nsrp refinery plant environmental impact assessment

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT INTRODUCTION FOR NGHI SON REFINERY AND PETROCHEMICAL COMPLEX Final Report

1

Section 1.

INTRODUCTION

1.1 OVERVIEW OF THE PROJECT The Vietnam Oil and Gas Group or PetroVietnam, in a Joint Venture with international companies, aims to build a refinery and petrochemical complex in the Thanh Hoa province. The partners of the Joint Venture include PetroVietnam (PVN), which holds 25.1 percent of the total paid-up capital, Japanese companies Idemitsu Kosan Co., Ltd. (IKC) 35.1% and Mitsui Chemicals Inc (MCI) 4.7% and the Kuwait Petroleum International (KPI) 35.1%. The Joint Venture was established on April 7, 2008 under the name of “Nghi Son Refinery and Petrochemical Limited Liability Company” (NSPR-LLC). The project is located within the Nghi Son Economic Zone (NSEZ) in the Tinh Gia district, Thanh Hoa Province, approximately 200 km south of the Ha Noi capital and 80km north of Vinh City, Nghe An province (Figure 1-1). The capital investment for the refinery is estimated to be about US$ 6 billion. The construction is expected to start in 2010, and the refinery and petrochemical complex to become operational by 2013.

Figure 1-1 Project Location

Project Location


2

The refinery and petrochemical complex is designed to process 200,000 BPSD (approximately 10 million tons/year) of imported Kuwait Export Crude (KEC) oil. The fuels section of the refinery includes Residue Hydrodesulphurisation and Residue Catalytic Cracking as the main upgrading units. The refinery is integrated with petrochemical production. The Aromatics plant produces Paraxylene and Benzene. A key product from the Residue Cracker is Propylene which is used to produce a Polypropylene product. The products of the refinery and petrochemical complex include the following:

• LPG

• Gasoline – 92/ 95 RON

• Kerosene / Jet A-1

• Diesel – Premium and Regular

• Fuel oil

• Paraxylene / Benzene

• Polypropylene

• Sulphur The NSRP Project includes all process units and associated utility, offsite and infrastructure facilities to support the refinery operation.

• Complete utility facilities designed to meet the refinery’s demands for cooling water, fuels, power, steam, water, instrument and plant air, inert gas, etc.

• Offsite facilities including tankage for feedstocks plus intermediate and final products as well as systems for import and export of feed and products.

• Other offsite facilities including flare, effluent treatment, firewater, interconnecting piping and pipelines, etc.

• General facilities, including Control System, Electrical and Telecommunication, Buildings.

• Marine facilities including a Single Point Mooring (SPM)/ Crude import line, product loading jetties, and cooling water intake and outfall.

The project components are listed as follows:

• Plant site area

• Pipeline system

• Single Point Moring (SPM)

• Harbour area

• Access road The NSRP will be the second major oil refinery in Vietnam after Dung Quat. This is one of the nation’s key projects that will ensure an adequate supply of energy to the country said by Prime Minister Nguyen Tan Dung at a groundbreaking ceremony (VN Oil and Gas News on March 3rd, 2009). It will promote the socio-economic development of the provinces and cities in the central part of Vietnam and as a result the whole country, but it will also satisfy the need for national energy safety in the future as well.


3

1.2 PROJECT OBJECTIVES The main project objective is to design and construct a grass root refinery of a 10 million TPA capacity. Refinery feedstock is Kuwait Export Crude (KEC), and the refinery will have the facilities for full conversion, with an integrated Aromatics complex and Poly Propylene Production. The objectives of the project are the following:

• To ensure the national security through the basic satisfaction of domestic fuel demand;

• To supply feedstock for the development of the Petrochemical Industry and to decrease foreign dependence;

• To contribute to the economic development of the Northern area and to ensure equal development within the country.

1.3 BACKGROUND AND NEED Vietnam's energy demand is increasing quickly therefore the country needs to speed up its investment plans for the energy sector. Presently, Vietnam is importing almost all of its refined oil products for domestic consumption. Vietnamese firms are operating a few small processing facilities, which supply small amounts of fuel to the domestic market. Even with the Dung Quat refinery in operation since 2009, less than 40% of domestic fuel demands are met, while the rest will have to be covered by imports with volumes increasing sharply in the next few years. Therefore, the purpose of constructing the Nghi Son Refinery and Petrochemical Complex is to reduce the shortage, saving hard currency for imports as well as minimizing the dependence on the international market.

Demands for refined products from other industrial fields are growing very fast. The capacity of polypropylene unit in the Dung Quat refinery that is 150 kt/y can satisfy only a small amount of chemical products compared to the market demands.

Therefore, securing another source of the feedstock for the development of the petrochemical industry is another major purpose of the Nghi Son Refinery-Petrochemical Complex Project (PP, P-Xylene, and Benzene.) The Project will not only produce petroleum-derived fuels but also generate feedstock for the petrochemical industry, partially meeting the domestic demand and minimizing the dependence on imported feedstock.

With the development of the Dung Quat refinery project, the rate of investment in the petroleum industry has changed dramatically the regions around Dung Quat, mainly in the Southern and Central areas. Presently, there are almost no oil & gas facilities in the North, except the Tien Hai gas field (Thai Binh province) but it is a very small production.

Thus, in order to implement one of the key targets set for the 2001 – 2010 Socio-economic Development Strategy as stated in the Resolution of 9th National Congress for equally developing all large economic zones in the three areas of the country, the building of Nghi Son Refinery - Petrochemical Complex in the North is of very great importance. The NSRP project implementation will bring many advantages, as follows:


4

• Contribute to national energy security, by securing a long-term, imported crude supply of about 10 million tons per year, which will be processed by this Complex to produce voluminous fuels and petrochemicals.

• Products of the Complex will include Mogas (2.1 millions tons per year MTPY), Diesel (2.7 MTPY), as well as jet LPG (1.4 MTPY), jet fuel/kerosene, fuel oils and petrochemicals. As the Project comes into operation, starting in 2013, the production of both the Project and Vietnamese first refinery (Dung-Quat) can supply 50% of the local demand for fuel products.

• Pave the way for the development of petrochemical industries, associated industries and other related services.

• Robustly motivate the socio-economic development of the south Thanh Hoa and north Nghe An province and vicinities.

• Create jobs for tens of thousands of people during the construction phase, and thousands of people during the operation phase.

1.4 SCOPE AND OBJECTIVES OF THE STUDY Based on the Official letter of 1370/TTg-KTN, dated 21st August 2008 by the Prime Minister, on approval of building the Nghi Son Refinery and Petrochemical Complex Project, the responsibilities of each of the related parties in project implementation are defined clearly as follows:

• Telecom VNPT Post is responsible for telecom.

• EVN is responsible for the supply of electricity to the boundary limit of the Refinery for the construction phase and for the operation phase of emergency case.

• PVN is responsible in mine-disarming, site leveling and initial dredging for the Jetty, SPM and access channel

• Thanh Hoa Province People’s Committee is responsible for compensation, resettlement, site clearance, road, water and infrastructure for resettlement sites.

PVN assigned the Nghi Son Project Management Board (NSPM) to take responsibility of mine-disarming, basic site leveling and initial dredging for the Jetty, SPM and access channel. Thanh Hoa People’s Committee assigned the Tinh Gia District People’s Committee to take responsibility for compensation and site clearance and assigned the Nghi Son Economic Zone Management Board (NSEZMB) to take responsibility of road and water access to the Refinery boundary limit, resettlement and infrastructure for the resettlement site. Therefore, resettlement of the plant site is the responsibility of the Thanh Hoa People Committee/Tinh Gia District People Committee and site leveling is the responsibility of PVN/NSPM. The basic site leveling and site leveling phase II have already been considered in the EIA report and the environmental commitment certification approved by NSEZ Management Board. Two of the following approved EIA decisions and certifications are carried out by NSPM:


5

• EIA approved Decision No.195/QĐ-BQLKKTNS dated 4th September 2008 by NSEZMB for soil exploitation for the site leveling period at Chuot Chu mountain, Hai Yen and Hai Thuong commune, NSEZ;

• Environmental commitment certification No.416/GXN-BQLKKTNS dated 16th April 2010 by NSEZMB for project site leveling Phase 2 before infrastructure construction of the Nghi Son Refinery and Petrochemical Complex.

The initial dredging required for the project will be carried out by the Vietnamese Government. Dredging methodology, transportation method, disposal location, impacts and mitigations will be assessed by the NSPM in the Environmental Protection Commitment for initial dredging. Commitment will be available in the 3rd quarter of 2011. NSRP will have full responsibilities from project construction, installation, and operation and decommissioning phases. The purpose of this ESIA is to conduct an environmental and social impact assessment in accordance with Vietnamese Laws, Regulations and Standards as well as the IFC Performance Standards on Social & Environmental Sustainability, the World Ban/IFC Environmental, Health, and Safety Guidelines, and the Equator Principles thus ensuring that the project will be developed in a manner that is socially responsible and reflects best environmental management practices. By doing so, the potential project negative impacts on environment and communities will be avoided where possible, and if these impacts are unavoidable, they will be reduced, mitigated and/or compensated appropriately. NSRP is currently conducting the Front-End Engineering Design (FEED). NSRP will have detailed information about the dredging for the crude oil pipelines from the SPM to shore, the cooling water outfall pipelines, the cooling water intake channel, the breakwater and revetment, the incinerator, construction equipment/large vessels (>200 tons), transportation/shipment of heavy equipment, and optimum routes. The impacts and mitigations will be assessed then; therefore, their impact and prevention measures are not included in the ESIA. This information will be available after the detailed engineering. The NSRP will request the EPC Contractor to assess the impacts and prevention measures prior project implementation in accordance to the Vietnamese Laws, Regulations and Standards as well as the IFC Performance Standards on Social & Environmental Sustainability and the World Ban/IFC Environmental, Health, and Safety Guidelines. The scope of this study will include the preparation of an:

• Environmental and Social Impact Assessment (ESIA), and an

• Environmental and Social Management Plan (ESMP). Event though, the project associated resettlement is the responsibility of the Vietnamese authorities at various levels, NSRP will ensure that these activities are conducted in accordance with IFC Performance Standard 5 – Land Acquisition and Involuntary Resettlement. Because resettlement activities have already started for most of the components of the project, NSRP commissioned a resettlement due diligence study with the following objectives:

• Assess land acquisition/compensation/resettlement/rehabilitation activities already undertaken by the Thanh Hoa People’s Committee in the project area.


6

• Identify any gaps between the government’s implementation of land acquisition and resettlement and the Performance Standard 5 on Land Acquisition and Involuntary Resettlement.

• Propose recommendations, if necessary, to bring land acquisition, compensation, resettlement and rehabilitation into compliance with Performance Standard 5 on Land Acquisition and Involuntary Resettlement.

A summary of the resettlement due-diligence can be found in the Resettlement Due-Diligence Summary and Resettlement Policy Framework Report. The following are the objectives of the ESIA:

• To identify the existing health, environmental and social baseline conditions of the project area and its vicinity;

• To carry out due diligence assessment for the compensation, resettlement and relocation aspects of the project;

• To evaluate the potential to result in positive or negative environmental, health and socio-economic impacts from the project activities;

• To propose feasible mitigation measures to minimize the negative impacts in the project area and around Nghi Son Bay during the site preparation, and construction and operations phases;

• To assess the working environment and health impacts associated with the project, including an evaluation of communicable and non-communicable diseases, chemical and physical impacts, etc;

• To set up environmental and social management plans and monitoring systems for the construction and operation phases of the project;

• To provide the basis for the Lenders and Vietnam Authority to assess the compliance of the project owner with the requirements listed in the ESIA.

1.5 PROJECT SCHEDULE NSRP aims to have the mechanical completion of the refinery and petrochemical complex in the year 2013. Duration for the FEED work is estimated to be 16 months from the effective date of FEED contract to the completion of FEED Package including the total cost estimation and preparation of EPC-ITB documents. The Overall Project Schedule is shown in Figure 1-2.


7

Figure 1-2 Overall Project Schedule 1.6 REPORT STRUCTURE The ESIA report includes the following sections: Section 1 – Introduction: provides an overview of the proposed development and project background. It presents the objectives of the study and the scope of work entailed in conducting the ESIA study. Section 2 – Legal and Administrative Framework: discusses various environmental standards and legislation of Vietnam, IFC guidelines, international treaties that are potentially applicable to the NSRP project. Section 3 – Project Description: describes the design basis of the Nghi Son Refinery and Petrochemical Complex, configuration, site location, refining process and various utilities, off-site facilities and site construction.

Section 4 – Environmental and Social Baseline: provides a summary of the physical (air, surface water, ground water, and soil) environment, biological (marine and terrestrial including flora and fauna) environment, and socioeconomic conditions in the project area and the vicinity.

Section 5 – Analysis of Alternatives describes project justification, siting alternatives, location of off-site facilities and refinery process related alternatives considered during project concept.


8

Section 6 – Environmental and Social Impact Assessment, Residue and Mitigation Measures: discusses and analyzes the impacts resulting from project activities during the pre-construction, construction, operation and decommissioning phases. Feasible mitigation measures are also recommended.

Section 7 – Cumulative Impacts: discusses and analyzes boundaries of the cumulative impacts.

Section 8 – Environmental and Social Management Plans: The environmental and social management plan provides the implementing and monitoring plan to ensure Project activities meet Project standards, as well as Vietnamese and international regulations.

Section 9 – Public Consultation and Disclosure: indicates relevant stakeholders consulted during the preparation of the ESIA. It also describes a disclosure mechanism that satisfies Vietnamese and IFC requirements and a detailed plan of execution during the various project implementation phases.

Section 10 – Conclusions and Recommendations

The ESIA also includes the following Appendices which support the discussion and engineering calculations used in the development of the ESIA:

I. Environmental baseline study report

II. Emission contour maps

III. Flora and Fauna investigation and biodiversity

IV. Coral investigation and assessment

V. Maps of Nghi Son Refinery and Petrochemical Complex Project

VI. Coarse quantitative risk assessment (QRA)

VII. Oil spill contour maps.

In addition to the ESIA, NSRP also prepared the following to documents related to the social aspects of the projects:

• Stakeholder Engagement Plan • Resettlement Due Diligence Summary and Resettlement Policy Framework

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT LEGAL & FRAMEWORK FOR NGHI SON REFINERY AND PETROCHEMICAL COMPLEX Final Report

9

Section 2.

LEGAL AND ADMINISTRATIVE FRAMEWORK This section presents the legal and administrative framework that is related to the NSRP project. This includes: Vietnamese environmental legislation and standards; international conventions and treaties ratified by Vietnam; IFC Performance Standards on Social & Environmental Sustainability and the World Ban/IFC Environmental, Health, and Safety Guidelines. These health, environment and safety standards and guidelines provide the basis for the selection of appropriate pollution prevention/mitigation/control/disposal measures for impact assessment, mitigation, and development of an environmental and social action plan discussed in the following sections. 2.1 CORPORATE COMMITMENTS NSRP LLC has established corporative commitments with the Vision of becoming the most efficient, reputable and successful supplier of energy for the Vietnamese market. The Mission for this commitment is to maximize the financial rewards to the shareholders, while being competitive, respectful of the environment, supportive to local communities and operate in the safest possible manner. In order to achieve its Vision and Mission, NSRP LLC will strive to accomplish the following objectives:

• Develop a world-class refinery and petrochemical plant, that is integrated and secured to a long term supply of feedstock;

• Achieve word-class performance in all activities, particularly in health, safety and environmental protection; • Achieve and sustain a level of operating and financial performance that is consistently superior to that of our

competitors; • Ensure opportunities for expansion, in all markets where we can achieve and maintain a long term

competitive position; • Reward our shareholders at a level which is comparable to / or higher than that of our competitors; • Establish and maintain a leading position in our core business, backed by the skills of our people and the

strengths and reputation of our parent companies in technical, financial, managerial fields and security of energy supply;

• Maintain good relationships with communities located in the vicinity of our intended project.

Under our vision, mission and strategic objectives, NSRP LLC will develop its activities in order to adhere to the HSSE Policy. HSSE Policy: NSRP LLC is committed to provide a safe, secure and healthy work environment, to protect the environment and to work closely with local communities in order to improve their livelihoods and achieve sustainable development.


10

To meet this commitment, NSRP LLC will develop high standards for safety performance, security, health care, environmental protection as well as promote awareness of safe working practices for all employees, contractors, visitors and members of the public who come in contact with our business with the following project Health, Safety, Security and Environment (HSSE) principles:

• Achieve world-class performance in Health, Safety, Security and Environment. • Give highest priority for assuring safety, and aim for accident-free and injury-free business. • Establish and implement an effective Health, Safety, Security and Environment Management System. • Minimize all risks related to environmental incidents associated with our construction and operation activities. • Comply with National Legislation together with the IFC Performance Standards on Social & Environmental

Sustainability, the World Ban/IFC Environmental, Health, and Safety Guidelines, and teh Equator Principles.

• Support our employees by providing HSSE training and development of knowledge and skills. • Exert care in the highest manner for the environment and for the health, safety and security of our employees

and the community where we operate. • Provide a safe environment to those who work for our company and demand the highest respect for our self

imposed rules to preserve their safety in the most effective manner. • Aim for the community to see us as a provider of safe and rewarding jobs, with no fear for their safety and

living style. • Healthy and constructive relations with stakeholders in the communities.

2.2 ENVIRONMENT, HEALTH AND SAFETY LEGAL FRAMEWORK IN VIETNAM The following sections will provide an overview of the Environment, Health and Safety Legal Framework applicable to the NSRP Project. 2.2.1 Environmental Protection Law The Constitution of the Vietnamese Socialist Republic (April 1992) states that state-owned enterprises, governmental agencies, cooperatives and national defense units must take full responsibility for implementation of the policy which ensures reasonable use of the country’s natural resources and environmental preservation. The Law on Environmental Protection (LEP) was passed on December 27th 1993 by the National Assembly and went into effect on January 10th, 1994. This Law was first amended and supplemented under the Resolution No. 1/2001/QH10 of December 25th, 2001 and second revised under the Resolution No. 52/2005/QH11 of November 29th, 2005 by the National Assembly. The LEP 2005 consists of 15 chapters divided into 136 articles which regulate the policy, natural resources, the rights and obligations of organizations, households and individuals for environmental protection. The LEP 2005 regulates clearly on environmental standards, elaboration and contents of strategic environmental assessment, environmental impact assessment and environmental protection commitment reports, conservation and appropriate natural resources application, environmental protection, waste management, prevention and emergency response and environmental recovery, etc. Article 18 of the LEP 2005 identifies the type of projects that is subject to EIA. A detailed list of projects subject to EIA is given in the Decree No. 21/2008/ND-CP (28 February 2008) Amending and supplementing a number of articles of the Government’s Decree No. 80/2006/ND-CP dated August 9,2006, detailing and guiding the implementation of a number of articles of the law on environmental protection. It is clearly stated in this


11

list of projects that Projects on Petrochemical Refineries must undertake an EIA. This EIA must be carried out at the Prefeasibility Phase of the project (Article 19, LEP 2005). Due to the specific characteristics of refinery and petrochemical projects, the Prime Minister promulgated the Decision No.321/TTg-DK dated 4 March 2008 to allow the refinery and petrochemical project owner to undertake an EIA Study and submit the EIA Report to the Authority before the construction phase. The LEP 2005, prohibits acts which include discharging wastes not yet treated in compliance with environmental standards; discharging toxic, radioactive and other hazardous substances into the land or water sources; and emitting smoke, dust or gases with toxic substances or odour into the air. The LEP 2005 contains specific provisions for the environment protection requirements for:

• concentrated production and service areas (Article 39), • production and services establishments (Article 40), • construction activities (Article 43), • transportation and traffic activities (Article 44), • mineral resources activities (Article 47), • production and service establishments (Article 52), • urban and residential areas (Articles 53 and 54)

The LEP 2005 has provisions for dealing with the production and service establishments causing environmental pollution. Sanctions imposed against organizations and individuals engaged in production, business and service activities that pollute the environment shall be specified (Article 49) as follows:

• Fines and enforced application of measures of waste reduction and treatment to meet the environmental standards;

• These activities will be suspended until the necessary mitigating and treatment measures have been completed. 2.2.1.1 EIA Regulations Under the LEP 2005, a number of Decrees, Circulars and Decisions regulating for EIA regulation have been promulgated. The most important environmental legislations regarding the project are described below:

• Decree No.80/2006/ND-CP on detailed Regulations and Guidelines for implementation of some articles of the LEP 2005 was adopted on 9 August 2006. This decree provides information regarding the following topics: environmental standards; strategic environmental assessment; environmental impact assessment and environmental protection commitments; environmental-friendly production service establishments and products; hazardous waste management; and disclosure of environmental information and data. The authority in charge of formulating national environmental standards and guiding the implementation of this Decree is the Ministry of Natural Resources and Environment (MONRE). The MONRE has the responsibility to organize the appraisal committee for reviewing and approving all EIA reports belonging to interdisciplinary and inreprovincial projects. For other types of projects, EIA Reports are reviewed and approved by provincial DONREs.

• Decree No. 21/2008/ND-CP was adopted on 28 February 2008 for amending and supplementing a number of articles of the Government's Decree No. 80/2006/ND-CP of 9 August 2006.


12

The Decree amends and supplements Article 4 on the conversion of technical standards into environmental technical regulations; amends and supplements Article 5 on responsibilities, order and procedures for the formulation, promulgation and stipulation of application of environmental technical regulations; amends and supplements Clause 1 of Article 6 on projects necessitating environmental impact assessment (EIA) reports; adds Article 6a on the consultation of commune, ward or township People's Committees and community representatives in the process of making EIA reports; amends and supplements Article 11 on the appraisal and approval of EIA reports; amends Point b, Clause 1 of Article 13; amends and supplements Article 17, and adds Articles 17a, 17b and 17c on the registration and certification of written environmental protection commitments, appraisal and approval of EIA reports, etc.; adds Article 21a on provisions on the discharge of waste into the sea; amends Article 22 and adds Article 23a on responsibilities of the ministries.

Projects requiring an environmental impact assessment report are listed in Appendix of this Decree.

• Circular No.05/2008/TT-BTNMT was issued on 08 December 2008 in guiding strategic environmental assessment, environmental impact assessment and environmental protection commitment:

This Circular provides a number of provisions of the Law on Environmental Protection and of Decrees that implement the Law. The Circular guides in detail provisions on strategic environmental assessment, environmental impact assessment and environmental protection commitment and in particular it provides for: elaboration and appraisal of strategic environmental assessment reports; elaboration, appraisal and approval of environmental impact assessment reports; implementation, examination and certification of the implementation of environmental impact assessment reports; elaboration, registration and certification of environmental protection commitment documents; etc. This Circular repeals Circular No. 08/2006/TT-BTNMT of 9 September 2006 guiding strategic environmental assessment, environmental impact assessment and environmental protection commitment.

2.2.1.2 Regulation on Waste Management The Ministry of Natural Resources and Environment (MONRE) has the responsibility to exercise the uniform state management of hazardous wastes and to organize and direct hazardous waste management activities. In addition, MONRE can develop and promulgate directives including sector environmental standards for the selection of hazardous waste landfill sites and the technical norms for the design, construction and operation of hazardous waste facilities. MONRE also has the responsibility to oversee and conduct inspections and to monitor and report on progress for the management of hazardous wastes. The Vietnam Environment Protection Agency (VEPA) has the functions of issuing generator registers and licenses for transportation and facilities and to coordinate these functions with the provincial DONREs in accordance with national regulations. VEPA can also direct provincial DONREs on data collection and the preparation of annual inventories for hazardous wastes. The Ministry of Construction (MOC) has responsibilities in two key areas. First, the MOC sets the sector standards for the construction of all hazardous waste transportation systems and facilities in Vietnam. The MOC collaborates with MOSTE (MONRE) in the development of these standards. Second, the MOC can direct PPCs in planning for the construction of hazardous waste facilities. The Ministry of Transportation (MOT) has the responsibility for setting sector operating standards and issuing general operating licenses for all general goods transporters, vehicle emissions and driver’s licenses. Under Circular 12/2006, VEPA and the provincial DONREs must ensure that these general operating licenses from MOT have been issued


13

before issuing any hazardous waste transportation licenses. MOT does not have a direct role in the issuance of the hazardous waste licenses. The Ministry of Science and Technology (MOST) has responsibility for coordinating the development of national standards including the development of standards for hazardous waste treatment technologies including obligated / regulated standards. The Ministry of Industry and Trade (MOIT) – (the former Ministry of Industry (MOI)) has key responsibilities for supervising, inspecting and applying measures to ensure that hazardous waste generators in the industrial sector comply with the regulations. They are also responsible for mobilizing capital for pollution abatement and for collecting statistics on hazardous waste management in the industrial sector in cooperation with MONRE. The Ministry of Labor, Invalid and Social Affairs (MOLISA) is in charge of workers’ safety and occupational health, including providing guidelines and hazardous waste good practices for workers who may be working with hazardous waste equipment. The Environmental Police Department with the Ministry of Public Security was formed in 2007. This Agency is responsible for investigations and prosecutions under the environmental laws of Vietnam. In terms of waste management, NSRP Project will comply with the following Vietnamese Regulations and Standards as well as the International Conventions:

• Decree No.02/CP of 5th January 1995 on Toxic Chemicals and Radioactive Substances Decree.

• Decision No.155/1999/QĐ-TTg dated 16th July 1999 – Promulgating the regulation on management of hazardous wastes. Hazardous wastes are waste containing substances or compounds that are flammable, explosive, poisonous, corrosive, infectious, or which exhibit other hazardous properties or may interact with other substances to cause hazards to the environment and human health. The standards for hazardous waste have been developed in line with the requirements of the Basel Convention.

The industrial project shall enter into agreement / contract with approved / licensed hazardous waste collectors, transporters, treaters and disposers and shall utilise their services for safe collection, transportation storage, treatment and disposal of hazardous waste generated at its facilities. The industrial project shall be responsible to inspect and confirm hazardous wastes in the course of collection, transportation, storage, treatment and disposal of such hazardous waste to/at the facilities or agencies as specified in the contracts.

• Decision No.23/2006/QĐ-BTNMT of 26th December 2006 by MONRE on List of Hazardous Wastes

• Circular No.12/2006/TT-BTNMT dated 26th December 2006 issued by MONRE on Guidelines for practice conditions of transporting and registering, licensing hazardous waste management practice and code;

• Governmental Decree No.59/2007/NĐ-CP of 9th April 2007 on solid waste management. Non-hazardous waste shall be controlled and separated at the source into those that can be recycled or re-used, and those which must be sent to disposal.

Waste materials which remain after the implementation of waste prevention, minimisation, recycling and re-use measures should be treated and disposed according to this decree. Solid Waste Management requires that the selection of solid waste disposal technologies be based on the characteristics and composition of waste and specific conditions of localities. The decree recommends the re-use and recycle of waste to create


14

raw materials and generate energy. The decree also encourages the use of advanced technologies to throughly dispose of waste and minimize solid waste volume to be buried, thus saving land used for disposal and ensuring environmental sanitation.

• Circular No.13/2007/TT-BXD dated 31st December 2007 issued by Ministry of Construction – Guidelines for implementing some Articles of Decree No.59/2007/NĐ-CP dated 9th April 2007 on solid waste management;

• Circular No.05/2006/TT-BKNCN dated 11th January 2006 issued by Ministry of Science, Technology and Environment on Guidelines for declaring, licensing procedures and activities concerned with radioactive substances;

• Decision No.3044 /QĐ-ATSKMT dated 13th June 2005 by Petrovietnam on Guidelines for the implementation of requirements on use and discharge of chemicals and drilling fluids in petroleum operations offshore Vietnam;

• Circular No.16/2009/TT-BTNMT dated 7th October 2009 issued by MONRE on Promulgating National Technical Regulations of QCVN 05:2009/BTNMT – Regulations on ambient air quality and QCVN 06:2009/BTNMT – Regulations on some toxic substances in ambient air environment;

• Circular No.25/2009/TT-BTNMT dated 16th November 2009 by MONRE – Application of National Technical Regulation of QCVN 19:2009/BTNMT – National Technical Regulations on industrial emission gases to dust and inorganic substances, QCVN 20:2009/BTNMT – National Technical Regulations on industrial emission gases to some organic substances, QCVN 22: 2009/BTNMT – National Technical Regulations on industrial emission gases in thermoelectric plant, QCVN 24:2009/BTNMT – National Technical Regulations on industrial wastewater;

• Decision No.16/2008/QĐ-BTNMT dated 31st December 2008 by MONRE – Promulgating National Technical Regulations on Environment, including QCVN 08:2008/BTNMT – National Technical Regulations on surface water quality; QCVN 09:2008/BTNMT – National Technical Regulations on ground water quality; QCVN 10:2008/BTNMT – National Technical Regulations on coastal water quality;

• Decision No. 41/1999/QĐ-TTg dated 8th March 1999 - Safety Management Regulation in Oil and Gas Activities, issued by the Prime Minister;

• Decision No.103/2005/QĐ-TTg dated 12th May 2005 on Regulations for Oil Spill Response Plan, issued by the Prime Minister;

• Decision No.129/2001/QĐ-TTg dated 29th August 2001 issued by the Prime Minister - National Oil Spill Response Plan for the Period 2001 – 2010;

• Decision No.2469/QĐ-DKVN of Petrovietnam dated 5th May 2006 on Oil Spill Response Plan;

The International Regulatory Conventions for waste management are based on the Basel Convention on the Control Transboundary Movements of Hazardous waste and their Disposal, June 1994. The requirements of the Basel Convention include:

• Hazardous waste may be exported only to parties which permit its importation;

• Hazardous and other waste shall be minimised;

• Waste Management shall be environmentally sound;

• Pollution due to hazardous waste should be prevented to avoid consequences to humans and the environment;

• Hazardous and other waste shall be transported and disposed of only by persons authorized to do so;


15

• Hazardous and other waste shall be accompanied by appropriate documentation when moved transboundary;

• Hazardous and other waste shall only be moved transboundary if the state does not have the technical capacity, necessary facilities or suitable sites to dispose of waste in an environmentally sound manner, or if the waste is required as a raw material in the state of import.

2.2.1.3 Regulation on Environment Protection for Industrial Park

The regulation on the protection of the environment in industrial parks was promulgated according to Decision No.62/2002/QD-BKHCNMT of August 9th, 2002 by the Ministry of Science, Technology and Environment (MoSTE). This regulation prescribes the uniform management over the protection of the environment in industrial parks, export-processing zones and high-tech parks in order to protect the environment inside the industrial parks and their vicinity. In particular, it indicates procedures for building up the infrastructures of manufacturing areas, the potential inspections by certified authorities to evaluate impacts on the environment, the start-up of the aforesaid areas after being cleared by the legal bodies, the processing of all wastes deriving from industrial activities. On March 14th, 2008, the Government promulgated the Decree No. 29/2008/ND-CP for Industrial Parks (IPs), Export Processing Zones (EPZs) and Economic Zones (EZs). This Decree stipulates regulations on the establishment, operation, policy and State administration of IPs, EPZs, EZs and Border gate EZs. The Decree is detailed in 6 chapters and 41 articles. On July 15th, 2009, the Ministry of Natural Resources and Environment (MONRE) issued Circular No.08/2009/TT-BTNMT on environmental management and protection in the Economic Zone, Hi-tech Park, Industrial Park and Industrial Group. 2.2.2 Petroleum Law and Related Regulations The Petroleum Law was promulgated on July 6, 1993 by the National Assembly of the Socialist Republic of Vietnam. This Law was first amended under Resolution No. 19/2000/HQ10 on June 9,2000 and second revised and supplemented under Resolution No.10/2008/QH12 on June 3, 2008. This Law governs petroleum exploration and production activities carried out within the territory, the exclusive economic zone and the continental shelf of the Socialist Republic of Vietnam. This Law consists of nine (9) chapters divided into 51 articles. The Vietnam Oil and Gas Group (Petrovietnam) has been given responsibilities by the Government on the legal, strategies, planning, inspecting and supervising for oil and gas exploration and exploitation activities. The Ministry of Planning and Investment shall assume the prime responsibility for the appraisal, granting investment licenses and adjusting investment licenses for petroleum investment projects according to the provisions of the legislation on foreign investment in Vietnam; submit to the Prime Minister for permission the transfer of rights and obligations of petroleum contracts; report to the Prime Minister on the situation of investment license granting in the field of petroleum in Vietnam; and perform other tasks under the Prime Minister's authorization. In order to implement this Law, several Decrees, Regulations, Guidelines and Circulars have been issued as shown below: • The Regulations on environmental protection in petroleum prospecting, exploration, field development,

production, storage, transportation and processing, and related services was issued on 10 April, 1998 with the Decision No. 395/QĐ-KHCNMT by MOSTE. These Regulations are promulgated for the purpose of


16

preventing pollution and minimizing adverse impacts on the environment inflicted by activities in petroleum prospecting, exploration, field development, production, storage, transportation and processing (gas liquefaction, oil refining) and services directly relating to these activities. In the case of petroleum processing, Articles 29-30 regulate clearly that a refinery must take appropriate measures to prevent pollution of surface and ground water caused by rain-water run-off from raw materials, products, and by oil leakage and/or spillage from processing equipment, storage and transportation facilities. Gaseous, liquid and solid wastes from a petroleum processing plant shall be treated according to the Vietnamese environmental standards, or must be permitted by MONRE for discharge in case of the unavailability of relevant Vietnamese environmental standards, prior to their discharge into the environment. Sites for the collection of liquid and/or solid wastes of petroleum processing plants must be designed and treated in order to avoid environmental pollution. Petrovietnam is assigned with the responsibility to guide, supervise and control the implementation of these Regulations by Contractors in accordance with the provisions in Petroleum Contracts.

• The Regulations for safety management related to petroleum activities were promulgated in accordance with

Decree No. 41/1999/QD - TTg dated 8 March 1999 by the Prime Minister.

These Regulations are applicable to the petroleum activities pertaining to exploration, development and production, transportation and storage, processing and refining, of oil and gas, and distribution of petroleum products, and services directly relating to these activities, on land, the territorial sea, in exclusive economic zone, and on the continental shelf of Vietnam. These Regulations also apply to the installations, pipelines, associated equipment and vessels used for such activities. Any organization or individual conducting petroleum activities is obliged to prepare and submit to Petrovietnam a Safety Management Programme as well as a Risk Assessment and Emergency Response Plan prior to commencing the petroleum activities for acceptance by the authorities. The operator shall establish, maintain and develop a safety management system that shall ensure that their activities are planned, organized, executed, and maintained according to the requirements stipulated in these Regulations and in accordance with other legislative provisions.

• Guidelines for monitoring of the marine environment in the vicinity of offshore petroleum installations in Vietnam were promulgated in 2001 to provide guidance on the procedures of the baseline and monitoring programs for Petroleum Organizations operating in Vietnamese waters. The main objective of these Guidelines is to ensure that all monitoring activities will be carried out in a similar manner over the areas where field development, oil production or pipelines installation is on-going or planned for the future.

The selection of parameters, the approach to sampling, and the analysis described in the Guidelines need to be considered carefully during the project’s design and implementation phases so that the results are relevant to international standards. However, depending on the actual conditions of the petroleum activities, the environmental conditions of the study area and the previous monitoring results, the petroleum organizations can propose some change(s) to the monitoring program and parameters to suit the actual circumstances but they have to justify them for Petrovietnam approval.

• Guidelines for monitoring of onshore environment surrounding the petroleum installations were issued on July 10th, 2006 by Petrovietnam to provide guidance on the baseline and monitoring programs for onshore


17

petroleum organizations operating in Vietnam. Monitoring for the surrounding environment includes guidance on monitoring frequency, sampling network, parameters, sampling procedures, analytical methodologies and reporting format.

• Guideline for the implementation of requirements on use and discharge of chemicals and drilling fluids in

petroleum operations offshore Vietnam was issued on June 13th, 2005 by Petrovietnam. These Guidelines are applied for Petrovietnam subsidiaries, petroleum joint ventures and petroleum contractors operating in Vietnam who are responsible for preparing the Environmental Impact Assessment reports, Registration for Securing Environment Standards as well as conducting the use and discharge of chemicals and drilling fluids for petroleum projects.

2.2.3 Marine Code The Marine Code was amended according to the Resolution No.51/2001/QH10 of December 25, 2001 and promulgated under the Resolution No.40/2005/QH11 by the National Assembly of June 14, 2005. This Code consists of 18 chapters divided into 244 articles regulating navigation activities including ocean ships, marine harbors, marine shipping, navigation safety and security, marine pollution prevention and other related activities for social, culture, mission and science study. The Ministry of Transportation (MOT) has been given responsibility for managing and operating the national navigation. The Provincial Port Authority has responsibilities for managing and operating of provincial waters and harbors. In order to implement this Law, the Decree No.71/2006/ND-CP was promulgated on July 25, 2006 in providing for investment, construction, management and operation of seaports and marine navigable channels and management of marine shipping activities in Vietnamese ports. The Decree consists of five (5) chapters divided into 62 articles. This Decree shall apply to military ports, fishing ports, inland ports and sea ports. Investment in and construction of seaports and marine navigable channels shall comply with the approved seaport development plan. The Minister of Transport has the competence to announce the opening or closure of seaports. Any foreign vessel may enter a seaport only if they satisfy conditions on safety, security and environmental pollution prevention. Requirements for oil vessels and on prevention of environmental pollution are set out in this Decree. Specialized state management agencies shall be coordinated by port authorities and shall have the responsibility to inspect, supervise, control and protect vessels, passengers, crew, etc. as well as operate in seaports. On March 6th, 2009, the Government promulgated the Decree No.25/2009/NĐ-CP on integrated resources management and marine and island environment protection. 2.2.4 Law on Water Resources The Law on Water Resources was promulgated under Resolution No.8/1998/QH10 on May 20, 1998. This Law consists of 10 chapters divided into 75 articles. The State adopts the policy for managing, protecting and rationally, economically and efficiently exploiting the water resource; prevent, combat and overcome the harmful effects caused by water with a view of ensuring water for the living people and , the economy, ensure national defense and security, protect the environment and serve to ensure sustainable development of the country. The Law covers surface water, rain water, groundwater, and sea water. Under the Law, it is strictly prohibited to introduce into water sources, without a permit, any noxious waste, unprocessed discharge water or water that has been


18

processed but not up to the permissible standards as provided for by the legislation on the protection of the environment. Permits to discharge wastewater must be based on the receiving capacity of the water source and the assurance of no pollution and the protection of the water resource. Those discharging wastewater under a permit must process it in order to reach the permissible criteria before discharge; and they must pay compensation for any damage. The Law provides that organisations and individuals have rights to exploit and use water resources. Generally a licence is required to take and use water. The Ministry of Agriculture and Rural Development (MARD) has been given the responsibility for carrying out the State Management function on water resources. The Ministries, ministerial-level agencies shall carry out the function of State Management over water resources as assigned by the Government. The People's Committees of the provinces and cities directly under the Central Government shall take responsibility for conducting State Management over water resources within their localities as prescribed by this Law, other regulations and as assigned by the Government. Under this Law, Decree and Circular are issued as follows: • Decree No.149/2004/ND-CP, promulgated on 27 July 2004, deals with the issuance of permits for water resource

exploration, exploitation and use, or for discharge of wastewater into water sources.

• Circular No.2/2005/TT-BTNMT, promulgated on 24 June 2005, deals with the guidance in the implementation of the Government's Decree No. 149/2004/ND-CP.

This Circular provides for the issuance, extension, change of duration, adjustment of contents, suspension of validity and withdrawal of permits for underground water exploration; permits for underground water exploitation and use; permits for surface water exploitation and use; permits for discharge of wastewater into river, stream, canal, coastal, lake or pond water sources; and sets forms of dossiers for permit applications as well as permits.

In order to obtain surface water and groundwater and to discharge wastewater in both surface and groundwater, individuals or Companies must apply for permits, issued by competent authorities. Those permits shall include, among others, specific duration, terms of issuance, renewal, variation, and withdrawal. This Circular applies to all domestic as well as foreign organizations and individuals conducting activities related to underground water exploration, exploitation and use; surface water exploitation and use; or discharge of wastewater into water sources.

2.2.5 Law on Forest Protection and Development

The Law on Forest Protection and Development was promulgated in 1992 and was first amended and supplemented under Resolution No. 51/2001/QH10 on 25 December 2001 and second amended under Resolution No.29/2004/QH11 on 14 December 2004. This Law provides for the management, protection, development and use of forests and rights and obligations of forest owners. This Law consists of 88 articles divided into eight (8) chapters in which the protection of the forest ecosystem is regulated in Article 40 that mentions all new construction activities causing effects to the forest ecosystem have to conduct an EIA as an environmental requirement and may only implement activities after receiving approvals from the Authority.


19

The Minister of Agriculture and Rural Development has been given responsibility to exercise the State Management over forests ensuring the observance of forest protection and development legislation. Under this law, a number of Decrees, Decisions and Circulars are issued as follows: • Decree No. 23/2006/ND-CP was issued on 03 March 2006 on the Implementation of the Law on Forest Protection

and Development. This Decree provides for forest protection and development planning and plans; forest assignment, lease and recovery; change of forest use purposes; recognition, registration, sub-lease, mortgage, etc. of forest use rights or ownership rights over planted production forests; statistics, inventory and monitoring of changes in forest resources; organization of forest management, protection, development and use. This Decree consists of seven (7) chapters divided into 59 articles. Institutions responsible for the state management of forest protection and development are outlined in the Decree. Protection forests, special-use forests and production forests shall be established. The Decree includes provisions on the protection of forest ecosystems, forest, flora and fauna.

• Decision of the Ministry of Agriculture and Rural Development No 82/2008/QD9-BNN of 17 July 2008. This

decision presents the list of endangered aquatic species in Vietnam.

• Decree No NĐ32/2006/NĐ-CP: IIB: Limits of exploitation and use of flora and fauna. 2.2.6 Land Law

The Land Law 2003 is a comprehensive law that establishes the regulations of land allocation, lease management, land acquisition for development purposes, changes of land value under market mechanisms, and gives people access to land through land-user rights via land use right certificates (LURCs), which are similar to private ownership. In essence the law allows the State to recover land in cases of national defence or security, or national and public interest. With respect to land acquisition, resettlement and compensation, the Land Law makes the following provisions:

(i) The State reserves the right to “recover” land for the purposes of defense, security and national and public interests (Article 38). Decree No. 181/2004/ND-CP defines “national and public interest” to include infrastructure projects such as the Nghi Son Economic Zone (NSEZ) and NSRP.

(ii) Individuals, households and organizations that have or are eligible to be granted land use right certificates for recovered land will receive compensation for the loss of these assets (Article 42(1)).

(iii) Before land is recovered, the user must be informed of the reasons for recovery; the schedule and plans for resettlement, if necessary; and, options for compensation. This must occur at least 3 months prior to recovery of agricultural land and 6 months prior to recovery of non-agricultural land (Article 39).

(iv) Compensation for recovered agricultural and rural residential land will be in the form of new land of the same purpose of use or, if no new land is available, cash equivalent to the land use right value of the recovered land (Article 42(2) and (3)). In the latter case, the land use right value is


20

established as the value of similar land under normal market conditions, as determined on an annual basis by PPCs (Article 56).

(v) Recovery of land from people directly involved in agricultural production but having no land available for continued production will receive cash compensation and, in addition, support from the State to stabilize their lives (Article 42(4)).

(vi) Where the use of right value of recovered residential land is greater than that of the land given as compensation, affected people will receive cash equal to the difference in the values (Article 42(3)).

(vii) Resettlement zones will be developed for people having residential land recovered and having to move their places of residence. Resettlement zones will be developed for many projects in the same area and will provide living conditions that are equal to or better than the conditions in the former places of residence. In areas where there is no established resettlement zone, people will receive cash for recovered residential land and priority to purchase or lease State-owned dwellings (Article 42(3)).

(viii) Recovery of land will occur without compensation in the following cases, among others: a) land is recovered from organizations that use State funds to pay land use levies for assigned land or land rents for leased land, or are assigned land without having to pay land use levies; b) recovered land has been illegally encroached or occupied, or the occupants are not eligible to be granted land use right certificates; c) recovered land is rented from the State; and, d) recovered land is traffic or irrigation land, or used for cemeteries or graveyards (Article 43(1)).

(ix) Structures and other fixed assets on recovered land will not be compensated in cases where they have been constructed without permission; in contravention of permitted uses in land use plans; or, when structures are located on illegally encroached land (Article 43(2)).

(x) In the event of temporary recovery of land, for example during construction, upon the expiry of temporary land acquisition the State will return the land and pay compensation for any damages (Article 45).

The Constitution of the Socialist Republic of Viet Nam (1992) confirms the right of citizens to own and protect the ownership of a house. In addition, the Government has enacted a number of laws, decrees and regulations that constitute the legal framework for land acquisition, compensation and resettlement. The principal documents include:

• The Land Law No. 13/2003/QH11, providing Vietnam with a comprehensive land administration law. The 2003 Land Law supersedes earlier versions of 1987 and 1993.

• Governmental Decree No.181/2004/NĐ-CP dated 29 October 2004 on implementing Land Law;

• Decree No. 197/2004/ND-CP, on compensation, rehabilitation and resettlement in the event of land recovery by the State.

• Circular 116/2204/TT-BTC, guiding the implementation of Decree 197.

• Decree No. 17/2006/ND-CP, amending Decree No. 181/2004/ND-CP, Decree No. 197/ 2004/ND-CP and other decrees.

• Decree No.84/2007/ND-CP of 25 May, 2007, on supplementary regulations for issuance of Certificate of land use rights, land recovery, implementation of land use rights, proceeding and


21

procedures of compensation, support, resettlement upon land recovery by the State, and settlement of land claims.

• Decree No.188/2004/ND-CP, specifying methods for land pricing and land price frameworks in the event of land recovery by the State.

• Circular 145/2007-TT-BTC, guiding the implementation of Decree 188.

• Decree No.17/2003/ND-CP, promulgating the regulation on the exercise of democracy in communes, including requirements for consultation with and participation of people in communes.

• Decree No.17/2001/ND-CP, on the management and use of Official Development Assistance (ODA).

• Direction 17/2004/CT-TTg, on speeding up the disbursement of ODA capital source. Decree No.197/2004/ND-CP regulates the eligibility and procedures for compensation, assistance and resettlement in the event of State recovery of land. The principles underlying compensation are: (i) recovery of land from eligible persons shall be compensated; (ii) in the event, the affected person is not eligible for compensation, consideration will be given to forms of assistance; (iii) compensation for affected land will be in the form of new land allocation with the same purpose of use or, if no such land is available, cash compensation equal to the value of land use rights at the time of recovery; and, (iv) outstanding financial liabilities associated with land to be recovered will be deducted from the amount of compensation or assistance money. The Decree and Circular No. 116/2004 TT-BTC set out in detail the types of compensation for different types of users and losses; assistance policies; provisions for individual and group resettlement; and, the roles and responsibilities for implementation of resettlement projects. Decree No.17/2006/ND-CP amends Decree 197 to strengthen several aspects of the provisions for compensation, assistance and resettlement, including: (i) a requirement to update official PPC prices, as necessary, to reflect market values for affected assets; (ii) life stabilization assistance for poor households; and, (iii) assistance for occupational change and job creation for APs losing significant portions of their productive assets, as well as for APs that relocate to resettlement sites. Decree No.84/2007/ND-CP provides additional provisions for issuance of land use right certificates; for land recovery; for exercise of land use rights; for order and procedures for compensation, assistance and resettlement when the state recovers land; and for resolution of complaints about land. The number of people eligible for compensation has significantly increased due to the improvements in eligibility for allocation or recognition of Land Use Rights contained in Decree 17 and Decree 84. Decree No.188/2004/ND-CP regulates the methodology for determining land prices and price frames for State recovery of land, as well as for taxation on land use and the transfer of land use rights and for land rents for government land. It establishes the minimum and maximum prices for different types and categories of land. The principle underlying the determination of land prices is the actual transfer price on the market under normal conditions between a willing seller and buyer without regard to factors such as speculation, changes in planning, forceful transfer or blood relationship. Circular No. 114/2004/TT-BTC elaborates in detail the methods (direct comparison and income methods) for determining land prices.


22

Decree No.17/2001/ND-CP stipulates that where an international aid agreement has provisions that are inconsistent with the provisions of Viet Nam law, the provisions of the ODA agreement shall prevail (Article 29). Decree No.197/2004/ND-CP corroborates that when compensation, assistance and resettlement for a project using official ODA differs from the provision of the Decree, the project must be submitted to the Prime Minister for consideration and decision (Article 2). Other laws, decrees and regulations relevant to land management, land acquisition and resettlement include:

• Construction Law No. 16/2003/QH11, on compensation and relocation of people affected by ground clearance for investment projects.

• Decree No. 16/2005/ND-CP, on the implementation of the Construction Law. • Decree No. 182/2004/ND-CP, on penalties for administrative violations in land issues. • Decree No. 123/2007/ND-CP, on supplementary regulations for Decree No. 188/2004/ND-CP,

specifying methods for land pricing and land price frameworks in the event of land recovery by the State;

• Decree No. 198/2004/ND-CP, on land use fees. • Circular 117/2004/TT-BTC, guiding the implementation of Decree 198. • Circular No 06/2007/TT-BTNMT guiding the implementation of Decree No. 84/2007/ND-CP 25

May 2007, on supplementary regulations for issuance of Certificate of land use rights, land recovery, implementation of land use rights, proceeding and procedures of compensation, support, resettlement upon land recovery by the State, and settlement of land claim;

• Decree No.60/1994/CP, on property ownership and the right to use urban residential land,

ensuring the right to own residential structures and use residential land. • Decree No.45/1996/CP regulates the amendment of Article 10 of Decree No. 60/1994/CP,

allowing land use rights to those not eligible under Decree No. 60. • Decree No.61/1994/CP, on the purchase, sale and trading of residential dwellings. • Decree No.64/1993/CP, on the distribution of agricultural land to households for long-term

agricultural purposes.

• Circular No.05-BXD/DT, 1993, on the classification of house types. • Decree No.70 stipulates that all documents registering family assets and land use rights must

be in the names of both husband and wife. At the Provincial Level, Thanh Hoa has approved the following Decisions regarding resettlement issues:


23

• Decision No. 3900/2007/QD-PPC dated 13/12/2007 of Thanh Hoa PPC on approval of overall on compensation plans, clearance of the site for Nghi Son Refinery and Petrochemical Project in Tinh Gia District, Thanh Hoa Province.

• Decision No.3931/2006/QĐ-UBND dated 31st December 2006 issued by Thanh Hoa PPC on approval of the land prices of Thanh Hoa Province in 2007;

• Governmental Decree 69/2009/NĐ-CP dated 13th August 2009 on promulgating supplemental regulations on land use, pricing, acquiring, compensating, assisting and resettlement plan.

• Decision No.1511/2007/QĐ-UBND dated 24th May 2007 issued by Thanh Hoa PPC on compensation rates for assets existing on land in the localities of Thanh Hoa Province;

• Decision No.4238/2007/QĐ-UBND dated 31st December 2007 issued by Thanh Hoa PPC on approval of the land prices in Thanh Hoa Province in 2008;

• Decision No.1151/2008/QĐ-UBND dated 28th April 2008 issued by Thanh Hoa PPC on admending and adjusting some prices for agricultural land in the Nghi Son Economic Zone;

• Letter No.1606/UBND-KTTC dated 18th April 2008 issued by Thanh Hoa PPC on prices of different types of land for compensation from the implementation of investment projects in the area of Nghi Son Economic Zone and Tinh Gia District;

• Decision No.1048/2008/QĐ-UBND dated 22nd April 2008 issued by Thanh Hoa PPC on compensation rates for structures.

• Decision No.2531/2008/QĐ-UBND dated 18th August 2008 issued by Thanh Hoa PPC on assistance policy for moving and relocation of APs applied for Nghi Son Economic Zone.

• Resolution No.128/2009/NQ-HĐND dated 15th July 2009 issued by Thanh Hoa PPC on policy of relocation assistance and resettlement applied for NSEZ.

• Guideline No.2108/HD/STC dated 25th September 2009 issued by the Financial Department of Thanh Hoa Province on implementation policy of relocation assistance and resettlement applied for NSEZ.

• Decision 2622/2009/QĐ-UBND dated 7th August 2009 issued by Thanh Hoa PPC on policy of relocation assistance and resettlement applied for NSEZ.

• Decision 4366/QĐ-UBND dated 9th December 2009 issued by Thanh Hoa PPC on replacing Decision 2622/2009/QĐ-UBND.

2.2.7 Labour Code Labour Code was adopted on 23 June 1994 then amended on 2 April 2002 as Law 35-2002-QH10. The Labour Code includes 16 chapters and 198 articles that lay down the rights and obligations of workers and employers, labour standards, the principles of labour utilization and administration; contributes to the uplift of production, and therefore holds an important place in social life and in the legal system of the nation. The Labour Code protects the right to work, interests and other rights of workers and, at the same time, the lawful - rights and interests of employers thereby creating conditions for a harmonious and stable labour relationship. It contributes to releasing the creativeness and talent of both manual and intellectual workers, of labour managers, with the aim of achieving a high level of productivity and


24

quality and social progress in labour, production and services, efficiency in the use and administration of labour; and contributes to the industrialization and modernization of the country, with the objective of* having prosperous people, a mighty country and a just, democratic, civilized society. The present Labour Code regulates the labour relationship between the wage earning worker and his employer, and the social relationships directly connected with this labour relationship. 2.2.8 Law on Community Health Protection

The Law on Community Health Protection consists of 11 chapters divided into 55 articles on community health protection. The law regulates clearly that state organizations/companies or person are prohibited from causing pollution to local water supply sources (Article 8). All state and private factories or companies have to carry out industrial waste treatments to prevent air, soil and water pollution as required by the council of ministries (Article 10). The necessary measures for work safety and hygiene conditions including temperature, smoke, dust, humidity, noise, vibration and others shall be done by all organization, companies/factories or individuals. The employers shall organize periodic medical check-ups for employees and provide necessary labor working devices (Article 14).

The government has the responsibility to look after people’s health and implement national policies and health improvement measures. The Ministry of Health (MOH) has been given the responsibility to manage occupational health services at the national level. Formulation of regulations and standards pertaining to occupational hygiene, determination of health standards for specific fields of work, management of occupational health care service delivery through its branches, performance of periodic health examination for workers, diagnosis of occupational disease, education and implementation of therapy and rehabilitation of workers and enhancing international cooperation in occupational health are its key responsibilities. 2.2.9 Law on Chemicals

The Law on Chemicals was promulgated on 5 December 2007 by the Order No. 15/2007/L-CTN. This Law provides for principles of chemical-related activities, safety in chemical-related activities and for rights and obligations of organizations and individuals engaged in chemical-related activities. The Law sets out requirements on chemical production and trade and responsibilities for assuring safety. . The Law also specifies procedures for obtaining certificates and permits for the production and trade of chemicals. The Law further provides for: chemical classification, labelling and packaging and chemical safety data sheets; rights and obligations of organizations and individuals using chemicals or hazardous chemicals for the production of other products; storage and preservation of hazardous chemicals; disposal of discarded chemicals which must follow environmental protection standards; prevention of and response to chemical incidents; environmental protection and safety for the community; state management responsibilities for chemical-related activities; etc.

Under this law, two Decrees were issued as follows:

• Decree No.108/2008/ND-CP was issued on 7 October 2008 for detailing and guiding the implementation of a number of articles of the Chemical Law.

The Decree provides for conditions on chemical production and trade in the industrial sector, in the food and chemical pesticide industry, etc.; the list of chemicals restricted from production or trade and the list of banned chemicals; the list of chemicals for which chemical prevention and response


25

plans are required; safety distances for establishments producing hazardous chemicals; the list of chemicals subject to compulsory declaration; and concentration limits for hazardous chemicals; information on chemicals.

• Decree No.68/2005/ND-CP on chemical safety was issued on 20 May 2005 for describing the safety in production, purchase, sale, transportation, storage, use, collection, destruction and discharge of dangerous chemicals. It is mentioned that chemicals must always be accompanied by chemical safety data sheets in the process of their circulation and must be labelled as dangerous chemicals. The Decree specifies the duties of the Industry Ministry and other ministries in regards to chemical safety, competence to formulate lists of groups of dangerous chemicals, etc.

• Circular No.05/2006/TT-BKHCN dated 11/01/2006 Guideline for Procedure in Declaration, Registration License and Operation License relating to Radiation;

• Circular No.01/2006/TT-BCN dated 11/4/2006 Guideline in the Management of importation/exportation of toxicants and products containing toxicant, predrugs and chemicals with technical standards managed by the Ministry of Trading and Technology;

• Circular No. 05/2006/TT-BKHCN dated 11 January 2006 from the Ministry of Science and Technology providing guidance on the procedures of notification, registration and licence issuance to radiation-related activities;

• Circular No. 12/2006/TT-BCN guiding the implementation of the Government’s Decree No. 68/2005/ND-CP dated 20 May 2005 on management over chemical safety, including declaration of dangerous chemicals, assessment of new chemicals, chemical safety data sheets, classification and labeling of chemicals, plans on prevention and remedy of chemical incidents, safety distance and chemical safety reports.

2.2.10 Law on Biodiversity The Law on Biodiversity took effect on July 1, 2009. With eight (8) chapters and 78 articles, the law will support and unify the management of biodiversity. At present, biodiversity management is stipulated in many laws, for instance the Law on Forest Protection, Law on Environmental Protection and the Law on Aquatic Protection. The Ministry of Natural Resources and Environment will become the sole agency responsible for the management and protection of the nation’s biodiversity, according to the new law. The Law on Biodiversity is an effective legal instrument to prevent biodiversity declination, to conserve precious plants and animals and to serve the sustainable social and economic development of the country. Decision No.79/2007/QD-TTg of 31 May 2007, approving the National Action Plan on Biodiversity up to 2010 and Orientation towards 2020 for Implementation of the Convention on Biological Diversity and the Cartagena Protocol on Biosafety. The NBPA 2007 consists of 5 major goals. Each goal contains several specific objectives. Some key objectives are: to improve, complete and develop the system of special-use forests (to reach a forest coverage of 42-43%); to restore 50% of the area of degraded watershed forests; to effectively protect precious, rare and endangered animals and plants; to establish 1.2 million hectares of internationally and nationally important protected wetlands and marine protected


26

areas; to restore 200,000 hectares of mangrove forests; to restore and develop important coral reefs and seagrass. 2.3 VIETNAMESE ENVIRONMENTAL STANDARDS The following environmental standards and national technical regulations have been developed by the Ministry of Natural Resources and the Environment (MONRE) and form the environmental framework for all industrial developments:

2.3.1 Air Quality

• QCVN 05:2009/BTNMT: National Technical Regulation on Hazardous substances in ambient air

• QCVN 06: 2009/BTNMT National Technical Regulation on ambient air quality • QCVN 19:2009/BTNMT National Technical Regulation on Industrial Emission of Inorganic

Substances and Dust • QCVN 20:2009/BTNMT National Technical Regulation on Industrial Emission of Organic

Substances • QCVN 22: 2009/BTNMT National Technical Regulation on Emission of Thermal Power Industry • TCVN 6438:2005 Road Vehicles. Maximum permitted emission limits of exhaust gas

2.3.2 Water Quality

• QCVN 08:2008/BTNMT Surface Water Quality • QCVN 09:2008/BTNMT Groundwater Quality • QCVN 10:2008/BTNMT Coastal Water Quality

2.3.3 Wastewater Quality

• QCVN 24: 2009/BTNMT National Technical Regulation on Industrial Wastewater • QCVN 14: 2008/BTNMT National Technical Regulation on Domestic Wastewater • TCVN 5298:1995 General requirements for the use of wastewaters and their sludges for

watering and fertilizing purposes

2.3.4 Hazardous Wastes

• TCVN 7221:2002 General environmental requirements for central industrial wastewater treatment plants

• QCVN 07: 2009/BTNMT National Technical Regulation on Hazardous Waste Thresholds • TCVN 6705:2000 Non-hazardous solid wastes. Classification • TCVN 6868:2001 Radiation protection. Radioactive waste management. Classification of

radioactive waste 2.3.5 Noise and Vibration

The following Vietnamese standards are compiled for noise and vibration:


27

• TCVN 3985:1999 Acoustics. Allowable noise levels at working place • TCVN 5290:1990 System of standards for environmental protection. General requirements • TCVN 5654:1992 Regulations on environmental protection at offshore mooring terminals for

loading exploited raw petroleum • TCVN 5948:1999 Acoustics. Noise emitted by accelerating road vehicles. Maximum Permitted

Noise Level • TCVN 5949:1998 Acoustics. Noise in public and residential areas. Maximum Permitted Noise

Level • TCVN 6436:1998 Acoustics. Noise emitted by stationary road vehicles. Maximum Permitted

Noise Level • TCVN 6962:2001 Vibration and shock. Vibration emitted by construction works and factories.

Maximum permitted levels in the environment of public and residential areas • TCXDVN175:2005 Maximum permitted noise levels for public buildings – Design Standard

2.4 INTERNATIONAL CONVENTIONS AND TREATIES

Vietnam is party to several international environmental and labor conventions, as summarized in the following tables. These conventions have been signed and/or ratified by the Government of Vietnam. The legal implications of ratification, accession, approval, and acceptance are the same. A brief description of the relevance of the signed and ratified conventions to the Project and if relevant, the Project’s compliance status, is given in Table 2.1.

Table 2.1 International Environmental Conventions

International Conventions Status in Vietnam Compliance

Ramsar Convention on Wetlands (1971)

− The conservation and wise use of wetlands by national action and international cooperation as a means of achieving sustainable development throughout the world.

− The Project does not affect any Ramsar designated wetlands

Signing

20 September 1989

Compliant

The United Nations Convention on the Law of the Sea (UNCLOS) 1982/1994

− The Law of the Sea Convention defines the rights and responsibilities of nations in their use of the world's oceans, establishing guidelines for businesses, the environment, and the management of marine natural resources.

Agreement relating to the implementation of Part XI of the Convention of 10 December 1982

− This part provides for a regime relating to minerals on the seabed outside any state's territorial waters or EEZ (Exclusive Economic Zones).

25 July 1994

27 April 2006

Compliant

Vienna Convention for the Protection of the Ozone Layer (1985)

− It acts as a framework for the international efforts to protect the ozone layer. However, it does not include legally binding reduction goals for the use of CFCs. These are laid out in the accompanying Montreal Protocol.

Signature

26 April 1994

Compliant

In application through the Montreal Protocol


28


Montreal Protocol 1987/90/92/95/97/99 on the Control of Substances that Deplete the Ozone Layer (CFCs, HFCs)

− This international agreement is designed to protect the stratospheric ozone layer.

Accession 26 Jan1994 Ratification

Montreal & Beijing

Amendments

3 December 2004

Compliant

Basel Convention 1989, Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal

− It is designed to reduce the movements of hazardous waste between nations, and specifically to prevent transfer of hazardous waste from developed to less developed countries.

Signature

22 March 1989

Ratification

3 March 1998

Compliant

The Protocol of 1978, Relating to the International Convention for the Prevention of Pollution From Ships 1973 (MARPOL), Annexes I & II

− It is designed to minimize pollution of the seas, including dumping, oil and exhaust pollution. Its stated object is: to preserve the marine environment through the complete elimination of pollution by oil and other harmful substances and the minimization of accidental discharge of such substances.

− MARPOL contains 6 annexes, concerned with preventing different forms of marine pollution from ships:

− Annex I – Oil − Annex II – Noxious Liquid Substances carried in Bulk − Annex III – Harmful Substances carried in Packaged Form − Annex IV – Sewage − Annex V – Garbage − Annex VI – Air Pollution

Ratification

Annex I & II

29 August 1991

Compliant

The United Nations Framework Convention on Climate Change 1992/1994

− The treaty is aimed at stabilizing greenhouse gas concentrations in the atmosphere at a level that would prevent dangerous anthropogenic interference with the climate system

Signature

16 November 1994

Compliant

In application through the

Kyoto Protocol

Kyoto Protocol 97/05, on Reducing CO2 Emissions and other Greenhouse Gases (GHG) that affect Climate Change

− The Protocol is designed to achieve quantified emission limitations and reduction commitments of greenhouse gases in developed countries and countries that are undergoing a process transition to a market economy.

Signature

3 February 1998

Ratification:

25 September 2002

Entry into Force:

16 February 2005

Compliant

NSRP will report its GHG emissions to

the environmental ministry on annual basis

International Declaration on Cleaner Production 1989

− This declaration aims for a continuous application of an integrated, preventive strategy applied to processes, products and services in pursuit of economic, social, health, safety and environmental benefits.

Signatory

22 September 1999

Compliant

The Convention on Biological Diversity (CBD) (1993) Ratification Compliant


29


− This convention aims to conserve biological diversity; to use biological diversity in a sustainable fashion and to share the benefits of biological diversity fairly and equitably.

16 November 1994

Cartagena Protocol on Biosafety (CPB) (2000)

− It is designed to ensure an adequate level of protection in the field of the safe transfer, handling and use of living modified organisms that may have adverse effects on the conservation and sustainable use of biological diversity, taking also into account risks to human health, and specifically focusing on transboundary movements.

Accession

20 April 2004

Compliant

Convention to Combat Desertification (1994)

− This Convention aims to promote effective action through innovative local programmes and supportive international partnerships.

− This project will not degrade land and contribute significantly to desertification.

Accession

25 August 1998

Entry into force

23 November 1998

Compliant

Stockholm Convention on Persistent Organic Pollutants (2001)

− It is a global treaty to protect human health and the environment from chemicals that remain intact in the environment for long periods, become widely distributed geographically and accumulate in the fatty tissue of humans and wildlife. The Convention requires Parties to take measures to eliminate or reduce the release of POPs into the environment.

Signature

23 May 2001

Ratification

22 July 2002

Compliant

Convention concerning the Protection of the World Cultural and Natural Heritage

− It aims to ensuring the identification, protection, conservation, presentation and transmission to future generations of the cultural and natural heritage.

Acceptance

19 October 1982

Compliant

No Cultural and Natural Heritage site located in the study area

Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITIES)

− Its aim is to ensure that international trade in specimens of wild animals and plants does not threaten their survival.

Accession

20 Jan 1994

Entry into force

20 April 1994

Compliant

Vietnam has also ratified the following 18 Labour International Conventions

Table 2.2 International Labor Conventions

Conventions Title Ratification

6 Night Work of Young Persons (Industry) Convention, 1919 3 Dec 1994

14 Weekly Rest (Industry) Convention, 1921 3 Dec 1994

27 Marking of Weight (Packages Transported by Vessels) Convention, 1929 3 Dec 1994

29 Forced Labour Convention, 1930 5 Mar 2007

45 Underground Work (Women) Convention, 1935 3 Dec 1994


30

Conventions Title Ratification

80 Final Articles Revision Convention, 1946 3 Dec 1994

81 Labour Inspection Convention, 1947 3 Dec 1994

100 Equal Remuneration Convention, 1951 7 Oct 1997

111 Discrimination (Employment and Occupation) Convention, 1958 7 Oct 1997

116 Final Articles Revision Convention, 1961 3 Dec 1994

120 Hygiene (Commerce and Offices) Convention, 1964 3 Dec 1994

123 Minimum Age (Underground Work) Convention, 1965 Minimum age specified: 18 year 20 Feb 1995

124 Medical Examination of Young Persons (Underground Work) Convention, 1965 3 Dec 1994

138 Minimum Age Convention, 1973 Minimum age specified: 15 years

24 Jun 2003

144 Tripartite Consultation (International Labour Standards) Convention, 1976 9 Jun 2008

155 Occupational Safety and Health Convention, 1981 3 Dec 1994

182 Worst Forms of Child Labour Convention, 1999 19 Dec 200

2.5 EQUATOR PRINCIPLES

Leading industry practice for international projects in emerging countries is generally drawn from the international lending community. The "Equator Principles," based on the International Finance Corportion (IFC) Policy and Performance Standards on Social and Environmental Sustainability, were established in 2003 through the voluntary participation of several Equator Principle Financial Institutions (EPFI) to ensure that the projects that are financed, are developed in a manner that is socially responsible and reflect sound environmental management practices. The Principles apply to all new project financings globally with total project capital costs of US$ 10 million or more.

By doing so, negative impacts on project-affected ecosystems communities should be avoided where possible, and if these impacts are unavoidable, they should be reduced, mitigated and/or compensated for appropriately. These Principles are intended to serve as a common baseline and framework for the implementation by each EPFI of its own internal social and environmental policies, procedures and standards related to its project financing activities.

The ten Equator Principles are:

• Principle 1: Review and Categorization: Obliges the categorization of projects based on the magnitude of its potential impacts and risks in accordance with the environmental and social screening criteria of the IFC.

• Principle 2: Social and Environmental Assessment: Requires the evaluation of the relevant social and environmental impacts and risks of the proposed project. The Assessment should also propose mitigation and management measures relevant and appropriate to the nature and scale of the proposed project.

• Principle 3: Applicable Social and Environmental Standards: The assessment will refer to the applicable IFC Performance Standards and Industry specific World Bank/IFC (WB/IFC) Environmental Health and Safety (EHS) Guidelines to complement the host country legislation as the basis for social and environmental performance. Justification to deviation from, the respective IFC Performance Standards and EHS Guidelines is required. The Assessment process should address compliance with relevant host country laws, regulations and permits that pertain to social and environmental matters.


31

• Principle 4: Action Plan and Management System: Requires the development of a plan for implementing the mitigation measures, correctives actions and monitoring measures necessary to manage the impacts and risks identified in the Assessment. Borrowers will build on, maintain or establish a Social and Environmental Management System that addresses the management of these impacts, risks, and corrective actions required to comply with applicable host country social and environmental laws and regulations, and requirements of the applicable Performance Standards and EHS Guidelines, as defined in the Action Plan.

• Principle 5: Consultation and Disclosure: Obliges free, prior and informed consultation and the facilitation of informed participation for projects that may have significant adverse impacts to local communities and the public disclosure of the Assessment and Action Plan in a culturally appropriate manner. At least two Public Consultations are required for projects of large magnitude.

• Principle 6: Grievance Mechanism: Requires the establishment of a grievance mechanism as part of the management system and that the affected communities are informed of the process.

• Principle 7: Independent Review: Calls for independent social or environmental expert not directly associated with the borrower to review the Assessment, Action Plan and consultation process documentation in order to assist EPFI's due diligence, and assess Equator Principles compliance.

• Principle 8: Covenants: Incorporates into the lending covenants compliance with the host country

requirements, Action Plan implementation, commitments, periodic reporting of social and environmental performance, and facility decommissioning and closure where appropriate.

• Principle 9: Independent Monitoring and Reporting: Calls for an independent environmental and/or social expert to verify monitoring and reporting information over the life of the loan; and

• Principle 10: EPFI Reporting: Commits the EPFI to publicly report at least annually about its Equator Principles implementation processes and experience.

Principle 3 obliges the Project to apply IFC Performance Standards, WB/IFC General EHS Guidelines and the applicable WB/IFC Industry specific EHS Guidelines. The Project should also comply with the Vietnamese Legislation and Standards. When both of them will apply, the more stringent standard will be selected. 2.6 IFC PERFORMANCE STANDARDS

The Performance Standards define a project’s role and responsibilities for managing health, safety, environmental and community issues to receive Equator participating lender support. The Performance Standards are summarized below, followed by more detailed content definitions:

• Performance Standard 1: Social and Environmental Assessment and Management System

This Standard aims to identify and assess social and environment impacts, both adverse and beneficial, in the project’s area of influence; to avoid, or where avoidance is not possible, minimize, mitigate, or compensate for adverse impacts on workers, affected communities, and the environment; to ensure that affected communities are appropriately engaged on issues that could potentially affect them; and to promote improved social and environment performance of companies through the effective use of management systems.


32

• Performance Standard 2: Labor and Working Conditions

This Standard seeks to establish, maintain and improve the worker-management relationship; to promote the fair treatment, non-discrimination and equal opportunity of workers, and compliance with national labor and employment laws; to protect the workforce by addressing child labor and forced labor; and to promote safe and healthy working conditions, and to protect and promote the health of workers.

• Performance Standard 3: Pollution Prevention and Abatement

This Standard is intended to minimize adverse impacts on human health and the environment by minimizing pollution and reducing emissions that contribute to climate change. The Standard recommends to consider during the design phase, the project’s lifecycle ambient conditions and apply pollution prevention and control technologies and practices (techniques) that are best suited to avoid or, where avoidance is not feasible, minimize or reduce adverse impacts on human health and the environment while remaining technically and financially feasible and cost-effective. The 2007 EHS Guidelines provide guidance for evaluating and selecting pollution prevention and control techniques for projects.

• Performance Standard 4: Community Health, Safety and Security

This Standard seeks to avoid or minimize risks to and impacts on the health and safety of the local community during the project life cycle; and to ensure that the safeguarding of personnel and property is carried out in a legitimate manner that avoids or minimizes risks to the community’s safety and security. Where the project poses risks to or adverse impacts on the health and safety of affected communities, the Project will disclose an Action Plan to enable the affected communities and relevant government agencies to understand these risks and impacts.

• Performance Standard 5: Land Acquisition and Involuntary Resettlement

This Standard aims to avoid or at least minimize involuntary resettlement wherever feasible by exploring alternative project designs; to mitigate adverse social and economic impacts from land acquisition or restrictions on affected persons’ use of land by: (i) providing compensation for loss of assets at replacement cost; and (ii) ensuring that resettlement activities are implemented with appropriate disclosure of information, consultation, and the informed participation of those affected; to improve or at least restore the livelihoods and standards of living of displaced persons; and to improve living conditions among displaced persons through provision of adequate housing with security of tenure at resettlement sites. During this Project, since the site is prepared by the Government of Vietnam, NSRP will ensure through due diligence monitoring that this Performance Standard is respected.

• Performance Standard 6: Biodiversity Conservation and Sustainable Natural Resource Management

This Standard calls for the balancing of conservation of biodiversity and the promotion of sustainable management of natural resources. The requirements of this Performance Standard are applied to projects in all habitats, whether or not those habitats have been previously disturbed and whether or not they are legally protected.


33

• Performance Standard 7: Indigenous Peoples

This Standard ensures that the development process respects the dignity, human rights, aspirations, cultures and natural resource-based livelihoods of Indigenous Peoples. In the Project Study area, the population belongs entirely (at few households exception) to the same Vietnamese ethnic group (Kinh). Therefore, it will not be required to follow this Performance Standard.

• Performance Standard 8: Cultural Heritage This Standard aims to protect cultural heritage from the adverse impacts of project activities and support its preservation and to promote the equitable sharing of benefits from the use of cultural heritage in business activities.

Stakeholder’s engagement is an important part of complying with EP (Principle 5) and IFC Performance Standards (PS 1). The purpose of stakeholder engagement is to build and maintain a constructive relationship with affected communities. The nature and the frequency of engagement should be in-line with the risks to and the adverse impacts on the communities. Engagement must be free of external manipulation, interference, or coercion, and intimidation, and conducted on the basis of timely, relevant, understandable and accessible information. Disclosure of relevant project information helps affected communities understand the risks, impacts and opportunities of the project. If communities may be affected by risks or adverse impacts from the project, the developer must provide such communities with access to information on the purpose, nature and scale of the project, the duration of proposed project activities, and any risks to and potential impacts on such communities. If affected communities may be subject to risks and adverse impacts from a project, consultation must be undertaken in a manner that affords affected communities the opportunity to express their views on the project risks, impacts, and mitigation measures and have due consideration given to that input in project decision-making. This consultation should begin early in the ESIA process, focus on the risks and adverse impacts and the measures and actions envisaged for their mitigation, and be carried out in a manner that is inclusive and culturally appropriate. The more significant the potential risks and impacts are for a project, the more rigorous the stakeholder engagement program must be. For higher risk projects with the potential for significant adverse impacts on affected communities, the consultation process will require their free, prior and informed consultation (FPIC) and facilitate informed community participation. Informed participation involves organized and iterative consultation and the incorporation of community views on matters that directly affect them directly into the project decision-making process. This may include proposed mitigation measures, the sharing of development benefits and opportunities, and implementation issues. EP (Principle 2) and IFC Performance Standards (PS 1) oblige an evaluation of cumulative and sectoral impacts where projects are likely to have significant adverse social or environmental impacts that are sensitive, diverse, or unprecedented. Evaluations should normally cover the cumulative impacts of other regionally relevant proposed developments and for reasonably foreseeable expansions to relevant existing developments. The analysis considers the combined effects of the relevant activities as they accumulate over time and space.


34

2.7 IFC ENVIRONMENTAL HEALTH AND SAFETY GUIDELINES The IFC Environmental, Health, and Safety (EHS) Guidelines are technical reference documents with general and industry-specific examples of Good International Industry Practice. IFC has developed General EHS Guidelines and Industry Sector EHS Guidelines which provide guidance to users on EHS in specific industry sectors. On complex projects like NSRP, multiple industry-sector guidelines are applicable per the list below:

• General Environmental, Health, and Safety (EHS) Guidelines. April 30, 2007 • EHS Guidelines for Petroleum Refinering. April 30, 2007 • EHS Guidelines for Large Volume Petroleum-based Organic Chemicals Manufacturing. April

30, 2007 • EHS Guidelines for Petroleum-based Polymers Manufacturing. April 30, 2007 • EHS Guidelines for Crude Oil and Petroleum Product Terminals. April 30, 2007 • EHS Guidelines for Ports, Harbors, and Terminals. April 30, 2007 • EHS Guidelines for Thermal Power Plants. December 19, 2008.

The EHS Guidelines contain the performance levels and measures that are generally considered to be achievable in new facilities by existing technology at reasonable costs. Application of the EHS Guidelines to existing facilities may involve the establishment of site-specific targets, with an appropriate timetable for achieving them. The applicability of the EHS Guidelines should be tailored to the hazards and risks established for each project on the basis of the results of an environmental assessment in which site-specific variables, such as host country context, assimilative capacity of the environment, and other project factors, are taken into account. The applicability of specific technical recommendations should be based on the professional opinion of qualified and experienced persons.

When host country regulations differ from the levels and measures presented in the EHS Guidelines, projects are expected to achieve whichever is more stringent. If less stringent levels or measures than those provided in these EHS Guidelines are appropriate, in view of specific project circumstances, a full and detailed justification for any proposed alternatives is needed as part of the site-specific environmental assessment. This justification should demonstrate that the choice for any alternate performance level is protective of human health and the environment. 2.8 PROJECT STANDARDS The NSRP Project and associated facilities are designed according to the more stringent environmental standards, and aim to minimize emissions to air, water and land. These requirements will be compliant with Vietnamese legislation and international standards including the IFC (International Finance Corporation) Environmental, health, and Safety Guidelines and they will respect the international conventions ratified by the Government of Vietnam. 2.8.1 Air Quality

2.8.1.1 Ambient Air Quality Standards

Ambient Air Quality Standards (AAQS) for Vietnam are set out in QCVN 05:2009/BTNMT National Technical Regulation on Hazardous substances in ambient air and QCVN 06:2009/BTNMT National Technical Regulation on ambient air quality.


35

The IFC Guidelines are based on the World Health Organisation (WHO) Air Quality Guidelines (Global Update, 2005).

The IFC guidelines expects facilities and projects to avoid, minimize, and control adverse impacts to human health, safety and the environment from emissions to air but goes on to acknowledge that in some instances this is not possible. The generation and release of emissions should be managed through a combination of energy use efficiency, process modification, selection of fuels and other materials, the processing of which may result in less polluting emissions and the application of emissions control techniques. Due consideration for the regulatory requirements, significance of the course, location of the emitting facility relative to other sources, location of sensitive receptors, existing ambient air quality, and potential for degradation of the airshed from a proposed project and the technical feasibility and cost effectiveness of the available options for prevention, control and release of emissions.

All emissions from the project will be limited in order to meet the requirements of the IFC and Vietnamese Standards. IFC states in their General Guideline that "Emissions do not result in pollutant concentrations that reach or exceed relevant ambient quality guidelines and standards by applying national legislated standards, or in their absence, apply WHO guidelines." Therefore, the Project applies the Vietnamese Standards as Project Standards which are shown in Table 2.3.

Table 2.3 Ambient Air Quality Standards (µg/m3)

Parameter Averaging Period Vietnamese Ambient Air

Quality Standards 1

Sulphur Dioxide (SO2) 1 hour 24 hour 1year

350 125 50

Carbon Monoxide (CO) 1 hour 8 hour 24 hours

30,000 10,000 5,000

Nitrogen Dioxide (NO2) 1 hour 24 hours 1year

200 100 40

Ozone (O3) 1 hour 8 hour 24 hour

180 120 80

Suspended Dust (TSP) 1 hour 24 hour 1 year

300 200 140

Dust ≤ 10µm (PM10)

24 hour 1 year

150 50

Lead (Pb) 24 hour 1 year

1.5 0.5

Notes: 1. QCVN 05:2009/BTNMT: National technical regulation on ambient air quality


36

Impacts should be estimated through qualitative or quantitative assessments by the use of baseline quality assessments and atmospheric dispersion models to assess ground level concentrations. 2.8.1.2 Source Emissions Standards The Vietnamese standards for the control of hazardous substances in the air are set out in QCVN 19:2009/BTNMT for inorganic gases, QCVN 20:2009/BTNMT for organic substances and QCVN 22:2009/BTNMT Emission standards for Thermal Power Industry. Applicable IFC Standards can be found in the Guidelines for Petroleum Refining, Petroleum based Polymer manufacturing, Thermal Power Plants, and Large Volume Petroleum based Organic Chemicals Manufacture. IFC Standards will take precedence, except for where the Vietnamese Standards are the more stringent, or where there is no IFC Standard for a substance which is regulated by Vietnamese Standards. These limits are summarized in Table 2.4 along side the corresponding Vietnamese standards. In case of variations between IFC and Vietnamese standards the more stringent level will be applied.

Table 2.4 Point Source Emission Standards (1)

Pollutants

Unit QCVN max allowable concentration

(mg/Nm3)(2)

Applicable IFC Guideline values

(mg/Nm3)(3)

Project standard

(mg/Nm3)(2)

Remarks

PM 1. For Refinery Boilers – Considering Non Degraded Airshed

(a) Fuel-Natural gas/other gases 42,5 Not Applicable 42,5 Dry gas@3% excess O2

(b) Fuel-Liquid> 50MWth to <600MWth

127,5 50 50 Dry gas@3% excess O2

(c) Fuel- Liquid > 600MWth 127,5 50 50 Dry gas@3% excess O2

2. For Gas Turbine – Considering Non Degraded Airshed

(a) Fuel-Natural gas (NG) >50MWth 42.5 Not Applicable 42.5 Dry gas@15% excess O2

(b) Fuel-Other than NG>50MWth 127.5 50 50 Dry gas@15% excess O2

3. For other process Heaters under Refinery Complex

(a) General Process Heaters/sources 160 (Dust in smoke)

40 for Dust containing Silica

50 50 Dry gas@3% excess O2

(b) Sulphur recovery Units 160 (Dust in smoke) 50 50 Dry gas@3% excess O2

4. For other Process Heaters under Large Volume Petroleum Based Organic Chemical Manufacturing

All Fuel 160 (Dust in smoke)

40 for dust containing Silica

20 20 Dry gas@3% excess O2

SO2 1. For Refinery Boilers – Considering Non Degraded Airshed

(a) Fuel-Natural gas 255 Not Applicable 255 Dry gas@3% excess O2

(b) For other gaseous fuel 400 400 400 Dry gas@3% excess O2

(c) Fuel-Liquid> 50MWth to<600MWth 400 900 (Lower value) 400 Dry gas@3% excess O2

(d) Fuel- Liquid> 600MWth 400 200 (Lower value) 200 Dry gas@3% excess O2

2. . For Gas Turbine – Considering Non Degraded Airshed

(a) Fuel-Natural gas (NG) >50MWth 255 Not Applicable 255 Dry gas@15% excess O2

(b) Fuel-Other than NG>50MWth 425 Use of 1% or less sulphur fuel

400

(Use of 1% or less fuel)

Dry gas@15% excess O2


37

Pollutants


(mg/Nm3)(2)


(mg/Nm3)(3)

Project standard

(mg/Nm3)(2)

Remarks


(a) General Process Heaters/sources 400 500 400 Dry gas@3% excess O2

(b) Sulphur recovery Units 400 150 150 Dry gas@3% excess O2


All Fuel 400 100 100 Dry gas@3% excess O2

NOx 1. For Refinery Boilers – Considering Non Degraded Airshed

(a) Fuel-Natural gas/other gases 212,5 240 212,5 Dry gas@3% excess O2

(b) Fuel-Liquid> 50MWth to <600MWth

510 400 400 Dry gas@3% excess O2

(c) Fuel- Liquid > 600MWth 510 400 400 Dry gas@3% excess O2

2. For Gas Turbine – Considering Non Degraded Airshed

(a) Fuel-Natural gas (NG) >50MWth 212.5 51 51 Dry gas@15% excess O2

(b) Fuel-Other than NG>50MWth 510 152 152 Dry gas@15% excess O2


(a) Solid fuels 680 450 450 Dry gas@3% excess O2

(b) Liquid and gaseous fuels 680 450 450 Dry gas@3% excess O2


All Fuel 680 300 300 Dry gas@3% excess O2

CO For all Emission sources 800 - 800 Maximum allowable concentration

Vanadium For all Emission sources - 5 5 Dry gas@3% excess O2

Nickel For all Emission sources - 1 1 Dry gas@3% excess O2

H2S For Refinery Emission sources 6 10 6 Maximum allowable concentration

For Unit associated with Organic Chemical manufacturing

6 5 5 Dry gas@273K, 101Kpa (1 atm), 6% O2 for Solid fuel & 3% for gaseous and liquid fuel

HCl For Refinery Emission sources 50 - 50 Maximum allowable concentration



Benzene For all Emission sources 5 5 5 Maximum allowable concentration

1,2 Dichloroethane


- 5 5 Dry gas@273K, 101Kpa (1 atm), 6% O2 for Solid fuel & 3% for gaseous and liquid fuel

Vinyl Chloride (VCM)

For Refinery Emission sources 20 - 20 Maximum allowable concentration



Ammonia For Refinery Emission sources 50 - 50 Maximum allowable concentration



VOCs For Unit associated with Organic Chemical manufacturing



38

Pollutants


(mg/Nm3)(2)


(mg/Nm3)(3)

Project standard

(mg/Nm3)(2)

Remarks

Heavy Metals For Unit associated with Organic Chemical manufacturing

- 1.5 1.5 Dry gas@273K, 101Kpa (1 atm), 6% O2 for Solid fuel & 3% for gaseous and liquid fuel

Mercury & Compounds



Formaldehyde For Refinery Emission sources 20 - 20 Maximum allowable concentration


20 0.15 0.15 Dry gas@273K, 101Kpa (1 atm), 6% O2 for Solid fuel & 3% for gaseous and liquid fuel

Ethylene For Unit associated with Organic Chemical manufacturing


Ethylene Oxide




Hydrogen Cyanide



Organic sulphide and Mercaptans




Phenols, cresols and xylos (as phenol)




Dioxins/Furans ng TEQ/Nm3



Notes: 1. Point source emission standards are based on as follows:

1. QCVN 19:2009/BTNMT National Technical Regulation on Industrial Emission of Inorganic Substances and Dusts 2. QCVN 20:2009/BTNMT National Technical Regulation on Industrial Emission of Organic Substances 3. QCVN 22:2009/BTNMT National Technical Regulation on Emission of Thermal Power Industry 4. IFC Guidelines values for Petroleum Refining Facilities. 5. IFC Guidelines values for for Large Volume Petroleum-based Organic Chemical Manufacture 6. IFC Guidelines values for Thermal Power Plants 7. IFC Guidelines values for Petroleum-based Polymers Manufacturing

2. Nm3 @ 0oC, 101Kpa (1 atm) 3. Nm3 @ 25oC, 101Kpa (1 atm)


39

2.8.1.3 Occupational Exposure Limits Predicted ground level concentrations of pollutants may be compared against occupational exposure limits for guidance as to their relative safety.

• Vietnamese legislation provides limits for in plant pollution in Decision No.3733/2002/QĐ-BYT, 21 Standards for hygiene, 5 rules and 7 parameters for labour hygiene.

• The IFC EHS Guidelines refer to the occupational exposure limits for inside the plant boundary set by the American Conference of Government Industrial Hygienists (ACGIH). There are Threshold Limit Values (TLVs) for 8 hour and 15 minute exposure levels.

Threshold Limit Values for the main relevant pollutants are listed in Table 2.5.

Table 2.5 Occupational Exposure Limits

Pollutants

Occupational Exposure Limits based on Decision

No.3733/2002/QĐ-BYT -2002

Maximum Average Concentration

(mg/m3)

Occupational Exposure Limits based on IFC

Guidelines-2008


(ppm)

Project Standards


STEL1 TWA2 STEL1 TWA2 STEL1 TWA2

H2S 15 10 15 10 15 mg/m3 10 mg/m3

SO2 10 5 5 2 10 mg/m3 5 mg/m3

NO 20 10 - 25 20 mg/m3 10 mg/m3

NO2 10 5 5 3 10 mg/m3 5 mg/m3

Particulates - - Respirable – 3 Inhalable - 10

Respirable – 3 Inhalable - 10

CO 40 20 - 25 40 mg/m3 20 mg/m3

O3 0.2 0.1 - 0.05-0.2 0.2 mg/m3 0.1 mg/m3

Benzene 15 5 2.5 0.5 2.5 ppm 0.5 ppm

Toluene 300 100 - 20 300 mg/m3 92 mg/m3

Xylene 300 100 150 100 300 mg/m3 100 mg/m3

Notes:

1. Short Term Exposure Limit (STEL), usually 15 minutes

2. Time Weighted Average (TWA), the recommended limit a person can be exposed to over a period of time without causing harm, is usually 8 hours.

IFC standards will take precedence, except for where the Vietnamese Standards are the more stringent, or where there is no IFC Standards for a substance which is regulated by Vietnamese Standards.


40

2.8.1.4 Emergency Response Planning Guidelines

Ground level concentrations under emergency conditions should be compared to the Emergency Response Planning Guideline (ERPG) values developed by the American Industrial Hygiene Association (AIHA). Emergency Response Planning Guideline Values (2009) listed in Table 2.6.

Table 2.6 Emergency Response Planning Guideline Values (2009)

Species ERPG-1

ppm ERPG-2

ppm ERPG-3

ppm

H2S 0.1 30 100 SO2 0.3 3 15

Benzene 50 150 1000

NO2 1 15 30 NH3 25 150 750 CO 200 350 500

ERPG-1 is the maximum airborne concentration below which it is believed that nearly all individuals could be exposed for up to 1 hour without experiencing other than mild transient adverse health effects or perceiving a clearly defined, objectionable odour. ERPG-2 is the maximum airborne concentration below which it is believed that nearly all individuals could be exposed for up to 1 hour without experiencing or developing irreversible or other serious health effects or symptoms which could impair an individual's ability to take protective action. ERPG-3 is the maximum airborne concentration below which it is believed that nearly all individuals could be exposed for up to 1 hour without experiencing or developing life-threatening health effects. 2.8.2 Wastewater Quality

Industrial wastewater discharged from the production process will be treated in an industrial wastewater treatment plant and shall comply with the standards as outlined before discharge into the receiving environment.

Clean effluents with low levels of contamination such as storm water run-off from non-process units, complying with the standards outlined below, will be discharged directly to sea. 2.8.2.1 Industrial Water Discharge Standard Vietnamese Standard QCVN 24:2009/BTNMT has been established to control industrial wastewater discharge. However considering that the Project will follow the international standards, the IFC – EHS Guidelines will be applied, except for where the Vietnamese Standards are the more stringent, or where there is no IFC – EHS Guidelines available for a substance which is regulated by Vietnamese Standards. Process discharge water and sanitary water will be treated in ETP to meet Project Standards in Table 2.7.


41

Table 2.7 Industrial Wastewater Discharge Standard

Notes:

1. Assumes an Integrated Petroleum Refinery

2. The effluent concentration of nitrogen (total) is up to 40 mg/l in processes that include hydrogenation.

3. From Vietnamese Standard QCVN 24:2009/BTNMT. Limit Values from Column B, factor applied where applicable. These limits are valid for discharges of industrial wastewater into water bodies used for navigation, irrigation purposes or for bathing, aquatic breeding and cultivation, etc only. For a full list of pollutants limited by QCVN 24:2009/BTNMT.

4. NSRP Project will comply with Vietnamese Standard 24:2009/BTNMT for discharge from sea water cooling system

5. COD as analysed by Chrome method as specified on ISO 6060-1989

Pollutants Units Vietnamese Standards – Max Limit Value 3

IFC EHS Guideline Values Project Standards Petroleum

Refining Facilities1

Petroleum –based polymer Manufacturing

Large Volume Petroleum-based

Organic chemicals Manufacturing

pH S.U 5.5-9 6-9 6-9 6-9 6-9

BOD5 mg/l 45 30 25 25 25

COD5 mg/l 90 150 150 150 90

TSS mg/l 90 30 30 30 30

Cadmium (Cd) mg/l 0.009 - 0.1 0.1 0.009

Hydrocarbons mg/l 4.5 (mineral oil and fat) or 18 (animal –

vegetable oil)

10 (oil and grease)

10 (oil and grease) 10 (oil and grease) 4.5 (mineral oil

and fat) or 10 (animal –

vegetable oil) Chromium (total) mg/l 0.9 0.5 0.5 0.5 0.5

Chromium (Hexavalent)

mg/l 0.09 0.05 0.1 0.1 0.05

Copper (Cu) mg/l 1.8 0.5 0.5 0.5 0.5

Zinc (Zn) mg/l - - 2 2 2

Iron (Fe) mg/l 4.5 3 3 3 3

Cyanide Total (Free)

mg/l

-

0.1

0.1

0.1

0.1

Cyanide (CN-) mg/l 0.09 1 1 1 0.09

Lead (Pb) mg/l 0.45 0.1 0.5 0.5 0.1

Nickel (Ni) mg/l 0.45 0.5 0.5 0.5 0.45

Mercury (Hg) mg/l 0.009 0.02 0.01 0.01 0.009

Vanadium mg/l - 1 1 1 1

Phenol mg/l 0.45 0.2 0.5 0.5 0.2

Benzene mg/l - 0.05 0.05 0.05 0.05

Benzo(a)pyrene mg/l - 0.05 0.05 0.05 0.05

Vinyl Chloride (VCM)

mg/l - - 0.05 - 0.05

Dicloroethane mg/l - - 1 1 1

Adsorbable organic halogens (AOX)

mg/l - - 1 0.3 0.3

Sulphide mg/l 0.45 1 1 1 0.45

Total Nitrogen mg/l 27 102 10 10 10

Total Phosphorus

mg/l 5.4 2 2 2 2

Temperature oC <404 Max increase <=3

Max increase <=3

Max increase <=3 - <40oC at final outfall

discharge - Max increase <=3 at the edge of mixing zone


42

2.8.2.2 Sanitary Water Discharge

Vietnam technical regulation on sanitary wastewater is regulated at QCVN 14:2008/BTNMT.

IFC General EHS Guidelines states “If sewage from the industrial facility is to be discharged to surface water, treatment to meet national or local standards for sanitary wastewater discharges or, in their absence, the indicative guideline values applicable to sanitary wastewater discharges shown in Table 1.3.1”. Considering this statement, the Project applies the National technical regulation on sanitary wastewater QCVN 14:2008/BTNMT as Project Standards which are shown in Table 2.8.

Table 2.8 Sanitary Water Discharge Standards

Pollutants Units Vietnamese Requirement

QCVN 14:2008/BTNMT

Max Limit Value

pH S.U. 5-9

BOD (20 Deg C.) mg/l 50

Total Suspended Solids (TSS) mg/l 100

Total Dissolved Solids (TDS) mg/l 1,000

Total of surface active substances mg/l 10

Hydrocarbon including fat and mineral oil mg/l 20

Ammonical Nitrogen mg/l 10

Nitrate Nitrogen mg/l 50

Sulphide (as H2S) mg/l 4

Phosphates as P mg/l 10

Total Coliform bacteria MPN/ 100 ml 5,000*

Notes: (*) Maximum limit value 400MPN/100ml in IFC coliform standard is not applied because IFC guidelines enable Owner

to apply national standards. That is why the maximum limit value of 5,000MPN/100ml in QCVN 14:2008/BTNMT is applied.

In fact, sanitary effluent from the Complex will be treated together with industrial effluent. Based on the MONRE official letter No. 238/QLCT & CTMT of 9th September 2009, the treated wastewater from Nghi Son Refinery and Petrochemical Complex is required to comply with QCVN 24:2009/BTNMT for industrial effluent.

The Sanitary effluent in Jetty area will be treated separately and required to comply with QCVN 14:2008/BTNMT before it is mixed with other effluents and discharged to the sea. 2.8.2.3 Seawater Cooling Discharge Standard Cooling water is not considered production wastewater, as the system is not used in a technological process, only in thermal exchange. Vietnamese standards do not regulate cooling water discharge temperature. However, the project will strictly comply with Vietnamese Standard QCVN 24:2009/BTNMT which requires that the temperature of cooling water discharged into a received environment is equal to or lower than 40ºC.


43

The IFC General EHS Guidelines specifies that cooling methods should be used to reduce the temperature of wastewater from utilities operations, to ensure the discharge water temperature does not result in a maximum temperature increase greater than 3ºC at the edge of a scientifically established mixing zone, which takes into account ambient water quality, receiving water use, potential receptors and assimilative capacity. 2.8.2.4 FGD Seawater Discharge Standard After the cooling process, one part of seawater cooling is used for FGD system to treat flue gas. This water will be treated to meet industrial water discharge standards in Table 2.7. 2.8.2.5 Demineralised Water Discharge Standard This water will be neutralised and meet industrial water discharge standards in Table 2.7. 2.8.3 Noise The general noise level requirements for NSRP Project are as follows:

• The increase in background levels should be no more than of 3 dB at the nearest receptor location off-site.

• For each off site receptor the more stringent standard will apply. Where there are no receptors nearby, a suitable limit shall be determined for the site boundary.

• Additional noise limits may be applied independently by national/local authorities in order to protect the environment.

NSRP noise limits are the most stringent of Vietnamese and IFC requirements (Table 2.9).

Table 2.9 Noise Limits (dBA)

Receptor

Vietnamese Noise Standards

TCVN 5949:1998

IFC Noise Level Guidelines

Project Noise Standards

Time One Hour Laeq (dBA)

One Hour LAeq (dBA)

06:00 –

18:00

18:00 –

22:00

22:00 –

06:00

07:00 -

22:00

22:00 -

07:00

06:00 –

18:00

18:00 –

22:00

22:00 –

06:00

Quiet Areas, including hospitals, libraries, schools

50 45 40 - - 50 45 40

Residential Areas, hotels, offices

60 55 50 55 45 55 45

Residential areas intermingled with trade, service and manufacturing activities

75 70 50 70 70 70 50

Industrial, Commercial - - - 70 70 70


44

Noise limits for different working environments are provided in Table 2.10.

Table 2.10 Noise Limits for Various Working Environments

Location / Activity Equivalent Level LAeq 8 Hrs in dB(A)

(TCVN 3985:1999)

Maximum LAmax. Fast in dB(A)

Heavy Industry (no demand for oral communication) 85 110 Light industry (decreasing demand for oral communication) 50 - 65 110

Open offices, control rooms, service counters or similar 45 - 50 -

Individual offices (no disturbing noise) 45 - 50 - Classrooms, lecture halls 35 - 40 - Hospitals 30 - 35 40

2.8.4 Vibration

Vibration caused by the construction and operation of the facility is regulated by TCVN 6962:2001. The allowable limits for vibration generated by light industrial facilities in nearby residential areas are shown in Table 2.11.

Table 2.11 Allowable Vibration Limits (TCVN 6962:2001)

Receptor

Vibration limits in construction activity

dB(A)

Vibration limits in production activity

dB(A) 07:00 – 19:00 19:00 – 07:00 06:00 – 18:00 19:00 – 06 :00

Quiet Areas, including hospitals, libraries, schools

75 Basic Level 1 60 55

Residential Areas, hotels, offices 75 Basic Level 1 65 60

Residential areas intermingled by trade, service and manufacturing area

75 Basic Level 1

70 65

Notes: 1. Basic level is vibration level measured when facilities are not working in the assessed area

2.9 PERMIT REQUIREMENTS (NSRP) Under the Government approval of the NSRP Project, authorizations to carry out some activities must be given regarding environmental protection, safety issues and fire fighting requirements. These authorizations are listed below: Environment

• Decision of MONRE in approval of Environmental Impact Assessment Report (EIA)

• License in surface water exploitation issued by MONRE

• License in discharging water issued by MONRE

• License of registration in hazardous solid waste discharging issued by MONRE


45

• Decision of Thanh Hoa People’ Committee in approval of Oil Spill Contingency Plan (OSCP)

• Certificate for SPM and Jetties in sufficient environment protection condition issued by MONRE Safety

• License of registration of radiation source issued by Ministry of Science and Technology

• License of operation of radiation source issued by Ministry of Science and Technology

• License in buying/selling of hazardous chemicals belonged to the list of restricted trading chemicals issued by Ministry of Industry and Trading

• License of registration in regularly using or suddenly buying of high toxicants issued by Thanh Hoa Province’s Police

• Certificates issued by Certifying Agency in safety technical verifying/auditing of machines and equipments requested in Decision of Ministry of Industry no 136/2004/QD-BCN

• Certificates issued by Department of Trading and Industry in registration of using of machines, equipments and toxic chemicals required in specific industrial safety, requested in Decision of Ministry of Industry no 136/2004/QD-BCN

• Certificates issued by Certifying Agency in verifying/auditing of machines, equipments and materials requested in Circular of Ministry of Labor, War, Invalids and Social Affairs no 04/2008/TT-BLDTBXH

• Certificates issued by Department of Trading and Industry in registration of using of machines, equipments and toxic chemicals required in strict labor-safety, requested in Circular of Ministry of Labor, War, Invalids and Social Affairs no 04/2008/TT-BLDTBXH

Fire fighting

• Decision of Fire Bureau in approval of fire fighting detection and protection design of FEED phase

• Decision of Fire Bureau in approval of fire fighting detection and protection design of EPC phase

• Certificate for SPM and Jetties in sufficient fire fighting detection and protection condition issued by Fire Bureau

• License of Fire Bureau in approval of sufficient fire fighting detection and protection condition. 2.10 PROJECT HSES PLANS 2.10.1 EPC Ccontractor HSES Plans EPC Contractor has the responsibility to prepare their HSES Plans for the construction phase, but not be limited to the following:

• HSES Management and Responsibilities.

• Selection Procedures for Contractor personnel

• Communication

• Training

• HSES Supervision


46

• Risk Management

• Environmental

• Waste Management

• Performance Monitoring

• Pre-Construction HSES Planning

• Welfare

• Fire Prevention and Protection

• Emergency Response Procedures

• Personal Protection Equipment

• Drugs and Alcohol Policy

• Security

• Reporting of Accidents and Incidents

• Undertaking 2.10.2 NSRP HSES Plans NSRP has the responsibility to prepare the HSES Plans for both the construction and operation phases, but not be limited to the following:

• HSES Management Procedure

• Emergency Response Plan

• Air Quality Management Plan

• Noise Management Plan

• Soil Contamination Management Plan

• Surface Water Management Plan

• Groundwater Management Plan

• Terrestrial Flora/Fauna Management Plan

• Marine Habitat Management Plan

• Coral Management Plan

• Waste Management Plan

• Incident and Accident Management Plan

• Social Impact Management Plan

• Employment Management Plan

• Grievance Management Plan

• Stakeholder Engagement Plan

• Resettlement Framework

Most of these plans are presented in the ESIA report but they will be developed further in the construction and operation phases.


47

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT PROJECT DESCRIPTION NGHI SON REFINERY AND PETROCHEMICAL COMPLEX

Final Report

48

Section 3.

PROJECT DESCRIPTION 3.1 SITE DESCRIPTION The Nghi Son Refinery and Petrochemical (NSRP) Project is located in the Nghi Son Economic Zone (NSEZ), Tinh Gia District, Thanh Hoa Province, Vietnam. The Project site is 200 km south of Hanoi and about 80 km north of Vinh City (Nghe An Province). The total onshore area is about 394 ha and the offshore area is about 259 ha (Figure 3.1) and they include: 1. Onshore area:

• Main Refinery plant (Area B, 328 ha)

• Onshore pipeline right-of-way (ROW) (Area E, 30 ha)

• Marine harbour (Area J, 36 ha) 2. Offshore area:

• Export berths, access channel, breakwater and intake channel (193 ha)

• Crude oil pipeline (35 ha)

• Single point mooring (SPM) (31 ha) 3.1.1 Plant Location The main component of the NSRP Project is the plant site where process units of the Refinery and Petrochemical Complex will be located. The plant site is 328 ha (Figure 3.2), and is located in an area that includes three communes: Mai Lam, Hai Yen and Tinh Hai. The elevation of the existing ground varies from +0.5m to +3.5m (National Datum). A small section of the plant site is separated by Coc Mountain which has a peak elevation of +83 m. The majority of the land that is planned to be occupied by the NSRP Complex is agricultural land and homesteads. The plant site is contiguous to:

• In the North, the Tinh Hai and Mai Lam Communes;

• In the South, the populated area of Hai Yen Commune;

• In the East, the populated area of Hai Yen Commune (Area C);

• In the West, Provincial Road 513 connects the National Highway 1A to Nghi Son integrated Port. The Cam and Chuot Chu Mountains are south of Provincial Road 513.

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT PROJECT DESCRIPTION FOR NGHI SON REFINERY AND PETROCHEMICAL COMPLEX Final Report

49

Figure 3.1 Location of Nghi Son Refinery and Petrochemical Complex


50

Figure 3.2 Location of Plant Site - Nghi Son Refinery and Petrochemical Complex

Table 3.1 Locations of main area of NSRP

Area Point Latitude N Longitude E

Refinery Plant (Area B)

C 19o 21’ 17” 105o 45’ 33”

F 19o 21’ 31” 105o 46’ 49”

G 19o 22’ 18” 105o 46’ 39”

H 19o 22’ 10” 105o 45’ 53”

Onshore Pipeline (Area E)

V 19o 22’ 07” 105o 46’ 41”

U’ 19o 22’ 13” 105o 47’ 11”

G’ 19o 22’ 24” 105o 47’ 08”

G 19o 22’ 18” 105o 46’ 39”

Marine Harbour (Area J)

T 19o 21’ 38” 105o 47’ 25”

G’ 19o 22’ 24” 105o 47’ 08”

R 19o 22’ 25” 105o 47’ 14”

S 19o 21’ 41” 105o 47’ 33”

SPM 19o 21’ 59.48” 106o 05’ 57.57”

The Project land acquisition affected a total of 2,743 households (HHs) in the three communes, in which 830 HHs were identified for relocation to new resettlement sites, namely Xuan Lam-Nguyen Binh, Tinh Hai and Mai Lam. When the Project enters its operation phase, the NSRP will be surrounded by agricultural and residential areas of Hai Yen, Mai Lam and Tinh Hai communes. There are local houses next to and close to the plant’s boundaries towards the east and north. The NSRP-LLC proposed to the Vietnamese Government to relocate all houses (in total about 700 households) located on the east side (area C) of the plant before the Project enters the operation phase. More specifically, in order to increase safety in the area during the construction and operation phases, and to acquire the space required for temporary storage yards for equipment and materials to be gathered during the


51

construction phase, NSRP proposed to the Government and the People’s Committee of Thanh Hoa Province to provide clearance for area C. To date, an official announcement has not yet been delivered. Furthermore, according to the Master Plan of NSEZ for the future development to 2025 (Figure 3.3), all local houses (no official data exists for the households) in close proximity to the plant will be relocated to an area further from the plant. Once completed, the closest distance from the plant to the nearest residential area will be about 1.7 km towards the north. The north side of the plant is 1.2 – 1.5 km away from the Lach Bang River system. The main aquaculture area of the Tinh Gia District is located along the Lach Bang banks. The Dap Ngoai creek starts in the Chuot Chu Mountains and flows to Lach Bang River. Currently it runs across the plant site; however, it is scheduled to be filled in. Six to seven kilometers south of the Plant, are the Yen Hoa River springs from the Xuoc Mountain and Bang Me Mountain which belong to the Hai Thuong and Hai Ha Communes in the Nghi Son harbour area (now the PTSC port). In the Project area, Provincial Road 513 connects the PTSC Port to National Road 1A, a or 10km. Communal roads also run nearly parallel to the seashore from the Hai Yen Commune to the Tinh Hai and Hai Binh Communes. Within a 7.5 km radius of the Project site, there are (i) a paper powder mill located in the northern part of Mai Lam Commune, and (ii) the Nghi Son Cement Factory, iii) the PTSC Port and iv) the Vinashin Shipyard in the region to the South, which belongs to the Hai Ha and Hai Thuong Communes. The Nghi Son Power Center, with a capacity of 1,800 MW, is being constructed on the opposite side of the PTSC Port.


52

LEGEND

1. Southern general port complex

2. Northern general port complex

2a. Cement / Oil Port

2b. Non-Tariff Port

3. Hon Me Port complex

4. Refinery and Petrochemical Complex

5. Nghi Son Cement Factory

6. Power Plant

7. Cong Thanh Cement Factory

8. Industrial Area 1

9. Industrial Area 2

10. Steel industrial Area

11. Shipyard

12. VINAXUKY automobile assembling plant

13. Planned Industrial Area

14. Kaolin Mining area

15. Beer plant Project

16. Industrial complex for repair of vessels

17. Terminal storage

18. Gasoline/oil depot

19. Non-Tariff zone 1

20. Metallurgy Industrial Park

21. Combination center area

22. Cultural center/ green area

23. Medical center

24. Educational center

25. Golf yard

26. Lach bang eco- tourism area

27. Hill No 84 tourist area

28. Khe Nhoi eco-resort area

29. Bien Son advanced eco-tourism area

30. Casino / resort Hon Mieng island

31. Advanced Tourist area - Hon Dot island

32. Cemetery area

33. Proposed Waste Disposal Site

34. Stop car service area

35. Military base

36. Slag dumping ground (power plant)

Figure 3.3 Overall plot plans for the future development to 2025 of the Nghi Son Economic Zone


53

3.1.2 Harbour Location The Nghi Son Harbour area will be located between the following geographical coordinates:

N 19° 22' 12”, E 105° 46' 12”, and N 19° 21' 18”, E 105° 48' 54”.

The harbour will be sited at the Refinery landfall on the eastern side of the plant and to the North of the existing jetty of the Nghi Son Cement Factory (Figure 3.4). The harbour site will be in front of the Petrochemical Complex. The total onshore area of the harbour is about 36 ha (area J in Figure 3.2). Product jetties / service berths for exporting products are located to the East of the plant, adjacent to the beach. The berth area belongs to the Trung Hau Ward of Hai Yen Commune. The harbour access route will run in an east-northeast direction passing about 5.5 km from the offshore islands of the Hon Me Archipelagos.

Figure 3.4 General Lay Out of Marine Facilities

3.1.3 SPM Location The offshore SPM is located at coordinates N 19° 21’ 59.48”; E 106° 05’ 57.57” with a depth of 27m on the eastern side of Hon Me Island, about 33.5 km from the harbour site (Figure 3.4). 3.1.4 Crude Oil & Product Export Pipeline A pipeline system will be built to transport the crude oil import from the SPM to the Refinery, and to send the refined products from the refinery to the product jetties. A 35 km long double crude oil pipeline will connect the SPM to the crude oil tank farm of the Refinery. Approximately 33.5 km of the line will be laid sub-sea with the remaining portion to be built onshore. The onshore crude oil pipeline route will be housed in the same pipeline corridor of the product pipeline system.


54

The product export pipelines will run along the northern 350 m corridor (area E in Figure 3.2) connecting the product tank farm and product jetties. 3.2 REFINERY AND PETROCHEMICAL COMPLEX DESIGN The Nghi Son Refinery and Petrochemical (NSRP) Project is designed to process 200,000 barrels-per-stream-day (BPSD) of 100% Kuwait Export Crude (KEC) oil. A maximum of 0.5% (by volume) water is assumed to be present in the crude. Per design configuration, NSRP can process up to 100% of KEC oil, or a mixture of 85% KEC oil and 15% of Murban crude oil. The design will incorporate features for optimizing energy utilisation and heat recovery that are consistent with product fractionation, as indicated in Section 3.3.1. All technologies which will be utilized by the NSRP are state-of-the-art and are currently implemented worldwide in the petroleum refining and petrochemical industry. The Project has been designed to comply with the most stringent of Vietnamese Standards and World Bank/IFC guidelines. The technologies employed for pollution abatement are as follows:

• State-of-the-art Flue Gas Desulphurization (FGD) for boiler flue gases.

• Residue Fluid Catalytic Cracking (RFCC) CO Incinerator.

• RFCC Flue Gas Scrubber (De-SOx).

• RFCC flue gas DeNOx.

• SCOT Tail Gas Treatment in the Sulphur Recovery Unit (SRU) to attain sulphur recovery

• Use of Low NOx and Ultra-Low NOx burners for process heaters and hydrogen manufacturing unit (HMU).

• Tertiary treatment of aqueous effluents.

• Layout and location of effluent discharge sea outfall pipeline based on computer modeling for optimum dispersion of the thermal plume.

The Refinery capacity is based on an average of 8,320 hours operation per year giving an operating factor of 0.95. The target operating factor will be 0.97. The design of NSRP includes all process units, utility facilities, offsite and infrastructure facilities (Figure 3.5).


55

Figure 3.5 Nghi Son Refinery and Petrochemical Complex Plot Plant


56

The Refinery and Petrochemical Complex will consist of 19 licensed process units by international suppliers (Figure 3.6 and Table 3.2).

Figure 3.6 Licensed Process Units

Table 3.2 Process Units and Designer/Licensor Supplier

No. Process unit Designer/Licensor

Refinery Process Units

1 Crude Distillation Unit (CDU) Foster Wheeler

2 LPG Recovery Unit (LRU) Foster Wheeler

3 LPG Treatment Unit (LTU) UOP

4 Kerosene Hydrodesulphuriser (KHDS) Axens

5 Gas Oil Hydrodesulphuriser (GOHDS) Axens

6 Residue Hydrodesulphuriser (RHDS) Chevron Lummus

7 Residue Fluid Catalytic Cracker (RFCC) Axens

8 RFCC Light Gasoline Treater Unit UOP

9 RFCC LPG Treater Unit UOP

10 Propylene Recovery Unit (PRU) Axens

11 Indirect Alkylation Unit (InAlk) UOP

Petrochemical Process Units

12 Polypropylene unit (PPU) Misui Chemicals

13 Naphtha and Aromatics Complex (NAC) UOP

Hydrogen Units


57

No. Process unit Designer/Licensor

14 Hydrogen Manufacturing Unit (HMU) Foster Wheeler

15 Hydrogen Compression and Distribution system (HCDS) Foster Wheeler

Sulphur Processing Units

16 Sour Water Stripper unit (SWS) Foster Wheeler

17 Amine Regeneration Unit (ARU) Foster Wheeler

18 Sulphur Recovery Unit (SRU) JACOBS

19 Tail Gas Treating Unit (TGT) JACOBS

Source: Provided by NSRP LLC, June 2010.

The utility facilities include storage tanks for feedstock including intermediate and final products all with state of the art safety features. In addition, it is designed to meet the Refinery’s demands for cooling water, fuels, power, steam, water, chemicals instrument and plant air, inert gas, ETP, flare, etc. Offsite facilities include SPM, pipelines, jetties, and road tankers for loading and unloading feedstock and products. 3.3 REFINERY AND PETROCHEMICAL COMPLEX CONFIGURATION 3.3.1 Material Balance The overall material balance for the Nghi Son Refinery is based on the processing of 100% KEC oil feedstock with 200,000 BPSD (base case), equivalent to 9,660 kilo-tones per annum (KTPA) (Table 3.3).

Table 3.3 Overall Refinery Mass Balance for Base Case – RFCC Max Propylene Operation Mode

Parameters Output (Ton/day)

Crude Oil 27,867

Fuel Gas to Process Unit Furnaces 1,242

LPG to Export 104

LPG to Gas Turbines 555

LPG to Heat Recovery Turbines 115

Benzene 710

Paraxylene 1,974

Gasoline 92 RON 3,314

Gasoline 95 RON 3,314

Kerosene / Jet 1,707

Polypropylene 1,075

Diesel – Premium 6,357

Diesel – Regular 4,238

Fuel Oil to boilers and RFCC CO boiler 1,003

Carbon on RFCC Catalyst 805

Sulphur Product 717

Loss 637

Source: Provided by NSRP LLC, June 2010.


58

3.3.2 Nameplate Capacities for Process Units The nameplate capacities for individual process units have been determined based on:

• The annual material balances presented in section 3.3.1 plus consideration of appropriate on-stream factors – for determination of stream-days.

• Design margins – to allow for design uncertainties and operational flexibility.

The Refinery is required to operate continuously for a minimum period of four (4) years between major turnarounds, although some process units may require ‘interim’ shutdowns for catalyst change-out, etc. Based on the turnaround frequency and other factors, the design on-stream plant factor is 0.95 (8,320 hours per year). The design of the Nghi Son Refinery and Petrochemical Complex is based on established technologies whose performances are both predictable and well proven in operation, meaning that no significant variations are expected to be found between predicted performance and actual performance in the field. As a result, the operation of the Refinery – and hence the generation of income – is very unlikely to be constrained by an unexpected bottleneck in a part of the process scheme. However, +10% margin on capacity is included for design purposes. Operating flexibility is accounted for in two main ways:

• The specification of alternative operating cases/modes for specific process units (e.g. gasoline and propylene modes for the RFCC, and ‘start-of-run’ and ‘end-of-run’ cases for other catalytic units);

• The incorporation of design margins in the design of specific items of equipment or sub-systems (e.g. pump capacity) to provide sufficient flexibility for regulatory control and/or on-line maintenance.

Nameplate capacity of a process unit is defined on the conventional basis of barrels-per-stream-day (BPSD) measured at 15°C which represents actual maximum unit throughput when the unit is in full operation under design conditions. The main process unit capacities are presented in Table 3.4.

Table 3.4 Main Process Unit Capacities of Nghi Son Refinery and Petrochemical Complex

UNITS CAPACITY REMARKS

Daily (BPSD) Annual (KTPA)

Crude Distillation Unit (CDU) 200,000 9,660

LPG Recovery Unit (LRU) - 2,413

Saturated LPG Treater (LTU) 6,500 201

Kerosene Hydrodesulphuriser (KHDS) 20,000 872

Gas Oil Hydrodesulphuriser (GOHDS) 60,000 2,906

Residue Hydrodesulphuriser (RHDS) 105,000 5,695

Residue Fluid Catalytic Cracker (RFCC) 80,000 4,135


59

UNITS CAPACITY REMARKS

Daily (BPSD) Annual (KTPA)

RFCC LPG Treater 43,000 1,326

RFCC Light Gasoline Treater 24,000 888

Indirect Alkylation (InAlk) 21,500 707 Based on FEED

Naphtha Hydrotreater 54,100 2,130 Incl. raffinate recycle

Isomerisation (Penex) 23,400 843 Incl. DIH recycle

Catalytic Reformer (CCR) 39,700 1,615 Based on HN FEED

Aromatics (Benzene) - 248 Benzene product

Aromatics (Paraxylene) - 794 PX product

Polypropylene (PPU) 1,154 TPD 400 PP product

Hydrogen Manufacturing Unit (HMU) 195,800 Nm³/h 145 Hydrogen product (Note A)

Amine Regeneration Unit (ARU) 789 m³/h - Lean amine circulation (Note B)

Sour Water Stripper (SWS) – Train 1 184.4 m³/h - Sour water FEED (Note B)

Sour Water Stripper (SWS) – Train 2 90.2 m³/h - Sour water FEED (Note B)

Sulphur Recovery Unit (SRU) 3 x 320 TPD - Sulphur product (Note C)

Tail Gas Treating Unit (TGTU) 2 x 640 TPD - Note D

Source: FEED Doc. 3550-8110-PD-0005 provided by FWL on 28 December 2009 Notes

A. Expressed as 100% hydrogen. The centralized Hydrogen Compression and Distribution System (HCDS) distribute hydrogen to consumers.

B. Volumetric flow rate @ 15 °C. C. SRU has 3 x 40% trains (Σ 120%). D. TGT is part of the SRU and is configured as 2 x 80% trains.

The design capacities of the main process units have been established as follows:

1. Crude Distillation Unit (CDU) The nameplate capacity of the CDU is 200,000 BPSD which corresponds to the nameplate capacity of the Refinery. No additional design margin is included to cover, for instance, the handling of different feedstock or rerunning of off-spec products. 2. LPG Recovery Unit (LRU) The LPG Recovery Unit (LRU) processes feed streams from the CDU and several other units. The nameplate capacity for the unit (2,413 KTPA) is based on a summation of the various feed streams on the assumption that all units are operating at their design capacity, and considering differences between start-of-run and end-of-run. 3. Saturated LPG Treater Unit (LTU)


60

The nameplate capacity of this unit (6,500 BPSD) corresponds to the mixed LPG yield from the LRU. 4. Kerosene Hydrodesulphuriser Unit (KHDS) The nameplate capacity of the KHDS unit (20,000 BPSD) is based on processing all the straight-run kerosene produced by the CDU. 5. Gas Oil Hydrodesulphuriser Unit (GOHDS) The nameplate capacity of the GOHDS unit (60,000 BPSD) is based on processing all the straight-run gas oil produced by the CDU plus all the light cycle oil (LCO) produced by the RFCC. 6. Residue Hydrodesulphuriser Unit (RHDS) The nameplate capacity of the RHDS unit (105,000 BPSD) is based on processing the entire atmospheric residue produced in the CDU. However, since the RHDS unit has an annual catalyst replacement cycle during which atmospheric residue feed is stored, the selected nameplate capacity includes an adequate margin to permit drawdown of the stored feed over an extended period for co-processing with direct feed from the CDU. 7. Residue Fluid Catalytic Cracker Unit (RFCC) The nameplate capacity of the RFCC unit (80,000 BPSD) is set equivalent to the yield of atmospheric residue from the CDU less the conversion loss in the RHDS based on start-of-run conditions. Note that the nameplate capacity does not quite match the actual stream/day output of the RHDS because the RHDS nameplate capacity is marginally increased to account for downtime for catalyst regeneration. 8. RFCC LPG Treater The nameplate capacity of the RFCC LPG Treater (43,000 BPSD) corresponds to the production rate of amine treated mixed LPG from the RFCC gas plant when the RFCC is operating in maximum propylene mode. 9. RFCC Light Gasoline Treater The nameplate capacity of the RFCC Light Gasoline Treater (24,000 BPSD) corresponds to the production rate of light gasoline from the gasoline splitter in the RFCC when the RFCC is operating in maximum gasoline mode. 10. Polypropylene Unit (PPU) The nameplate capacity of the PPU corresponds to the design production rate of propylene from the propylene recovery section of the RFCC. The resultant polypropylene product output of 400 KTPA falls within the maximum capacity limit of a single train PPU.


61

11. Naphtha and Aromatics Complex (NAC) The design throughput of the NAC is based on the yield of fresh full-range naphtha from the naphtha stabilizer in the LPG Recovery Unit. This stream comprises straight-run naphtha from the CDU plus naphtha from the GOHDS and the RHDS units. This stream is fed to the Naphtha Hydrotreater (NHT) unit together with a raffinate stream recycled from the Aromatics Extraction (Sulpholane) unit. The resultant nameplate capacity of the NHT is 54,100 BPSD.

12. Hydrogen Manufacturing Unit (HMU) The determining case which establishes the nameplate capacity of the HMU is the upset scenario when the Catalytic Reformer (and hence the whole of the Aromatics Complex) is shutdown while the remainder of the Refinery, including the KHDS, GOHDS and RHDS units, are operating at a minimum throughput of 50% under end-of-run conditions. In this case, the HMU is the only source of hydrogen treat gas for the Refinery and the requirement is 195,800 Nm³/hr of hydrogen (on a 100% purity basis). During normal refinery operations at 100% throughput, the Catalytic Reformer provides a significant yield of hydrogen which allows the HMU to operate at approximately 75% of design capacity. 13. Indirect Alkylation Unit (InAlk) The nameplate capacity of the InAlk unit (21,500 BPSD) is set to match the yield of C4 from the C3/C4 Splitter in the RFCC unit when the RFCC is operating in maximum propylene mode. 14. Amine Regeneration Unit (ARU) The common ARU handles the circulating amine solvent demands of all amine absorbers/extractors within the Refinery with the exception of those located in the RFCC Complex (which are served by a separate RFCC amine system). The nameplate capacity (789 m3/h) is based on a summation of solvent demands defined by the designers of each absorber/extractor. 15. Sour Water Stripper Unit (SWS) The SWS is configured as two independent trains. The design feed rate of sour water to each train is based on a summation of the various sour water feed component streams plus a +10% capacity margin for SWS-1 and 30% margin for SWS-2 to allow for design uncertainty and to provide operating flexibility. 16. Sulphur Recovery Unit (SRU) The SRU is configured as three (3) parallel Claus trains. The overall sulphur production rate is based on a calculation of the sulphur yield from processing 200,000 BPSD of fresh KEC Oil plus an allowance for the additional sulphur yield from the RHDS unit due to co-processing of cold residue feed, less an allowance for sulphur ‘lost’ in products. The estimated theoretical yield of sulphur is 800 tons-per-day (TPD). The SRU is configured as 3 x 40% trains (i.e. 320 TPD each). The tail gas treating and incinerator section is configured as 2 x 80% trains (i.e. each train handles tail gas


62

equivalent to 640 TPD of sulphur production). Note that sulphur feed to the SRU arrives in the form of acid gases from both the common ARU and the ARU in the RFCC, plus acid gases from the SWS trains.

3.4 FEEDSTOCK AND PRODUCTS 3.4.1 Feedstock The feedstock of Nghi Son Refinery and Petrochemical Complex is 100% KEC Oil. The oil quality is good for refining. The KEC Oil specifications are presented in Table 3.5.

Table 3.5 Technical Characteristics of the KEC Oil

Parameters Unit Crude Balance*

Gravity API 29.9 30.2

Specific gravity 60/60 0.8765 0.8752

Density Kg/dm3 0.8760

K Factor 11.84

Sulfur WT% 2.65 2.64

Mercaptan Sulfur ppm 135.0

H2S ppm <1

Nitrogen ppm 930.0 956.2

Basic Nitrogen ppm 372.0 394.6

Con Carbon WT% 6.11 6.21

Ash WT% 0.00

Asphaltenes WT% 2.50

Wax Content WT% 3.80

Iron ppm 0.7

Nickel ppm 10.1 10.9

Vanadium ppm 31.1 31.5

Sodium ppm 3.3

Pour Pt. Deg C <-36

Salt PTB 10.5

Reid Vapor Pressure kPa 26.2

TAN mg OH/g 0.18

Water VOL% 0.000

Kin.Viscosity@

15.5oC

20oC

37.8oC

40oC

50oC

60oC

cSt

cSt

cSt

cSt

cSt

cSt

22.73

11.41

8.88

27.02

22.65

12.36

11.57

8.79

6.89

Source: FEED Doc. 3550-8110-PD-0003 REV D3 provided by NSRP on 28 December 2009 Note: (*) Analytical values are obtained from phases after crude oil distillation process.


63

3.4.2 Project Products Products of NSRP will consist of the following:

• Liquefied Petroleum Gas (LPG)

• Gasoline – RON (research octane number) 92 & 95

• Kerosene and Jet Fuel

• Diesel – Premium and Regular

• Fuel Oil

• Benzene

• Paraxylene

• Polypropylene

• Sulphur In general, pollutant concentrations in products deriving from the Project are lower than the Vietnamese Fuel Standards currently in force (Table 3.6).

Table 3.6 Products Quality Standard of the Project

Characteristic Project Standard TCVN LPG S ppm weight 100 140

Gasoline

RON 92/95 90/92/95

S ppm weight 50 500

Pb g/l 0 0.013

Benzene % volume 1.0 2.5

Kerosene S % weight 0.1 0.3

Diesel S ppm weight 50/350 500/2,500

Fuel Oil S % weight 1.0 2.0/3.5 Source: NSRP LLC, June 2010

3.5 UNIT PROCESSES AND OPERATIONS The overall diagram for the base case mass balance of the NSRP Project is shown in Figure 3.7.


64

Figure 3.7 Ove

rall Mass Balan

ce Bas

e case


65

3.5.1 Refinery Process Units 3.5.1.1 Crude Distillation Unit (CDU) The design of the CDU is consistent with the overall Refinery objective of maximizing distillates and minimizing residue. The design incorporates flexibility in distillate production, will allow for minor variations in feed quality, and will enable consequent flexibility in refinery blending operations. The design case of the CDU feedstock is based on 100% KEC Oil. A maximum of 0.5% (by volume) water is assumed to be present in the crude. Design cases are considered as follows:

• Base case: CDU will be designed for TBP (true boiling point) cut points and products specifications.

• Maximum Kerosene case: CDU will be capable of producing a wider range of kerosene draw of acceptable quality in order to take advantage of market changes. This corresponds to an increase in kerosene production of 17%.

• Minimum Kerosene Case: CDU will be able to increase wild naphtha production at the expense of kerosene cut in order to maximize profits in the Aromatics Complex.

• Cold Reflux Case: CDU will have the flexibility to operate with 5 wt% cold reflux ratio (cold naphtha/hot top pump around). This facility consists of wild naphtha stream from the column overhead receiver routed into the top pump around return.

The CDU will operate under this scenario during start-up, cleaning and off-design operation. Crude oil will be preheated against product and pump around streams before being routed to a fired heater. Primary fractionation will be carried out in the preflash vessel/ main crude column fractionator and associated side stream strippers. Overhead naphtha will be further stabilized in the naphtha stabilizer column in the LPG Recovery Unit. Products will be cooled and rundown to product blending, intermediate storage or further processing as appropriate. The CDU unit will produce the following streams:

• A sour overheads gas stream routed to the LPG Recovery Unit.

• A full-range unstabilized naphtha stream routed to the LPG Recovery Unit for further processing.

• A kerosene stream routed to the Kerosene Hydrodesulphuriser Unit (KHDS) and to product blending.

• A combined gas oil stream routed to the Gas Oil Hydrodesulphurisation Unit (GOHDS) or to GOHDS intermediate tankage.

• An atmospheric residue stream routed to the Residue Hydrodesulphurisation Unit (RHDS) or to RHDS intermediate tankage.

3.5.1.2 LPG Recovery Unit (LRU) The LPG Recovery Unit is designed as a common saturated gas plant to collect and process saturated feed streams (off-gas, LPG and naphtha). These streams will be fed by many sources such as CDU,


66

Naphtha Hydrotreater, Continuous Catalyst Regeneration Reformer (CCR), Isomerisation Unit and three Hydrodesulphuriser Units (KHDS, GOHDS & RHDS). The LPG Recovery Unit is operated to:

• Collect off-gas, LPG and Naphtha streams from the CDU and other Process Units

• Produce an Off-gas stream for use in the Refinery Fuel Gas System after hydrogen sulphide removal

• Produce a mixed LPG product stream, after removal of hydrogen sulphide and water washing, for routing to the licensed Saturated LPG Treatment Unit which removes mercaptan sulphur components

• Receive the sweet mixed LPG stream from the Treatment Unit for stabilization in a Deethaniser and subsequent separation in a Depropaniser to produce C3 and C4 LPG streams, which are routed to LPG storage

• Produce stabilized full-range naphtha which is routed as feedstock to the Naphtha Hydrotreater Unit

• Produce a sour water stream which is routed to the Sour Water Stripper Unit

• Produce a rich amine stream which is routed to the Amine Regeneration Unit.

3.5.1.3 Saturated LPG Treater Unit (LTU) The unit is designed to process mixed LPG feedstock from the amine extractor in the LPG Recovery Unit (LRU) to produce treated LPG with a maximum total mercaptans sulphur content of 5 ppm wt. The unit design includes facilities for spent caustic treatment and recycles. The treated LPG product returns to the LRU for C3 / C4 separation. The following by-products are expected to be produced in the LTU:

• Foul air to the CDU Heaters or RFCC CO Boilers or Incinerators located at the Sulphur Recovery Unit or HC Flare

• Disulphide Oil (DSO) to Naphtha Hydrotreating Unit (NHT) or Slop Tank

• Spent caustic and wastewater to the Effluent Treatment Plant (ETP). 3.5.1.4 Kerosene Hydrodesulphuriser Unit (KHDS) The Kerosene Hydrodesulphuriser Unit (KHDS) processes the kerosene fraction from the CDU and produces desulphurised Kerosene /Jet Fuel with max. 50 ppm wt sulphur content and max. 0.003 wt% mercaptan sulphur content. The Unit also produces a number of by-product streams:

• Unstabilised Naphtha, which is sent to the CDU

• Sour off-gas sent to the LRU

• Sour water sent to the Sour Water Stripping Unit (SWS-1).


67

3.5.1.5 Gas Oil Hydrodesulphuriser (GOHDS) The Gasoil Hydrodesulphuriser Unit (GOHDS) processes atmospheric Gas Oil from the (CDU and Light Cycle Oil from the RFCC. The unit desulphurises these feeds to produce low sulphur (max 50 ppm wt) diesel blendstock. The Unit also produces a number of by-product streams:

• Unstabilised Naphtha sent to the CDU

• Treated off- gas sent to the LRU

• Sweet gas to the HCDS for hydrogen recovery in a Pressure Swing Adsorption (PSA) unit

• Sour water sent to the Sour Water Stripping Unit (SWS-1). This unit will incorporate the amine absorber for removal of H2S from sour off-gas and recycled gas. The amine solvent will be methyl diethanolamine (MDEA). Lean amine will be supplied from the common Amine Regeneration Unit (ARU). 3.5.1.6 Residue Hydrodesulphuriser Unit (RHDS) The RHDS is designed to process atmospheric residue from the CDU to produce a feedstock that is suitable for processing in a downstream RFCC. The unit produces the following product streams:

• Desulphurised atmospheric residue to the RFCC

• Unstabilised Naphtha to the CDU

• Desulphurised RHDS diesel to the diesel pool. The Unit also produces the following by-products:

• Off-gas from the product recovery section to the LRU

• Off-gas from the reactor section to Hydrogen Compression and Distribution System (HCDS) for hydrogen recovery.

This unit will incorporate the amine absorber for removal of H2S from sour off-gas and recycled gas. The amine solvent will be MDEA. Lean amine will be supplied from the central ARU. 3.5.1.7 Residue Fluid Catalytic Cracker Unit (RFCC) The RFCC is designed to process the residue stream received from the Residue Hydrodesulphuriser (RHDS). The RFCC is designed for two modes of operation: maximum olefin (propylene) and maximum gasoline. The Unit produces the following product streams:

• An amine treated LPG stream. This LPG stream will be caustic treated (RFCC LPG Treater) to remove mercaptans. The mercaptan free LPG will be routed back to the RFCC C3/C4 splitter


68

• After mercaptan removal, the LPG stream will be split to produce a propylene stream to the Polypropylene Unit, a mixed butane stream to Indirect Alkylation Unit, and a propane stream to the LPG pool

• Light FCC gasoline (LFG) to the gasoline pool via caustic merox treating

• Heavy FCC gasoline (HFG) to the gasoline pool

• Light cycle oil (LCO) product to the Gas Oil Hydrodesulphurisation Unit and/or fuel oil

• Clarified Oil (CLO) product to refinery fuel oil. The Unit also produces the following by-products:

• Treated off-gas sent to the Refinery fuel gas system

• Sour water sent to Sour Water Stripping Unit (SWS-2)

• Regenerator flue gas which is sent to atmosphere via a stack. The RFCC unit includes dedicated amine absorber/extractor/regenerator facilities to serve only the RFCC Complex. 3.5.1.8 RFCC LPG Treater The Unit is designed to process LPG feedstock from the RFCC unit after amine scrubbing. The Unit produces treated LPG with a maximum total mercaptans content of 3 ppm wt with maximum total sulphur of 10 ppmw. Spent caustic treatment includes the spent caustic from RFCC Light Gasoline Treater Unit for treatment. Regenerated caustic shall be recycled back to the extraction section. The following by-products are produced by the RFCC LPG Treater:

• Foul Air to the CDU Heaters or RFCC CO Incinerator or Incinerators located at the Sulphur Recovery Unit (SRU) or HC Flare

• Disulphide Oil (DSO) to Naphtha Hydrotreating Unit (NHT) or slop tank

• Spent caustic and wastewater to the Effluent Treatment Plant (ETP). 3.5.1.9 RFCC Light Gasoline Treater The primary objective of the Residue Fluid Catalytic Cracker (RFCC) Light Gasoline Treater Unit is to reduce the mercaptan and total sulphur content and remove H2S from the light gasoline obtained from the RFCC. The product will meet the quality requirement to produce treated light gasoline with a maximum total sulphur specification of 35 ppmw (for feed containing 55 ppmw RSH-S) and 25 ppmw (for feed containing 15 ppmw RSH-S). The following by-products are expected to be produced by the RFCC Light Gasoline Treater:

• Spent caustic and wastewater to the ETP.


69

3.5.1.10 Propylene Recovery Unit (PRU) The Propylene Recovery Unit (PRU) is designed to recover high-purity propylene from the mixed C3 feedstock received from the RFCC. The propylene product is fed forward to the Polypropylene Unit (PPU). The PRU also produces a propane by-product stream which is routed to LPG product blending and storage. 3.5.1.11 Indirect Alkylation Unit (InAlk) This Unit comprises three separate process units: a Selective Hydrogenation Process (SHP), a Nitrile Removal Unit (NRU) and an Indirect Alkylation Unit (InAlk) designed to maximize the production of high octane alkylate suitable for gasoline blending based on maximizing octane-barrels. The feed to the units is the mixed butane/butene product from the RFCC. This stream is first processed in the SHP to remove dienes and then into the NRU to remove nitriles before passing to the InAlk unit where isobutylene is reacted with light olefins to yield an iso-octane rich alkylate product. The hydrogen requirement for the SHP and InAlk units is taken from the Hydrogen Compression and Distribution System (HCDS). The InAlk unit also produces a mixed C4s stream (unreacted butanes) which is sent to the LPG pool. The product of InAlk will meet the specifications of Alkylate and LPG (Butanes). The following by-products are expected to be produced in the InAlk unit:

• Off-gas to the LRU or RFCC Amine Absorber

• Wastewater to Sour Water Stripper (Train 1)

• Oily contaminated water to Effluent Treatment Plant 3.5.1.12 Hydrogen Manufacturing Unit (HMU) The objective of the Hydrogen Manufacturing Unit (HMU) is to produce high purity hydrogen for the hydrodesulphurisation units; and for use in the Indirect Alkylation, Selective Hydrotreater, Polypropylene Unit, Tail Gas Treatment Units, Isomer and Tatoray within the NSRP Complex. The HMU uses steam-methane reforming of hydrocarbon feedstock (refinery fuel gas and LPG) to produce a hydrogen-rich gas product which is purified in a PSA unit to yield hydrogen with a minimum purity of 99.9 % vol hydrogen. The hydrogen product is routed to the RHDS unit with the balance of production distributed throughout the Complex via the HCDS. The HMU generates a substantial quantity of high pressure steam from waste heat and this steam makes a significant contribution to the refinery steam balance.


70

3.5.1.13 Hydrogen Compression and Distribution System (HCDS) The Hydrogen Compression and Distribution System (HCDS) receive high-purity hydrogen from two sources: the Hydrogen Manufacturing Unit (HMU) and the PSA section within the Catalytic Reformer (CCR) in the Naphtha and Aromatics Complex. In addition, a PSA unit shall be installed within HCDS which shall recover pure H2 from the RHDS & GOHDS H2 rich off-gases. The objective of the HCDS is to compress and distribute highly purified hydrogen to the following units normally at the required battery limit pressures:

• Kerosene Hydrodesulphuriser

• Gas Oil Hydrodesulphuriser

• Selective Hydrogenation / Indirect Alkylation Units

• Isomar

• Tatoray Normally the hydrogen requirement to the Polypropylene (PP) Unit shall be met by the H2 from the CCR Platforming PSA Unit. The hydrogen treat-gas requirements within the Naphtha and Aromatics Complex (i.e. the Naphtha Hydrotreater and Isomerisation units) are fed directly by hydrogen-rich gas produced in the CCR; hence, these units are not normally served by the HCDS. 3.5.1.14 Sour Water Stripper Unit (SWS) The objective of the Sour Water Stripper unit (SWS) is to treat refinery sour water streams such that the quality of stripped water enables it to be reused as wash water within the Refinery and/or discharged to the Effluent Treatment Plant (ETP) for final clean-up. The sour gases (H2S and NH3) stripped from the sour water in the SWS are routed to the Sulphur Recovery Unit (SRU) for further treatment. Due to a considerable difference in output and sources, the SWS is configured as two separate trains in order to prevent contamination from products and towards an environmental friendly process; the routings of the most significant sour water streams are indicated here:

• SWS Train 1: Used to treat sour water production generated from CDU, LRU, NHDS, GOHDS, SRU/Tail Gas Treatment Unit (TGTU)

• SWS Train 2: Dedicated to RFCC (Figure 3.8)


71

Figure 3.8 Sour Water Stripper Unit Outline

Input constituents and loading of sour water are presented in Table 3.7.

Table 3.7 Feed Sour and Loading in SWS Unit

Parameter

Train 1 Train 2

CDU (kg/h)

LRU (kg/h)

NHDS (kg/h)

GOHDS (kg/h)

RHDS (kg/h)

SRU/TGTU (kg/h)

Total (kg/h)

RFCC (kg/h)

H2O 27,404 786 10,727 24,696 72,411 24,127 160,151 58,896

H2S 6 14 3 349 3,012 3 3,387 50

NH3 4 6 0.2 175 1,391 2 1,578 74

H2S ppm 20,513 850

NH3 ppm 9,560 1,250 Source: NSRP – LLC, June 2010 Product standards will be the following: H2S 10ppm; NH3 50ppm. 3.5.1.15 Amine Regeneration Unit (ARU) Sour steam and LPG contain H2S and NH3 at high concentrations and will be treated in amine absorbers by MDEA, 40% of weight. There will be seven (7) amine absorbers in the Refinery. Each of the GOHDS, RFCC and TGTU units have one (1) amine absorber; two (2) absorbers will be installed in the LRU unit and two (2) absorbers in high pressure and low atmospheric pressure RHDS. Amine Regeneration Unit (ARU) is designed to strip hydrogen sulphide (H2S) from the contaminated amine steam returned from amine absorbers/extractors of the Refinery.

From the ARU, acid gas (containing H2S) is routed to a Sulphur Plant for producing Sulphur element. High quality regenerated solvent is returned to the Refinery for consumption. In summary, the ARU will treat contaminated amine steam from absorbers in the following units:

SWS Train 1 SWS Train 2

Sour gases to SRU Sour gases to SRU

Steam

Sour water Sour water

Steam

Effluent Treatment Plant

Effluent Treatment Plant

To user


72

• Gasoil Hydrodesulphuriser Unit (GOHDS)

• Residue Hydrodesulphuriser Unit (RHDS)

• LPG Recovery Unit. RFCC off-gas absorbers/treaters will also be treated in the ARU of RFCC and shown in the design basis of RFCC designer/licensor. Tail gas will also be treated in the Amine Absorber (Figure 3.9) with SRU and TGTU and shown in the design basic of designer/licensor.

Figure 3.9 Amine Absorber Outline Properties and loading of contaminated amine steam and quality of output off-gas are presented in Table 3.8 and 3.9.

Table 3.8 Constituent and Loading of Contaminated Amine Steam in ARU

Parameter Off Gas Absorber LPG Absorber GOHDS RHDS

Loading (kg/h) 109,953 14,757 77,915 587,870

H2S (kgmol/h) 122.88 12.03 98.98 742.03

Source: NSRP – LLC, June 2010

Table 3.9 Quality of Output Off Gas in ARU

Parameter % Weight

H2S 90.53

SO2 0

NH3 0.06

Loading (kg/h) 35.144 Source: NSRP – LLC, June 2010 3.5.1.16 Sulphur Recovery Unit (SRU) and Tail Gas Treating Unit (TGTU)

The objective of the Sulphur Recovery Unit (SRU) is to process acid and sour water stripper gases generated within the Refinery to produce elemental sulphur. SRU and TGTU have a design capacity of 800 tons of sulphur/day, with a sulphur recovery efficiency of 99.9%, SOx concentration in off-gas of 150 mg/Nm3.

Amine Absorber for treating

gases from GOHDS, RHDS…

Amine Regeneration Unit

Acid Gas

to SRU

Treated

Off Gases

Off Gases Contaminated Amine

Steam


73

The SRU is configured as follows:

• 3 x 40% Claus trains

• 2 x 80% TGT trains

• 2 x 100% incinerator trains. The acid gas feed to the SRU is taken from the Amine Regeneration Units (ARU) of RFCC and desulphurization system in off-gas; the sour water stripper gases from the Sour Water Strippers (SWS). Product sulphur will be stored in an above ground tank and exported to the Sulphur Forming and Storage Unit. The objective of TGTU is to recover the majority of the sulphur remaining in the SRU tail gas as H2S and return for reprocessing in the SRU. The treated tail gas is then sent to an incinerator (thermal oxidizer) to convert any trace of sulphur remaining to sulphur dioxide before venting to the atmosphere. Sulphur recovery and tail gas treater outline is shown in Figure 3.10.

Figure 3.10 Sulphur recovery and tail gas treater

Properties and loading of feedstock in SRU and TGTU are presented in Table 3.10.

Acid gas from SWS 1 & 2

Amine acid from ARU &

RFCC

Acid gas from FGD

SRU-1

SRU-2

SRU-3

TGTU-2

TGTU-1

Incinerator

1

Incinerator

2

Sulphur liquid to SFU

Stack

Sulphur tanks A

33.3% for each SRU

320 tons/day

80% for each TGTU

640 tons/day

80% for each incinerator

640 tons/day

Normal operation Design capacity

(SRU tail gas) (TGTU tail gas)

Sulphur tanks B


74

Table 3.10 Properties and Loading of Feedstock in SRU and TGTU

Parameter ARU SWS FGD

H2S (wt%) 90.53 50.55 0

SO2 (wt%) 0 0 98

NH3 (wt%) 0.06 26.43 0

Loading (kg/h) 35,114 6,077 1,000 Source: NSRP – LLC, June 2010 3.5.2 Petrochemical Process Units 3.5.2.1 Naphtha and Aromatics Complex (NAC)

The Naphtha and Aromatics Complex (NAC) is designed to process a full-range of naphtha feedstock to produce Paraxylene and Benzene products at a purity that is suitable for sale, also for aromatic gasoline and isomerate streams suitable for gasoline blending. The design philosophy of the Complex is to maximize economic Paraxylene production. The Aromatics Complex comprises the following process units:

• Naphtha Hydrotreater (including naphtha splitter)

• CCR Platformer / CCR Regenerator section (incl. reformate splitter)

• Sulpholane (Aromatics Extraction)

• Benzene / Toluene Fractionation

• Isomar (Xylenes Isomerisation)

• Tatoray (Toluene Transalkylation)

• Xylene Fractionation

• Parex (Paraxylene Separation)

• Penex (Isomerisation) The NAC feedstock has a full-range of naphtha produced in the LPG Recovery Unit. Fresh naphtha feedstock (and recycled raffinate from the Sulpholane Unit) is processed in the Naphtha Hydrotreater. Treated naphtha product is then sent to the Naphtha Splitter where it is fractionated into two streams: light naphtha as feed to the Penex Unit and heavy naphtha to the CCR Platformer. The latter is sent to the CCR Platformer and the resultant reformate is then routed to the Aromatics units for production of Paraxylene, Benzene and gasoline blending components. The primary products from the Naphtha and Aromatics Complex are:

• Paraxylene – sent to paraxylene product storage

• Benzene – sent to benzene product storage

• An isomerate stream – sent to gasoline blending.


75

By-products include:

• A raffinate stream from the Sulpholane unit – which is totally recycled to the Naphtha Hydrotreater

• A toluene stream – can be produced, if required, for gasoline blending

• A C9/C10 aromatics stream (Aromatic Gasoline) from the Heavy Aromatic column overheads – to gasoline blending, if required

• A heavy aromatics stream (C10+) from the Heavy Aromatic column bottoms – to refinery fuel oil blending

• LPG from the CCR Platformer – to the LPG Recovery Unit

• A hydrogen-rich gas stream from the CCR Platformer PSA unit – part of which is consumed internally within the NAC with the remainder routed to the Refinery’s Hydrogen Compression and Distribution System.

3.5.2.2 Polypropylene Unit (PPU) The Polypropylene Unit is designed to produce polypropylene from propylene feedstock and hydrogen. Propylene feed is obtained from the Propylene Recovery Unit within the RFCC Unit. Normally hydrogen feed gas is supplied from the CCR Platforming PSA Unit. The primary product from the PPU is polypropylene homopolymer. A minor purge gas stream is recycled back to the Propylene Recovery Unit. The polypropylene product is bagged and loaded into containers on-plot for dispatch by road to the dockside where containers are transferred to ships. 3.6 PLANT UTILITIES 3.6.1 Crude Oil Storage Tanks The Crude Oil will be loaded via 48” Sub-sea pipeline with a flow rate of around 14,100m3/hr from the SPM to the Refinery’s Crude Storage Area. There are 8 Crude Oil storage tanks each with a capacity of 120,000m3 including 3.6 tanks for crude unloading, 3.4 tanks for CDU feedstock and one tank as back-up for off-line maintenance and inspections (Table 3.11). The maximum height of the tank should be restricted to 20 m and tank diameter is about 90 m. External Floating Roof Tanks will be used for this service.


76

Table 3.11 Total Number of Crude Oil Tanks Required for NSRP

Parameter Unit Capacity (m3)

Number of tanks (120,000 m3/tank) Nos 8

Total Installed Capacity m3 960,000

Total Effective Capacity m3 768,000

Number of tanks for the parcel receipt Nos 3.6

Number of crude oil supply tanks (for CDU) Nos 3.4

Number of spare tanks Nos 1

Frequency of visiting ship Day/time 10.9

Shipment window Day 5.4

Source: FEED document provided by FW in October 2009

The Crude Storage facility provides a capacity for 10 days of operational demand plus capacity for simultaneous receipt of one crude oil shipment parcel. The 10 day window includes 2 days for continuous crude oil pumping to the tank area, 2 days for water depositing, 1 day for dewatering and testing crude oil quality, and 5 days for any delays in ship arrival (bad weather or operational delays). The maximum liquid level is 90% of tank height and the low liquid level (dead level) is 10% of tank height. Therefore, effective working capacity is at (90%-10%) of tank capacity. Total nominal capacity required for unloading crude oil from Very Large Crude Carrier (VLCC) is 427,845 m3. Four tanks are required for operation. 3.6.2 Product Tankage Farm 3.6.2.1 Product Storage Tank Product tankage is based on storing the blended final product and exporting by means of ship/truck loading by providing a sufficient storing volume which will not hamper the product off take / intake. Ship loading pumps are provided for all product tanks and in addition truck loading pumps are provided for gasoline and diesel. The quantity and required capacity of product tanks are given in Table 3.12.

Table 3.12 Quantity and Capacity of Product Tanks

Storage tank for Number of tanks

Type of Tank Total Working Capacity (m3)

Gasoline 92 2 Floating roof tank 86,600

Gasoline 95 2 Floating roof tank 86,600

Jet fuel ship 3 internal floating roof tank 26,735

GO (Prem) ship 3 Cone roof tank 115,572

GO (IND) ship 2 Cone roof tank 75,500

Benzene 2 internal floating roof tank 16,641

PX (Para-Xylene) 2 internal floating roof tank 34,000 Source: FEED document provided by FW in October 2009

Provision is made to export fuel oil from the refinery fuel oil system when the FGD unit is shutdown or if fuel oil products are accumulating.


77

Provisions to import gasoline will be provided. Import is achieved by using the export line with a bypass around product ship loading pumps and will be routed to either 92 or 95 tanks depending on whichever is available. Facilities to send this for reblending gasoline in a blender will be provided. 3.6.2.2 Product Blending Component Storage Tanks Product blending component storage tanks (Table 3.13) are used to store the product components that are required for blending to obtain the final products.

Table 3.13 Quantity and Capacity of Product Blending Component Tanks

Storage tank for Number of tanks Type of Tank Total Working Capacity (m3)

Isomerate 2 Dome roof tank 22,025

Alkylate gasoline 2 Floating roof tank 17,114

Light FCC Gasoline 2 Dome roof tank 17,978

Heavy FCC Gasoline 2 Floating roof tank 19,129

Aromatics Gasoline 1 Cone roof tank with internal floating roof tank

7,650

RHDS Diesel 2 Cone roof tank 33,106

Kerosene 1 Cone roof tank with internal floating roof tank

8,900

Source: FEED document provided by FW in October 2009

3.6.2.3 Intermediate Storage Tanks

These include inter-unit storage tanks for intermediate products or supplies feedstock when downstream or upstream units are corrupted. These are storage supplies for the unscheduled and emergency shutdowns, except for residue crude and desulphurised residue crude tanks. The residue crude and desulphurised residue crude tanks provide ullage during shutdown of RHDS for annual catalyst change as well as for supporting unscheduled shutdowns. The storage capacities for the intermediate products are based on anticipated unscheduled shutdown durations for the associated units and the impact of shutdown of these units on the remainder of the Refinery. Quantity and capacity of required intermediate storage tanks are given in Table 3.14.

Table 3.14 Quantity and Capacity of Intermediate Storage Tanks

Storage tank for Number of tanks

Type of tank Total working capacity (m3)

Full range naphtha 2 Cone roof tank with internal floating roof tank 29,960

GO HDS Feed 4 Cone roof tank 34,275

Reduced crude/desulphurised crude 6 Floating roof tank 244,800

Desulphurised Heavy Naphtha 1 Cone roof tank with internal floating roof tank 12,032

Full Range Reformate, Light Reformate and Heavy Reformate

3 Cone roof tank with internal floating roof tank 31,000

Propylene 6 Sphere tank 15,873

Butane/Butene 6 Sphere tank 23,345

Propane/Butane 8 Sphere tank 21,464 Source: FEED document provided by FW in October 2009


78

Tank levels are always maintained at about 50% level of working volume to provide ullage for upstream/downstream process units. It is understood that any unscheduled shutdown spanning per the anticipated number of days can result in a 50% turndown of the Refinery. 3.6.3 Other Receiving and Storage Utilities 3.6.3.1 Catalyst and Chemicals Storage The chemicals storage receives commercial caustic flakes/beads and prepares and distributes dilute (14.35wt. %) caustic solution, a widely used chemical, to various refinery process units and utility systems. Other chemicals and additives include, but are not limited to, amines, inhibitors, hydrochloric acid, ammonia, sulphuric acid etc. These are also consumed in a few units and their storage would be part of the corresponding unit. 3.6.3.2 Slop Storage Tanks Slop tanks are used to receive the off-spec product from the Refinery and Offsite facilities. Separate tanks are provided for straight run products and cracked products. Straight run product slop liquid is re-processed in the CDU and cracked slops are sent to the RFCC Unit for re-processing. The slop tanks will be floating roof tanks. The number and capacity of the slop tanks are presented in Table 3.15.

Table 3.15 Quantity and Required of Slop Tanks

Tank Number of tank Type of tank Storage capacity (m³)

Straight Run Slop Tank 1 floating roof tank 12,000

Cracked Gasoline Slop Tank 1 floating roof tank 12,000

Spare Tank 1 floating roof tank 12,000

Sour Water Storage Tank 1 floating roof tank 12,000

Total 48,000

3.6.3.3 Sulphur Forming and Storage Unit The objective of this Unit is to solidify the molten sulphur from the Sulphur Recovery Unit (SRU) and to stockpile, reclaim, transfer, weigh and shipload the solidified sulphur. The Unit will be located in the jetty area. The molten sulphur will be supplied from the SRU located in the refinery area by an electrical heat traced pipeline. The product from this Unit will be exported through a dedicated sulphur loading berth at the solid products export jetty.


79

3.6.3.4 Gas Recovery System There will be two (2) gas recovery systems in the Complex. A system is designed to recover gas from tanks containing Isomer, light Naphtha FCC, Benzene, Paraxylene and gas released from RON92 and RON95 gasoline export process into tank trucks. Other similar gas recovery systems are designed to serve for export processes into tankers. Operation of the gas recovery system is based on physical absorption by activated carbon combined with an absorption process by a solvent to recover hydrocarbon. Gas released from the absorption tower will not contain hydrocarbon and will be emitted into the atmosphere at a safe location. At least 99.5% of hydrocarbon gas will be recovered via this system. 3.6.3.5 Fuel System Fuel gas generated from process units will be recovered by a main fuel gas pipeline system and routed to high and low pressure fuel gas extractors. Based on the economy and the need for process units, the fuel system of the Refinery will be divided into a fuel gas system and a fuel oil system. In normal operation, the total volume of used gas is much more than the volume of emission gas. The shortage will be supplemented with LPG. The fuel oil system is designed to receive product flow of fuel oil, such as Light Cycle Oil (LCO) from RFCC, Diesel from RHDS, Clarified Oil (CLO) from RFCC, Diesel from GOHDS, Kerosene, Automotive Gas Oil (AGO) and heavy Aromatics. These flows are blended at different ratios to form specific fuel oil products, such as Refinery Fuel Oil (RFO), Ultra Fuel Oil (UFO) and Export Fuel Oil (EFO). Blending systems are installed to mix fuel oils. A separate system used to blend RFO 0.24%S and UFO/EFO 1%S is located near the fuel oil tank to supply the demand units.

Fuel storage and distribution systems for each kind of fuel are shown in Table 3.16.

Table 3.16 Fuel Storage and Distribution Systems

Fuel

Destination

Maximum Polypropylene Case Maximum Gasoline Case

MW ton/day MW ton/day

LPG 356 670 136 256

GTG 294 555 104 196

HRSG 61 115 32 60

Process unit heater 0 0 0 0

Fuel gas Process unit heater 634 1,242 559 1,085

Fuel oil 0.24%S Process unit heater 0 0 77 154

Fuel oil 1%S 459 1,003 717 1,565

Ultra unit boiler 431 941 688 1,503

CO boiler 28 62 28 62

Total used fuel 1,449 2,915 1,489 3,060 Source: NSRP-LLC, June 2010

It is envisaged that blenders will be provided, and separate blenders will also be provided, for low sulphur (Refinery Fuel Oil) and for high sulphur fuel (Utility Fuel Oil), in the utility area nearby corresponding tanks to meet requirements. The typical blenders are as follows:


80

• RHDS Diesel + RFCC LCO from storage are blended and stored in tanks. This will supply oil to GT and Refinery Heaters.

• NAC Heavy Aromatics + RFCC CLO are blended and stored in tanks as Utility Fuel Oil. This will supply oil to Utility Boilers.

Provision is made to export fuel oil via the jetty when the Refinery has an excess of fuel oil or the FGD is shutdown. During start-up, the Refinery Oil products will not be available from the Refinery. In order to meet the start-up demand, imported diesel (via Diesel Oil Line) will be used for GT/Refinery Heaters and imported fuel oil (via Black Oil Line) will be used for the Utility Boiler. Fuel gas from various process unit sources is collected via fuel gas collection headers and fed to High Pressure (HP) Knock-Out drums and Low Pressure (LP) Knock-Out drums. Unsaturated high pressure gas is collected in the HP drum and saturated low pressure gas is collected in LP drum. Any droplets of liquid condensation that form in the pipelines will be removed from the gas in fuel gas-mixing / knock out drums. This liquid will be flashed to the flare header. The Crude Distillation Unit (CDU), Xylenes Fractionation (Aromatics Complex) and BT Fractionation (Aromatics Complex) will run normally on refinery fuel gas with provision for oil firing during start-up operations. Therefore, during Refinery start-up, as there will be no fuel gas production from process units, all the gas only fired refinery furnaces will be supplied by vaporizing LPG into the Fuel Gas distribution system. A LPG Vaporiser system with LPG Superheaters have been provided in the fuel gas system to meet the requirements of normal fuel gas demand and start up requirements. 3.6.3.6 Flushing Oil System The flushing oil system will supply flushing oil (typically Straight Run Gas Oil) to the Refinery process units and utility systems handling fluids with a viscosity > 43 cSt @ 40 °C. Flushing oil is required for the following main purposes:

• Flushing of equipment under maintenance

• Start up/ Shut down Unit Circulation Flushing oil for pump seal flushing systems and instruments flushing would be provided by independent systems in respective units and are not considered in this basis. However, it is envisaged that a quantity of 10m³/hr will be continuously supplied to make up the flushing oil requirements for systems handling the Pump Seal and Instrument Flushing. During commissioning and start-up, diesel will be provided from one of the GOHDS feed tanks as an alternate source of flushing oil.


81

3.6.3.7 Waste Oil Recovery, Storage and Pump Systems Waste oil generated from process units and support constructions will be collected and treated in the Refinery. Waste oil generated from RHDS, NHDS, Penex, CCR, Aromatic, flare system and export berths will be collected by the waste oil tank, and then routed to the crude oil distillation unit to be processed. Waste oil generated from RFCC and InAlk will be collected by the Catalyst Cracking Unit to be processed. 3.6.3.8 Power and Steam Generation System The purpose of the steam and power generation system is twofold:

• To supply all electric power to meet the demands of the Complex;

• To supply steam to meet the demands of the Complex. The Refinery requires a segregated power generation system resulting in two electrical islands in order to reduce the Refinery wide flare loads. On-site electrical power generation is provided by the following sources:

• Gas Turbine Generators (GTGs)

• Steam Turbine Generators (STGs) Refinery users are divided into two islands, namely Island-1 and Island-2.

• Island-1: 3 steam turbines – capacity norm of 35.6 MW/turbine. Total power demand in Island-1 is 106 MW

• Island-2: 3 steam turbines – capacity norm of 41.4 MW/turbine. Total power demand in Island-2 is 124 MW

The Plant with two gas turbine generators has a capacity norm of 61.896 MW/turbine. The power generated from the STGs is insufficient to meet overall power demands and hence the balance power is to be generated by the GTGs provided in each island. On-site steam generation is achieved at two pressure levels – HHP Steam and HP Steam. Conceptually, in each of the electrical islands, the steam turbine generator (STG) is the main generator. HHP steam is generated in a utility boiler package which then drives the STG. The STG is operated between HHP and condensate, with pass outs at HP, MP and LP pressure levels to generate power. The utility boiler package is fired using high sulphur utility fuel oil, which is a blend of clarified oil and heavy Aromatics. Refinery fuel oil is also available as additional fuel for the utility boiler package. Flue gases from Utility Boilers are routed to flue gas Desulphurization units, where SOx content is limited to


82

65 mg/Nm3 before atmospheric discharge to stack. In each island, power is also generated in gas turbine generators (GTG), which are fired on mixed LPG as primary fuel with low sulphur GT fuel oil (a blend of light cycle oil and RHDS Diesel) as back up for start up. Each GTG is connected to a heat recovery steam generator (HRSG) which produces HP steam using the hot exhaust gases from the gas turbine. Supplementary firing is done in HRSG with LPG with a limitation of 850°C on a burner duct exit temperature. Flue gas from HRSGs is routed directly to the stack. HP and MP steam are exported from the STGs/HRSGs to a common header from where they are distributed to the Refinery Complex. Condensate is generated in the STGs to balance the power demand, after the generation of HP and MP levels. LP steam is in excess in the Refinery and is used to augment the power generation from the HP-Condensing STG in Island-2. Condensate that is generated in STGs is cooled against sea water and sent to the Demineralised Water plant for polishing prior to re-use. HP, MP and LP steam is used in the Refinery Complex for different purposes such as running steam turbine drives, providing heat to the process and also direct use in the process (for reactions, stripping etc.). Steam used in drives is exhausted to lower pressure levels based on overall steam balance. Steam consumed in the process is typically lost or recovered as sour water which is treated elsewhere in Sour Water Strippers. Steam used for process heating of exchangers is recovered as condensate at the respective pressure levels and is finally recovered as suspect condensate after flashing to recover LP steam. Suspect condensate is treated in the condensate treatment section of the Demineralised Water plant and is recycled as Demin Water to the Deaerators, from where Boiler Feed Water (BFW) is generated for supply to the Steam Generators. Any shortfall in the water supply to deaerator is made up by demineralised water. 3.6.3.9 Nitrogen Supply System The Nitrogen Supply System generates nitrogen for distribution to various users and liquid nitrogen for storage. The stored liquid nitrogen is vaporized at different pressure levels to supply continuous or intermittent demands. Nitrogen is required during start-up and shut down for purging and pressurizing of systems, circulation during start up and cooling down during shut down, catalyst regeneration, blanketing during long shutdown and seal purging of compressors in the units. It is also required in the off-sites for blanketing of storage tanks and purging of the flare header. One of the critical consumers is the CCR unit which requires an independent source of nitrogen supply at a higher pressure level. This system consists of the following units:

• Nitrogen generation package is a cryogenic nitrogen generation unit. In this unit, atmospheric air is separated into an oxygen rich waste gas stream and a nitrogen product stream.

• Liquid nitrogen storage tank and vaporizers store the liquid nitrogen product from the generation units and is stored in the cryogenic storage tanks. The storage tanks serve as a backup source of nitrogen for the Refinery.


83

• Liquid nitrogen cryogenic pump.

3.6.3.10 Water Supply System Water from Dong Chua Lake is treated at Nghi Son Water Treatment Plant. Treated water referred to as “service water” will be supplied through a pipeline system and the flow will be metered at the barrier of the Refinery, then routed to process water, domestic water, demineralised water systems and to firefighting water storage tanks for storage. Designed capacity of this system is 1,560m3/hour.

Table 3.17 Service Water Demand for the Complex

Capacity (m3/hour)

Total supplied water 1,162

Domestic water 14

Process water 178

Demineralised water 970 Source: NSRP-LLC, June 2010 Based on initial estimations, a total volume of 17,220 m3 of fire fighting water inside the Complex will be stored in a separate tank. The demineralization plant is fed by service water and produces demineralised water for use within the Refinery. The primary consumer is made-up of the boiler feed water system for steam generation. A Demineralised Water Tank provides buffer storage. 3.6.3.11 Water Intake System 3.6.3.11.1 Structure The Water Intake system will be built along the seashore with an intake channel routing water to the water storage structure of the Refinery. The Intake system includes the following parts: Intake channel and low-crested breakwater: The intake channel will be approximately 350 m in length and 70 m wide at the level of -7.92 m (-6.00 m CD). It will allow seawater to be extracted at all stages of the tide, including Lowest Astronomical Tide (LAT). The intake channel is bordered by the main harbour breakwater and a low-crested breakwater. The slopes of the breakwaters bordering the channel will be constructed at a gradient of 1:2 and 1:1.5, respectively. Intake forebay: The forebay is the transition between the intake channel and the coarse and fine screens. It is designed with a finished floor level at -8 m, again to allow the collection of fine sediment that has not settled in the channel. On the seaward side of the forebay there will be a 6 m wide roadway supported by reinforced concrete columns. The intake forebay acts as a settlement tank to reset suspended solids and needs to be periodically dredged. The front side of the intake forebay has pillars which routes seawater flowing directly to the water drum. Intake screens: There are 8 screening channels, each fitted with stop gates and coarse screens. Each


84

channel is 3.45 m wide and each pair of channels feeds 1 x 10 m diameter. The Intake channel is built at the seashore from the low crested breakwater paralleling the main breakwater in the North. At this location, a silt deposit process will occur and the channel will need to be dredged periodically at a suitable depth so that it does not affect the current. Sea water from the intake channel will be routed to the water storage structure. The water storage structure consists of a slope section, intake forebay/sediment settlement and water channel. The sea water from the intake channel will flow into the intake forebay along the slope section, with the following specifications:

Flow through works: 154.000 m3/h Number of intake channels: 8 Number of drum screens: 4 Velocity of water through intake: 0.1 - 0.5 m/s

3.6.3.11.2 Cooling Water Cooling water is used for removing excess heat from the process units within the Refinery and Petrochemical Complex. It is supplied from a closed loop fresh water cooling water system which is indirectly cooled by sea water supply. The cooling water is cooled from 47°C to 34°C by transferring heat to sea water in the sea water exchangers. The sea water is filtered to remove fine particles before entering the exchanger where it cools the closes circuit. Then, it is returned to sea. Sea water outlet temperature is restricted to 40°C to be in compliance with environmental regulations. Cooling water is used for the following systems:

• Indirect cooling system with fresh water

• Condenser in Steam and Electricity unit, RFCC and RHDS

• Sulphur extractor unit by absorbing SO2 and treating waste sea water. Sea water flow from Steam and Electricity unit is used for this purpose.

The designed capacity of the intake structure is 123,899 tons/hour while the cooling water demand for the Refinery is presented in Table 3.18.


85

Table 3.18 Cooling Water Demand for NSRP

Unit Capacity (tons/hour)

Total input 100,677

Undirected cooling water

- Cooling water system 38,576

Directed cooling water

- Condenser of vapor turbine generator– System 1 21,631

- Condenser of vapor turbine generator– System 2 25,133

- Condenser of fans in RFCC 7,041

- Condenser of air compressors in RFCC 6,061

- Condenser of recirculated air compressors in RHDS 2,235 Source: NSRP-LLC, June 2010

3.6.3.12 Chemicals and Catalysts Storage and Handling Catalysts, absorbents, chemicals and similar materials are used to support refinery operations: some are consumed continuously while others are subject to periodic replacement. Appropriate stocks of these materials are held on-site to enable continuous refinery operations. Materials handled include:

• Catalysts and inert support materials

• Lubricating oil and greases

• Caustic soda

• Transformer oil

• Amine (MDEA)

• Corrosion inhibitors

• Dimethyl disulfide (DMDS)

• Antifoam agents

• Activated carbon A list of main chemicals and catalysts is provided in Table 3.19.

Table 3.19 List of Main Catalysts and Chemicals used for NSRP

Unit Material Purpose/component etc. Amount

CDU De-Emulsifier Chemical 97.08 Ton/year

Caustic Soda Chemical 40 Ton/ year

Anti-foulant Chemical 266.96

Corrosion Inhibitor Chemical 71.39

KHDS Ni-Mo catalyst HDS 20.1 Ton/4 year

GOHDS Ni-Mo Catalyst HDS reaction 503 Ton/4 year

Corrosion inhibitor Chemical 3994 Liter/ year

Fouling inhibitor Chemical 32448 Liter/ year

RHDS Catalyst (ICR 161NAQ) HDM 30 Ton/ year


86

Unit Material Purpose/component etc. Amount

Catalyst (ICR 161LAQ) HDM 30 Ton/ year

Catalyst (ICR 161KAQ) HDM 298 Ton/ year



Catalyst (ICR 131KAQ) HDS 446 Ton/ year

Catalyst (ICR 153KAQ) HDS 418 Ton/ year Catalyst (ICR 156 SSA) Hydroprocess catalyst 63 Ton/ year

DMDS Sulphiding agent 139 Ton/ Batch

RFCC Nickel Passivator Chemical 14.6 Ton/ year

Corrosion inhibitor Chemical 40.8 Ton/ year

Zeolite catalyst Cracking catalyst 19 Ton/ year

Caustic Soda Chemical 5.5 m3/day

Merox WS catalyst Oxidizer (Liquid) 11.5 liter/day

InAlk Catalyst (SPA-1) Solid phosphoric acid 118.5 m3/1.25 to 2 year

Catalyst (S-100 ) Ni & Mo 185 m3/4 year

Catalyst (H-15 SHP) Ni for selective hydrogenation

15.8 m3/3 year

NAC Catalyst (KG55) silica alumina 1.61 m3/4 year

Catalyst (KF647-3Q) Ni/Mo 3.22 m3/4 year

Catalyst (KF542-5R) Ni/Co/Mo 3.22 m3/4 year

Catalyst S-120 Co & Mo on Alumina support

44.8 m3/4 year

Penex catalyst (I-84) Amorphous, chloride alumina

101.12 m3/5 year

Penex chemical Perchloroethylene 38.2 Ton/3 month

Penex chemical Caustic Soda 36 ton/week

CCR Adsorbent (CLR-011) Activated Alumina 100.8 m3/6 month

CCR Catalyst (R-264) Pt 0.25% for Reforming 194.8 m3/6 month

Chloriding agent Perchloroethylen 117 ton/6 month

Clay catalyst Xylene Fractionation 231 m3/4 to 6 month

Parex Absorbent Zeolite 1186 m3/12 year

Isomer Catalyst (I-300) Pt on zeolite 58.6 m3/4 year

Tatoray Catalyst (TA-20) Zeolite catalyst 83 m3/5 year

Sulforane chemical for Extractive distillation 231 ton/initial make-up

Clay catalyst B/T Fractionation 80.8 m3/6 to 12 month

PPU Catalysts and chemicals (Refer to detail list)

HMU Co/Mo Catalyst HDS 20.9 m3/4 year

Zinc Oxide catalyst Sulphur absorber 294 m3/4 year

Nickel Oxide catalyst Prereforming 75.35 m3/2 year

Iron/chromium oxide cat. HTS reactor 119.7 m3/4 year

ARU MDEA Sulphur recovery 1300 ton

SRU Catalyst (CR-35) Claus reaction 116.3 ton/5 year

Catalyst (CRS-31) Claus reaction 56.7 ton/5 year

TGTU Catalyst (TG-107) Scot Catalyst 76.57 ton/5 year

Cooling water system

Sodium Nitrate Corrosion inhibitor 147 ton/year

All units which provide reactors

Ceramic balls Catalyst support by contractor Source: NSRP-LLC, June 2010


87

Most of the chemicals, materials and equipment will be transported by ship through the sea way in the East of the Complex. Other material will be transported by trucks on the National Road 1 and Provincial Road 513. Appropriate storage and handling facilities will be provided including mechanical handling systems for the receipt, segregation, storage and transfer of materials, secure warehouse facilities, stock control systems, safety facilities, etc. Bulk stocks will be held in a central warehouse. Daily consumption will then be distributed to on-site chemical storage located within the Refinery. The caustic storage system will provide caustic soda solution to various users in the Complex. Caustic flake/beads will be delivered in 25 kg bays by truck. The caustic is dissolved in DM water to prepare a concentrated caustic solution. The caustic is further diluted with DM water, stored and then distributed to refinery users. 3.6.3.13 Flare System The flare system is designed to discharge safely off-gas generated from the process units in the Refinery. Design of the flare is based on the following cases:

• Separate incidents, e.g. output clogging of a system

• Incidents occurring in the process units, e.g. loss of support sources

• Incidents affecting the entire Refinery, e.g. loss of electricity/support. All potential discharge sources from process units and support areas will be calculated in the flare design. It should be noted that in the Complex, the electricity distribution system is divided into 2 separate systems in order to reduce the total load of flare in case of loss of electricity. Initial height of flare is 180m with a thermal radiation standard as follows:

• Thermal radiation in the restricted area is 6.31 kw/m2 (API Standard). The minimum radius of the restricted area is 60m to avoid injuring people in case of incidents

• Thermal radiation in the limited area is 3.18 kW/m2. The radius of the limited area is established at the Plant site.

Common flare system consists of hydrocarbon (HC) flare and acid gas (AG) flare:

• Hydrocarbon Flare System (main flare) Discharges from all relief valves (except Acid Gas Service) are routed to the HC flare system. A separate small diameter HC Purge Flare is provided to dispose of the continuous purge and low flow discharges and the HC flare is purged with nitrogen with pilots ignited. If low flow discharge gas is burnt at the large capacity HC main flares, the burn-back will occur and damage the flare tip. The design capacity of the HC purge flare is 10% of the design capacity of the HC flare or AG flare


88

capacity, whichever is greater. Flaring gas will be routed to the HC purge flare / HC flare by maintaining the different head in the HC purge flare seal drum and HC flare seal drum. The HC purge flare is steam assisted to provide a completely smokeless flare. When sour gas is flaring, smokeless steam will be stopped to avoid flame out due to low calorific value of acid gas. A Lighter Flare also uses steam assisted to create a completely smokeless flare during the maintenance period of the HC purge flare stack or other emergency situations. The HC purge flare and lighter flare are demountable and are housed in the same derrick structure.

• Acid Gas Flare System The AG flare system disposes of hydrocarbon releases which are toxic, potentially corrosive or difficult to combust. These include streams containing appreciable quantities of hydrogen sulphide. Hydrocarbon discharges containing more than a nominal 10 percent (vol) of hydrogen sulphide are routed to this flare system. Input of this flare is from CDU, GOHDS, KHDS, PRU, SRU, TGTU, ARU and SWS units. The flared gas may have a low heat of combustion. Assist (supplementary) fuel gas is added upstream of the knock-out drum via flow ratio control to achieve an acceptable degree of combustion. The same control loop will be used to stop smokeless steam injection to the HC Purge Flare when acid gas is flaring at a high rate. The flare is made of carbon steel. The receiving head is heated with steam to maintain a minimum temperature of 1100C in order to reduce condensation and erosion or dregs. A high temperature will support the H2S dispersion process in case of blazing up. The system will be directly connected to supported flares to burn acid gas. During AG flare maintenance, acid gas will be routed to the main flare. The HC purge flare is designed as a sour flare stack with steam tracing and insulation to avoid corrosion from acid gas.


89

Figure 3.11 HC/AG flare system


90

3.6.3.14 Fire and Gas Detection and Protection System The Project Fire and Gas Detection and Protection System is based on the assumption that there is no outside help to the Refinery and tank storage areas or the jetty and thus the fire fighting facilities on the sites will need to be self supporting. The Fire and Gas Detection and Protection System will consist of the following components: 1. Fire and Gas (F&G) Detection and Alarm

The F&G detection and alarm system will be designed as an integrated collection of F&G sub-systems. There will be four main sub-systems: one for the Refinery, one for Petrochemicals, one for Utilities and one for Offsite. Alarms from the sub-systems will be transmitted to the main Fire and Gas display panel in the Central Control Room (CCR) where the alarms will be displayed on a plant-wide F&G display. Synoptic panels providing an overview of F&G display will be installed in the fire station and main gate house. The F&G detection system on the jetty will be a standalone addressable system reporting to a main panel located in a CCR at the berth area or, if there is no common control building, in a dedicated shelter or building which would act as a fire fighting operations centre in the event of an incident. The F&G detection system for non-process area or buildings will be based on an addressable system. Any detector in a non-process area will be identifiable on the main F&G panel located in the CCR and any detector in a non-process building will be identified on the building fire and gas panel.

• Manual Call Points Every occupied building will have manual alarm call points (break glass units) located at all exit ways from each floor of the building. These units will automatically sound the building alarm bells. On site call points will be located along all roadways, generally spaced at intervals of 100 meters or less, and specifically at the exit ways from process units or tank storage bunds. Call points will be located at a maximum of 100 meter spacing along the jetty approach from the shore line to the berths themselves. On each berth a call point will be located at the entrance way to the berth and on the berth itself such that the travel to a call point from any location on the berth will not exceed 20 meters. Call points on the jetty approach will activate the alarm at the jetty control room only, however call points on a berth shall automatically sound the alarms on that berth in addition to reporting to the jetty control room panel. Buildings protected with sprinkler or deluge systems will rely on the heat detection alarm on the fusible bulbs in the water or pneumatic detection lines. Each open top floating roof storage tank will have fire detection provided by a heat sensitive cable set round the rim seal area on the roof.


91

Point type heat detectors will be located in all battery rooms in the Jetty area to alarm the building panel and sound the local alarm devices.

• Smoke Detection Point type smoke detectors will be installed in all general purpose buildings. The more sensitive point type infra-red type units will be fitted in computer rooms and control rooms. All buildings associated with the jetty operation will be fitted with smoke detectors which will sound the local building bell and report to the jetty fire and gas alarm panel.

• Flame Detection Infra-red flame detectors will be located to view pump rows where hydrocarbons are handled, the sphere storage facilities and associated pumps and the truck loading area. Any hydrogen risk on the site will have potential fire locations monitored by Ultra-violet flame detectors (not Infra-red units). Loading and unloading operations will be monitored by twin infra-red flame detectors which will be so located that they face each other. The area covered by these detectors will include all pumps, tanker hose connections, vapor recovery line connections and the adjacent hull section of the tanker at the berth.

• Gas Detection Three hydrocarbon gas detectors will be located in the air inlets to all Heating, Ventilating and Air Conditioning (HVAC) systems in all areas where a building is in the path of any possible hydrocarbon gas leak. Where there is a possibility of H2S gas being present, two H2S detectors will also be located in the HVAC inlet ducts. At the refinery, hydrocarbon gas detectors will be located in all pump houses and over pump rows where the pumps are handling hydrocarbon products, in all areas handling light hydrocarbons and adjacent to LPG spheres, in all compressor enclosures and at other major potential gas leak locations. Hydrogen sulphide point type detectors will be located at points where the gas can be present, for example at the seals of pumps handling products rich in H2S gas. Beam type hydrocarbon gas detectors provide an efficient method of detecting a gas cloud emanating from a process unit. All the berths will have suitably positioned beam type gas detectors to detect any gas drifting towards the shore or sources of ignition. Depending on the berth design it may be necessary to install more than one beam gas detector to adequately detect gas leaks during loading and unloading operations. A point type gas detector will be installed in the inlet of the HVAC system for the Jetty Control Room.


92

• Alarm Systems All buildings, including Analyzer houses, will be fitted with alarm bells to automatically sound on the initiation of a fire detector in the building itself. The process, tank storage, utility, road loading, packing, container storage and administration areas will be fitted with site sirens. Each berth will have a fire alarm, a gas alarm and a gas alarm flashing beacon located in a prominent location on the berth itself.

2. Fire Protection

The basic design is based on the requirements of the TCVN specifications that it should be possible to tackle two simultaneous fires on the Complex. This is achieved by utilizing both the fresh water pumps on site and the sea water pumps on the jetty area. In the event of an incident either at the Refinery or at the Jetty the first intervention will be by the site operators using the portable and fixed firefighting equipment, e.g. the portable extinguishers, hydrants, monitors, hose reels and fixed deluge systems. On the raising of an alarm, the fire station personnel and operators trained in fire fighting techniques will respond and fire fighting vehicles will travel to the scene.

• Fixed and Semi-Fixed Foam Systems Foam systems to all storage tanks other than the crude oil tanks will be fitted with such a fixed foam system. Each foam station will have a range of discharge flows available and may thus be utilized for more than one tank. Semi-fixed foam systems will be installed for the protection of the crude tanks with the foam solution being manufactured and supplied from the site fire vehicles. Fixed foam systems will be installed at the truck loading area and on the jetty and berth locations

• Safety Showers Safety showers will be located in process areas where there is a perceived risk. In particular they will be located close to any caustic or acid handling plant and any chemical store on site. The water flow in a safety shower will be 88 l/min. minimum.

• Portable Fire Extinguishers Portable and mobile fire extinguishers will be provided in all areas in accordance with TCVN requirements.


93

3.6.3.15 Waste Treatment System 3.6.3.15.1 Off-gas Treatment System 1. Flue Gas Desulphurization System with Sea Water The purpose of the flue gas desulphurization (FGD) is to remove SO2 out of off-gas from boilers before releasing into the atmosphere. Off-gas must meet allowed limits, the FGD system is designed with a capacity of 943,000 Nm3/hour. 2. RFCC De-SOx and De-NOx System The purpose of this system is to remove SO2 and NO2 out of emission gas generated from the RFCC before discharging it into the atmosphere. Treated gas must meet allowed limits. Treatment technologies used for this system are as follows:

• De-SOx unit: absorption by humid NaOH

• De-NOx: deoxidation by ammonia and catalyst (stable catalyst) De-SOx and De-NOx systems will be presented in detail in Section 6 – Mitigation Measures. 3.6.3.15.2 Effluent Treatment Plant 1. Effluent Collection System Waste water is classified, collected and managed up to their nature/feature by the following system:

• Clean process water: Clean water will be disposed directly without treatment. Disposal and regeneration effluents from the demineralization unit are considered as clean flow after being neutralized checked and may be directly discharged through the sea water circulation pipeline.

• Clean storm water (CSW): Storm water collected from areas of the Refinery where it not is possible that storm water be contaminated in normal operation. A storm water drainage system is designed to meet disposal standards without treatment.

• Accidentally oil contaminated waste water (AOC): Surface effluents (rain water, cleaning water) collected from areas where there exists a risk of water being contaminated. The drainage system in these areas has a preliminary cleaning tank designed to reduce treatment.

• Continuous oil contaminated waste water (COC): All effluents having oil content over 10mg/l need to be separated and treated by biological methods.

• Domestic waste water: Having a specific biological treatment plant. Furthermore, special effluents will be collected into specific systems before being routed to Effluent Treatment Plant (ETP), which include:

• Close Benzene contaminated waste water collection system in order to avoid dispersion of Benzene into the atmosphere.


94

• Spent caustic effluent collection system to moderate flow and prevent dispersion of H2S.

• Oil contaminated waste water collection system from the bottom of crude oil tanks will connect to the specific API system to remove oil. This system will serve other tanks if necessary.

Waste water from fire fighting activity will also be routed to AOC or CSW. All effluents from these systems will be temporarily stored in case of fire incidents, so they are kept in the Refinery. 2. Effluent Treatment Plant (ETP) The ETP is designed to receive and treat the following effluents in accordance with Project standards:

• Effluents from processes and support units in the Complex

• Effluents from storage tanks

• Effluents from operation, maintenance and devices in the administrative house area

• Effluents from devices at the harbor area. ETP is not designed to receive the following flows:

• Overflow clean water

• Waste water from the demineralization unit and other clean flows are considered to meet standards.

The treatment process of wastewater in the Refinery plant is summarized as follows: First Stage Treatment Process

• For sanitary wastewater Sanitary wastewater will be collected in the septic tank in the plant, then routed to the ETP plant by dedicated drainage for further biological treatment. The sanitary system septic tanks will require a vacuum truck service for sludge removal.

• De-oiled wastewaters Oily wastewater (via COC sewer and header) flows are collected in a flow balancing tank (Oily Water Equalization Tank), where gross oil contamination can be skimmed. A Corrugated Plate Interceptor (CPI) oil separator further separates solids and entrained oil from the wastewater, and additional oil removal is effected in a Flocculation Flotation Unit (FFU, also known as DAF – dissolved air flotation). Collected oil is sent to the refinery slop oil system and oily sludge is collected for treatment. The characteristics of CPI and outfall effluents are as follows:

• Discharge oil concentration to be less than 60 mg/l

• CPI to be designed with head space purge (swipe air) to the vent extraction fan for air emission control


95

Afterwards, the CPI effluents will be routed to the FFU, as the effluents will require further treating, for this unit.

• Coagulant and polymer dosing system to be provided.

• The coagulant and polyelectrolyte dosing rates will be optimized based on regular Jar Test and the initial design rates are 50 and 5 mg/L of Fe2(SO4)3 and active polymer respectively.

The characteristics of the first stage treated effluents are presented below:

• Output oil concentration must be less than 10 mg/l;

• Output suspended solids concentration must be less than 25 mg/l. The sludge from CPI and FFU units will be collected and treated at the sludge incinerator. The outfall effluent from the FFU unit will be continually routed to the ETP for further treating. Second Stage Treatment Process (ETP) The de-oiled wastewater is mixed with the sanitary effluent before passing to biological treatment. The plant utilizes a conventional activated sludge process with a contact chamber, a pre-de-nitrification reactor and aeration basins for COD and TKN oxidation, clarifiers and sludge and mixed liquor recycle. Waste sludge is sent to aerobic storage which is operated as a batch thickener to reduce sludge volumes. Tertiary Stage Treatment Process Two-staged tertiary treatment is required in order to meet strict effluent treatment Project standards. Initial physico-chemical treatment utilizing a coagulant and PAC (powdered activated carbon) will remove a significant part of the remaining COD. Sludge generated will be separated in a downstream clarifier before being routed for sludge treatment. Ozonation of the settled effluent is necessary to oxidize sufficient parts of the remaining COD to meet the discharge standard. Treated effluent flows to a treated wastewater tank that provides retention that is sufficient for analyses to be performed and the results to be confirmed before final discharge to the seawater return header. Effluent that does not comply with the discharge standards can be diverted to the guard basin. This basin also acts as a check basin for AOC flows in excess of FFB capacity and effluent can be stored by closing off the outlet and allowing the basin level to rise. Firefighting runoff from either the AOC or diverted from the CSW systems can also be retained in the same manner. The guard basin can also store partially treated effluent from the ETP by the use of a bypass header that allows diversion of partially treated wastewater from any process stage of the ETP for subsequent treatment. Oily sludge is sent to the oily sludge storage tank where they are steam heated to enhance oily water and solid separation in the downstream phase separator (such as a two phase hydro-cyclone). Separated oily water returns to the oily water storage tank for oil/water separation in the CPI. Sludge is combined with the thickened biological and tertiary sludge for dewatering before being incinerated.


96

In order to meet the Project air emission standards, especially for benzene and H2S, all equipment upstream of bio-treatment (ETP), including oily water storage tank, CPI, FFU/DAF, as well as the oily sludge storage tank are covered with the vent directed to a Bio-tower for benzene and H2S treatment and air emission control. Furthermore, the ETP will treat a great amount of wastewater coming from the hydrotesting process, high contaminated waste water generated from irregular maintenance, fire fighting water and process water that, not meeting the Project standards, will be required to be treated based on specific cases. The designed capacity of the ETP is 631m3/hour. The capacity is based on the normal averaged flow plus increased or intermittent discharges expected as part of normal refinery operation (back-washing, purging etc) and the contaminated storm water flow. Quality of treated effluent at the outfall of ETP will meet industrial wastewater discharge standards as shown in Table 2.7. The outfall system is proposed to be located at the offshore of the Nghi Son bay. Several types and dimensions of diffusers and risers will be carefully considered in order to maximize dispersion discharge volumes to the coastal environment. A general diagram of the treatment process for wastewater (ETP) is illustrated in Figure 3.12. 3. Separated Collection and Treatment System for Export Berth At the port, storm water from the floor area will be routed to the sea through a slope. Clean storm water will be allowed to discharge directly into the sea. Overflow water may be contaminated by oil and waste water from equipment maintenance processes at the export berth and will be collected in sumps. These sumps are large enough to contain the first contaminated water as well as overflow water in case of typhoons. Collected oily water will be treated to meet industrial wastewater discharge standards as shown in Table 2.7 before being discharged to the sea or routed to the main treatment plant. Treatment methods will be identified by the Contractor. Domestic waste water will be collected and treated intermittently to meet sanitary waste discharge standards as shown in Table 2.8 before discharge. 3.6.3.15.3 Incinerator The purpose of the oil residue incinerator is to burn residue oil (cleaning water/sludge from API, CPI, FFU/DAF), biological and chemical sludge from tertiary treatment process (iron sludge and activated carbon), waste oil and plastic powder from PPU into suitable ash for disposal. The incinerator is designed to burn 57,360 kg dehydrated sludge and 2,000 liters of waste oil and plastic powder in a day. Emissions from the incinerator must meet industrial source emission standards shown in Table 2.4. Other technical specifications such as resident time, destruction efficiency, etc., will be defined in detail during the engineering phase.


97

Figure 3.12 Scheme Effluent Treatment Plant (ETP) for NSRP project

Slu

dg

e

Oill

y w

ate

r

Bio

slu

dg

e

Fe

rric

/AC

do

sin

gSlu

dg

e L

iqu

ors

Slu

dg

e

Slu

dg

e

Slu

dg

e

Slu

dg

e

de

wa

terin

g

S

lud

ge

inc

ine

rati

on

FB

I

Inc

ine

rato

r a

sh t

o o

ff-s

ite

dis

po

sal

Tert

iary

tre

atm

en

t

ph

ysi

co

ch

em

ica

l

Tert

iary

tre

atm

en

t

o

xid

ati

on

No

rth

Tra

pe

zoid

al C

ha

nn

el

No

rth

Tra

pe

zoid

al C

ha

nn

el

Se

aw

ate

r O

utf

all

NN

F

NN

F

Gu

ard

Ba

sin

Sa

nit

ary

Se

wa

ge

N

orm

ally

op

en

va

lve

NN

F

N

orm

ally

no

flo

w

KE

Y:

Oily

wa

ste

wa

ter

FFB

Tre

atm

en

t

Sp

en

t c

au

stic

Cle

an

pro

ce

ss w

ate

r

ne

utr

alis

ed

de

min

re

ge

n w

ate

r

CSW

FFB

Ov

erf

low

Cle

an

su

rfa

ce

wa

ter

Se

aw

ate

r re

turn

Re

co

ve

red

oil

to d

isp

osa

l

Ae

rob

ic s

tora

ge

Bio

tre

at

Oily

slu

dg

e

Tre

atm

en

t

Flo

at

Slu

dg

eSlu

dg

e

Oily

flo

ats

FFU

CP

I

Oily

wa

ter

eq

ua

lisa

tio

n

Skim

me

d o

il

Tre

ate

d w

ate

r ta

nk


98

3.6.3.15.4 Waste Storage Area The waste storage area will be arranged by the Refinery for easy transport and storage of hazardous and non-hazardous wastes before delivery to an approved waste management area. The waste storage area is designed in accordance with waste generation rates and will have maximum storage duration of 90 days. An additional storage area will be provided for hazardous wastes that are untreated. The waste storage area inside the Complex is sited near the western fence and Coc Mountain (Figure 3.5). 1. Design Requirement

• The waste storage will be located in a downwind direction at a safe distance from the process units/ utilities and other building areas.

• The storage facilities will be designed and constructed in such a manner that risk of loss will be minimized.

• The hazardous waste storage area will be roofed with adequate ventilation and lighting arrangements and will meet building and fire code requirements.

• Flooring in the waste storage area will be impervious and sloped to facilitate proper drainage and collection of spilled liquid. A liquid waste collection system comprised of a drainage channel, wastewater sump and pumping system, will be provided for collection of liquid waste spilled from the storage area.

• The area around the storage area will be properly kerbed to prevent any leakage of spilled material from the storage area and to control the runoff water flowing into the storage area.

• The storage area will be divided into different categories according to the chemical characteristics of the hazardous wastes and provision will be made for isolated storage of reactive, flammable and toxic wastes.

• Materials of construction of storage facilities will be consistent with the safe long term storage of the chemicals or wastes under consideration.

• Changes in the chemicals or wastes to be stored in a given facility will not be permitted until a competent assessment has been made of the suitability of the facility for such a change in service.

• The degree to which measures are taken to ensure the integrity of a storage facility will be dictated by the severity of the potential environmental, health and safety effects of the loss of the product to be stored.

• Where possible, storage facilities will not be located where, in the event of a spill, waste product may enter a natural watercourse or a sewage or drainage system, or contaminate potable surface or groundwater supplies, or contribute to air contamination and bad odor.

• Emergency measures such as eye wash fountains, deluge showers, etc. must be provided and maintained in good repair, commensurate with the identified level of risk.

• Adequate fire protection system will be provided to handle fire emergency arising from flammable and reactive wastes.


99

2. Safety Requirements The following are some of the key safety requirements for the Waste Storage facility:

• Access to and exit from the storage facility will be restricted either through locked gates, doors, or both. A sign visible from 8 m (25 feet) distance away will be placed on all access roads and entrances to the storage facility. The sign will state: "Danger - Unauthorized Personnel Keep Out".

• Personal Protective Equipment (PPE) should include the use of impervious gloves ( type and material), coveralls, boots (rubber or safety), eye protection (safety glasses/chemical goggles), details of respiratory equipment (particulate respirator, half face piece respirator, full face piece respirator, self contained breathing apparatus or supply air respirator certified by NIOSH) if required.

• Eyewash/deluge showers will be provided within 10 seconds and within 100 feet of travel distance for both long- and short-term storage facilities (in conformance with Emergency Eyewash and Shower Equipment, ANSI Standard Z 358.1-1981).

• Only non-leaking containers that are safe to handle and correctly labeled will be stored in this facility. The containers will be stored according to type and in such a manner as to facilitate inspection and removal with a minimum of handling.

• Worker training in the proper use, care and maintenance of any required personal protective equipment, including fit testing of respiratory equipment, if used, must be provided.

3.6.3.16 List of Main Equipment of the Refinery A list of main equipment will be attached in a separate annex of the Project. At present, the Project is at a tender phase. After the EPC contract is signed, the Contractor will implement a detailed design and choose equipment suppliers. NSRP LLC has committed that all equipment used for the Project are new, modern and provided by globally recognized suppliers. 3.7 OFFSITE FACILITIES 3.7.1 Marine Facilities The development of the harbour is divided into two phases as follows: Phase 1: A temporary construction jetty (TCJ) will be constructed. This facility will be used for the development of the Refinery and Petrochemical Complex and thus for the import of the needed equipment and material. Phase 2: The marine harbour elements will be constructed, comprising (Figure 3.13):

• The north breakwater

• Four berths (two berths per jetty) for export gasoline, jet fuel, diesel, paraxylene and benzene) (2a, 2b, 4a and 4b)

• One berth for the export of LPG (3)

• Berthing facility for service vessels/tugs

• One berth for transfer of sulphur (dry bulk) (1a)


100

• One berth for the transfer of polypropylene (containerized) (b)

• Harbour access channel and turning basin (dredged by Vietnamese Government)

• Harbour revetments

• Navigational aids

• SPM

• Intake and outfall structure for cooling water. After this stage, the harbour will be able to accommodate vessels up to 30,000 DWT.

Figure 3.13 NSRP Port Layout

The Nghi Son harbour layout comprises the following main elements:

• Onshore area (refinery site)

• Main breakwater (north of harbour basin)

• Access channel (outer section, bend and inner section)

• Turning basin

• Product berth areas (1, 2, 3, 4)

• Service (vessel) berths

• Construction berths

• Future developments (future jetties and breakwater). Some main bathymetric information in the port area is summarized below:

• Harbour basin: The depth contours run approximately parallel to the shoreline up to a depth of about CD – 9 m. The harbour basin (up to and including turning basin) will be built in depths ranging from about CD + 0 to CD – 5 m


101

• Main breakwater: The northern breakwater head is located at a seabed level of about CD – 5.5 m

• Access channel: The end of the access channel (adjoining the turning basin) is located in a natural depth of about CD – 4.5 m. The start of the access channel is located at a seabed level of CD – 13.2 m. From depths of CD – 9 m to – 13.2 m the depth contours are oriented more obliquely to the shoreline.

In the future, the largest vessel expected in the harbour will be a 50,000 DWT vessel. In the present design of the harbour layout, additional space reservation (e.g. larger required channel width) is taken into account. Additional capital dredging will be required for widening and deepening the access channel, turning basin and berth 4. 3.7.1.1 Access Channel An access channel with 6,200m length is designed to facilitate entry of vessels up to 30,000 tonnes. The access channel is split into two straight sections by a bend located at a distance of about 2.2 km offshore:

• Outer channel section: This is the section from deep water in west-south-westerly direction (247°) towards the harbour up to the bend. It has a length of approximately 4,375m. Over the last 600 m the channel widens up to the required bend width.

• Inner channel section: In the bend the channel direction turns to the direction of 273°. From the end of the bend up to the turning basin the channel width is maintained equal to the bend width in order to avoid any alignment transitions in this section (i.e. narrowing from bend width to straight channel width and subsequently widening again into the turning basin). As the channel width of this straight section is larger than required, additional channel widening into the turning basin is not applied. The inner section length including bend is approximately 1,825m.

The access channel will have the following dimensions:

• Inner channel length: 1,180 m

• Channel bend: 645 m

• Outer channel length: 4,375 m

• Channel bend width: 150 m

• Radius of the bend: 1,215 m

• Channel width: 120 m

• Channel depth: -13.2 m

• Overdepth: 1.0 m In the future the largest vessel will increase to 50,000 DWT. Consequently, the required nautical depth increases to CD – 16.2 m, channel width increases to approximately 150 m and additional capital dredging will be required.


102

An over-depth of 1.0 m is recommended and applied in the design. This means that, in principle, maintenance dredging is not required in the first 4 years after completion of the port. 3.7.1.2 Turning Basin The centre of the turning basin is located at approximately N 19o 22’ 0.78”, 105o 47’ 56.24”. The diameter of the turning basin is 360 m. The nautical depth of the turning basin is CD – 12.1 m. In the future the nautical depth of the turning basin will increase to CD – 14.85m for the 50,000 DWT vessels. An over-depth of 0.5 m is recommended and applied in the design of the harbour basin areas. This means that in principle, maintenance dredging is not required in the first 4 years after completion of the port. 3.7.1.3 North Breakwater Breakwaters are used to create sheltered areas where marinas, ports or entrance channels are located. The breakwater function is to reduce waves in the sheltered area to an acceptable level. The general characteristics of the breakwater are:

• Length of the breakwater: 1800 m

• Crest level: CD +9 m

• Crest width: 12 m

• Slopes of 1:2.5

• Average water depth of CD -3 m

• Average layer thickness of soil improvement of 5 m

• Primary armour layer thickness for the trunk (3.0-6.0 tonne rock): 2.4 m

• Primary armour layer thickness for the head (4.0-7.0 tonne rock): 2.6 m

• Secondary armour layer thickness (0.3-1.0 tonne rock): 1.2 m

• Quarry run core 3.7.1.4 Harbour Revetments Shore protection is anticipated alongside the shore, including underneath both jetties alongside the shore. Rock revetments protect the slope (from the sea bed up to the reclamation level) against erosion by wave action. 3.7.1.5 Berth Pockets There are 7 product berths (Table 3.20) for exporting liquid products or dry bulk and containers. Five berths are located at a jetty with loading platforms. The two others are individual loading platforms. These berths will provide all facilities and installations for safe and reliable operations at the required capacity. The berths will be suitable for a range of vessels up to 30,000 DWT and up to 50,000 DWT in future developments.


103

Table 3.20 Dimensions of Berth Pockets

Berth pocket Length (m) Width (m) Nautical depth (m CD)

1a 203 42 – 9.25

1b 188 43 – 8.50

2a/2b 170 22 – 8.25

3 133 31 – 6.40

4a/4b* 252 (281) 50 (65) – 12.1 (14.85) Note: * Based on 30,000 DWT vessel. Between brackets are the values based on the future 50,000 DWT vessel

The areas between the berth pockets and the tuning basin must have a sufficient depth (not less than CD -12.1m at turning basin and not less than the required nautical depth mentioned in Table 3.20 for each berth pocket) to allow safe vessel maneuvering from and to the berths and avoid grounding. Similar as for the turning basin, an over-depth of 0.5 m is applied in the other harbour basin areas. Two jetties are envisaged alongside the shore: the first (berths 1a and 1b) will be for the export of solids (sulphur and polypropylene) and the second (Temporary Construction Jetty TCJ) will be temporary and will be used for the offloading of the construction materials for the refinery. Three jetties will be located in the harbour basin (jetties 2, 3 and 4) and a fourth jetty is optional (jetty 5). Jetty 2 is for small vessels, 3,000 – 10,000 DWT (two berths 2a and 2b), jetty 3 is for tankers that carry pressurized LPG, 1,000 – 3,000 DWT. Finally, jetty 4 (and the optional jetty 5) will be used for the biggest vessels, up to 30,000 DWT (two berths 4a and 4b). In summary:

• Berths 1a/1b: are envisaged alongside the shore. Berth 1a (north) is designed to accommodate dry bulk carriers exporting sulphur, ranging from 10,000 to 15,000 DWT. Berth 1b (south) will be for exporting polypropylene, with carriers ranging from 5,000 to 10,000 DWT.

• Berths 2a/2b: will be used to handle gasoline, jet fuel, diesel, fuel oil, paraxylene and benzene. The tanker sizes will range from 3,000 to 10,000 DWT.

• Berth 3: will be used for exporting LPG, with carriers ranging from 3,000 to 5,000 DWT.

• Berth 4a/4b: will be used to handle oil product tankers, meant for the transport of white products. The products are gasoline and diesel. The tanker sizes will range from 5,000 to 30,000 DWT.

• Berth S2 (future expansion): is designed to handle oil product tankers, meant for the transport of white products. The tanker sizes will range from 3,000 to 50,000 DWT.

3.7.1.6 Dredging Activities Based on the harbour layout, the required dredging depths and the existing bathymetric information, the required capital dredging volumes are determined. These volumes are also divided in the dredging volume to reach the nautical depth as well as the volume of dredging the overdepth. The dredging volumes for the harbour basin and access channel are summarized in Table 3.21.


104

Table 3.21 Estimation of Capital Dredging Volumes at NSRP Harbour Area Dredged Area

[m2] Nautical Depth Dredge [m3]

Over-depth Dredge [m3]

Total Dredge Volume [m3]

Area 0 26,500 129,514 13,250 142,764

Berth 1 124,700 1,018,468 62,350 1,080,818

Berth 2 110,100 666,210 55,050 721,260

Berth 3 54,200 168,639 27,100 195,739

Berth 4 262,700 2,472,043 131,350 2,603,393

Construction berth 41,737 227,560 20,869 248,428

Side slope shore 40,684 160,949

Side slopes other 84,309 359,180

Total harbour basin 744,930 5,512,531

Channel 790,800 3,000,316 790,800 3,791,116

Slope channel offshore 216,050 412,466 412,466

Slope channel nearshore 182,175 651,700 651,700

Total channel 1,189,025 4,855,282

Grand total volume of capital dredging 10,367,813 Source: Technical doc. Provided by FWL, 30 October 2009 (Doc. No. 9T7151/R049)

Capital dredging volume, including overdepth quantities, will be approximately 10.4Mm3 in which 4.9M m3 will be dredged at the access channel and 5.5 M m3 at Harbour Basin. 3.7.2 Single Point Mooring (SPM) The Single Point Mooring (SPM) will be located 35 km from the shoreline to avoid dredging a very large approach channel and affecting environmental sensitive areas (coral reef). Crude will be unloaded via 300,000 DWT tankers. The offshore element typically consists of a mooring and fluid transfer system (SPM), connected by means of a subsea pipeline to the facility onshore. The SPM mooring system enables the vessel to freely weathervane in response to the wind, wave and current conditions, thus enabling it to offload even under relatively adverse conditions. The SPM system, which is a type of Catenaries Anchor Leg Mooring (CALM) system, will be used for importing crude oil from Very Large Crude Carrier (VLCC) tankers and will send it to a plant storage area via 48” subsea pipeline. The design life of the SPM system is 25 years. The SPM main components include the following facilities (Figure 3.14):

• Mooring buoy

• Anchoring System

• Anchor legs

• Pipeline End Manifold (PLEM)

• Floating Hose Strings

• Under Buoy Hose Strings


105

Figure 3.14 SPM Main Components

The SPM, the riser from the SPM, and the subsea pipeline end manifold (PLEM) will be coated and cathodically protected. 3.7.3 Crude Oil Pipeline The crude oil pipeline has been designed 3.7 km away from Hon Me archipelago to avoid the environmentally sensitive coral reef(see Figure 3.4). The crude oil pipeline will be a 48” double pipeline (with a inter-distance between the two parallel lines of about 43.5 m). The pipeline route starts at pig trap locations at the plant crude oil storage area and ends at the offshore SPM. Crude oil is transferred from tankers through the SPM to the double pipelines running towards the plant storage area. The total length of the crude pipeline system is 35 km in which there are 33 km offshore and 2 km onshore. The pipelines will be divided into three sections as follows:

• The onshore pipelines which will be buried along their route

• Near shore sections of the pipelines route will also be trenched and backfilled to protect the lines against human activities and wave/current forces

• Offshore pipelines will terminate at PLEM flanges to provide a connection to the SPM. The pipeline pressure is designed against pipeline incidental pressure. The pipeline design pressure will be considered as a multiple of maximum allowable operating pressure (MAOP) with a logical margin of not less than 10%.


106

3.7.4 Product Pipeline

Product pipelines will be used for exporting liquid products. The pipelines will accommodate to a pipe bridge. The pipelines will be coated externally with a protective painting system, with two layers to avoid corrosion. There will be nine product pipelines (one pipeline per product) for liquid product loading from the plant to the Jetties and one pipeline for the return of LPG vapor to plant. Based on product specifications and exported volumes through the jetties, product pipeline sizes (Table 3.11) are designed at 12” for LPG, 14” for jet fuel and Benzene, 16’’ for fuel oil and Paraxylene and 24” for Gasoline (92 & 95) and Diesel (Premium and Regular).

3.7.5 Ship Loading System A ship loading system will be provided to export 95% of LPG, Gasoline, Diesel & Fuel Oil and 100% of the remaining products by ship. Liquid products There will be 11 dedicated single product loading arms and 12 shared loading arms. Loading rates and pipeline sizes are given in Table 3.22.

Table 3.22 Loading Rates and Loading Ship Capacity

Product Loading Rates (m³/h)

Product Pipeline Size (inches)

Normal Loading Ship Capacity (DWT)

Maximum Loading Ship Capacity (DWT)

LPG 600 12 1,000 - 2,000 3,000

Gasoline 92 3,000 24 3,000 - 30,000 30,000

Gasoline 95 3,000 24 3,000 - 30,000 30,000

Jet Fuel 600 14 3,000 -5,000 5,000

Premium Diesel 3,000 24 3,000 -30,000 30,000

Regular Diesel 3,000 24 3,000 - 30,000 30,000

Fuel oil 500 16 3,000 -5,000 5,000

Benzene 750 14 3,000 6,000

Paraxylene 1200 16 5,000 10,000 Source: FEED document provided by FW in October 2009 All liquid products will be transferred from the NSRP Refinery to the jetties in dedicated product pipelines. All product dispatch through the jetties will be made directly by pumping from respective storage tanks at the Refinery. Solid products The solid sulphur from the bulkhall will be reclaimed and moved to the ship by the export conveying system (including Sulphur Export Weigher) to feed the ship loaders.


107

Polypropylene will be received in pallets from the refinery and will be exported by 10,000 DWT ships from the solid export berth. 3.7.6 Product Truck Loading System The Product Truck Loading System is designed for 5% of liquid products. The loading system is located inside the Refinery. The truck loading facilities are designed to achieve the following:

• Receive finished products (LPG (future), Gasoline RON92, Gasoline RON 95, Premium Diesel, Regular Diesel and Fuel Oil (future) from tanks within the Product Tankage area

• Load products into trucks using top loading /bottom loading (for LPG future) system

• Loading will be undertaken for 12 hours per day and 6 days a week for LPG, and 12 hours per day and all 7 days of the week for other products.

The truck size required is a 16 m3/truck for all products, except for a 20 m3/truck required for LPG in the future. The estimated number of trucks required is 72 trucks per day. 3.8 REFINERY LAYOUT AND PLOT PLAN PHILOSOPHY A general layout of the NSRP complex is presented in Figure 3.15:

Figure 3-15 Layout of NSRP Refinery and Petrochemical Complex Areas of the facilities are assigned as follows:

• Administration area: 14 ha

• Technology area: 88 ha

• Support area, flare and ETP: 41 ha

• Tankage area: 118 ha


108

• Processing/Packing area: 14 ha

• Other areas: 39 ha

• Barrier area: 10 ha

• Planting area: 49 ha The plot plan philosophy is based mainly on safety reasons and minimizing land acquisition, as discussed below. 3.8.1 Process Area

• The process units should be located on an area with good geology in order to minimize the time and cost for construction of civil works.

• The units which process flows and connect to each other should be located in close proximity in order to allow operation of all units in a short time.

• To reduce the likelihood of heat dissipation and to reduce the piping costs, the associated units should be located nearby.

• A road is needed around the process unit. One main centre road is also needed for maintenance, transfer of large equipment and fire fighting.

• Those facilities which require chemicals, or catalysts on stream, or produce waste products should be located along the process area road in order to have easy access to vehicles.

• The road around the process area should be designed for the transfer of heavy machines, equipment and fire engines, and be easily accessible.

3.8.2 Tankage Area

• Crude oil tanks should be located to the Northeast in order to minimize the length of the crude pipeline between tanks and the SPM.

• Product tankage should be located to the East side area in Area-B in order to minimize the length of the product pipeline between tanks and the Jetty.

• Intermediate tankage should not be located far from the process area in order to minimize the length of the pipeline between intermediate tankage and process unit.

• LPG tankage should be located as far as possible from process units to minimize explosion hazards.

• Similar property tankage should be located in one dike in order to reduce the total tankage number.

3.8.3 Administration Area, Control Building and Truck Loading Area

• The Administration and Control Building will not be located downwind or down slope from the process area in order to avoid emissions from the process area itself.

• The Administration and Truck Loading Area should face a public road in order to ensure easy access without passing through the plant area.

• The Administration Area should be minimized in order to reduce the total area of the Refinery.


109

3.9 PROJECT CONSTRUCTION It is anticipated that the Engineering, Procurement and Construction (EPC) Contract will be awarded to a Consortium of Contractors to undertake the EPC of the NSRP Project. The Consortium will consist of a number of experienced international EPC Contractors well recognized as leaders in the EPC contracting industry.

3.9.1 Onshore Construction Massive land development is being carried out by the Vietnamese Government to ensure the appropriate quantity and quality of ground is available for project development. This includes relocation of dwellings, site filling and site preparation. The construction activities for these works are mentioned in other reports (see section 1, item 1.4) prepared by the authorities, and therefore they are not included in this ESIA Report. There are no existing foundations or underground obstructions including rock formations in the plant site area. Soil improvement measures may be required by the EPC Contractor prior to construction. Foundations for the Project consist of the following types:

• Major equipment, buildings and structure foundations will be piled

• Minor equipment and pipe supports will be on ground bearing foundations. For tankage area, construction methods may be summarized as follows:

• Tank foundations will be prepared by the civil contractor. The civil contractor will present the prepared ground to the tank contractor for review and acceptance.

• The tank manufacturer will prepare pre-assembled sections of the tank, including the roof, in a preassembly workshop away from the NSRP site. Each pre-assembled section consists of flat plates which are formed and welded into circular courses of around 2.5 m each in length. Each course will be fitted with nozzles, ladder and platform clips etc. as required.

• The preassembled circular courses (layers) and all other raw materials including piping, flanges, welding consumables, lining materials, painting materials etc. will be delivered to a lay down area at the NSRP site.

• The bottom plate (floor plate) and annular plate will be welded in situ, in sections.

• The first circular course will be lifted into place and welded to the bottom plate and annular plate in situ.

• Each circular section will be lifted into place and welded to the section below.

• As the height of the tank increases, scaffolding will be erected to provide access for welding and NDE of the circumferential joints and for fitting of piping etc.

• The final top section and fixed roof or floating roof will be fitted.

• Each circumferential and longitudinal weld will be subjected to RT, UT, magnetic particle, and dye penetrated as required by the code and project requirements.

• All external fittings, stairways, ladders, platforms, and hand railings will be installed.

• Water Spray Cooling Systems, Tank Foam Systems, Tanks Roof Drain Systems, and Floating Roof Seal System will be fitted and tested.

• All internals, mixers etc. will be fitted.


110

• Tanks will be filled with hydrotest water and tested with positive air pressure when required by code requirements.

• The internal surfaces of the tank will be prepared for lining and lining will be carried out per code and Project requirements.

• The external surfaces of the tank will be prepared and prime and finish painted in accordance with Project requirements.

It should be noted that different tank manufacturers will have varying methods for site fabrication of storage tanks. Fabrication method statements will be reviewed and agreed upon prior to the tank manufacturer commencing work. The onshore section of the 48” crude inlet pipeline will include electrical isolation facilities at the refinery boundary interface and at the interface with the subsea section. All product pipelines connecting the plant to the jetties are buried and coated externally with three layers of polyethylene pipe coating systems. Each pipeline will have above ground isolation joints at each end and be provided with impressed current cathodic protection. The estimated number of heavy equipment units used in the construction phase is presented in Tables 3.23 and 3.24.

Table 3.23 Estimated Number of Equipment used in the Construction Phase

Device Maximum Quantity (piece) Average Quantity (piece)

Heavy crane and equipment 3 2

Chain roller and crane (200-600 tons) 6 4

Chain roller and crane (100-200 tons) 16 10

Mobile crane (up to 100 tons) 35 23

Transport truck and bulldozer 15 10

Unloading truck 10 7

Shovel 12 8

Excavator 25 17

Water tanker 8 5

60-seat bus 183 122

Others 150 100

Total 463 308 Source: Technical Document No.3550-8710-PR-003 provided by FWEL, August 2009

Table 3.24 Estimated Number of Excavators. Bulldozer, Rollers and Graders

Device Maximum Quantity (piece) Average Quantity (piece)

Unloading truck 254 170

Excavator 48 32

Bulldozer 51 34

Roller / Press 32 21

Grader 10 7

Watering cart 30 20

Total 425 284 Source: Technical Document No.3550-8710-PR-003 provided by FWEL, August 2009


111

3.9.2 Offshore Construction Crude Pipeline System The pipeline construction methodologies are different between offshore pipelines and shore approaching. For offshore crude pipelines, the following procedures will be applied:

• Pipe delivery and preparation including field joint coatings, cathodic protection, line pipe delivery to the barge and preparation for welding

• Pipeline fabrication: the work stations will be arranged approximately every 12 m along the side of the barge, matching the length of individual pipe sections such that a welded joint can be found in every station

• Pipelay operations including overbend control, sagbend control and buckle detector

• Initiation of pipelay including pipelay startup and dead man anchor start-up. For shore approaching, the laybarge will be set up over the right-of-way centreline with its stern towards the beach. This will depend on the laybarge draft and its operation period. Dredging may be carried out to provide an approach channel for the barge so it can come closer to the shore. Particularly, shallow water anchor handling vessels may be used to set the barge's anchors. Main procedures for shore approaching include:

• Trenching and backfilling

• Pipe pulling operation

• Anchorage construction (for pull-to-shore) PLEM Tie-In Tie-in activities at the offshore end of the pipeline will depend on the installation phase of the SPM and PLEM. The main procedures applied for the PLEM tie in will be as follows:

• Lay-down Near PLEM It is important to ensure that the end of the pipeline lands on the seabed at the target location. The engineering design and barge positioning systems will control the approach direction of the pipe route such that the heading of the pipeline at lay down is correct. It then remains to ensure that the length of the pipeline laid is such that the end of the pipeline arrives in the right place. This is achieved by using the laybarge navigation and positioning systems to accurately monitor the location of the barge.

• Lay-down Head The lay down head for the oil pipeline is designed to take in the full pipeline test pressure. The 48” lay down head will be fitted with a valve and check valve. This arrangement will allow air from the pipeline to escape. However, it will prevent seawater from the outside to enter the pipeline. During lay down of the pipeline the valves are closed.


112

• Spool Tie-in The spool piece and the PLEM will be connected using flanged joints. After flooding and any testing of the pipeline in accordance with project requirements, the flanged lay down head will be unbolted and recovered to the surface. Divers will take accurate measurements between the pipeline end flange and the PLEM tie-in flange.

Northern Breakwater

A land based construction method is considered most likely for the construction of the breakwater. It will be decided by the EPC Contractor and be based on technical studies such as geological conditions and construction time. The core of the breakwater will likely be constructed using dump trucks in a land based construction method. Starting from land, trucks dump their load into the water. Excavators are used for rock placement and shaping. The construction seawards is continued using the already placed section at the construction road. The armour layers of the breakwater are placed by large land based cranes. Harbour Revetments A rock armour will be installed at the slope for protection, at different layers. The largest rock is the primary armour layer of the revetment while the internal layers are appropriately sized to prevent migration of underlayer material through the armour layer. The core and the filter are made of granular material (quarried rock). The revetments will be built using a land based construction method. The rock for the revetments is placed by long reach excavators or cranes from the new reclaimed/profiled strip of land. Approach Channel and Harbour Basin

It will be necessary to dredge the approach channel and harbour basin in order to make it suitable for vessels to navigate and to be accommodated (3,000 up to 30,000 DWT). The equipment required for dredging will be a cutter suction dredger (CSD). This device has a cutter head at the suction inlet, to loosen the sea bed material and transport it to the suction mouth. The cutter can be used for hard surface materials such as gravel or rock. It can dredge in willow water. The dredged material is usually sucked up by a wear-resistant centrifugal pump and discharged through a pipeline or to a barge. Jetties

The Construction Jetty is currently estimated to be 300 m wide and will include one or more finger jetties to accommodate a number of flat top, low draft, barge carrying bulk cargoes. A marwilling area, approximately 300 m wide, will be constructed immediately behind the construction jetty to allow expeditious offloading and turnaround of ships and to consolidate materials and equipment for transportation to the site.


113

Haul roads will be constructed from the construction jetty to the site for the transportation of materials and equipment, and will be designed and constructed for heavy and large loads. Both jetties 1 and the temporary construction jetty (TCJ) consist of a deck on piles extending from the shore. Underneath the deck, the slope to the shore is protected by a rock revetment. The three jetties that are not attached to the shore consist of an approach bridge, a jetty head and berthing and mooring dolphins. The jetty head (also called the platform) and access bridge structures mainly consist of a concrete deck founded on (most likely steel tubular) piles. Marine based construction is considered most likely for the access bridges given the size of the spans. For the platforms the length of the spans is considerably smaller, and therefore a land based construction method is possible. The piles of the jetties (both access bridges as platforms) will be driven into the sea bed using floating equipment. This floating equipment consists of a rig with a diesel of hydraulic pile hammer and an additional crane to lift the piles into position for the piling crane.

3.9.3 Supply Source of Construction Material

As mentioned in Section 1.4, all compensation activities, site clearance and leveling are carried out by the Vietnamese Government, and therefore they are not part of the scope of this ESIA. Materials for site leveling are taken from borrow pits which are nearby the Project area (such as Chuot Chu, Dong Vang Mountain, etc.). The major exploitation equipment are excavators and graders. Transport of materials is by trucks of 10-15 tons. During the construction phase, the EPC contractor will select suppliers for chemicals, materials and equipment for the project; therefore NSRP-LLC does not have detailed information at this stage. Almost all of the chemicals, materials and equipment will be transported by ships to the eastern portion of the project. Other material will be transported by trucks through the national road 1A and the provincial road 513. 3.9.4 Accommodation Facilities for Construction and Operation Workers It is currently envisioned that NSRP will not provide workers’ accommodation for EPC Contractor and its Subcontractors. However, NSRP will require the Contractor to build it in accordance to best safety practices. The estimated number of labour force for the construction and operation phases is presented in Table 3.25.


114

Table 3.25 Estimated Number of Employees Working for NSRP

Work force

Construction phase (person) Operation phase (person) Average Maximum

Direct and indirect labour 21,862 32,795 1,700*

Source: Technical Document No.3550-8710-PR-003 provided by FWEL, August 2009 Note: *1700 employees in the operation phase including: 900 people managed directly by NSRP LLC; 600 people managed by NSRP LLC’s Contractors and

200 international specialists. 600 people managed by contractors are outsourced service labour, so NSRP LCC have no orientation to reduce it. However, the Company is considering reducing the number of expatriates in the operation phase. It is very difficult to provide a schedule at this time because it depends on the capacity of local labour to comprehend the complex operation and management.

The currently estimated total manpower figures for EPC Contractor, Construction Subcontractors, NSRP LCC and its PMC are nearly 33,000 at its peak and the requirement for space to accommodate this number of persons is estimated to be 730,000 m2. The optimum location of accommodation camps is driven by a number of key considerations, including topography and suitability of available land, distance from site, quantitative risk assessment issues associated with the introduction of hydrocarbons at site during commissioning and in the future, safety and other issues associated with conditions of routes and roads. As indicated above, the EPC Contractor will be responsible for building workers’ accommodation camps following good practice and safety, as a requirement of NSRP LLC. The accommodation camps will include, but are not limited to, the following:

• Temporary access and egress roads

• Temporary lighting

• Drainage facilities

• Security gatehouses and associated facilities, including road and pedestrian barriers, fencing and lighting

• Parking areas for mass transportation buses, cars, motorbikes and bikes

• Kitchens, canteens and mess halls

• Camp management offices

• Sleeping quarters

• Bathrooms and toilet facilities

• First-Aid and medical treatment facilities

• Fire-fighting

• Emergency response and evacuation facilities, including vehicles

• Temporary utility distribution facilities for electrical power, potable water and telecommunications

• Potable water storage facilities

• Waste water and sanitary sewage collection, treatment and disposal facilities. The construction camps will be located near the Project site, and as remote as possible from adjoining communities. The expected safety and hygiene features and living conditions for workers camps will comply with International standards, as well as Vietnamese National standards (see section 8).


115

The NSRP LLC will rent buildings constructed by NSPM in Xuan Lam commune for NSRP staff's accommodation during both construction and operation phases. The area is 25ha and 15km away from the Plant.

nsrp refinery plant environmental impact assessment

Documents

nghi son refinery

refinery operation

major oil refinery

offsite facilities

petrochemical production

nsrp project

vietnam oil

general facilities