environmental compliance audit - world...

Environmental Compliance Audit

Manila Second Sewerage Project

Manila Water Company Inc.

December 2003

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Administrator

E94 V. 26

Environmental Compliance Audit

Reference R03-80

Prepared for

Manila Water Company Inc.

Prepared by

Maunsell Philippines Inc

11/F Ayala Life - FGU Center

6811 Ayala Avenue

Makati City

Philippines

Tel +632 843 6336

Fax +632 843 6125

[email protected]

December 2003

510500004

© Maunsell Philippines Inc 2003 The information contained in this document produced by Maunsell Philippines Inc is solely for the use of the Client identified on the cover sheet for the purpose for which it has been prepared and Maunsell Philippines Inc undertakes no duty to or accepts any responsibility to any third party who may rely upon this document. All rights reserved. No section or element of this document may be removed from this document, reproduced, electronically stored or transmitted in any form without the written permission of Maunsell Philippines Inc.

Quality Information

Document Environmental Compliance Audit

Ref 51050004 j :\51050004\administration\reports\rev 1\rev1.eca.mssp.mwci.8dec03.doc

Date December 2003

Revision Revision 1

Description Manila Second Sewerage Project

Originator

Eliza Paruñgao/Luc Valencia

Checked

Naniel Aragones

Approved

Jess P. Bayrante

Environmental Manager

Environmental Compliance Audit December 2003

Table of Contents

1.0 Introduction 1

2.0 Scope and Coverage of the Audit 2

3.0 Methodology 3

4.0 Manila Second Sewerage Project 4

4.1 Background 4

4.2 Project Status 4

4.2.1 Septage Management 4

4.2.2 Rehabilitation of Sewer Netw orks 5

4.2.3 Closed Circuit Television Inspection on Sewer Networks 5

4.2.4 Rehabilitation of Ayala Sewage Treatment Plant 5

4.2.5 Community Sanitation Projects 6

4.2.6 Laboratory and Maintenance Equipment 8

4.2.7 Consultancy Support Services 8

5.0 Audit Findings 9

5.1 Compliance With ECC Conditions 9

5.1.1 MSSP 9

5.1.2 STP 13

5.1.3 Notice of Violation (NOV) 17

5.2 Compliance With Environmental Management Plan 17

5.2.1 Septage Collection and Sea Disposal 17

5.2.2 Upgrading of the Magallanes (Ayala) Sewage Treatment and Network Facility 17

5.2.3 Sewerage Projects 22

5.3 Compliance With Philippine Environmental Guidelines 28

5.3.1 Sanitation Code 28

5.3.2 Effluent Standards 28

5.3.3 Ecological Solid Waste Management Act 30

5.3.4 Toxic Substances and Hazardous and Nuclear Wastes Control Act 31

5.3.5 Clean Air Act 31


5.4 Compliance With International Environmental Guidelines 32

5.4.1 World Bank Environmental Guidelines 32

5.4.2 London Convention 33

5.5 Compliance with Other Relevant Guidelines 34

5.5.1 Occupational Safety and Health Standards 34

5.5.2 Agriculture Chemicals Regulations 35

6.0 Conclusion and Recommendation 36

6.1 Conclusion 36

6.2 Recommendations 36

7.0 References 38

LIST OF ANNEXES

Annex A ECC of MSSP

Annex B ECC of STP Projects

Annex C Results of Sea Disposal Monitoring

Annex D PCG Permits

Annex E Minutes of Meeting – Environmental Training

Annex F Typical Environmental Monitoring Plan

Annex G Typical Environmental Management Plan

Annex H Permit to Operate

Annex I Monitoring Data

Annex J Certification from DENR Declaring Wastes as Non-hazardous

Annex K FPA Permit

LIST OF TABLES

Table 1 Underground Sewage Treatment Plant

Table 2 ECC Compliance Status of STP Projects

Table 3 EMP Septage Collection, Transport and Disposal

Table 4 Integrated EMP for MSSP and STP Projects

Table 5 Ayala STP Effluent Quality Analysis


LIST OF TECHNICAL ABBREVIATIONS AND NOMENCLATURE

Abbreviations Description AALA Agreement Amending Loan Agreement

AC Authority to Construct ASTM American Society for Testing and Materials

BFAR Bureau of Fisheries and Aquatic Resources

BOD Biochemical Oxygen Demand

CAA Clean Air Act

CCTV Closed Circuit Television

COD Chemical Oxygen Demand

CSS Consultancy Support Services

DAO DENR Administrative Order

DENR Department of Environment and Natural Resources

DO Dissolved Oxygen

DOH Department of Health

DPWH Deparment of Public Works and Highways

ECC Environmental Compliance Certificate

EGF Environmental Guarantee Fund

EIA Environmental Impact Assessment

EIS Environmental Impact Statement

EMB Environmental Management Bureau

EMP Environmental Monitoring Plan

GPS Global Positioning System

IEE Initial Environmental Examination

IRR Implementing Rules and Regulations LGU Local Government Unit

LTO Land Transportation Office

MBAS Methylene Blues Active Substances MMDA Metro Manila Development Authority

MMT Multipartite Monitoring Team

MOA Memorandum of Agreement

MPN Most Probable Number

MSSP Manila Second Sewerage Project

MWCI Manila Water Company, Inc.

MWSS Manila Waterworks and Sewerage System

NCR National Capital Region

NGO Nongovernmental Organization


NPI New or Proposed Industry

NOV Notice of Violation

NTU Nephelometric Turbidity Unit

OEI Old or Existing Industry

OSHS Occupational Safety and Health Standards

PD Presidential Decree

PCG Philippine Coast Guard

PCO Pollution Control Officer

PCU Platinum-Cobalt Unit

PO Permit to Operate

PPE Personal Protective Equipment

STARRT Safety Task Assessment Risk Reduction Talk

STP Sewage Treatment Plant

TSS Total Suspended Solids

WBGEG World Bank General Environmental Guidelines

Environmental Compliance Audit December 2003 Page i

Executive Summary

Manila Water Company, Inc. (MWCI) commissioned Maunsell to conduct an Environmental Compliance Audit (ECA) for the Manila Second Sewerage Project (MSSP) funded by the World Bank. This ECA was undertaken

as part of MWCI’s compliance to environmental regulatory requirements and fulfilment of conditions of the

MSSP loan package.

The ECA focused on whether:

• MWCI conforms with the conditions of MSSP’s Environmental Compliance Certificate (ECC) and

commitments made in the Environmental Impact Statement (EIS) • MWCI executes MSSP’s Environmental Management and Monitoring Plan

• MWCI implements MSSP in accordance with Philippine Environmental Guidelines, International

Environmental Guidelines, and other relevant laws, policies and regulations.

The table below summarizes the findings of the audit:

Compliance Status

Complied Audit Criteria

Yes No Remarks

MSSP Environmental Compliance Certificate • Project components �� Project implementation is in accordance with the components

as identified in the ECC. Separate ECC’s were secured for community sanitation projects.

• Endorsements, approvals and other pre-construction requirements

�� Endorsements, approvals and permits secured prior to construction.

• Relocation NA There are no settlement issues at the selected project sites. • Construction �� Occupational safety and health guidelines were observed and

mitigation measures as identified in the ECC were implemented.

• Septage management �� Operation of septage in collection, transport and disposal is in accordance with the ECC.

• Monitoring �� Monitoring and reporting were inadequate to meet ECC requirements.

• Training �� Training for engineers and contractors was conducted prior to start of construction activities.

• Environmental liability protection

�� No Environmental Guarantee Fund (EGF) was established.

• Transfer of ownership �� There has been no transfer of ownership to date. STP Environmental Compliance Certificate • Pre-construction/

Construction Phase �� MWCI complied with some requirements although there are

inadequacies in fulfilling requirements on orientation and posting of ECC.

• Operation Phase NA STP’s are still under construction. Environmental Management and Monitoring Plan • Septage collection �� • Septage transport ��

Measures as identified in EMMP are implemented.

• Septage sea disposal NA Sea disposal ceased operation in June 2002. • STP �� Measures as identified in EMMP are implemented.

Environmental Compliance Audit December 2003 Page ii

Compliance Status Complied Audit Criteria Yes No

Remarks

Sanitation • Submission of plans,

designs, etc. �� No submittal of such documents to Department of Health

(DOH) was made by MWCI. • Septage disposal methods �� No approval was secured from DOH on sea disposal and

land application of septage. Effluent • Effluent quality

�� Parameters such as temperature, pH, oil/grease, heavy metals and BOD within standards. Occasional exceedances were only noted for TSS, COD and total coliform.

• Monitoring �� Effluent monitored weekly. • Permitting �� Permit to Operate (PO) secured for Ayala STP. Solid Waste Management • Solid waste management

program �� MWCI currently implementing company-wide segregation

program. Chemicals and Hazardous Wastes Management • Chemicals management �� Chemical use limited to disinfectants. • Hazardous waste

management �� No hazardous wastes generated from the facility.

Air Quality Management • Emission quality �� Project not a significant source of emission. • Monitoring NA • Control facilities �� Vegetative buffer and odor control pit facility present at Ayala

STP. • Permitting �� No permits were secured for the odor control pit facility and

standby generators. World Bank General Environmental Guidelines • Effluent quality �� Several exceedance with total coliforms were noted. • Air quality �� Project not a significant source of emissions. Vegetative

buffer and odor control pit facility present at Ayala STP. • Solid waste management �� MWCI currently implementing company-wide segregation

program. • Hazardous waste

management �� No hazardous wastes generated from the facility.

• Noise –– No monitoring to assess compliance. • Record-keeping and

reporting �� MWCI still in the process of organizing documents, records,

data, etc. London Convention • Permitting �� Permits secured from the PCG and other endorsements were

secured. • Monitoring �� Monitoring inadequate to assess impacts on water quality and

marine biota. Occupational Health and Safety • Personal protective

equipment (PPE) �� On-site workers provided with PPE.

• Safety training and monitoring

�� Training and safety logging conducted by contractors. Random checks conducted by MWCI.

Agricultural Chemical Use • Permitting �� Permits secured from Fertilizer and Pesticide Authority on

land application of septage

Environmental Compliance Audit December 2003 Page 1

1.0 Introduction

In February 1997, the Metropolitan Waterworks and Sewerage System (MWSS) was privatised. This resulted in the operation of two concessionaires namely, the Manila Water Company Inc. (MWCI) for the East Zone and

the Maynilad Water Services Inc (MWSI) for the West Zone.

The Manila Second Sewerage Project (MSSP) aims to reduce the environmental pollution and health hazards from untreated wastewater through the improvement of sewerage and sanitation services in Metro Manila. To

implement this project, a USD$36 million loan from the World Bank was secured by the Government of the

Republic of the Philippines through MWSS, MWCI and MWSI.

As part of compliance to environmental regulatory requirements and fulfilment of conditions of the loan

package, MWCI commissioned Maunsell to conduct an Environmental Compliance Audit for the MSSP. This

report documents the findings of the study.


2.0 Scope and Coverage of the Audit

The first environmental compliance audit for the Manila Second Sewerage Project of Manila Water Company, Inc. covered the East Zone Concession. The components are outlined in Section 4.

This audit focused on compliance within the period of 2002-2003. However, since this is the first environmental

compliance audit, project activities prior to the period of coverage were also referenced in order to obtain a more precise assessment.

The limitations of the audit are as follows:

1. The audit covers only the components of MSSP for the East zone/concession and parts of the ECC

which are applicable to MWCI’s east zone concession. These are identified in the discussion.

2. The audit represents the results of site visits, interviews and data gathered from MWCI records.

3. Compliance issues as per ECC/EMP stipulations relating to the construction phase of the Ayala

Wastewater Treatment Plant Rehabilitation Project were not included in this audit. All rehabilitation

works were completed in October 2001 and April 2003 for Phase 1 and Phase 2, respectively. As such, only the requirements for the operation phase were considered by the audit team.

4. Community Sanitation Projects were only audited for applicable ECC/EMP requirements as the

facilities such as the sewage treatment plants (STPs) are yet to be completed.


3.0 Methodology

The procedures and techniques adopted for this study is consistent with ASTM Practice E-2107-00 for Environmental Regulatory Compliance Auditing and World Bank Environmental Sourcebook Update No. 11.

The methodology utilized in the study consisted of the following:

• Desk Review and Assessment of Documents

All relevant documents (reports, correspondences, permits, agreements, etc.), which are available at MWCI were reviewed and evaluated. An audit questionnaire was prepared to provide reference to status of the

project, compliance with ECC conditions and EIS commitments as well as compliance with applicable rules,

regulations and other legislation. A checklist of commitments and stipulations relevant to the audit report

was also prepared based on the EIS and ECC.

• Field Survey and Audit Proper

A meeting with MWCI representatives was conducted prior to the site visit for coordination. Site visits were

then undertaken between 14-30 October 2003. The various construction sites of sewage treatment plants were inspected as well as rehabilitation works on the sewer network and septage collection and disposal.

Photodocumentation was undertaken as well as interviews with on-site personnel and contractors’

representatives.

An interview with EMB Central Office and EMB-NCR personnel was scheduled. However, the EMB-NCR

office was in the process of relocating to another site during the scheduled interview, as such, none was

conducted.

The following persons were interviewed:

Name Company

Eva Matibag Manila Water Company Inc.

Ben Velasco Manila Water Company Inc.

Benjie Sacdalan Manila Water Company Inc.

Gilbert Apruebo Manila Water Company Inc.

Val Tanqueco Manila Water Company Inc.

Rolando S. Antonio Safety Engineer, JFE Construction

Cenon Bulatchino Site Manager, JFE Construction

Mon Dolores Manila Water Company Inc.

Dan Gozar Environmental Management Bureau – Central Office

Esperanza Sajul Environmental Management Bureau – Central Office

• Report Preparation

This report details the findings of the study as well as presents recommendations to address potential issues.


4.0 Manila Second Sewerage Project

4.1 Background

The MSSP was initiated by the Metropolitan Waterworks and Sewerage Systems (MWSS) in 1996 through a

loan with the International Bank for Reconstruction and Development. An Environmental Compliance

Certificate was issued on 10 October 1996. Concurrent with securing this loan, MWSS was privatised in February 1997. This resulted in the creation of two concessions. The East Zone was acquired by the MWCI

and the West Zone by Maynilad Water Services, Inc. The East Zone covers the cities of Quezon, Pasig,

Mandaluyong, San Juan, Pateros, Taguig, Rizal, Marikina, Manila and parts of Makati.

Under the General Conditions of the Loan Agreement, MWSS was required to formulate and implement an

Environmental Management Plan (EMP) and an initial EMP was prepared in January 1996. The Agreement

also required MWSS to implement the project according to appropriate environmental practices (Article III).

On 1 August 1997, MWSS and MWCI entered into a Concession Agreement to operate the system of

waterworks and sewerage services in the East Zone. On 16 March 1998, MWSS and MWCI entered into a

Project Agreement for the management and implementation of the East Zone component of the MSSP. The

agreement also carries the requirement to implement the EMP in a manner satisfactory to the Bank. Subsequently, on 17 March 1998, an Agreement Amending Loan Agreement (AALA) was signed assigning

project components to the concessionaires.

The ultimate objectives of the MSSP are to:

• Reduce the pollution of Metro Manila waterways and Manila Bay;

• Reduce the health hazards associated with human exposure to sewage in Metro Manila; and

• Establish a gradual low-cost improvement of sewerage services in Metro Manila by expanding MWSS’ septage management program.

4.2 Project Status

The MSSP has the following components for the East Service Area: (1) Provision for Septage Management; (2)

Rehabilitation of Sewer Networks; (3) Closed Circuit Television (CCTV) Inspection on Sewer Networks; (4)

Rehabilitation of Ayala Wastewater Treatment Plant; (5) Community Sanitation Projects; (6) Purchase of Laboratory and Maintenance Equipment; and, (7) Consultancy Services. The project is implemented by the

Wastewater Department of MWCI. The status of project implementation is discussed in the following section.

4.2.1 Septage Management

A Barge Loading Station for septage disposal trail has been constructed at Napindan Hydraulic Research

Center in Makati City. Construction of the facility started on 8 May 2000 and was completed on 2 March 2001.

The Barge loading station was designed to accommodate 700 tons of septage to be disposed of at a


designated sea disposal site. The site for the barge loading station is currently being leased from the

Department of Public Works and Highways. The facility is no longer used as a barge loading station since

MWCI has ceased septage sea disposal on 30 June 2002. Currently, septage and sludge recovered from the wastewater treatment plants and septic tanks from the East Zone, is applied as soil conditioner in lahar areas.

This is discussed in detail in Section 5.2.1. At present, the loading station is used for parking and temporary

storage area for various supplies and materials (Plate 32).

4.2.2 Rehabilitation of Sewer Networks

The rehabilitation works were divided in three phases. The areas covered by this project are as follows:

• Phase 1 – Magallanes Interchange, Makati City

• Phase 2 – Makati City (Forbes Park, San Lorenzo Village and Salcedo Village) and Quezon City

(Mayaman St., Maningning St., Makisig St., Mabuhay St., Sct. Gandia St. and Malvar St.)

• Phase 3 – Makati City (Dasmariñas Village) and Quezon City (Kamuning, South Triangle, Project 2, Project 3, Project 4, Project 6, PhilAm Life Subdivision, Heroes Hill, Malaya Subdivision and Roxas

District)

As of January 2001, Phase 1 and Phase 2 have been completed by MWCI. Construction is still on going for Phase 3 (Plate 1). To date, approximately 75% of the sewer network under Phase 3 have been rehabilitated.

4.2.3 Closed Circuit Television Inspection on Sewer Networks

A van equipped with CCTV unit specifically designed for pipeline inspection was purchased by MWCI in June

2002 (Plate 2). The following sewer networks have been inspected by MWCI:

• Phase 1 – Makati Sewer Network (Legaspi Village, San Lorenzo Village, Ecology Village, Chino Roces Ave., Pasong Tamo Ext., South Super Highway, Magallanes Village, EDSA, Dasmariñas

Village, Forbes Park, Urdaneta Village and Bel -Air Subd.) and Quezon City Network (South Triangle,

East Ave., Malaya Subd., Diliman, Project 1, Project 2, Project 3, Project 4, Project 6, Kamuning,

Heroes Hill and PhilAm Life Subd) • Phase 2 –Quezon City Network (South Triangle, EDSA, Project 4)

Inspection of sewer networks under Phase 1 and 2 were completed in July 2001 and October 2001,

respectively.

4.2.4 Rehabilitation of Ayala Sewage Treatment Plant

The Ayala Sewage Treatment Plant (STP) currently services Legaspi Village, Ecology Village, Chino Roces Avenue, Magallanes Village, Dasmari ñas Village, Forbes Park, Urdaneta Village and Bel-Air Subdivision.

Phase 1 rehabilitation of the Ayala STP started in November 2000 and was completed in October 2001. The


rehabilitation works include retrofitting of various process units (i.e., sedimentation tanks, aeration tanks, air

blowers, sludge drying beds, dosing facilities, etc.), pump replacements, improvements in the air-blower rooms,

de-clogging operations and repair works on the pipeline. For Phase 2, rehabilitation works commenced in December 2001 and was completed in April 2003. Several equipment, including the existing electrical system,

were replaced. A new odor control facility, automated dissolved oxygen (DO) and 1,000 KVA generator set

facility were also installed at the Ayala STP. Plates 3 – 6 show current conditions onsite.

4.2.5 Community Sanitation Projects

Community sanitation projects (CSP) consist primarily of construction of underground STPs. A total of 24

STPs servicing about 21,000 households are programmed to be constructed within this year and/or first quarter 2004. The location and areas serviced by the various STPs are shown in Figure 3. Selected STP projects,

most of which are located in Makati City, have not been implemented due to design and development issues.

The details and the status of STP projects are summarized in Table 1.

Table 1

Underground Sewage Treatment Plants

Location No. of

Households

Estimated

Capacity

(m3/day)

Remarks

PhilAm Homes, Quezon City 800 6,041 Concreting and steel works

ongoing (Plate 7)

Kalayaan Avenue, Quezon City 1800 4,414 Concreting on going (Plate 8)

Pag-asa BLISS Housing, Quezon City 600 780 Steel works on going (Plate 9)

Sikatuna BLISS Housing, Quezon City 600 609 Steel works on going (Plate 10)

Belarmino CST, Quezon City 800 1,640 Steel works on going (Plate 11)

Visayas Avenue, Quezon City 750 1,050 Existing communal septic tank

being demolished (Plates 12-13)

UP Campus, Quezon City (a) 7,027 Lean concrete laying ongoing (Plate 14)

K1 Karangalan Village, Cainta, Rizal 850 931 Steel works on going (Plate 15)

K2 Karangalan Village, Cainta, Rizal 777 1,193 Concrete curing on going (Plate

16)

K3 Karangalan Village, Cainta, Rizal 961 764 Steel works on going (Plate 17)

K4 Karangalan Village, Pasig City 945 1,265 Excavation works on going

(Plate18)

K5 Karangalan Village, Pasig City 401 577 Steel works on going (Plate 19)

K6 Karangalan Village, Pasig City 318 504 Repair of retaining walls on going

(Plate 20)

K7 Karangalan Village, Pasig City 957 968 No site activities. Construction


Location No. of

Households

Estimated

Capacity

(m3/day)

Remarks

pending issuance of permit to cut

trees and revised STP design

(Plate 21)

K8 Karangalan Village, Pasig City 742 968 Excavation works on going (Plate

22)

K9 Karangalan Village, Pasig City 588 777 Temporary holding tank

constructed (Plate 23) Caniogan BLISS, Pasig City 144 200 No site activities according to

MWCI.

Guadalupe BLISS, Makati City 760 851 Excavation works on going (Plate

24)

Mandaluyong MRH 180 300 Concreting works on going (Plate

25)

Lakeview Manors, Taguig 458 513 No site activities according to

MWCI.

Maharlika Village MRH, Taguig 420 470 Steel and concreting works on

going (Plate 26)

Centennial Village, Taguig 1,140 2,960 Steel and concreting works on going (Plate 27)

Fortville, Taguig 1,140 1,142 Steel and concreting works on

going (Plate 28)

Bagong Lipunan, Taguig 1,213 1,750 Mobilization and site survey on going (Plate 29).

Diego Silang Village, Taguig 2,880 Rehabilitation works on-going

(Plate 30).

Tejeros BLISS, Makati City Will not be implemented

San Miguel Village, Makati City Will not be implemented

San Lorenzo Village, Makati City Will not be implemented

Kaimitoville, Valle Verde, Pasig City Will not be implemented

Coryville Condominium, Makati City Will not be implemented

Note: (a) for UP Campus only

Part of the CSP is the rehabilitation of existing treatment facilities. Rehabilitation works on the Karangalan Village Lift Stations were completed by MWCI in December 2002. For Pamayanang Diego Silang Sewage

Treatment Plant, the rehabilitation works is yet to commence although the project has been awarded to a

contractor ( Plate 30).


4.2.6 Laboratory and Maintenance Equipment

Vehicles, machinery and tools needed for the mai ntenance of the sewerage system together with specialized equipment, tools, spare parts and materials for the MWSS laboratory were secured through the MSSP.

4.2.7 Consultancy Support Services

Part of the MSSP funding was allocated for Consultancy Support Services (CSS). The CSS are intended for

the following programs:

• Master planning for sewerage and sanitation projects • Studies and database compilation on septage collection, disposal and treatment

• Environmental impacts monitoring, assessments and reporting of the project

• Preparation of succeeding sewerage development projects

• Development of detailed design packages


5.0 Audit Findings

This section discusses MWCI’s compliance with ECC conditions, Environmental Management and Monitoring Plan, relevant environmental guidelines and MWCI’s Environmental Policy.

5.1 Compliance With ECC Conditions

In December 1994, MWSS submitted an Environmental Impact Statement (EIS) for MSSP. An ECC was

issued on 10 October 1996 covering the various components of MSSP for the East and We st Zone

concessions. A copy of the ECC for the MSSP project is attached as Annex A. ECCs were also secured for

the construction of each STP. The location of these STPs and ECC details are presented in Annex B.

5.1.1 MSSP

• ECC Condition No. 1 – This Certificate is valid only for the implementation of the Manila Second Sewerage Project (MSSP) that includes the following components:

A. Septage Collection and Septage Sea Disposal;

B. Dagat-Dagatan Pilot Sewage Treatment Plant;

C. Upgrading of the Ayala and Manila Central Sewerage System; D. Strain Drainage Improvement; and

E. Other advanced septage treatment plant in Quezon City, Taguig and other Pasig River adjoining

areas.

Complied with throughout the project implementation period. The components of the project are

implemente d in accordance with this condition. To date, MWCI conducts septage collection but has

ceased septage sea disposal since 30 June 2002. Apart from the Dagat-Dagatan Pilot Sewage Treatment

Plant and Manila Central Sewerage System, all other items are included in the East Zone. Separate ECCs were secured by MWCI for the construction of each STP.

• ECC Condition 2 – Endorsements from the different Local Government Units (LGU) concerned to include

the coastal municipalities of Bataan, Zambales and Cavite shall be secured before project implementation;

Complied. Endorsements from identified LGUs were issued as summarized below:

Office of the Provincial Governor, Bataan 12 January 2000 Office of the Governor, Zambales 20 July 2000

Office of the Governor, Cavite 3 April 2000

Copies of these endorsements were transmitted to EMB on 5 August 2002 as part of the ECC Compliance Monitoring Report (January – March 2002).


• ECC Condition 3 – The proponent shall closely coordinate with the DPWH regarding the settlem ent of the

ROW, specifically, for the Estero de Vitas; the MMDA regarding the dumping of sludge to San Mateo

Landfill; the LLDA; the BFAR; DOH; EMB and the relevant regional offices of the DENR before and during project implementation;

Complied. The agencies mentioned above are members of the MMT. This is discussed in more detail

under Condition 12. Furthermore, there were no right-of-way issues as there was no relocation required. Also, sludge is not being dumped in the San Mateo Landfill. Dried sludge from the Ayala STP are

collected by individuals and used as fertilizer.

• ECC Condition 4 – Affected families shall be properly informed and consulted before any plan to relocate/resettle them is consummated;

Not applicable as of this audit. According to MWCI, no families were relocated for the East Zone

projects. MWCI selected project sites where there are no existing settlements.

• ECC Condition 5 – An acceptable Relocation Program to include a just and fair compensation scheme for

affected households shall be submitted to the EMB within thirty (30) days upon receipt of the ECC;

Not applicable as of this audit. A Relocation Program was not necessary since there were no families

that required relocation.

• ECC Condition 6 – Measures to mitigate noise, odor and dust/particulates generated during construction and operation of loading stations and other related facilities shall be effected;

Complied. The loading station is no longer operational as a barge loading station. During the use of the

Napindan transfer station, the airtight pipe system conveyed septage from the vacuum tankers to the barge to minimize odor. Currently, it is used as a depot for MWCI vehicles and materials. For other related

facilities such as the Ayala STP, measures are in place to mitigate noise, odor and dust from operational

activities. For STPs under construction, mitigating measures are being implemented to minimize such

impacts. These measures are detailed in the Environmental Management Plan. For operational activities such as septage collection, vacuum tankers with sealed suction hoses are being used.

• ECC Condition 7 – An adequate buffer zone vegetated with appropriate tree species shall be established

at the periphery of the Sewage Treatment Plants (STPs) to be constructed to minimize odor.

Not applicable as of this audit. All STPs are still under construction. The Ayala STP was observed to

have an adequate vegetative buffer (Plates 3 and 6).

• ECC Condition 8 – All cut, stripped and exposed surfaces shall be rehabilitated immediately to minimize

soil erosion and siltation;


Not applicable as of this audit. As previously noted, construction activities are still on-going at the STP

sites. According to the project contractors, the site will be rehabilitated as necessary. For rehabilitation of sewer networks, excavated sections of the road are immediately restored upon completion of works (Plate

1).

• ECC Condition 9 – Proper collection, storage and transport of septage from septic tanks shall be effected;

Complied. On 30 October 2003, the audit team observed septage collection from a residence along 18 th

Street in Quezon City. Vacuum tankers with sealed suction hoses were used. The team then followed the

tanker to the Philam Sewage Treatment Plant where septage is temporarily stored in the existing Imhoff tanks. During transport, the audit team observed occasional swerving of the tanker on the way to the

Philam Sewage Treatment Plant.

• ECC Condition 10 – Health and sanitation practices shall be observed at all times and protective gadgets/devices shall be provided to workers to avoid accidents and hazards posed by the project;

Complied with as of this audit. As observed during the site reconnaissance, construction workers were

provided with protective gadgets/devices such as hardhats, earplugs and safety shoes (Plate 25). Portable toilet and trash bins are likewise provided on site. Compliance with the Occupational Safety and Health

Standards (OSHS) are further discussed in Section 5.5.1.

• ECC Condition 11 – All septage/effluent shall meet the National Water Quality Standards and shall be disposed of only at the designated disposal sites identified by the Philippine Coast Guard (PCG) in

accordance with the 1972 London Convention on the Prevention of Marine Pollution by Dumping of Waste

and Other Matter;

Complied with within the septage sea disposal operation period. MWCI have ceased septage sea

disposal since 30 June 2002. The one-year trial period amounted to 25,396 cu m of septage disposed to

sea. This was equivalent to about 7,000 septic tanks that have been emptied. During this time, monitoring

of water quality was undertaken at the disposal site as well as the nearby coastal waters. The results of these activities are summarized in Annex C.

Permits and the disposal of septage were coordinated with PCG (Annex D). Compliance with the

provisions of the London Convention is discussed in detail in Section 5.4.2.


• ECC Condition 12 – A Mutipartite Monitoring Team (MMT) composed of representatives from the BFAR,

LLDA, MMDA, DOH, PCG, DPWH, MWSS, LGU concerned and the affected parties shall be formed within

60 days from the receipt hereof to ensure effective environmental monitoring at all phases of project development/implementation;

Complied. Based on agreements, a MMT was formed in 18 March 2003 to monitor effects of septage sea

disposal in the water. To date, MWCI have not pushed to reconvene the MMT. However, according to the EMB, an MMT is still required even if septage sea disposal is no longer being conducted. The EMB is in

the process of responding to queries sent by MWCI on this matter.

The Memorandum of Agreement (MOA) for the MMT still requires the signature of some invited members. The EMB had stated that the refusal of some members to sign the MOA does not invalidate it since

majority have signed including the DENR Secretary.

• ECC Condition 13 – Regular monthly monitoring of affected water resources to include the coastal waters of Bataan, Zambales and Cavite for biological, physical and chemical parameters including BOD, DO,

turbidity, suspended solids, color, nitrogen, phosphorus, oil/grease, fecal coliforms and total coliforms shall

be undertaken, the results of which shall be submitted to EMB and the relevant DENR Regional Office on a

quarterly basis;

Not complied. Water quality monitoring was conducted during sea disposal activities. However, there is

no documentary evidence to show that this has been submitted to EMB or its regional office on a quarterly

basis.

• ECC Condition 14 – Annual monitoring of marine biota (planktons, algae and important fish species) in

coastal waters and off-shores of Bataan, Zambales and Cavite shall be conducted, the results of which

shall be submitted to the EMB and the DENR Regions III and IV-A;

Not complied. A preliminary study was conducted in October 2002 and this was submitted as part of the

ECC compliance monitoring report to the EMB. However, the report is insufficient to show adequate

compliance to the requirement of the condition since it is explicitly identified as a preliminary study and this was limited to plankton survey. Post-sea disposal monitoring may also be required to ascertain that the

activity did not pose significant impacts to marine biota. Should MWCI opt to cease annual monitoring,

written approval should be secured from the EMB.

• ECC Condition 15 – All other mitigating measures stated in the EIS document, modifications to them and

as approved by the EMB, shall be strictly implemented;

A detailed discussion of compliance with mitigating measures and the EMP is provided in Section 5.2 . Since the issuance of the ECC, the EMP for MSSP has been revised twice. The latest version (September


1998) was submitted to EMB on July 2003. It is unclear whether the EMB have issued an approval for the

submitted EMP.

• ECC Condition 16 – An Environmental Guarantee Fund (EGF) shall be established by the proponent

through a MOA to cover the cost of monitoring and compensation/rehabilitation for damages by the project;

Not complied with. A MOA to establish the EGF was not formulated.

• ECC Condition 17 – The proponent shall undertake an environmental training for its various project

component contractors and their staff/workers to gain understanding of the rationale for the required

mitigation and monitoring work and to get acquainted with the standard operations and procedures as well as the health and safety measures of pertinent project components;

Complied with. MWCI conducted an environmental awareness training for its engineers and contractors

prior to the start of construction activities. The training highlighted conditions and requirements of the ECC. The minutes of the meeting is presented as Annex E.

• ECC Condition 18 – On-the-spot monitoring and inspection can be initiated by the EMB and/or DENR

NCR/Regions III&IVA anytime in coordination with concerned groups; and

MWCI Compliance Not Required. To date, there have been no on-the-spot monitoring and inspections

conducted by the DENR.

• ECC Condition 19 – Transfer of ownership of this project carries the same conditions in this ECC for

which written notification shall be made within fifteen (15) days from such transfer.

Complied with. There has been transfer of ownership of the project. The MWSS remains the proponent of the MSSP. Under the Concession Agreement between MWSS and MWCI, MWCI shall have

supervisory responsibility for existing projects. This includes supervision, quality control and contract

administration.

5.1.2 STP

MWCI proposed to construct 24 STPs as part of the community sanitation project. This section presents the compliance status of each project relative to ECC conditions and commitments made in the submitted Initial

Environmental Examination (IEE) Reports. The IEE included the following: an Environmental Monitoring

Program, an Environmental Monitoring Plan (EMP) Matrix, and an Environmental Management Plan. Each of

these are discussed in the succeeding sections. The ECCs for the individual STPs are presented as Annex B.


• Environmental Compliance Certificate

The ECC compl iance status of the STP projects is summarized in Table 2. The key issue identified in the assessment of ECC compliance of the STP projects was the absence of the ECC at the Guadalupe BLISS site.

A number of STP projects identified in Table 1 are no longer going to be implemented due to design and/or

development issues. In compliance with Condition 8 of the ECCs issued for these projects, MWCI shall inform EMB of any abandonment or indefinite work stoppage. This will also prevent the unnecessary issuance of

notices in the future.


Table 2. ECC Compliance Status of STP Projects

ECC Condition Compliance Status

P1 P2 P3 P4 P5 P6 P7 P8 P9 P10 P11 P12* P13 P14

Pre-Construction and Construction Phase: 1. All amenities/utilities affected shall be immediately restored and rehabilitated NA NA NA NA NA NA NA NA NA NA NA NA NA

2. Conduct orientation for resident engineers and contractor regarding ECC conditions and mitigating measures

��

3. Billboard bearing the ECC number shall be displayed in a conspicuous location. �� ×× ��

Operation Stage:

4. Operational capacity and service coverage of STP NA NA NA NA NA NA NA NA NA NA NA NA NA

5. Adequate maintenance procedures to avoid objectionable odor NA NA NA NA NA NA NA NA NA NA NA NA NA

Others:

6. Implementation of proposed Environmental Management Plan Refer to discussion Section 5.2.3

7. Stoppage of all activities causing adverse impacts and implementation of remedial measures and compensation of aggrieved parties.

NA NA NA NA NA NA NA NA NA NA NA NA NA

8. In case of abandonment or indefinite work stoppage, submit written notification and restore site to original condition or provide safety and protective measures to prevent adverse environmental impacts


9. Restoration of works/grading of exposed grounds shall be immediate undertaken for safety, enhancement and ecological purposes


10. Posting of ECC in a conspicuous place in the Administration Office �� ×× �� NA �� 11. Implementation of EMP and reporting of monitoring and compliance annually ×× ×× ×× ×× ×× ×× ×× ×× ×× ×× ×× ×× ×× 12. Written notification to DENR-NCR for approval in case of non-compliance of conditions for technical reasons.


13. DENR-NCR inspection and monitoring of ECC conditions without prior notice NA NA NA NA NA NA NA NA NA NA NA NA NA Note: Legend in succeeding page.


Legend:

Project/Location ECC Number: Date Issued:

P1 Centralized Sewage Treatment Plant, PhilAm Life Homes, West Avenue, Quezon City NCR-2000-12-11-0267-211 2009-274-QC-211 11 December 2000

P2 Construction and Operation of Sewage Treatment Plant, Guadalupe BLISS, JP Rizal St., Bgy Cembo, Makati City

NCR-2000-10-04-0217-120-2008-213-MK-120 04 October 2000

P3 Construction and Operation of Sewage Treatment Plant, PAG -ASA BLISS, Bgy. Bagong Pag-asa, Quezon City

NCR-2000-10-04-0219-120-2008-221-QC-120 4 October 2000

P4 Construction and Operation of Sewage Treatment Plant, Mandaluyong Medium Rise Housing Project, G. Aglipay St., Old Zaniga, Mandaluyong City

NCR-2002-02-22-059-211-2002-01-34-MD-211 22 February 2002

P5 Construction and Operation of Sewage Treatment Plant, Maharlika Bliss-Maharlika Condominium, Lot 4, Blk 10, Maharlika Village, Taguig

NCR-2000-10-04-0216-120-2008-240-TG-120 04 October 2000

P6 Centralized Sewage Treatment Plant, MRB Condominium, Circumferential Road, Brgy. Western Bicutan, Taguig

NCR-2000-12-22-0265-211-2009-267-TG-211 22 December 2000

P7 Centralized Sewage Treatment Plant, Centennial Village, Circumferential Road, Western Bicutan, Taguig NCR-2000-12-11-0268-211-2009-265-TG-211 11 December 2000

P8 Centralized Sewage Treatment Plant, Sikatuna BLISS, Brgy. UP Campus, Quezon City NCR-2000-12-11-0266-211-2009-275-QC-211 11 December 2000

P9 Centralized Sewage Treatment Plant, Kalayaan Avenue (near Kamias St.), Bgy. Malaya, Quezon City NCR-2001-03-22-032-211-2009-283-QC-211 22 March 2001

P10 Construction and Operation of Sewage Treatment Plant, BLC BLISS and Tenement Housing, Bgy. Lower Bicutan, Taguig

NCR-2000-10-04-0215-120-2008-250-TG-120 04 October 2000

P11 Nine Units of Centralized Sewage Treatment Plan, Karangalan Village, Pasig City NCR-2000-02-19-0289-211-2009-284-PS-211 19 February 2001

P12 Lakeview Manors Sewage Treatment Plant NCR-2001-12-21-278-211-2001-04-111-TG-211 21 December 2001

P13 U.P. STP (MWCI to provide copy of ECC)

P14 Barangay Vasra, Visayas Avenue (MWCI to provide copy of ECC)

�� Complied

×× Not complied

NA Not applicable at the time of the audit.

P13* was not audited. According to MWCI, no site activities have been initiated.


5.1.3 Notice of Violation (NOV)

On 26 July 2002, MWSS was issued a Notice of Violation for Conditions No. 13 and 14 regarding regular

monthly monitoring of coastal waters and submission of quarterly reports to EMB and relevant DENR Regional

Office and annual monitoring and reporting of marine biota in coastal waters, respectively. The NOV also asked MWSS to provide proof of compliance to condition no. 11 (compliance with effluent standards) as

reported by BFAR and PCG.

On 5 August 2002, MWCI submitted to EMB an ECC Compliance Monitoring Report for the period of January-March 2002.

5.2 Compliance With Environmental Management Plan

The EMP for the MSSP have continuously been revised since the ECC was granted. In November 1996,

EMPs for each component were prepared by Original Engineering Consultants Co., Ltd. In association with

DCCD Engineering Corporation. The EMP was submitted to EMB in November 1996.

On 24 September 1998, MWCI prepared an EMP for the east zone concession. This EMP was submitted to

EMB in September 1998. In 2002, the EMP was further revised and more details included. This was

submitted to EMB in July 2002. According to MWCI, there have been no response from EMB regarding approval of the submitted documents.

This section discusses MWCI’s compliance with the 2002 EMP which is divided into four parts as discussed

below.

5.2.1 Septage Collection and Sea Disposal

The environmental management plan for septage collection and sea disposal was obtained from the 1998 version of the revised EMP. At the time of the audit, the mitigating measures for septage collection and

transport were applicable as sea disposal was no longer being undertaken. Assessment of compliance with

the EMP is presented on Table 3.

5.2.2 Upgrading of the Magallanes (Ayala) Sewage Treatment and Network Facility

The EMP for the Ayala STP was applicable for the duration of the construction phase. At the time of the audit,

the Ayala STP had already finished the construction phase and is operational. As such, compliance to the EMP was not assessed.


Table 3. EMP - Septage Collection, Transport and Disposal

Potential Impact Mitigating Measure Responsibility Schedule Remarks

A. Septage Collection

Noise pollution during

transfer of septage from

septic tank to tanker

Septage collection will be done

during daytime or as agreed

with the local community

MWCI Every desludging

operation

Complied. Septage collection is done according to

schedule by MWCI as part of desludging program or

as requested by customers. These activities are

undertaken during daytime.

Odor emission during

transfer of septage from

septic tank to tanker

Tankers used will be vacuum

tankers and operations will be

kept airtight

MWCI Every desludging

operation

Complied. Vacuum tankers are used in collection of

septage. Odor emission is minimal and confined to

the open septic tank as well as the tanker during

collection.

B. Septage Transport

Vacuum tanker

spillage/accident

• Training of personnel on safe

and proper use of vacuum

tanker and equipment

• Stand-by emergency team

available to address any

tanker accident

MWCI Quarterly training of

personnel. Regular

maintenance of

tankers.

Complied. According to MWCI, performance of

drivers are assessed monthly by the Health and

Safety Committee.

Diesel fume emissions of

vacuum tankers

Regular maintenance and

check-up of vehicles

MWCI Quarterly Complied. Regular maintenance and checks for

emissions are part of requirements of the Land

Transportation Office prior to registration of vehicle.


Table 3 continued.


Spillage during transfer of

septage from tanker to barge

• Loading station is equipped

with an automatic shut off

valve to ensure no spillage

will occur during the transfer

• Hypochlorite solution will be

applied to the affected area

MWCI Regular

maintenance of

tankers and barge

equipment

No longer applicable at the time of the audit.

Tanker breakdown An Emergency Team will

always be on standby to

address breakdown of vehicles

and equipment

MWCI Daily operations Complied. An emergency team is available 24-hours

a day to respond to emergencies.

Hazard and Risk to

personnel

Awareness of operators and

truck drivers on health and

safety regulations (eg,

protective gear, etc.)

MWCI Daily operations.

Quarterly training on

safety and health

regulations

Complied. MWCI have a Health and Safety

Committee which conducts training and assesses

compliance to health and safety policies

C. Septage Disposal

Overlading of barge resulting

to barge sinking

Safety check and permit

issued by Philippine Coast

Guard (PCG) before every

barge sailing

MMT, PCG Before every barge

sailing

Sea disposal has been stopped since June 2002.

Based on document review, permits were secured

from the PCG.


Table 3 continued.


Adverse impact on the

coastal water quality

• Regular off-shore monitoring

in key areas to determine

impact of dumping on water

quality

• Water quality monitoring at

the disposal site

• Septage quality monitoring

• Strict compliance to dumping

regulations

MMT • Monthly

• Every dumping

• Before every

barge sailing

• Every barge

sailing

Sea disposal has been stopped since June 2002.

Non-compliance to dumping

restrictions

• Provision of Global

Positioning System (GPS)

to barges

• PCG will escort the barge

from the barge station to

the disposal site to ensure

that the barge will dump on

the designated site

MMT, PCG Every barge sailing No longer applicable at the time of the audit.


Table 3 continued.


Spillage of barge due to

adverse weather conditions

• No dumping policy on

rainy/stormy months to

ensure safety of the barge

• Regular check up of the

sea worthiness of the barge

MMT, PCG July, August,

September

Before every barge

sailing

No longer applicable at the time of the audit.

Independent auditors will annually assess the environmental compliance of MWSS and MWCI under

MSSP.

This audit fulfils the requirement of the EMP

commitment.


5.2.3 Sewerage Projects

In the Initial Environmental Examinations Reports submitted for the proposed STP projects, the following were

submitted:

• Environmental Monitoring Program

Based on the Initial Environmental Examination Reports submitted for the STPs, the typical Environmental

Monitoring Program for the STP Projects indicated the following:

Construction Phase: Visual inspection shall be carried out to e nsure that:

§ Construction schedule of high noise activities is followed

§ Construction trucks are washed down prior to departure from site to avoid mud tracks in the area

§ Standing water is avoided to minimize mosquitoes § Dust control measures are implemented

§ Workers have access to toilet facilities on-site

§ Construction materials are stored so as to avoid inconvenience and danger to the locators,

pedestrians and motoring public.

During the site visits, on-site personnel confirmed that these parameters are monitored visually on a daily

basis.

• Environmental Monitoring Plan

The typical Environmental Monitoring Plan (EMP) Matrix (Annex F) for the construction phase covers the

following parameters: ambient air/odor, solid waste, noise, vehicular traffic and labourers/employees. However, the EMP does not specify what are being monitored in these aspects.

• Environmental Management Plan

The typical Environmental Management Plan is presented as Annex G.

For the above environmental monitoring and management plans, these have been consolidated with the MSSP

EMP and are discussed in Section 5.2. Table 4 presents a consolidated EMP.

The findings on the compliance to EMP commitments showed that housekeeping needs to be improved

particularly in the K6, Karangalan Village site. There is also a commitment to formulate a monitoring program.

While there was a typical one submitted along with the IEE, there is a need to improve this. For example, the frequency of monitoring activities are stated as “daily” while the standard references are DENR Administrative

Orders 34 and 35 which require water quality monitoring. MWCI conducts daily process control monitoring as

well as weekly effluent quality monitoring as part of its commitment in the EMP.


Table 4. Integrated EMP for MSSP and STP projects

Project Activities Impacts Mitigation Measures Responsible

Unit Schedule Guarantees Remarks

A. Pre-Construction/ Construction Phase

1. Site

Preparation

Works

• Clearing

• Fencing

• Accumulation of solid

wastes

• Slight temporary

disturbance due to dust

• Noise

• Solid wastes shall be segregated and

disposed of properly

• Ground shall be sprinkled with water to

minimize dust

• Site development activities shall be

limited during daytime

Project

Contractor

Before

Construction

• Scope of work

of project

contractor

• ECC

Conditions

Two sites were observed

as being prepared for

construction works:

Karanganlan 7 and

Bagong Lipunan BLISS in

Taguig

2. Delivery of

Construction

Materials

• Increased on-site traffic

due to delivery vehicles

• Noise from delivery

vehicles

• Implement traffic management scheme

• Delivery shall be limited during daytime

• Install temporary sound barriers around

the working area

Project

Contractor

During

construction

• Scope of work

of project

contractor

There were no deliveries

observed duri ng the site

visits

3. Excavation, Civil Air Quality

Works,

Finishing,

Commissioning

and Start-up

• General impacts on air

quality/emissions

• Efficient construction planning and work

scheduling

• Provision of properly maintained storage

area for keeping stocks of construction

materials and equipment

• Development and enforcement of strict

health and safety pollution control

regulations specific for the project site

Project

Contractor

During

construction

and testing

• Scope of work

of project

contractor

• ECC

Conditions

K6, Karangalan Village

was identified as requiring

better housekeeping

efforts (Plate 20)


Table 4 continued.

Project

Activities Impacts Mitigation Measures

Responsible


• Temporary disturbance

due to dust

• Ground shall be sprinkled with water to

minimize dust

• Prompt and fast removal of excavated or

dredged spoils from the construction site

• Dust accumulation will also be prevented

through proper washing of vehicles prior

to its departure from the site

• Good housekeeping of workplace and

construction of affected areas

At the time of the audit and

site visit, there was evidence

of increased dust dispersion

from the construction

activities. However, rains

have been sufficient in

minimizing dispersion.

• Air pollution from

vehicle emissions

• Control of vehicle emissions

Vehicles are being

maintained and emissions

tested as required by the

Land Transportation Office

• Noise due to operation

of equipment and use of

construction tools

• Construction activities shall be limited

during daytime

• Equipment shall be provided with mufflers

and noise suppressors

• Provision of personal protective

equipment to all workers

According to on-site

personnel, construction

activities are limited during

daytime with the exception of

concreting which occurs

during the evening due to the

truck ban. However, this is

done with the permission of

residents. PPE were provided

to workers.


Table 4 continued.



• Odor from workers’

sewage

• Provide temporary toilet facilities for

workers

Temporary toilet facilities

are provided on-site

Water Quality

• Soil erosion • Provide shores and braces to prevent

soil erosion

Shores and braces are

not necessary due to the

terrain and type of

construction being

undertaken

• Water pollution due to

wastewater, oil

leakage/spills

• Provide temporary drain systems and

storage facilities for excavation soils,

fuel and oils needed for equipment

• Cautious and sensible planning for

construction and post-construction

phases of the project

• Provision of routine chemical and oil

spill clean-up plan

• Formulation of a monitoring program

Drain systems are in

place in all construction

sites. At the time of the

audit, there have been no

recorded or reported oil

spills/leaks. However,

there is inadequate

implementation of

monitoring program.

Solid Waste

• Accumulation of solid

wastes

• Solid wastes shall be segregated and

disposed properly

According to on-site

personnel solid wastes

(such as those produced

by workers) are collected

along with the domestic


Table 4 continued.



solid waste. Construction

wastes are hauled by an

independent contractor

Health and Safety

• Health and safety of

workers

• All operators will be required to fill up

the Safety Task Assessment Risk

Reduction Talk (STARRT) Card before

entering the construction site and before

doing a particular work

The audit team observed

a toolbox meeting where

the STARRT Card was

filled out and health and

safety instructions were

given to workers

B. Operation Phase*

Operations • Accumulation of solid

waste

• Sludge will be stabilized/dewatered and

used as soil conditioner

MWCI Operation

and

Not applicable at the time

of the audit.

• Noise

• STP shall be constructed underground

• Pumps and other equipment shall be

provided with encasement, mufflers and

noise suppressors

maintenance Not applicable at the time

of the audit.

• Wastewater

• The effluent shall conform with DENR

Standards set forth in DENR

Administrative Order 34 and 35 for

Class C waters.


of the audit.


Table 4 continued.



• Odor

• Provision of odor control mechanisms

(deodorizer/absorbent/masking agent)

to prevent malodorous emissions

• Maintenance of greenbelt zones with

appropriate tree species


of the audit.

• Health and safety of

operators

• All workers will be required to fill up the

Safety Task Assessment Risk

Reduction Talk (STARRT) Card before

entering the site and doing a particular

work.


of the audit.

* EMP items for operations phase are not yet applicable at the time of the audit


5.3 Compliance With Philippine Environmental Guidelines

The following sections detail MWCI’s compliance with applicable provisions of the Sanitation Code, Effluent

Standards, Ecological Solid Waste Management Act , Toxic Substances and Hazardous and Nuclear Waste

Control Act and Clean Air Act. The audit team focused on these particular guidelines, as these are the most

relevant audit criteria for the project. Related environmental regulations are also included in the compliance assessment.

5.3.1 Sanitation Code

The Implementing Rules and Regulations (IRR) of Chapter XVII of Code on Sanitation of the Philippines (PD

856) provides specific provisions for sewage and excreta collection and disposal system projects. Section 5 of

the IRR, pertains to public sewerage systems. Under this section, the project proponent is required to submit

plans, design and necessary data and specifications to the Office of Secretary of Health or his duly authorized representative for approval prior to start of work. For existing facilities, as-built plans and specifications should

be submitted for review and approval. The manner of disposal of sludge from septic tanks and STPs should

also be approved by the Department of Health (DOH). For a tr eatment plant in operation, as in the case of

Ayala STP, the facility should be approved by DOH and capable of treating sewage to levels meeting DENR effluent standards. The operator should also provide laboratory facilities to conduct control tests and water

quality examinations. Records from such tests including operating data, cases of breakdown and improper

functioning of the treatment facility should be submitted to local health authorities. A registered sanitary

engineer should also manage the facility.

To date, the MWCI coordination with the DOH is limited to meetings with DOH at the Committee for the

Creation of Supplemental Guidelines for PD 856 of which MWCI is a member since 2001. According to MWCI,

DOH is informed of ongoing and new projects during the meetings. For instance, the DOH was informed during such meetings of the septage sea disposal conducted in 2001-2002 and the current land application of

septage. MWCI, however, was not able to provide proceedings or minutes from such meetings to the audit

team.

There were also no submittals of plans, specifications, operating data, etc., for approval or review to the DOH.

According to MWCI, all approvals are sought from the DENR. Results of monitoring and other operating data

are reported through the Pollution Control Officer (PCO) quarterly monitoring reports.

5.3.2 Effluent Standards

Domestic wastewater generated from Metro Manila and primarily discharged to the Pasig River and its

tributaries. Previous studies show that the water quality of Pasig River and its tributaries fall under Class D Waters as described in the DENR Administrative Order No. 34 Series of 1990 (DAO 1990-34, Revised Water

Usage and Classification/Water Quality Criteria). However, there are several projects being implemented by

the local and national government in partnership with private sector and non-governmental organizations


(NGOs) with the aim of improving Pasig River, including other waterways in Metro Manila, to Class C. As such,

the most often adopted classification is Class C. The prescribed concentration limits for Class C are detailed in

the DENR Administrative Order No. 35 Series of 1990 (DAO 1990-35, Revised Effluent Regulation). Separate concentration limits were given for old/existing industries (OEI) and new/proposed industries (NPI).

For the projects under the East Zone, only the Ayala STP is operational. Treated wastewater is discharged to

Maricaban Creek, at the southern perimeter of the facility. A Permit to Operate (PO) has been secured by MWCI and this is renewed every six months (Annex H). MWCI currently conducts at least once a week

monitoring at the facility. The results of the monitoring are reported on the quarterly PCO reports. Data

generated from the monitoring since the completion of Phase 1 Rehabilitation in December 2001 was provided

by MWCI to the audit team (Annex I). Among the parameters regularly monitored by MWCI in the effluent samples are pH, temperature, dissolved oxygen, BOD, COD, residual chlorine and total and fecal coliform.

Other parameters such as settleable and dissolved solids, solid, color, phenols, oil and grease, surfactants and

selected heavy metals were also occasionally monitored by MWCI. The data were compared to the DAO

1990-35 Standards for Class C Waters for NPI. A summary statistics of the results of the monitoring are shown in Table 5. The limits as given in the World Bank Environmental Guidelines are also shown in the table. This

will be discussed further in Section 5.4.1.

Table 5.

Ayala STP Effluent Quality Analysis

Parameter Minimum Maximum Average Na

DAO 90-35

Effluent

Standard for

Class C

Waters

World Bank

General

Environmental

Guidelines

(WBGEG)

pH 6.94 8.00 7.57 90 6.5-9.0 6-9

Temperature increase, °C 12.4 28.80 20.81 82 3 3

Total Suspended Solids, mg/L 2.0 127.0 12.4 90 70 50

Dissolved Oxygen, mg/L 2.54 7.77 5.24 47 - -

BOD, mg/L 5.00 50.00 24.41 90 50 50

COD, mg/L 4.9 135.2 43.4 90 100 250

Residual Chlorine, mg/L ND 3.25 0.45 87 - 0.2

Total Coliform, MPN/100mL ND 230,000 4862 87 10,000 400

Fecal Coliform, MPN/100mL ND 23000 737 87 - -

Color, PCU 5.0 20.0 8.9 14 150 -

Turbidity, NTU 2.0 430.0 42.4 14 - -

Settleable Solids (1-hr), mg/L 0 0 0 28 0.5 -

Dissolved Solids, mg/L 134.0 332.0 247.9 14 - -

Surfactant (MBAS), mg/L 0.01 0.29 0.12 12 5 -


Table 5 continued.

Parameter Minimum Maximum Average Na

DAO 90-35

Effluent

Standard for

Class C

Waters

World Bank

General

Environmental

Guidelines

(WBGEG)

Oil and Grease, mg/L 0.1 5.0 3.1 22 5 10

Phenols, mg/L ND ND ND 7 0.1 0.5

Cadmium, mg/L ND ND ND 13 0.05 0.1

Copper, mg/L ND 0.238 0.024 13 - 0.5

Chromium6+, mg/L ND 0.008 0.001 10 0.1 0.1

Iron, mg/L ND 0.558 0.170 13 - 3.5

Lead, mg/L ND ND ND 13 0.3 0.1

Manganese, mg/L ND 0.120 0.046 13 - -

Zinc, mg/L ND 55.48 4.36 13 - 2.0 Note: Compliance with World Bank Environmental Guidelines discussed in Section 5.4.1. 1 N = Number of monitoring data.

Based on the monitoring data, there have been very few instances where the results of the analysis exceed the

DAO 90-35 standards. Parameters such as pH, temperature, BOD, color, settleable solids, phenols and heavy metals were within the prescribed limit. Exceedance were only noted for such parameters as total suspended

solids (TSS), chemical oxygen demand (COD) and total coliform. TSS exceeded standards on 18 July 2002

and 6 November 2002. For COD, the level exceeded the standard on 10 July 2002. In the case of total

coliform, exceedances were noted on 12 December 2001 and on 12, 20 and 26 March 2002, with levels ranging from 23,000 MPN/100 ml to 230,000 MPN/100 ml.

5.3.3 Ecological Solid Waste Management Act

The Ecological Solid Waste Management Act (RA 9003) and its IRR (DAO 2001-34) provides for state policy

on the adoption of systematic, comprehensive and ecological solid waste management system. The Act also

emphasizes waste minimization at source through recycling, re-use, recovery and composting. Although the

RA 9003 retains primary enforcement and responsibility with local government in solid waste management, it encourages greater private sector participation.

Solid wastes, as covered by RA 9003, include discarded household wastes, commercial wastes, non-

hazardous institutional and industrial wastes, street sweepings, construction debris, agricultural wastes and other non-hazardous/non-toxic solid was tes. Septage sludge/solids are not included in this list.

Section 21, Article 2 of RA 9003, requires the segregation of wastes at the source. The waste should be

segregated prior to collection according to waste type by providing, at the minimum, on-site collection containers labelled as compostable, non-recyclable, special wastes, etc. According to MWCI, it is currently

implementing a company-wide program on waste segregation. Compliance to this program is checked by


MWCI’s Committee on Health and Safety on a per facility basis. The committee conducts random inspection

and good performance on safety and cleanliness. During the site survey, the audit team was not able to

confirm on-site segregation.

Solid wastes generated at the Ayala STP includes refuse generated from grit separators and domestic wastes.

According to MWCI these are hauled and disposed off-site by a contractor. At the construction sites domestic

solid wastes and construction debris are also disposed in the same manner. Excess excavated soil is also hauled off-site and according to the contractors, this is used as fill material in other construction sites.

5.3.4 Toxic Substances and Hazardous and Nuclear Wastes Control Act

RA 6969 otherwise known as the Toxic Substances and Hazardous and Nuclear Wastes Control Act of 1990

provides for the rules and regulation for management of chemicals, hazardous wastes and nuclear wastes. RA

6969 and its IRR (DAO 1992-29) covers the importation, manufacture, processing, sale distribution, use and

disposal of chemical substances and mixtures that present unreasonable risk/or injury to the health or the environment.

Chemical use at the Ayala STP is limited to sodium hypochlorite. This is used as disinfectant for the

wastewater prior to discharge. Sodium hypochlorite is listed on the Philippine Inventory of Chemicals and Chemical Substances (PICCS). Under Section 16 of Title II of DAO 92-29, users of substances included in the

PICCS are not required to secure clearance from the DENR.

There are also no known hazardous wastes generated from the facility. Based on the provisions of Section 25 of Title III of DAO 92-29, septic tank effluent and associated sullage wastewaters are not classified as

hazardous wastes. In addition to this, a certification was secured from the DENR declaring that the waste

generated from the facility is not considered hazardous (Annex J).

5.3.5 Clean Air Act

The Clean Air Act (CAA), RA 8749 and its IRR, DENR Administrative Order No. 2000-81, provides for a

comprehensive and integrated approach on managing air quality and protecting the public health. The Clean Air Act also provides specific guidelines and permit requirements for stationary and emission control for mobile

sources (i.e., motor vehicles).

In terms of production of air pollutants, the wastewater treatment facilities are not seen as significant source of emissions such as SOX, NOX, CO and particulates. The facilities, however, generate noxious odor due to

aerobic and aerobic digestion of wastewater and septic sludge. At the Ayala STP, an Odor Pit Control Facility

has been in installed to reduce the odor generated from the wastewater (Plate 4). According to MWCI, the

STPs under construction are designed to limit odor. For noise generating equipment such as blowers and standby generators, these were equipped with mufflers and silencers.


There are no specific monitoring requirements set by the DENR for the project. At present, monitoring for

Ayala STP are performed through the Customer Benchmark Monitoring System wherein facility operators

check out complaints of foul odor from nearby residential areas. In spite of the presence of vegetation buffer and the odor pit facility at the Ayala STP, there have been previous complaints of odor. MWCI procedure is to

immediately address such complaints by visiting the area where the complaint originated and validate the odor

emission. According to MWCI, complaints are isolated and unsubstantiated.

At the construction sites, no noise monitoring is conducted on-site. However, complaints from residents and

homeowners are handled by the contractors. To limit disturbance, construction activities are scheduled during

the day and may extend only up to 9:00 p.m.

For the vacuum tankers, emission testing is conducted yearly in compliance with the requirements of the Clean

Air Act. The tankers are sent to Land Transportation Office (LTO) accredited emission testing centers.

According to MWCI, all vacuum tankers are equipped with exhaust mufflers.

Part of the requirements under the CAA is that the owner or operator should secure an Authority to Construct

(AC) and Permit to Operate (PO) for fuel burning equipment and other emission source installations and control

facilities. For the Ayala STP, there were no POs secured for standby generators and odor pit control from the

DENR.

5.4 Compliance With International Environmental Guidelines

The implementation of the MSSP were also audited as per compliance with the World Bank Environmental

Guidelines and the London Convention. Projects funded by the World Bank should comply with World Bank

Environmental Guidelines, which emphasize resource consumption minimization and elimination or reduction

of pollutants from the source. The London Convention, to which the Philippines is a party to the agreement, provides guidelines on sea disposal of wastes.

5.4.1 World Bank Environmental Guidelines

As there are no specific environmental guidelines for water and sewerage infrastructure projects, the World

Bank General Environmental Guidelines (WBGEG) contained in the Pollution Prevention and Abatement

Handbook was referenced. The WBGEG provides requirements for liquid effluent, air emissions, noise, solid

wastes, hazardous wastes, record-keeping and reporting.

The WBGEG limits for effluents are applicable for process wastewater, domestic sewage and contaminated

stormwater. Effluent monitoring at the Ayala STP is in accordance with the monitoring requirements of

WBGEG. As shown on Table 5 in Section 5.3.2, the WBGEG limits for TSS and total coliform are more stringent than that of the DAO 1900-35 Standard for Class C waters. The limit for TSS and total coliform under

WBGEG are 50 mg/L and 400 MPN/100 ml, respectively while the limit under the DAO 1990-35 are 70 mg/L


and 10,000 MPN/100 ml. As such, exceedances were only noted for these parameters. Based on the results

of monitoring from December 2001 to present, there have been only two instances where TSS levels exceed

the standards. However, about a fourth of the monitoring results show exceedance with the WBGEG total coliform limit.

As noted in Section 5.3.5, there is no actual monitoring on ambient air quality and noise. There were no

significant issues in solid wastes and hazardous wastes management.

In terms of record-keeping and reporting, there is a need for MWCI to improve management of monitoring data

and documents submitted to public offices especially regulatory entities. Some of the supporting documents

were not readily available. At the time of the audit, MWCI was in the process of organizing records, documents and monitoring data relating to the implementation of MSSP.

5.4.2 London Convention

The London Convention on the Prevention of Marine Pollution by Dumping of Wastes and Other Matter of 1972

is a legally binding international agreement controlling the deliberate dumping of non-ship generated wastes at

sea. Under the agreement, disposal of certain wastes are prohibited while others are permitted through

issuance of special or general permit depending on the characteristics and composition of the waste. The 1996 Protocol to the London Convention provides guidelines for waste characterization, site selection, impacts

assessment, field assessment, permit requirements and compliance monitoring. Specific guidelines for the

assessment of sewage sludge have been formulated.

Prior to the operation of the sea disposal, an Environmental Impact Assessment (EIA) has been undertaken.

The selected disposal site is located at South China Sea, around 40 km southeast of Mariveles Bataan.

Endorsements were secured from the province of Bataan, Zambales and Cavite.

Under the London Convention, contracting parties should designate an appropriate authority to issue permit

and perform record-keeping and monitoring of sea disposal of wastes. The Philippine Coast Guard (PCG) is

mandated to do such task by virtue of Presidential Decree 979 (PD 979), otherwise known as the Marine

Pollution Decree of 1976. According to MWCI, disposal of septage were coordinated with the Philippine Coast Guard (PCG). Prior to disposal, permits were secured from the PCG. Copies of the permits issued to MWCI

are presented in Annex D.

Septage sea disposal were conducted from May 2001 to June 2002 except during rainy/stormy months (July, August and September). During the one-year trial period, a total amount of 25,396 cu m of septage have been

disposed to the sea, equivalent to 7,000 emptied septic tanks. As part of its compliance with the ECC, monthly

water quality monitoring were conducted on occasions when sea disposal were performed. These were

conducted at five designated coastal stations and sampling stations at the dumpsite and control areas. Water quality samples were analyzed for BOD, DO, turbidity, suspended solids, color, nitrogen, phosphorus, oil

/grease, fecal total col iforms and heavy metals. Based on the records provided by MWCI, not all the stations


were covered through the monitoring period. For the water quality monitoring, trend and statistical analysis

were not performed. As such, there were no conclusions of significance on the impact of septage sea disposal

were derived from the monitoring.

MWCI were also required under the ECC to conduct an annual marine biota monitoring, focusing on plankton,

algae and important fish species at the coastal stations. In Oct ober 2002, a preliminary plankton survey was

completed. The survey is limited to taxonomic identification and estimation of biomass values. As with the water quality monitoring, the study is inconclusive.

Results of the monitoring were submitted both to DENR and PCG. Compliance monitoring was primarily

performed by the DENR, through the assessment of MWCI’s compliance with ECC requirements.

As noted in previous sections, MWCI has ceased septage sea disposal and has since shifted to land

application of septage.

5.5 Compliance with Other Relevant Guidelines

Based on the current project implementation program of MSSP, the project activities were also assessed for compliance with Occupational Safety and Health Standards (OSHS) and regulations on agriculture chemical

use. These are detailed in the following sections.

5.5.1 Occupational Safety and Health Standards

Employers are required to implement the Occupational Safety and Health Standards (OSHS) at the work place

as part of compliance with the Labor Code of the Philippines (PD 442) and its Implementing Rules and

Regulations. The OSHS are compulsory rules on occupational safety and health safeguarding workers against the risks of injury, sickness or death through safe and healthful working conditions.

Currentl y, MWCI is actively involved in ensuring workers’ safety at the MSSP project sites. MWCI conducts

random safety checks and requires contractors to submit daily progress and safety reports. According to MWCI, penalty is given to contractors with lapses in regards to health and safety provisions. The penalties are

explicitly expressed under the terms of the each contract signed by MWCI and the contractors.

As noted in Section 5.1.1, appropriate PPE such as hard hats, safety shoes and hearing protection were provided to site workers. Construction sites were also properly cordoned and appropriate signages were

posted (Plates 15, 16 and 25). Health and safety guidelines and procedures are also conspicuously posted

within the site project office. At the different project sites, safety engineers are on hand providing supervision

and monitoring along with safety briefing prior to start of construction activities. The contractors also maintain a safety log as part of their internal monitoring. To date, none of the contractors has logged an instance of major

incident or accident at the MSSP project sites.


5.5.2 Agriculture Chemicals Regulations

By virtue of Presidential Decree 1144 (PD 1144) the Fertilizer and Pesticide Authority was created in 1977.

The mandate of FPA is to protect the public from risks inherent in the use of agricultural chemicals.

Since 2000, MWCI has collaborated with Central Luzon Sugarcane Research Institute on research on land application of biosolids. The field trials were conducted in lahar -affected areas in Porac, Pampanga. In 2001,

researchers from CLSRI were able to establish optimum applications for of the septage on lahar soil. Pilot

tests have been conducted by CLSRI. To date, CLSRI is in the process of performing technology transfer to

the farmers. Since MWCI shifted to this type of septage disposal method, approximately 26,000 m3 of septage have been applied to the lahar affected areas in Pampanga. A permit has been secured from the FPA for the

land application of septage (Annex K).

Environmental Compliance Audit D ecember 2003 Page 36

6.0 Conclusion and Recommendation

6.1 Conclusion

The findings of first environmental compliance audit for MSSP showed the need to address details of

commitments made in the Environmental Impact Statement, Environmental Management Plans and

Environmental Compliance Certificate. While there have been efforts to comply with conditions and stipulations, these are inadequate to state that there has been full compliance. Some of these findings pertain

to the required implementation of monitoring activities and the need to submit reports of such activities to the

EMB.

Specifically, the following conditions were not complied with: Condition 13 which requires monthly monitoring of

affected water resources and submission of results to EMB on a quarterly basis; Condition 14 which requires

the annual monitoring of marine biota and submission of results to EMB; Condition 16 which requires the

establishment of an Environmental Guarantee Fund; and Condition 14 which requires training of engineers and contractors on the ECC conditions, EMP measures and EIS commitments. For the STP projects which are no

longer to be implemented, MWCI should inform EMB in writing as this is required under Condition 8 of the

ECCs.

For the EMP, housekeeping needs to be improved in K6, Karangalan Village. The key issue with EMP

compliance is the implementation of the monitoring program. Review of the submitted EMP for the STP

projects showed that there is a need to clearly define parameters and sampling frequencies.

On other environmental guidelines, the requirement to submit plans and specifications for approval and review

by the DOH was not done. For effluent standards, there have been occasional exceedance with prescribed

standards. Furthermore, the Ayala Wastewater Treatment Plant was found without a Permit to Operate or the

air pollution sources and control facilities from the EMB as required by the Clean Air Act.

It is also concluded that records keeping management is insufficient to handle the volume of data and reports

generated by the project. Considering the numerous components of the project, there is a need to implement a

more systematic way of managing such documents and data. 6.2 Recommendations

The following recommendations are made:

• On the ECC, clarify issues with EMB regarding compliance with conditions such as the establishment

of the EGF; • Should MWCI propose to amend the EMP or any part thereof, written notification and approval has to

be secured from the EMB; • For the STP projects which were not implemented (such as San Miguel Village, San Lorenzo Village,

Kaimitoville, and Coryville Condominium) it is recommended that EMB -NCR be formally informed

through written correspondence that MWCI have decided not to implement the above.


• Maintain copies of correspondence with EMB which contain evidence of receipt and transmittal. • In line with efforts to improve environmental performance, MWCI should implement more stringent

waste disposal procedures.


7.0 References

American Society for Testing and Materials. 2000. ASTM Practice E-2107-00 Environmental Regulatory Compliance Auditing.

Department of Health. 1995. Implementing Rules and Regulations of Chapter XVII -“Sewage Collection and

Disposal, Excreta Disposal and Drainage” of the Code on Sanitation of the Philippines (PD 856).

Department of Environment and Natural Resources. 2000. Implementing Rules and Regulations of Clean Air

Act (RA 8749).

Department of Labor and Employment. 1990. Primer on the Occupational Safety and Health Standards.

Bureau of Working Conditions, Manila.

Internati onal Maritime Organization. 1972. London Convention on the Prevention of Marine Pollution by Dumping of Wastes and Other Matter.

Manila Water Company Inc. 2002. Manila Second Sewerage Project IBRD 4019, Environmental Compliance

Report First Quarter 2002.

Manila Water Company, Inc. 2002. Manila Second Sewerage Project IBRD 4019, Environmental Compliance

Report 2nd Quarter 2002, 3rd Quarter 2002.

Manila Water Company, Inc. September 2003. Manila Second Sewerage Project (IBRD Loan No. 4019-PH)

Progress Report No. 10.

Presidential Decree 442. Marine Pollution Prevention Decree of 1976.

Presidential Decree 1144. Decree Creating the Fertilizer and Pesticide Authority and Abolishing the Fertilizer

and Pesticide Authoriy and Abolishing the Fertilizer Industry Authority of 1977.

Republic Act 6969. Toxic Substances and Hazardous and Nuclear Waste Management Act of 1990.

Republic Act 8749. Clean Air Act of 1999.

Republic Act 9003. Ecological Solid Waste Management Act of 2000.

World Bank. 1995. Environmental Auditing – Environmental Assessment Source Book Update No. 11.

Environmental Department. Washington D.C.

World Bank. 1998. Pollution Abatement and Control Handbook. Was hington D.C.