Flood Damage Emergency Reconstruction Project Output 3: Irrigation and Flood Control

Transcription

1 Ministry of Water Resources and Meteorology (MOWRAM) Asian Development Bank Cambodia Flood Damage Emergency Reconstruction Project Output 3: Irrigation and Flood Control ADB Loan Number : 2852-CAM(SF) AusAID Grant Number: 0285-CAM(EF) SUB-PROJECT PROFILE PHDAV CHUM Version 1 AUGUST August 2012 In association with KEY CONSULTANTS (CAMBODIA)

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3 Document quality information Document quality information General information Author(s) Project name Document name Date 22 August 2012 Reference FDERP-MOWRAM TA; EGIS EAU / KCC Flood Damage Emergency Reconstruction Project Output 3: Irrigation and Flood Control PHDAV CHUM SUB-PROJECT PROFILE FDERP-SPP Addressee(s) Sent to: Name Organisation Sent on (date): H.E. Ponh Sachak PIU 23/8/12 Copy to: Name Organisation Sent on (date): PCMU ADB History of modifications Version Date Written by Approved & signed by: Control Page 3 Version 1

4 Contents Contents Chapter 1 - INTRODUCTION Background Purpose of report...9 Chapter 2 - SUB-PROJECT DESCRIPTION Description and history Flood Damage Location Existing Situation Description of the facilities Socio-economic and Agriculture Area Beneficiaries / O&M Population Hydrology Chapter 3 - SCOPE OF WORKS Design Approach Repairs Cost estimate Photos...17 Chapter 4 - SUB-PROJECT SCREENING Resettlement Resettlement Impact Categorization Check-list Environment Environmental Assessment and categorization Chapter 5 - CONCLUSIONS Screening Proposed interventions...21 Control Page 4 Version 1

5 List of Tables List of Tables Table 1 Community data...11 Control Page 5 Version 1

6 List of figures List of figures Figure 1 Figure 2 Location Map for Phdav Chum...13 Satellite Image showing dyke and N6 highway...14 Control Page 6 Version 1

7 List of appendices List of appendices Appendix 1 Involuntary Resettlement Impact Check-list...22 Appendix 2 Screening of potential environmental impacts...23 Appendix 3 Sketches of typical profile and cross-section of dyke...27 Appendix 4 Hydrology for Phdav Chum...29 Control Page 7 Version 1

8 Acronyms and Abbreviations Acronyms and Abbreviations ADB AusAID CARM EA FDERP FWUC IA IEE MEF MOU MOWRAM O&M PAM PCMU PDWRAM PIU PP RGC ROW RRP SAH SPS TA TOR Asian Development Bank Australian Agency for International Development Cambodian Resident Mission (of ADB) Executing Agency Flood Damage Emergency Reconstruction Project Farmer Water User Community Implementing Agency Initial Environmental Examination Ministry of Economy and Finance Memorandum of Understanding Ministry of Water Resources and Meteorology Operation and Maintenance Project Administration Manual Project Coordination and Monitoring Unit (MEF) Provincial Department of Water Resources and Meteorology Project Implementation Unit Procurement Plan Royal Government of Cambodia Right-of-way Report and Recommendation of the President (to the board of directors) Severely Affected Households Safeguard Policy Statement Technical Assistance Terms of Reference Control Page 8 Version 1

9 SUB-PROJECT PROFILE-PHDAV CHUM Chapter 1 - INTRODUCTION 1. Background Following the 2011 floods in Cambodia that caused widespread damage to infrastructure, the Government of Australia and ADB has approved funding under the Flood Damage Emergency Reconstruction Project (FDERP) to assist the Royal Government of Cambodia (RGC) with implementation of repairs. The Project includes restoration irrigation scheme facilities to be implemented by the Ministry of Water Resources and Meteorology (MOWRAM). During the ADB fact finding mission in January and February 2012, interventions were identified within a framework for structuring project activities and divided into 3 Stages. Stage 3 interventions were to follow the Stage 2 fast-track repairs necessary to repair damaged facilities within the following two dry seasons. The project documents identify Stage 3 sub-projects/contract packages in the Procurement Plan (PP). However the PP was a hastily prepared list of sub-projects requiring interventions with guess estimates of cost (with total cost well above actual funding availability) 1. Thus, a project requirement is for the Stage 3 sub-projects to be confirmed prior to commencing detailed design. 2. Purpose of report A project requirement is for the PIU to select the sub-project based on the selection criteria, and prior to commencing detail design, to submit details of the proposed sub-project together with the sub-projects safeguard classification, to the PCMU for endorsement and to the ADB for no objection. This sub-project profile report concerns the Stage 3 intervention for Phdav Chum sub-project located in Batheay district in Kampong Cham province, which is will consist of the emergency reconstruction of the flood protection embankment. The profile includes a brief description and justification of the sub-project. The Phdav Chum sub-project emergency reconstruction work is included in the PP as Contract No. MOWRAM-CW4 for an estimated final contract value of US$2.13 million including Por Tatres sub-project works. 1 The PP was recently revised and included in the Inception Mission MOU of July 2012 Page 9

10 SUB-PROJECT PROFILE-PHDAV CHUM Chapter 2 - SUB-PROJECT DESCRIPTION 1. Description and history The Phdav Chhum sub-project is not an irrigation scheme but a flood protection dyke that was first constructed in the 1960s, and repaired during the Pol Pot regime and later was rehabilitated under the previous Emergency Flood Rehabilitation Project under ADB support in The dyke which is approximately 17 km long starts at Srah Prinh and ends at the junction with the Cheung Prey district road near Siem Bay. The dyke provides protection to a large area including Skun town (Cheung Prey) and a section of the N6 Highway. The existing dike is about 17 km in length and serves to protect the adjacent community and agricultural and non agricultural land including roads from inundation during flooding from the Mekong River. 2. Flood Damage The embankment that constitutes the Phdav Chum flood protection was damaged in parts by erosion and wave action by the extreme flood events of the last two years (2010 and 2011) but was not overtopped or breached. However, the stability of the embankment matrix is in question and the dyke is in need of overall rehabilitation to ensure continued flood protection to the adjacent area. 3. Location The sub-project area is located near the Commune Kouk Rovieng and is accessible through the rural road network from the right side of National Road No.6 at Phaav market. The village road networks are in good condition from the junction of the national road to the sub-project area. The rural road connects to the dike. See Figures 1 and 2 below. 4. Existing Situation The dike is about 17 km in length, nominally 4 m wide with laterite surfacing, and approximately 4 m height at its highest part and includes 3 culverts with stop logs as well as 2 non return flap valves along its course. Rip-rap protection was provided for about 11 km on the flood side embankment slope. The surface of the immediate area protected by the dike is about 7,000 hectares measured between the dike and the national road No.6, which includes not only the agricultural land but also villages, towns, non agricultural land, and roads Description of the facilities Since its rehabilitation in the year 2002 the dike has not undergone any rehabilitation works and is now in state of disrepair (see Ch.3 section 4 Photos). Page 10

11 SUB-PROJECT PROFILE-PHDAV CHUM a) The upstream slope i.e. facing the flooded area is provided with dry stone riprap with geotextile underneath especially at low lying areas. The existing condition at the slope area is damaged to a varying degree and the stones are dispersed. At the higher ground where dike height is lesser, there are no riprap protections and the dike body has already been eroded. b) There are also locations where the damages of the dry stone riprap are minimal and could be retained but there are damages at mid height, some at the topmost and some with total destruction. c) The geotextile is already torn and damaged by the shrubs and movement of the stones. d) The downstream slope with no provision of grass sodding has been eroded and scoured by the water surface runoff. This condition is almost the same throughout the entire stretch of the dike. e) The crest of the dike is provided with laterite and is thinning out. The edges of the crest of the dike especially at the upstream side are destroyed in many portions of the entire stretch. Holes of various sizes of openings are observed which could extend to the original ground. The same condition is also observed at the crest width of the dike. f) These holes are evidence of damage to some sections of the dyke due to the presence of dispersive soils in the embankment matrix Socio-economic and Agriculture Area The overall area is 7,000 ha as mentioned above of which 3,174 ha are reported to be under agricultural activity (see table below) Beneficiaries / O&M The Phdav Chum sub-project is not an irrigation scheme but a flood protection dyke and the responsibility of its operation and maintenance falls under the responsibility of the MOWRAM and PDWRAM. It is therefore suggested that the participatory preparation of the Phdav Chum sub-project involves collaboration with the PDWRAM and the local authorities including the chiefs of the respective communes and the chiefs of villages as representatives of the communities who benefit from this flood protection scheme. Within this perspective the community development would concentrate it is effort on building the capacity of the PDWRAM and the local administration to operate and maintain the flood protection infrastructure Population Table 1 Community data Commune Number of households (hh) Total Population Number of villages Agricultural area & WS (ha) DS area (ha) Kouk Rovieng Khnar Dambong Phdau Chum Prey Char Control Page 11 Version 1

12 SUB-PROJECT PROFILE-PHDAV CHUM Commune Number of households (hh) Total Population Number of villages Agricultural area & WS (ha) DS area (ha) Soutip TOTALS Page 12

13 SUB-PROJECT PROFILE-PHDAV CHUM Figure 1 Location Map for Phdav Chum Page 13

14 Sub-project Profile-PHDAV CHUM Figure 2 Satellite Image showing dyke and N6 highway Control Page 14 Version 1

15 SUB-PROJECT PROFILE_ PHDAV CHUM 4.3. Hydrology The hydrology of the Phdav Chum area is covered by the brief report attached here as Appendix 4. Of particular interest for the FDERP sub-project Phdav Chum is the stage hydrograph which shows the high water level stages. The main problem for the designers is to correlate the hydrological stage datum level with that used for the topographical surveys. Experience has shown that in Cambodia the local people have very good reference marks for flood levels experienced during extreme flood events. The dyke has not been overtopped since it was rehabilitated in Page 15

16 SUB-PROJECT PROFILE_ PHDAV CHUM Chapter 3 - SCOPE OF WORKS 1. Design Approach a) The initial design calls for an addition of 50 cm to the existing crest elevation of the highest portion as shown in the survey to provide adequate free board. The crest elevation has not been overtopped by the flood but due to settlement and erosion the original crest elevation has probably been lowered. Verification of freeboard shall be confirmed at detailed design stage. b) The side slope for the upstream shall be 2.0 horizontal and 1.0 vertical while downstream side slope shall be 1.5 horizontal to 1.0 vertical. Dry stone pitching at the upstream side and grass sodding at the downstream shall provide additional protection. c) The finished grade from the centre of the crest width to each side shall have a slope of 2% to let surface runoff flow to the sides and not stagnate at the centre. d) The limits to the proposed improvements shall be finalized upon completion of the survey plan and profile. e) A walk through shall be undertaken to pinpoint the exact location and delineate the extent of the works to be done. Computations of the quantities shall be based on this activity. Initial staking out of the location of the proposed works shall be also included in the walk through for easier ground identification f) Selection of suitable material for fill is of utmost importance as will be control of compacted fill. The soils in the immediate vicinity appear to be highly dispersive and should be tested prior to selection and avoided if presence of dispersive soils is indicated. 2. Repairs The proposed scope of principle works identified for reconstruction includes the following: a) Stripping of the soil and removal of shrubs b) Embankment construction and compaction to meet the design elevation and section c) Excavation of loose soil materials in holes and backfilling with compaction d) Excavation at toe for the dry stone pitching cut off. e) Removal of stones at upstream slope and restoration according to the design thickness f) Placing of filter and geotextile underneath the stone pitching g) Construction of laterite pavement at crest of dike h) Grass sodding at the downstream slope of the dike Page 16

17 SUB-PROJECT PROFILE_ PHDAV CHUM 3. Cost estimate The cost estimate prepared at this pre-detailed design stage is based on the topographical data and amounts to some US$2.36 million including contingencies, which is more than the US$ 2.13 million of the PP that includes another sub-project in the package. However, the cost will also depend on the walk through described above (design approach (e)). Efforts to minimize the total cost but maintain effective rehabilitation works shall be considered. Major items are the dike embankment and the dry stone riprap. Thus the average repair cost of the emergency reconstruction works are reckoned to be less than US$ 1000 per ha, if the gross agricultural area is taken. Of course this project is not an irrigation scheme as such and the works provide flood protection to a wide area and interests. 4. Photos The following photos show the existing conditions of the Phdav Chum dyke. Section requiring total reconstruction Section with minimum repair requirement Dispersion of bank protection Section with sink holes Page 17

18 SUB-PROJECT PROFILE_ PHDAV CHUM Section with temporary repairs Side slope erosion Page 18

19 SUB-PROJECT PROFILE_ PHDAV CHUM Chapter 4 - SUB-PROJECT SCREENING 1. Resettlement There is no evidence of involuntary resettlement impact at this pre-design stage from the proposed repairs to the Phdav Chum. Two solid built rest shelters were identified on the dyke, which have been constructed by the local community. One poses no problem as it is built on piles and adjacent to the dyke top on the inside of the polder and rehabilitation is possible without affecting the structure. The second shelter has been partly built on the dyke and is already affecting use of the dyke as a road. This feature has been noted in the topographic survey and the dyke alignment may be altered to compensate at this location in detailed design. Pushing out the embankment at this point will not require land acquisition as the toe of the revised embankment will be in public land (flood side) Resettlement Impact Categorization Check-list The resettlement impact check-list is included in Appendix 1 and confirms that there are no involuntary resettlement impacts and that the project interventions are within the Category C for resettlement as per the SPS. The screening for resettlement categorization was conducted on the 17 th August 2012 by the national Resettlement Specialist accompanied by other team members including design engineers. Initial screening for involuntary resettlement is to be revisited following detailed design. 2. Environment The Phdav Chum sub-project is not situated in a protected area and there will be no change in downstream impacts. Short term environmental impacts may occur during the construction phase. Pre-flood O&M measures will be maintained or improved by the already established PDWRAM and local authorities. Phdav Chum sub-project was subjected to environmental screening process using ADB s Classification System. Based on SPS 2009, a project category is evaluated by the category of its most environmentally sensitive component, including direct, indirect, cumulative, and induced impacts in the project s area of influence. The subprojects are classified according to the following Categories: 1 Category A. A proposed subproject is classified as category A if it is likely to have significant adverse environmental impacts that are irreversible, diverse, or unprecedented. These impacts may affect an area larger than the sites or facilities subject to physical works. 2 Category B. A proposed subproject is classified as category B if its potential adverse environmental impacts are less adverse than those of category A projects. These impacts are site-specific, few if any of them are irreversible, and in most cases mitigation measures can be designed more readily than for category A projects. Page 19

20 SUB-PROJECT PROFILE_ PHDAV CHUM 3 Category C. A proposed subproject is classified as category C if it is likely to have minimal or no adverse environmental impacts Environmental Assessment and categorization The environmental screening presented in Appendix 2 was used as basis for environment categorization and confirms that the sub-project interventions have minimal or no adverse environmental impacts and may be placed in Category C. Based on the rapid environmental assessment conducted, sensitive areas such as cultural heritage site, protected area, wetland, mangrove, estuarine and buffer zone of protected area are not adjacent or within the project area. During construction, impacts on surface water quality, occupational health and safety, noise and vibration, hazardous driving conditions, poor sanitation and solid waste disposal are expected, however, these are minimal and short term in which mitigation measures can be readily formulated and be implemented. Hence, Phdav Chum subproject should be classified as Category C and therefore as per the ADBs SPS an environmental assessment or preparation of an Environmental Management Plan (EMP) is not required 2. 2 ADB PAM appendix 7 Environmental Assessment and Review Framework Page 20

21 SUB-PROJECT PROFILE_ PHDAV CHUM Chapter 5 - CONCLUSIONS 1. Screening The Phdav Chum sub-project emergency reconstruction works will not change pre flood hydrology and the dyke is existing infrastructure. The sub-project conforms to the FDERP general criteria for selection as provided in the ADB project documents 3, principally it is a flood control structure that has been damaged by the consecutive floods of recent years. However, the sector-specific criteria call for existence of an existing FWUC and since this is not and irrigation scheme as such, this criterion should not apply. Average repair costs will amount to less than $1,000 per ha of gross area (agricultural lands) protected after repairs and following project criteria 4 may proceed without having to verify the economic viability. A sub-project review has confirmed that there are no involuntary resettlement impacts and confirm that the project interventions are within the Category C for resettlement. The Phdav Chum sub-project is not situated in a protected area and there will be no change in downstream impacts. Short term environmental impacts may occur during the construction phase. Pre-flood O&M measures will be maintained by PDWRAM. The project interventions are within Category C for environmental screening. 2. Proposed interventions The proposed interventions described above will be defined in detailed design and based on the topographic survey recently carried out. Typical cross-sections for the proposed embankment works are included here in Appendix 3. 3 PAM Annex 1; Selection Criteria for Sub-projects, March Threshold for average repair costs of US$1,000 per ha; PAM Annex 1 Selection Criteria for sub-projects. Page 21

22 Sub-project Profile-PHDAV CHUM Appendix 1 Involuntary Resettlement Impact Check-list Subproject: Phdav Chum Involuntary Resettlement Effects Yes No Remarks Information on Project areas and Involuntary Acquisition of Land 1. Does the sub project include upgrading or rehabilitation of existing physical facilities? 2. Will easement be utilized within an existing Right of Way (ROW)? 3. Will there be land acquisition? 4. Is there site for land acquisition? 5. Is the ownership status and current usage of the land known? 6. Is the ownership status and current usage of land to be acquired known? 7. Will there be loss of shelter and residential land due to the land acquisition? 8. Will there be loss of agricultural plots and other productive assets due to the land acquisition? 9. Will there be loss of crops, trees, and fixed assets due to the land acquisition? 10. Are there any non titled people who live or earn their livelihood at the site or within the COI / Right of Way? 11. Will there be loss of businesses or enterprises due to the land acquisition? 12. Will there be loss of income due to the land acquisition? 13. Will any social or economic activities be affected by land userelated changes? Involuntary restriction on land use or on access to legally designated parks and protected areas 14. Will people loss access to natural resources, communal facilities and services? 15. If land use is changed, will it have an adverse impact on social and economic activities? 16. Will access to land and resources owned communally or by the state be restricted? Information on Displaced Persons: 17. Any estimate of the likely number of persons that will be displaced by the project? If YES, approximately how many? 18. Are any of them poor, Female headed of household, or vulnerable to poverty risks? 19. Are there any displaced persons from endogenous or ethnic minority groups? Whereby physical facilities are road shoulders. Government land; Right of Way Page 22

23 Sub-project Profile-PHDAV CHUM Appendix 2 Screening of potential environmental impacts A. PROJECT SITING Screening Questions Yes No Remarks IS THE PROJECT AREA ADJACENT TO OR WITHIN ANY OF THE FOLLOWING ENVIRONMENTALLY SENSITIVE AREAS? PROTECTED AREA WETLAND MANGROVE No cultural heritage sites are adjacent to or within the subprojects area There are no environmentally sensitive areas within the subproject area. ESTUARINE BUFFER ZONE OF PROTECTED AREA SPECIAL AREA FOR PROTECTING BIODIVERSITY B. POTENTIAL ENVIRONMENTAL IMPACTS WILL THE PROJECT CAUSE loss of precious ecological values (e.g. result of encroachment into forests/swamplands or historical/cultural buildings/areas, disruption of hydrology of natural waterways, regional flooding, and drainage hazards)? conflicts in water supply rights and related social conflicts? impediments to movements of people and animals? potential ecological problems due to increased soil erosion and siltation, leading to decreased stream capacity? Insufficient drainage leading to salinity intrusion? No loss in ecological values as the subproject is to replace the structure and repair the existing canal to the pre-flood conditions. Water User Group (WUG) has been already established and confirmed to be working effectively to operate and maintain the scheme. During construction temporary bypass will be provided to local people and animal passage and to be specified in EMP. Repair includes grass sodding bank protection to reduce erosion risk. Good construction practices to mitigate soil erosion and silt runoff will be specified in the EMP. over pumping of groundwater, leading to salinization and ground subsidence? No salinity issues are expected at any sites Page 23

24 Sub-project Profile-PHDAV CHUM impairment of downstream water quality and therefore, impairment of downstream beneficial uses of water? any sites Not expected as ground water will not be used. dislocation or involuntary resettlement of people? disproportionate impacts on the poor, women and children, Indigenous Peoples or other vulnerable groups? potential social conflicts arising from land tenure and land use issues? soil erosion before compaction and lining of canals? noise from construction equipment? dust during construction? waterlogging and soil salinization due to inadequate drainage and farm management? The construction activities will be carried out only on the existing dyke and no chemical will be used for construction. Thus, the downstream water quality will not be affected by the subproject activities. No IR impacts envisioned. The works will be carried out only within the existing embankments. Fill materials will be taken from existing reservation area or existing designated borrow pits/quarries. The subproject will not affect indigenous people or other vulnerable groups. The reconstruction works are to restore the existing dyke and head regulator to the pre-flood conditions. Thus, there will be no conflict on land use. Good construction practices to mitigate soil erosion before compaction will be specified in the EMP. Noise is expected during construction but impacts will be temporary and short in duration. In addition, most construction activities are far from local residents. Good construction practices to mitigate noise to be specified in the EMP. Dust is expected during construction but impacts will be temporary and short in duration. In addition, most construction activities are far from local residents. Good construction practices to mitigate dust to be specified in the EMP. During construction, temporary channel will be constructed to allow adequate water flow. Page 24

25 Sub-project Profile-PHDAV CHUM leaching of soil nutrients and changes in soil characteristics due to excessive application of irrigation water? reduction of downstream water supply during peak seasons? soil pollution, polluted farm runoff and groundwater, and public health risks due to excessive application of fertilizers and pesticides? The reconstruction works are to restore the existing dyke to the preflood conditions. Soils characteristics will not be changed compared to preflood conditions. The construction activities will be carried out only on the existing embankment of the dyke. Bridge construction across the dyke drain will not affect flows. No change compared to pre-flood conditions. soil erosion (furrow, surface)? scouring of canals? clogging of canals by sediments? clogging of canals by weeds? seawater intrusion into downstream freshwater systems? introduction of increase in incidence of waterborne or water related diseases? dangers to a safe and healthy working environment due to physical, chemical and biological hazards during project construction and operation? large population influx during project construction and operation that causes increased burden on social infrastructure and services (such as water supply and sanitation systems)? No change from pre-flood conditions. Good construction practices to mitigate soil erosion during construction will be specified in the EMP. No scouring of canal is expected as the repair works will not affect the existing pre-flood conditions. No clogging of canal is expected as the repair works will not affect the existing pre-flood conditions. No clogging of canal is expected as the repair works will not affect the existing pre-flood conditions. Not applicable. The reconstruction works are to restore the existing regulator to the pre-flood conditions. Only natural materials such as soils or laterites will be used. No chemicals will be used. Personal protective equipment will be provided to all workers. The EMP will specify that regular safety training will be also conducted. No chemical, biological and radiological hazards are expected during construction and operation. The number of non-local workers will be small in number. If necessary, construction contractors will be required to provide a worker s camp with independent basic facilities. Page 25

26 Sub-project Profile-PHDAV CHUM social conflicts if workers from other regions or countries are hired? risks to community health and safety due to the transport, storage, and use and/or disposal of materials such as explosives, fuel and other chemicals during construction and operation? Priority in labor employment will be given to local residents and non-local workers will be small in number No explosives and chemicals will be used for the subprojects. community safety risks due to both accidental and natural hazards, especially where the structural elements or components of the project (e.g., irrigation dams) are accessible to members of the affected community or where their failure could result in injury to the community throughout project construction, operation and decommissioning? Construction area will be clearly demarcated and access controlled. Only workers and project staff will be allowed to enter the operational sites. Climate Change and Disaster Risk Questions Yes No Remarks The following questions are not for environmental categorization. They are included in this checklist to help identify potential climate and disaster risks. Is the Project area subject to hazards such as earthquakes, floods, landslides, tropical cyclone winds, storm surges, tsunami or volcanic eruptions and climate changes? Not Applicable Could changes in temperature, precipitation, or extreme events patterns over the Project lifespan affect technical or financial sustainability (e.g., increased glacial melt affect delivery volumes of irrigated water; sea level rise increases salinity gradient such that source water cannot be used for some or all of the year)? Not Applicable Are there any demographic or socio-economic aspects of the Project area that are already vulnerable (e.g., high incidence of marginalized populations, rural-urban migrants, illegal settlements, ethnic minorities, women or children)? Not Applicable Could the Project potentially increase the climate or disaster vulnerability of the surrounding area (e.g., by diverting water in rivers that further increases salinity upstream, or encouraging settlement in earthquake zones)? Not Applicable Page 26

27 Sub-project Profile-PHDAV CHUM Appendix 3 Sketches of typical profile and cross-section of dyke Page 27

28 Sub-project Profile-PHDAV CHUM Page 28

29 Sub-project Profile-PHDAV CHUM Appendix 4 Hydrology for Phdav Chum Page 29