & Construction
194. ECC ECC Nhà thầu Đào xúc & Thi công
Contractor
Environmental Compliance
195. ECS ECS Chuyên gia Môi trường
Specialist
196. ED exposure duration (years) ED thời gian phơi nhiễm (số năm)
Environment and Social Văn phòng Phát triển môi trường và
197. EDSO EDSO
Development Office xã hội
198. EDW excavation derived waste EDW chất thải phát sinh từ đào xúc
tuần suất phơi nhiễm (số
199. EF exposure frequency (days/year) EF ngày/năm)
Exposure Factors Handbook Sổ tay các yếu tố gây phơi nhiễm
200. EFH EFH
(U.S. EPA, 1997a) (U.S. EPA, 1997a)
201. EFT Electronic Fund Transfer EFT Chuyển tiền điện tử
Economic Growth, Agriculture, Cục Tăng trưởng kinh tế, nông
202. EGAT EGAT
and Trade nghiệp và thương mai
Environmental Impact
203. EIA ĐTM Đánh giá Tác động môi trường
Assessment
Electronic Information
204. EIT EIT Công nghệ Thông tin điện tử
Technology
Environmental Laboratory Chương trình Chứng nhận phòng
205. ELAP ELAP
Accreditation Program thí nghiệm môi trường
Environmental Mitigation and Kế hoạch Quan trắc và giảm thiểu
206. EMMP EMMP
Monitoring Plan tác động môi trường
Environmental Management
207. EMP EMP Kế hoạch Quản lý môi trường
Plan
208. EMR Experience Modification Rate EMR Tỷ lệ Sửa đổi kinh nghiệm
209. EO Executive Order EO Sắc lệnh, Lệnh thi hành

Environmental Protection
210. EPA EPA Cục Bảo vệ môi trường Hoa Kỳ
Agency
211. EPC exposure point concentration EPC Nồng độ phơi nhiễm an toàn
212. EPP Environmental Protection Plan EPP Kế hoạch bảo vệ môi trường
213. ER environmental regulation ER quy định môi trường
214. ERT Emergency Response Team ERT Đội Ứng phó khẩn cấp
215. ESC erosion and sediment control ESC kiểm soát xói lở và trầm tích
Environmental and Social Văn phòng Phát triển môi trường và
216. ESDO ESDO
Development Office (USAID) xã hội (USAID)
Environmental Scoping Báo cáo Xác định phạm vi môi
217. ESS ESS
Statement trường
218. ESTD Ex-Situ Thermal Desorption ESTD Giải hấp nhiệt trong mố
219. EU European Union EU Liên minh Châu Âu
220. EV extracted vapors EV hơi chiết xuất
221. eV electron volt eV năng lượng electron
222. EV event frequency (events/day) EV tần số tiếp xúc (lần/ngày)
223. EVN Vietnam Electricity EVN Điện lực Việt Nam
224. EVSA Excess Volume Stockpile Area EVSA Bãi Tập kết vật liệu thừa
225. EXOs Executive Officers EXOs Chuyên viên Điều hành
226. EZ Exclusion Zone EZ vùng cấm, vùng cách ly
227. F angle of internal friction F góc nội ma sát
228. F&O Finance & Operations F&O Phụ trách tài chính & hoạt động
229. FAA Foreign Assistance Act FAA Luật Viện trợ nước ngoài
Federal Aviation
230. FAA FAA Cục hàng không Liên bang
Administration
Food and Agriculture Tổ chức Lương thực và nông
231. FAO FAO
Organization nghiệp
Quy chế Đấu thầu Liên bang Hoa
232. FAR Federal Acquisition Regulation FAR
Kỳ
Findings, Conclusions, and
233. FCR FCR Nghiên cứu, kết luận và đề xuất
Recommendations
Cục Quản lý thực phẩm và dược
234. FDA Food and Drug Administration FDA phẩm Hoa Kỳ
235. FDI Foreign Direct Investment FDI Đầu tư trực tiếp nước ngoài
236. fg femtogram (international unit) fg femtogram (đơn vị quốc tế)
Kế hoạch Thực hiện chính thức
237. Final AWP–Y2 Final Annual Workplan - Y2 Final AWP–Y2
Năm 2
238. FIO for information only FIO để biết, để nắm thông tin
239. FMP Fatigue Management Plan FMP Kế hoạch Quản lý rủi ro mệt mỏi
240. FP Floating Plant FP Thực vật nổi
241. FPAF Fire Prevention and Fighting PCCC Phòng cháy chữa cháy
242. fpm feet per minute fpm feet trên phút
243. FS Feasibility Study FS Nghiên cứu khả thi
244. FSDS Field Sampling Data Sheet FSDS Bảng Dữ liệu mẫu hiện trường
245. FSP Field Sampling Plan FSP Kế hoạch Lấy mẫu hiện trường
246. ft feet ft feet
fourier-transform infrared quang phổ hồng ngoại biến đổi
247. FTIR FTIR
spectroscopy Fourier
248. FTO flameless thermal oxidizer FTO oxy hóa nhiệt nung gián tiếp
249. FY fiscal year FY tài khóa, năm tài chính
250. g gram - unit weight g gam - đơn vị trọng lượng

251. g/m3/hr gram per cubic meter per hour g/m3/hr gam trên mét khối trên giờ
252. G2L Gate 2 Lake G2L Hồ Cổng 2
253. GAC granular activated carbon GAC Than hoạt tính thể hạt
254. GAD Gender and Development GAD Giới và Sự phát triển
Thảm sét địa kỹ thuật, lớp lót sét
255. GCL Geosynthetic Clay Liner GCL
địa kỹ thuật
Gas Chromatography – Mass
256. GC-MS GC-MS Sắc ký khí –khối phổ
Spectrometry
257. GDP gross domestic product GDP tổng sản lượng quốc nội
258. GDS gas distribution system GDS hệ thống phân phối khí
259. GEF Global Environment Facility GEF Quỹ Môi trường toàn cầu
260. GFCI ground fault circuit interrupter GFCI bộ ngắt mạch lỗi nối đất
261. GFH granular ferric hydroxide GFH hydroxide sắt dạng hạt
262. GGI Gender Gap Index GGI Chỉ số cách biệt giới
263. GHG greenhouse gas GHG khí nhà kính
264. GHS Globally Harmonized System GHS Hệ thống Hài hòa toàn cầu
265. GI gastrointestinal GI tiêu hóa
266. GII Gender Inequality Index GII Chỉ số bất bình đẳng giới
Geographic Information
267. GIS GIS Hệ thống Thông tin địa lý
System
phương pháp thực hành thí nghiệm
268. GLP good laboratory practice GLP
tốt
269. GNI gross national income GNI tổng thu nhập quốc dân
270. GPS global positioning system GPS hệ thống định vị toàn cầu
Hydrocarbon dầu mỏ bay hơi (C6-
271. GRO gasoline range organics GRO
C10)
272. GSD geometric standard deviation GSD độ lệch chuẩn hình học
273. GSO General Statistics Office GSO Tổng cục Thống kê
274. GVN Government of Vietnam CPVN Chính phủ Việt Nam
275. GW groundwater GW Nước ngầm
276. GWG Gender Working Group GWG Nhóm Công tác Giới
277. ha hectare ha héc ta
278. HAP hazardous air pollutant HAP chất gây nhiễm không khí nguy hại
279. H&S health and safety H&S sức khỏe và an toàn
280. HASP Health and Safety Plan HASP Kế hoạch sức khỏe và an toàn
281. HAZMAT hazardous materials HAZMAT Vật liệu nguy hại
Hazardous Waste Operations Hoạt động và phản ứng khẩn cấp
282. HAZWOPER HAZWOPER
and Emergency Response chất thải nguy hại
283. HBV Hepatitis B Virus HBV Virus viêm gan B
284. HCl hydrochloric acid HCl Acid Chlohydic
285. HD high definition HD độ nét cao, độ phân giải cao
286. HDI Human Development Index HDI Chỉ số Phát triển người
287. HDPE high-density polyethylene HDPE polyethylene cường độ cao
288. HE high explosive HE Chất nổ công phá lớn
289. HEAT high explosive anti-tank HEAT Chất nổ công phá lớn chống tăng
high efficiency particulate air
290. HEPA filter HEPA filter Bộ lọc khí chuẩn HEPA
filter
Hunger Eradication and
291. HEPR HEPR Xóa đói giảm nghèo
Poverty Reduction
292. HFD hazardous fragment distance HFD khoảng cách văng mảnh nguy hại

Human Health Evaluation Cẩm nang Đánh giá sức khỏe
293. HHEM HHEM
Manual người
Human Health and Ecological Đánh giá rủi ro sinh thái và sức
294. HHERA HHERA
Risk Assessment khỏe người
Human Health Risk
295. HHRA HHRA Đánh giá rủi ro đến sức khỏe người
Assessment
296. HI Hazard Index HI Chỉ số nguy hại
Human and Institutional Xây dựng năng lực thể chế và con
297. HICD HICD
Capacity Development người
Vi rút gây suy giảm miễn dịch ở
298. HIV human immunodeficiency virus HIV người
299. hp horsepower hp Mã lực
300. HQ hazard quotient HQ tỷ số nguy hại
Headquarters, U.S. Army
301. HQUSACE HQUSACE Trụ sở, Công binh lục quân Hoa Kỳ
Corps of Engineers
302. HR Human Resources HR Phòng Nhân sự
303. hr hour hr h, giờ
304. HR heart rate HR nhịp tim
high resolution gas
305. HRGC HRGC sắc kí khí phân giải cao
chromatography
high resolution mass
306. HRMS HRMS khối phổ phân giải cao
spectrometry
307. HSO Health and Safety Officer HSO Chuyên viên Sức khỏe và an toàn
Hazardous, Toxic and Chất thải nguy hại, độc hại và
308. HTRW HTRW
Radioactive Waste phóng xạ
309. Hz hertz Hz tần số
International Air Transport
310. IATA IATA Hiệp hội Hàng không quốc tế
Association
311. IBC International Building Code IBC Tiêu chuẩn Xây dựng quốc tế
312. IBT Institute of Biotechnology IBT Viện Công nghệ sinh học
kiểm soát thể chế, biện pháp hành
313. IC institutional control IC
chính
Institute of Clean Air Viện các nhà cung cấp thiết bị xử lý
314. ICAC ICAC
Companies không khí
315. ICE internal combustion engine ICE động cơ đốt trong
International Centre for Trung tâm Quản lý môi trường quốc
316. ICEM ICEM
Environmental Management tế
International Conference on
Hội thảo quốc tế về ô nhiễm, phục
317. ICEPORM Environmental Pollution, ICEPORM
hồi và quản lý môi trường
Restoration, and Management
318. ICP inductively coupled plasma ICP plasma cặp cảm ứng
số định danh, chứng minh nhân
319. ID identification ID
dân
immediately dangerous to life
320. IDLH IDLH mức độ nguy hiểm tức thời
and health
321. IDW investigative derived waste IDW chất thải phát sinh từ khảo sát
information, education and
322. IEC IEC thông tin, đào tạo và truyền thông
communication
Initial Environmental
323. IEE IEE Giám định môi trường ban đầu
Examination
Institute of Electric and
324. IEEE IEEE Viện Kỹ nghệ điện và điện tử
Electronic Engineers
International Finance
325. IFC IFC Hợp tác Tài chính quốc tế
Cooperation
Institute of International
326. IIE IIE Viện Giáo dục quốc tế
Education
International Labor
327. ILO ILO Tổ chức Lao động quốc tế
Organization

328. IM Interim Measure IM Biện pháp tạm thời
329. IMF International Monetary Fund IMF Quỹ Tiền tệ quốc tế
330. in inch in inch
331. IP National Implementing Partner IP Đối tác hành động quốc gia
332. IP ionization potential IP Điện thế ion hóa
International Program on the Chương trình Xóa bỏ lao động trẻ
333. IPEC IPEC
Elimination of Child Labor em quốc tế
334. IPTD® In-Pile Thermal Desorption IPTD® Khử hấp thu nhiệt trong mố
335. IQC Indefinite Quantity Contract IQC Hợp đồng theo sản phẩm
336. IR Intermediate Result IR Kết quả trung gian
ingestion rate (for water,
337. IR IR mức tiêu thụ (nước, lít/ngày)
liters/day)
338. IR Inception Report IR Báo cáo đầu kỳ, Báo cáo ban đầu
Integrated Risk Information
339. IRIS IRIS Hệ thống Thông tin rủi ro tích hợp
System
International Safety Equipment
340. ISEA ISEA Hiệp hội An toàn thiết bị quốc tế
Association
Incremental Sampling
341. ISM ISM Phương pháp lấy mẫu đơn
Methodology
International Organization for
342. ISO ISO Tổ chức Tiêu chuẩn hóa quốc tế
Standardization
343. ISTD in-situ thermal desorption ISTD giải hấp nhiệt tại chỗ
344. IT information technology IT công nghệ thông tin
international toxic equivalent
345. I-TEF I-TEF hệ số độc tương đương quốc tế
factor
Độc tính tương đương được quốc
internationally agreed TEQ - 1
346. I-TEQ I-TEQ tế công nhận 1 g TCDD = 1 g I-
g TCDD equals 1 g I-TEQ TEQ
Interstate Technology and
347. ITRC ITRC Ban Công nghệ lập quy Liên bang
Regulatory Council
International Union for Liên minh quốc tế Bảo tồn thiên
348. IUCN IUCN
Conservation of Nature nhiên
khả năng tiếp cận sinh học trong
349. IVBA in vitro bioaccessibility IVBA
ống nghiệm
350. JAC Joint Advisory Committee JAC Hội đồng Tư vấn hỗn hợp
knowledge, attitude, and
351. KAP KAP kiến thức, thái độ và thực hành
practice
equilibrium partition coefficient
hệ số phân chia cân bằng giữa lớp
between the epidermis and
352. Kew Kew biểu bì và nước đối với hóa chất
water for the absorbing hấp thụ (không thứ nguyên)
chemical (dimensionless)
353. kg kilogram kg kilogram
kilôgram trọng lượng cơ thể trên
354. kg bw/d kilograms body weight per day kg bw/d ngày
Phỏng vấn người cấp tin quan
355. KII Key Informant Interview KII
trọng
356. km kilometer km kilômét
357. km2 square kilometer km 2
kilômét vuông
octanol/water partition hệ số phân chia octanaol và nước
358. Kow Kow
coefficient (dimensionless) (không thứ nguyên)
dermal permeability coefficient hệ số thẩm thấu qua da của hợp
359. Kp Kp
of compound in water (cm/hr) chất trong nước (cm/hr)
360. kV kilovolt kV kilovolt
361. kVa kilovolt Ampere kVa kilôvôn ampe
362. kWh kilowatt-hour kWh kilowatt giờ
363. L liter L lít

Land Access to Women Chương trình Quyền phụ nữ về đất
364. LAW LAW
Program đai
365. lb pound – unit weight lb pound - đơn vị trọng lượng
366. lb/hr pound per hour lb/hr pound trên giờ
367. LCS laboratory control sample LCS mẫu kiểm soát phòng thí nghiệm
Low Concentration Storage
368. LCSA LCSA Bãi lưu giữ nồng độ thấp
Area
369. LD 50 median lethal dose LD 50 liều gây chết trung bình
370. LE Lead Local Engineer LE Kỹ sư Trưởng
effective thickness of the độ dày hiệu dụng của lớp biểu bì
371. Le Le
epidermis (cm) (cm)
372. LEL lower explosive limit LEL giới hạn cháy nổ khí ga, cận dưới
Law of Environmental
373. LEP LEP Luật Bảo vệ môi trường
Protection
liquid-phase granular activated
374. LGAC LGAC than hoạt tính thể hạt pha lỏng
carbon
polyethylene cường độ thấp tuyến
375. LLDPE linear low-density polyethylene LLDPE tính
chất lỏng ngoài pha nước dạng
376. LNAPL light nonaqueous-phase liquid LNAPL
loãng, NAPL loãng
377. LO/TO lock-out/tag-out LO/TO Quy tắc khóa cảnh báo an toàn
378. LOC Law on Chemicals LOC Luật Hóa chất
379. LOD level of design LOD mức thiết kế
380. LOE level of effort LOE mức nỗ lực
Bureau for Legislative and Cục Đặc trách Lập pháp và Công
381. LPA LPA
Public Affairs chúng
apparent thickness of stratum
382. lsc lsc độ dày biểu kiến của lớp sừng (cm)
corneum (cm)
Lead Safety and Environmental Trưởng Chuyên gia an toàn và môi
383. LSECS LSECS
Compliance Specialist trường
Limited Scope Grant Thỏa thuận viện trợ không hoàn lại
384. LSGA LSGA
Agreement bản hạn chế
385. LTSA Long -Term Storage Area LTSA Bãi lưu giữ lâu dài
Long-Term Technical
386. LTTA LTTA Hỗ trợ Kỹ thuật dài hạn
Assistance
387. LUC Land Use Certificate LUC Chứng nhận Quyền sử dụng đất
388. LVTP liquid vapor treatment plant LVTP trạm xử lý hơi/lỏng
Lightweight Insulating
389. LWIC LWIC Bê tông nhẹ, cách nhiệt
Concrete
390. m meter m mét
391. M million M triệu
392. M&E monitoring and evaluation M&E giám sát & đánh giá
393. m/s meter per second m/s mét trên giây
394. m2 square meter m 2
mét vuông
395. m3 cubic meter m 3
mét khối
maximum achievable control công nghệ đáp ứng yêu cầu kiểm
396. MACT MACT
technology soát tối đa
Ministry of Agriculture and Bộ Nông nghiệp và phát triển nông
397. MARD BNNPTNT
Rural Development thôn
398. masl meters above sea level masl mét trên mực nước biển
399. MCD mechano-chemical destruction MCD phân hủy hóa cơ
400. MCL maximum contaminant level MCL mức ô nhiễm tối đa
maximum contaminant level
401. MCLG MCLG mục tiêu mức ô nhiễm tối đa
goal
402. MCS Matrix Constituent Separator MCS Giải Hấp nhiệt hồng ngoại

munitions and explosives of
403. MEC MEC đạn dược và chất nổ quan ngại
concern
404. MEK methyl ethyl ketone MEK methyl ethyl ketone
Monitoring, Evaluation and Giám sát, đánh giá và rút kinh
405. MEL MEL
Learning (Plan) nghiệm (Kế hoạch)
406. MET meteorological MET khí tượng
407. mg/kg milligrams per kilograms mg/kg milligram trên kilogram
408. mg/L milligrams per liter mg/L miligam/lít
munitions with the greatest đạn dược có khoảng cách văng
409. MGFD MGFD
fragmentation distance mảnh lớn nhất
410. MIBK methyl isobutyl ketone MIBK methyl isobutyl ketone
411. MIS multi-increment® sampling MIS lấy mẫu đa điểm (phương pháp)
412. MLA Mixing and Loading Area MLA Khu vực trộn và bốc xếp
413. mm millimeter mm milimét
414. mm Hg millimeter of mercury mm Hg milimét thủy ngân
415. mm/d millimeters per day mm/d milimét trên ngày
416. MMBTU million British Thermal Unit MMBTU triệu đơn vị nhiệt Anh
Military Munitions Response Chương trình Ứng phó đạn dược
417. MMRP MMRP
Program quân sự
418. MND Ministry of National Defense BQP Bộ Quốc phòng
419. MOC Ministry of Construction BXD Bộ Xây dựng
420. MOF Ministry of Finance (Vietnam) BTC Bộ Tài chính
421. MOH Ministry of Health BYT Bộ Y tế
422. MOI Memorandum of Intent MOI Bản ghi nhớ ý định
423. MOIT Ministry of Industry and Trade BCT Bộ Công thương
Ministry of Labor, Invalids and
424. MOLISA BLĐTBXH Bộ Lao động, thương binh, xã hội
Social Affairs
Ministry of Natural Resources
425. MONRE BTNMT Bộ Tài nguyên và môi trường
and Environment
Ministry of Science and
426. MOST BKHCN Bộ Khoa học và công nghệ
Technology
427. MOT Ministry of Transportation BGTVT Bộ Giao thông vận tải
Memorandum of
428. MOU MOU Bản Ghi nhớ thỏa thuận
Understanding
429. MPE multi-phase extraction MPE chiết tách nhiều pha
macroporous-polymer
430. MPPE MPPE chiết tách nhựa macroporous
extraction
materials potentially presenting
431. MPPEH MPPEH vật liệu tiềm ẩn nguy cơ nổ
an explosive hazard
Hiện trường ứng phó đạn được
432. MRS Munitions Response Site MRS
(Quy tắc)
433. MS matrix spike MS mẫu thêm chuẩn
434. MSD Military Science Department CKHQS Cục Khoa học quân sự
435. MSD minimum separation distance MSD khoảng cách ly tối thiểu
bảng chỉ dẫn an toàn vật liệu (hóa
436. MSDS material safety data sheets MSDS
chất)
437. MTBE methyl tert-butyl ether MTBE methyl tert-butyl ether
438. MV molar volume (cm3/mole) MV thể tích phân tử (cm3/mole)
439. MW megawatt(s) MW megawatt(s)
440. MW molecular weight (g/mole) MW trọng lượng phân tử (g/mole)
441. NA not available NA không có, chưa có

National Action Centre for Trung tâm Hành động quốc gia
442. NACCET Toxic Chemicals and NACCET khắc phục hậu quả chất độc hóa
Environmental Treatment học và môi trường
443. NAP National Action Plan NAP Kế hoạch Hành động quốc gia
444. NAPL non-aqueous phase liquid NAPL chất lỏng ngoài pha nước, NAPL
445. NAS Naval Air Station NAS Trạm Hàng không hải quân Hoa Kỳ
National Center for Trung tâm Đánh giá môi trường
446. NCEA NCEA
Environmental Assessment quốc gia
National Center for Trung tâm Nghiên cứu môi trường
447. NCER NCER
Environmental Research quốc gia
National Committee for the
Ủy ban Quốc gia vì sự tiến bộ của
448. NCFAW Advancement of Women in NCFAW
phụ nữ Việt Nam
Vietnam
449. NCR Nonconformance Report NCR Báo cáo Không tuân thủ
450. ND not detected ND không phát hiện, chưa phát hiện
451. NDP National Development Plan NDP Kế hoạch Phát triển quốc gia
452. NE not established NE chưa thành lập, chưa xây dựng
453. NEC National Electric Code NEC Quy chuẩn Điện quốc gia
National Environmental
Chương trình Chứng nhận phòng
454. NELAP Laboratory Accreditation NELAP
thí nghiệm môi trường quốc gia
Program
National Electric Hiệp hội Nhà sản xuất điện quốc
455. NEMA NEMA
Manufacturers Association gia
456. NESC National Electric Safety Code NESC Bộ luật An toàn điện quốc gia
National Emission Standards Tiêu chuẩn quốc gia về Xả thải gây
457. NESHAP NESHAP
for Hazardous Air Pollutants nguy hại không khí
National Fire Protection
458. NFPA NFPA Hiệp hội Cứu hỏa quốc gia
Association
459. ng nanogram ng nanogam
460. ng/kg nanogram per kilogram ng/kg nanogam trên kilogam
461. NGB National Guard Bureau NGB Cục Vệ binh quốc gia
Non-Governmental
462. NGO NGO Tổ chức Phi chính phủ
Organization
National Health and Nutrition Nghiên cứu kiểm tra sức khỏe và
463. NHANES NHANES
Examination studies dinh dưỡng quốc gia
National Institute of Viện An toàn và sức khỏe nghề
464. NIOSH NIOSH
Occupational Safety and Health nghiệp quốc gia
465. NIP National Implementation Plan NIP Kế hoạch thực hiện quốc gia
National Institute of Standards Viện Tiêu chuẩn và kỹ thuật quốc
466. NIST NIST
and Technology gia
467. NLT no later than NLT không trễ hơn, hạn chót
468. nm nanometer nm nano mét
469. Nm3 normal cubic meter Nm 3
khối khí đo ở điều kiện chuẩn
470. No. number No. số thứ tự
471. NODEL non-delegation NODEL không phân quyền
472. NOx nitrous oxide NOx nitrous oxide (khí gây cười)
National Primary Drinking
473. NPDWR NPDWR Quy chuẩn Nước uống quốc gia
Water Regulations
Natural Resources and
474. NRE NRE Tài nguyên và môi trường
Environment
Natural Resources Quản lý Nguồn tài nguyên thiên
475. NRM NRM
Management nhiên
476. NTP Notice to Proceed NTP Lệnh khởi công
477. NTU nephelometric turbidity unit NTU đơn vị đo độ đục nepholometric

Standard Penetration
478. N-value N-value Sức kháng xuyên tiêu chuẩn
Resistance
479. O&M operation & maintenance O&M vận hành & bảo dưỡng
480. O.D. outside diameter O.D. đường kính ngoài
481. OCDD octachlorodibenzodioxin OCDD octachlorodibenzodioxin
482. OCDF octachlorodibenzofuran OCDF octachlorodibenzofuran
483. ODS Ozone Depleting Substance ODS Chất làm duy giảm tầng ozone
Office of the National Steering Văn phòng Ban chỉ đạo quốc gia
Committee on Resolving Post- khắc phục hậu quả chất độc hóa
484. Office 33 VP 33
war Consequences of Toxic học do Mỹ sử dụng trong chiến
Chemicals tranh ở Việt Nam
Office of the Standing Board of
the National Steering Ban chỉ đạo quốc gia khắc phục
485. Office 701 Committee on Overcoming VP 701 hậu quả bom mìn và chất độc hóa
Post-War Consequences of học sau chiến tranh ở Việt Nam
UXO and Toxic Chemicals
Office of Health and Văn phòng Đánh giá sức khỏe và
486. OHEA OHEA
Environmental Assessment môi trường
487. OHS Occupational Health and Safety OHS Sức khỏe và an toàn nghề nghiệp
other potentially infectious
488. OPIM OPIM các vật liệu có nguy cơ nhiễm khác
materials
Occupational Safety and Health Cục quản lý An toàn sức khỏe nghề
489. OSHA OSHA
Administration nghiệp
Orphans and Vulnerable
490. OVC OVC Trẻ mồ côi và trẻ em bị tổn thương
Children
491. OWS oil- water separator OWS bộ lọc tách dầu/nước
Piping & Instrumentation
492. P&ID P&ID Sơ đồ công nghệ & thiết bị lắp ống
Diagrams
493. PAD Project Appraisal Document PAD Hồ sơ Thẩm định Dự án
polycyclic aromatic
494. PAH PAH hydrocarbon thơm đa vòng
hydrocarbons
polynuclear aromatic
495. PAH PAH polynuclear aromatic hydrocarbon
hydrocarbon
đối tượng chịu ảnh hưởng của dự
496. PAP project affected people PAP
án
powered air purifying
497. PAPR PAPR mặt nạ phòng độc
respirators
498. PAR public administration reform PAR cải cách hành chính công
499. PAVN People’s Army of Vietnam QĐNDVN Quân đội nhân dân Việt Nam
500. Pb lead Pb chì
polybrominated diphenyl
501. PBDE PBDE polybrominated diphenyl ethers
ethers
502. PC People's Committee UBND Uỷ ban nhân dân
503. PCB polychlorinated biphenyl PCB chất polychlorinated biphenyl
product of complete
504. PCC PCC sản phẩm cháy hoàn toàn
combustion
polychlorinated dibenzo-p- chất polychlorinated dibenzo-p-
505. PCDD PCDD
dioxin (Dioxin) dioxin (Dioxin)
Polychlorobenzodioxins and các chất Polychlorobenzodioxins và
506. PCDD/F PCDD/F
polychlorodibenzofurans polychlorodibenzofurans
polychlorinated dibenzofuran chất Polychlorinated dibenzofuran
507. PCDF PCDF
(Furan) (Furan)
508. PCE tetrachloroethene PCE tetrachloroethene
Preliminary Design and
509. PDE PDE Thiết kế và dự toán sơ bộ
Estimate
510. PE Professional Engineer PE Kỹ sư chuyên ngành
511. PEF particulate emission factor PEF Hệ số phát thải hạt vật chất

Permissible Exposure Level Giới hạn phơi nhiễm cho phép
512. PEL PEL
(OSHA) (OSHA)
513. PEP post exposure prophylaxis PEP điều trị dự phòng sau phơi nhiễm
514. PFD personal flotation device PFD áo phao cứu sinh
515. PFM Public Finance Management PFM Quản lý tài chính công
516. PFOS penta fluorooctane sulfonate PFOS penta fluorooctane sulfonate
517. PG Professional Geologist PG Chuyên gia Địa chất
518. pg picogram (international unit) pg picogam (đơn vị quốc tế)
519. pg/g picograms per gram pg/g picogram trên gram
520. pg/L picograms per liter pg/L picogram trên lít

521. PI Pacer Ivy PI Khu Pacer Ivy
product of incomplete
522. PIC PIC sản phẩm cháy không hoàn toàn
combustion
523. PID photoionization detector PID máy dò quang hóa ion
Programmable Logic
524. PLC PLC Hệ thống điều khiển logic lập trình
Controller
525. PM Project Manager PM Giám đốc Dự án
526. PMP Performance Monitoring Plan PMP Kế hoạch theo dõi thực hiện
Project Management Unit
527. PMU BQLDA Ban Quản lý Dự án
(PMU)
528. POC point of contact POC điểm tiếp xúc
529. POP persistent organic pollutant POP chất ô nhiễm hữu cơ khó phân hủy
530. Pparticle particle density (g/cm3) Pparticle mật độ hạt vật chất (g/cm3)
531. PPE personal protective equipment PPE bảo hộ Lao động
532. ppm parts per million ppm phần triệu
sức mua tương đương, ngang giá
533. ppp purchasing power parity ppp
sức mua
534. ppq parts per quadrillion ppq phần triệu tỉ
535. ppt part per trillion ppt phần nghìn tỉ (đơn vị quốc tế)
536. PQM Project Quality Management PQM Quản lý chất lượng Dự án
537. psi pounds per square inch psi pound trên inch vuông
538. PSPS Project SharePoint® System PSPS Hệ thống Sharepoint Dự án
539. PTSs persistent and toxic substances PTSs chất độc và khó phân hủy
540. PUF polyurethane foam PUF xốp polyurethane
541. QA quality assurance QA Đảm bảo chất lượng
quality assurance/quality bảo đảm chất lượng/kiểm soát chất
542. QA/QC QA/QC
control lượng
Kế hoạch Đảm bảo chất lượng Dự
543. QAPP Quality Assurance Project Plan QAPP án
544. QAR Quality Control Report QAR Báo cáo kiểm soát chất lượng
545. QC quality control QC kiểm soát Chất lượng
546. QCVN Vietnam Regulation QCVN Quy chuẩn Việt Nam
547. QLFT qualitative fit test QLFT kiểm định sự phù hợp định tính
548. QNFT quantitative fit test QNFT kiểm định sự phù hợp định lượng
549. QSC Quality Control System QSC Hệ thống kiểm soát chất lượng
550. RAP Resettlement Action Plan RAP Kế hoạch tái định cư
551. RBA relative bioavailability RBA tính khả dụng sinh học tương đối
Request for Categorical
552. RCE RCE yêu cầu nhóm không có tác động
Exclusion

Resource Conservation and Luật Bảo tồn và khôi phục tài
553. RCRA RCRA
Recovery Act nguyên
554. RFI Request for Information RFI Yêu cầu cung cấp thông tin
555. RFP Request for Proposal RFP Yêu cầu đề xuất
556. RME reasonable maximum exposure RME phơi nhiễm tối đa dự kiến
557. RPD relative percent difference RPD chênh lệch phần trăm tương đối
558. RQD rock quality designation RQD Chỉ số chất lượng đá
559. RS Remediation Specialist RS Chuyên gia Xử lý
560. RSD relative standard deviation RSD Sai lệch chuẩn tương đối
561. RSL Regional Screening Level RSL Ngưỡng rà soát khu vực
Remediation Technologies
562. RTN RTN Tích hợp Công nghệ xử lý
Network
563. RTO regenerative thermal oxidizer RTO oxy hóa nhiệt tái sinh
Strategic Approach for
Tiếp cận chiến lược về quản lý hóa
564. SAICM International Chemical SAICM
chất quốc tế
Management
565. SAP Sampling and Analysis Plan SAP Kế hoạch lấy mẫu phân tích
Sampling and Analysis
Kế hoạch lấy mẫu, phân tích/Kế
566. SAP/QAPP Plan/Quality Assurance Project SAP/QAPP
hoạch đảm bảo chất lượng Dự án
Plan
Superfund Amendments and Luật Sửa đổi tái ủy quyền quỹ
567. SARA SARA
Reauthorization Act of 1986 Superfund 1986
self-contained breathing
568. SCBA SCBA bình dưỡng khí
apparatus
569. scfm standard cubic foot per minute scfm feet khối chuẩn trên phút
570. SCM site conceptual model SCM mô hình Khái niệm Thực địa
Site Contractor Project Giám đốc Dự án Nhà thầu tại công
571. SCPM SCPM
Manager trường
572. SCR silicon controlled rectifier SCR chỉnh lưu điều khiển bằng silicon
573. SDS Safety Data Sheet SDS Bảng số liệu an toàn
574. S-E Socio-economic S-E Kinh tế - xã hội
575. SEC Office of Security SEC Phòng An ninh
Kế hoạch huy động bên liên quan
576. SEP Stakeholder Engagement Plan SEP
tham gia
Project data management
577. SharePoint® site SharePoint® site Hệ thống Quản lý dữ liệu Dự án
system
Supplemental Health and Safety Kế hoạch Sức khỏe và an toàn bổ
578. SHASP SHASP
Plan sung
chuyên viên sức khỏe và an toàn
579. SHSO site health and safety officer SHSO
hiện trường
580. SI Site Investigation SI Khảo sát hiện trường
Superfund Innovative Đánh giá công nghệ mới thuộc quỹ
581. SITE SITE
Technology Evaluation Superfund
582. SLM sound level meter SLM máy đo ồn
583. SME subject matter expert SME chuyên gia chuyên trách
584. SO strategic objective SO mục tiêu chiến lược
585. SOP standard operating procedure SOP quy trình thực hành chuẩn
586. SOW statement of work SOW phạm vi công việc
587. SOx sulfur oxides SOx sulfur oxides
Synthetic Precipitation
588. SPLP SPLP Quy trình rỉ chiết kết tủa tổng hợp
Leaching Procedure
589. SpO Special Objective SpO Mục tiêu đặc biệt
Strategic Planning and Program Quy hoạch chiến lược và chương
590. SPPS SPPS
Support trình hỗ trợ

591. SPT Standard Penetration Test SPT Thí nghiệm Xuyên tiêu chuẩn
592. SRB sex ratio at birth SRB tỷ lệ giới tính khi sinh
593. SSC Site Safety Coordinator SSC Điều phối viên an toàn hiện trường
594. Stdev standard deviation Stdev độ lệch chuẩn
595. STEL short term exposure limit STEL giới hạn phơi nhiễm ngắn hạn
596. STS standard threshold shift STS mức thay đổi ngưỡng chuẩn (nghe)
Short-Term Technical
597. STTA STTA Hỗ trợ kỹ thuật ngắn hạn
Assistance
598. SU sample unit SU đơn vị mẫu
599. SVE soil vapor extraction SVE chiết xuất hơi trong đất
600. SVOC semivolatile organic compound SVOC hợp chất hữu cơ bán ổn định
601. SW Surface water SW Nước mặt
Site-wide Environmental Kế hoạch Quan trắc và giảm thiểu
602. SWEMMP SWEMMP
Monitoring and Mitigation Plan tác động môi trường tổng thể
Site-Wide Health and Safety Kế hoạch Sức khỏe và an toàn tổng
603. SWHASP SWHASP
Plan thể
Stormwater Pollution Kế hoạch ngăn chặn ô nhiễm nước
604. SWPPP SWPPP
Prevention Plan mưa
605. t ton t tấn
606. TBC to be considered TBC cần xem xét
607. TBD to be determined TBD xác định sau, cần xác định
608. TC thermocouple TC lưỡng kim nhiệt
609. TCDD tetrachlorodibenzo-p-dioxin TCDD chất tetrachlorodibenzo-p-dioxin
610. TCE trichloroethylene TCE chất trichloroethylene
611. TCH Thermal Conductive Heating TCH Gia nhiệt truyền dẫn
Toxicity Characteristic
612. TCLP TCLP Quy trình rỉ chiết độc tính đặc trưng
Leaching Procedure
613. TCP Traffic Control Plan TCP Kế hoạch Điều tiết giao thông
614. TCVN Vietnam Standard TCVN Tiêu chuẩn Việt Nam
615. TD Thermal Desorption TD Giải hấp nhiệt, khử bám nhiệt
lượng dung nạp hóa chất vào cơ
616. TDI tolerable daily intake TDI
thể hàng ngày cho phép
617. TDS total dissolved solids TDS tổng chất rắn hòa tan
618. TDU turbidity units TDU đơn vị độ đục
619. TEF toxicity equivalency factor TEF hệ số đương lượng độc tính
620. TEQ toxicity equivalency TEQ đương lượng độc tính

Dioxin Remediation at Biên Dự án Xử lý Ô nhiễm Dioxin Khu
621. Project Project
Hòa Airbase Area Project vực Sân bay Biên Hòa
622. TLV Threshold Limit Value TLV Giá trị giới hạn ngưỡng
623. TM Technical Memorandum TM Ghi nhớ Kỹ thuật
Thermal Module Treatment
624. TMTS TMTS Hộp gia nhiệt module
System
625. TO Task Order TO Chỉ thị, Sự vụ lệnh
626. TOC total organic carbon TOC tổng carbon hữu cơ
627. tph tons per hour tph tấn trên giờ, tấn/h
628. TPH total petroleum hydrocarbon TPH tổng hydrocarbon dầu mỏ
629. TSS total suspended solids TSS tổng chất rắn lơ lửng
Temporary Sediment Storage
630. TSSA TSSA Bãi tạm lưu giữ trầm tích
Area
631. TTZ Thermal Treatment Zone TTZ Vùng xử lý nhiệt

632. TV television TV vô tuyến truyền hình
Trafficking Victims Protection Đạo luật Bảo vệ nạn nhân buôn

633. TVPA TVPA
Act người
nồng độ chất gây nhiễm trung bình
634. TWA time-weighted average TWA
trong không khí
635. U.S. United States U.S. Hoa Kỳ
636. UCL upper confidence limit UCL giới hạn tin cậy trên
Unified Facilities Guide Chỉ dẫn kỹ thuật thi công thống
637. UFGS UFGS
Specification nhất
638. UFP Uniform Federal Policy UFP Chính sách Liên bang thống nhất
Unified Federal Policy -Quality Chính sách Liên bang thống nhất -
639. UFP-QAPP UFP-QAPP
Assurance Plan Kế hoạch Đảm bảo chất lượng
Tổ chức Phi chính phủ về an toàn
640. UL Underwriters Laboratory UL
Underwriters Laboratory
United Nations Development Chương trình Phát triển Liên hiệp
641. UNDP UNDP
Program quốc
United Nations Economic and Ủy ban Kinh tế và xã hội Liên hiệp
642. UNESCAP Social Commission for Asia and UNESCAP quốc về vấn đề Á châu và Thái bình
the Pacific dương
United Nations Educational,
Tổ chức Giáo dục, khoa học, văn
643. UNESCO Scientific and Cultural UNESCO
hóa của Liên hợp quốc
Organization
United Nations Population
644. UNPF UNPF Quỹ Dân số Liên hợp quốc
Fund
Văn phòng Liên hợp quốc tại Việt
645. UNVN United Nations Vietnam UNVN
Nam
Unintentionally Persistent Chất ô nhiễm hữu cơ khó phân hủy
646. UPOPs UPOPs
Organic Pollutants phát sinh không chủ định
Unintentionally Produced Chất ô nhiễm hữu cơ khó phân hủy
647. U-POPs U-POPs
Persistent Organic Pollutants sản sinh không chủ định
United States Army Corps of
648. USACE USACE Công binh Lục quân Hoa Kỳ
Engineers
United States Agency for
649. USAID USAID Cơ quan Phát triển Quốc tế Hoa Kỳ
International Development
650. USCG United States Coast Guard USCG Tuần duyên Hoa Kỳ
651. USD or $US United States Dollar USD or $US Dollar Mỹ
United States Environmental Cơ quan Bảo vệ môi trường Hoa
652. USEPA USEPA
Protection Agency Kỳ
653. USG United States Government USG Chính phủ Hoa Kỳ
United States Geological
654. USGS USGS Cơ quan Khảo sát địa chất Hoa kỳ
Survey
655. UST underground storage tank UST bồn chứa ngầm
656. UTM Universal Transverse Mercator UTM Hệ tọa độ UTM
657. UV ultraviolet UV cực tím
658. UXO Unexploded Ordnance UXO Bom mìn, vật nổ
Unexploded Ordnance
659. UXO Clearance UXO Clearance Rà phá bom mìn, vật nổ
Clearance
Vietnam Academy of Social
660. VASS VKHXHVN Viện Khoa học xã hội Việt Nam
Sciences
Vietnam Academy of Science Viện Khoa học và công nghệ Việt
661. VAST VAST
and Technology Nam
662. VAT Value added Tax VAT Thuế Giá trị gia tăng
Vietnam Association of Victims Hội Nạn nhân chất độc da cam Việt
663. VAVA VAVA
of Agent Orange Nam
Vietnam Bank for Social
664. VBSP NHCSXH Ngân hàng Chính sách xã hội
Policies
665. VCP Vietnamese Communist Party ĐCSVN Đảng cộng sản Việt Nam
666. VDA Vegetation Disposal Area VDA Bãi đổ cây cỏ

667. VF volatilization factor VF hệ số bay hơi
vapor-phase granular activated
668. VGAC VGAC than hoạt tính thể hạt pha hơi
carbon
669. VLS vapor/liquid separator VLS bộ tách hơi/lỏng
670. VND Vietnam Dong VND Đồng Việt Nam
Vietnam Environment
671. VNEA TCMT Tổng cục Môi trường Việt Nam
Administration
672. VOC volatile organic compound VOC hợp chất hữu cơ bay hơi
Vietnam Public Health
673. VPHA VPHA Y tế cộng đồng
Administration
Vietnam-Russia Tropical
674. VRTC VRTC Trung tâm Nhiệt đới Việt-Nga
Center
Quy chuẩn Kỹ thuật Quốc gia Việt
675. VTR Vietnam Technical Regulation VTR
Nam
676. WBS Work Breakdown Structure WBS Phân cấp công việc
677. WHO World Health Organization WHO Tổ chức Y tế thế giới
678. WMP Waste Management Plan WMP Kế hoạch Quản lý chất thải
679. Y1 Year One Y1 Năm 1
680. Y2 Year Two Y2 Năm 2
681. Y3 Year Three Y3 Năm 3
682. ZT ZI Taxiway ZT Đường lăn Z1
683. ZVI zero valent iron ZVI Sắt hóa trị 0


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DIOXIN REMEDIATION AT BIEN HOA

AIRBASE AREA PROJECT

FINAL MASTERPLAN – VOLUME 1

DECEMBER 28, 2020

FINAL MASTERPLAN – VOLUME 1

US AGENCY FOR INTERNATIONAL DEVELOPMENT

Special acknowledgement to:

DIOXIN REMEDIATION AT BIEN HOA AIRBASE AREA PROJECT

DIOXIN REMEDIATION AT BIEN HOA AIRBASE AREA PROJECT

DIOXIN REMEDIATION AT BIEN HOA AIRBASE AREA PROJECT

DIOXIN REMEDIATION AT BIEN HOA AIRBASE AREA PROJECT

DIOXIN REMEDIATION AT BIEN HOA AIRBASE AREA PROJECT

DIOXIN REMEDIATION AT BIEN HOA AIRBASE AREA PROJECT

Updated Executive Summary and MND and USAID

DIOXIN REMEDIATION AT BIEN HOA AIRBASE AREA PROJECT

DIOXIN REMEDIATION AT BIEN HOA AIRBASE AREA PROJECT

• EXCAVATION AND TRANSPORT OF CONTAMINATED SOIL AND SEDIMENT – soils and

• LONG-TERM STORAGE OF SOIL AND SEDIMENT WITH “LOW” DIOXIN

DIOXIN REMEDIATION AT BIEN HOA AIRBASE AREA PROJECT

• TREATMENT OF SOIL AND SEDIMENT WITH “HIGH” DIOXIN CONCENTRATIONS

• RECONTAMINATION CONTROLS TO PREVENT SOIL AND SEDIMENT EROSION WILL

REMEDIATION ACTIVITY PACKAGING

SUMMARY TABLE 1 MASTERPLAN SCHEDULE

Interim Measures 2 (IM2)

Civil Works Phase 1

Civil Works Phase 2

ANNUAL REMEDIATION WORK

DIOXIN REMEDIATION AT BIEN HOA AIRBASE AREA PROJECT

REMEDIATION SUPPORT ACTIVITIES

WORK BREAKDOWN STRUCTURE AND CAPITAL COST

DIOXIN REMEDIATION AT BIEN HOA AIRBASE AREA PROJECT

DIOXIN REMEDIATION AT BIEN HOA AIRBASE AREA PROJECT

DIOXIN REMEDIATION AT BIEN HOA AIRBASE AREA PROJECT

1.1 PROJECT OBJECTIVES

1.2 PROJECT ROLES AND RESPONSIBILITIES

DIOXIN REMEDIATION AT BIEN HOA AIRBASE AREA PROJECT

DIOXIN REMEDIATION AT BIEN HOA AIRBASE AREA PROJECT

TABLE 1-1 MASTERPLAN IMPLEMENTATION STAKEHOLDERS

Government of Vietnam (GVN)

1.2.1 GOVERNMENT OF VIETNAM (GVN)

1.2.1.1 NATIONAL STEERING COMMITTEE 701

1.2.1.2 MINISTRY OF NATIONAL DEFENCE (MND)

• Military Science Department;

DIOXIN REMEDIATION AT BIEN HOA AIRBASE AREA PROJECT

1.2.1.2.1 MILITARY SCIENCE DEPARTMENT (MSD)

1.2.1.2.2 AIR DEFENCE AIR FORCE COMMAND (ADAFC)/PROJECT OWNER

– VIETNAM-RUSSIA TROPICAL CENTRE (VRTC) – provides technical support to GVN

1.2.1.3 MINISTRY OF NATURAL RESOURCES AND THE ENVIRONMENT (MONRE)

DIOXIN REMEDIATION AT BIEN HOA AIRBASE AREA PROJECT

1.2.2 UNITED STATES AGENCY FOR INTERNATIONAL DEVELOPMENT (USAID)

1.2.2.1 IMPLEMENTING CONTRACTOR(S)

1.2.2.2 A&E BIEN HOA CONTRACTOR

DIOXIN REMEDIATION AT BIEN HOA AIRBASE AREA PROJECT

• Applicable or Relevant and Appropriate Requirements (ARARs);

• Applicable cleanup levels, reuse, and waste characterization criteria;

• Roles and responsibilities of all parties implementing the Masterplan;

• Maps outlining where remedial elements are located.

DIOXIN REMEDIATION AT BIEN HOA AIRBASE AREA PROJECT

FIGURE 1-2 PROJECT ROADMAP MEETINGS