Civil Engineering and Development Department

Land Works Division

2/F, Civil Engineering and Development Building

101 Princess Margaret Road

Homantin, Kowloon

Demolition of Kwai Chung Incineration Plant

Environmental Permit No.

EP-121/2002

Monthly EM&A Report for Dec 2008 Rev A

Report No.: 203204/KCIP/EM&A/13/A

January 09

Mott MacDonald Hong Kong Limited

7/F, West Wing Office Building

New World Centre

20 Salisbury Road

Tsim Sha Tsui, Kowloon

Hong Kong

Tel: 2828 5757

Fax: 2827 1823

This document has been prepared for the titled project or named part thereof and should not be relied upon or used for any other project without an independent check being carried out as to its suitability and prior written authority of Mott MacDonald being obtained. Mott MacDonald accepts no responsibility or liability for the consequence of this document being used for a purpose other than the purposes for which it was commissioned. Any person using or relying on the document for such other purpose agrees, and will by such use or reliance be taken to confirm his agreement to indemnify Mott MacDonald Hong Kong for all loss or damage resulting therefrom. Mott MacDonald accepts no responsibility or liability for this document to any party other than the person by whom it was commissioned.

To the extent that this report is based on information supplied by other parties, Mott MacDonald accepts no liability for any loss or damage suffered by the client, whether contractual or tortious, stemming from any conclusions based on data supplied by parties other than Mott MacDonald and used by Mott MacDonald in preparing this report.

Demolition of Kwai Chung Incineration Plant

Environmental Permit No.

EP-121/2002

Monthly EM&A Report for Dec 2008 Rev A

Report No.: 203204/KCIP/EM&A/13/A

January 09

Issue and Revision Record

Rev	Date	Originator	Checker	Approver	Description
A	Jan 2009	Isaac Chu	Joseph Chan	Anne F Kerr	Submission to EPD

List of Contents Page

EXECUTIVE SUMMARY iii

1. INTRODUCTION 1-1

1.1 Background to the Project............................................................................... 1-1

1.2 Coverage of this EM&A Report...................................................................... 1-1

1.3 Project Management Organisation................................................................... 1-1

1.4 Project Program............................................................................................. 1-1

1.5 Works Undertaken in the Reporting Month....................................................... 1-2

2. EM&A Requirements 2-1

2.1 Summary of EM&A Requirements.................................................................. 2-1

2.2 Environmental Quality Performance Limits....................................................... 2-1

2.3 Event and Action Plans................................................................................... 2-1

2.4 Implementation of Environmental Mitigation Measures...................................... 2-1

3. Monitoring Results 3-1

3.1 Impact Monitoring Schedule............................................................................ 3-1

3.2 Monitoring Methodology.................................................................................. 3-1

3.3 Monitoring Equipment..................................................................................... 3-3

3.4 Equipment Calibration..................................................................................... 3-3

3.5 Results of Impact Monitoring........................................................................... 3-3

4. Project Environmental Status 4-1

4.1 Environmental Meetings.................................................................................. 4-1

4.2 Status of Environmental Submissions, Permits and Licenses.............................. 4-1

4.3 Waste Management Status.............................................................................. 4-2

4.4 Review of Environmental Monitoring Procedures.............................................. 4-3

4.5 Implementation Status of Environmental Mitigation Measures............................ 4-3

5. AUDIT FINDINGS 5-1

5.1 Site Environmental Audit................................................................................. 5-1

5.2 Site Effluent Discharge/WPCO Effluent Discharge.......................................... 5-2

6. Environmental COMPLAINTS AND NON-COMPLIANCE 6-1

6.1 Summary of Environmental Complaints, Notifications of Summons and Successful Prosecutions 6-1

6.2 Environmental Enquires................................................................................... 6-1

6.3 Environmental Events..................................................................................... 6-1

6.4 Environmental Exceedance/ Non-compliance................................................... 6-1

7. future key issues 7-1

7.1 Key Issues and Recommendations for Coming Month....................................... 7-1

8. conclusion and recommendation 8-1

8.1 Conclusions.................................................................................................... 8-1

8.2 Recommendations.......................................................................................... 8-1

List of Appendices

Appendix A.......... Environmental Quality Performance Limits

Appendix B.......... Event and Action Plans

Appendix C.......... Schedule of Mitigation Measures from the EIA/ EM&A Manual and Event Contingency Plan for Environmental Compliant

Appendix D.......... EM&A Schedule

Appendix E.......... Air Quality Monitoring Results and Graphical Presentation

Appendix F.......... Calibration Certificates

Appendix G.......... Works Programme

List of Tables

Table 2‑1............. Summary of Impact EM&A Requirements....................................................... 2-1

Table 3‑1............. TSP Monitoring Equipment.............................................................................. 3-3

Table 3‑2............. Equipment Calibration Frequencies.................................................................. 3-3

Table 3‑3............. Results of 1-Hour TSP Impact Monitoring........................................................ 3-3

Table 3‑4............. Results of 24-Hour TSP Impact Monitoring...................................................... 3-4

Table 4‑1............. Status of Environmental Submissions, Permits and Licenses.............................. 4-1

Table 4‑2............. Monthly Summary Waste Flow Table for 2008................................................. 4-2

Table 5‑1............. Summary of Environmental Site Inspections..................................................... 5-1

Table 6‑1............. Summary of Environmental Complaints and Prosecutions.................................. 6-1

Table 6‑2............. Summary of Exceedances............................................................................... 6-1

Table B‑1............. Event and Action Plan for Air Quality.............................................................. B1

Table C‑2............. Implementation Schedule of Recommended Mitigation Measures From the EIA.. C1

Table C‑3............. Event Contingency Plan for Environmental Complaints...................................... C5

List of Figures

Figure 1.1 Layout Plan of Work Site and the Environs

Figure 1.2 Project Organisation Chart

Figure 2.1 Location of Air Quality (Dust) Monitoring Station

3. Monitoring Results

3.1 Impact Monitoring Schedule

3.1.1 Regular site inspections were carried out on 4, 11, 17, 24 & 31 Dec 2008 in the reporting month to assess the compliance with environmental requirements. The EM&A schedule is given in Appendix D.

3.1.2 Impact monitoring for air quality (dust) due to the demolition work continued during the reporting month.

3.2 Monitoring Methodology

24-hour TSP Monitoring

Installation

3.2.1 The HVS has been installed close to representative air sensitive receivers. The following criteria have been considered in the installation of the HVS.

· A horizontal platform with appropriate support to secure the sampler against gusty wind was provided.

· The distance between the HVS and any obstacles, such as buildings, was at least twice the height that the obstacle protrudes above the HVS.

· A minimum of 2m separation from walls, parapets and penthouse was required for rooftop sampler.

· No furnace or incinerator flues were nearby.

· Airflow around the sampler was unrestricted.

· Permission was obtained to set up the samplers and to obtain access to the monitoring stations.

· A secured supply of electricity is needed to operate the samplers.

Preparation of Filter Papers

· Glass fibre filters, G810 are to be labelled with sufficient filters that are clean and without pinholes.

· All filters are to be equilibrated in the conditioning environment for 24 hours before weighing. The conditioning environment temperature is to be around 25 °C and not variable by more than ±3°C, the relative humidity (RH) is to be < 50% and not variable by more than ±5 %. A convenient working RH is 40%.

Field Monitoring

· The power supply is to be secured to ensure the HVS works properly.

· The filter holder and the area surrounding the filter are to be cleaned.

· The filter holder is to be removed by loosening the 4 bolts and a new filter, with stamped number upward, on a supporting screen to be aligned carefully.

· The filter is to be properly aligned on the screen so that the gasket forms an airtight seal on the outer edges of the filter.

· The swing bolts are to be fastened to hold the filter holder down to the frame. The pressure applied is to sufficient to avoid air leakage at the edges.

· The shelter lid is then closed and is secured with the aluminium strip.

· The HVS shall be warmed-up for about 5 minutes to establish run-temperature conditions.

· A new flow rate record sheet is to be set into the flow recorder.

· The flow rate of the HVS is to be checked and adjusted at around 1.1 m³/min. The range specified in the updated EM&A Manual is between 0.6-1.7 m³/min.

· The programmable timer is set for a sampling period of 24 hrs + 1 hr, and the starting time, weather condition and the filter number are to be recorded.

· The initial elapsed time is to be recorded.

· At the end of sampling, the sampled filter is to be removed carefully and folded in half length so that only surfaces with collected particulate matter are in contact.

· It was then placed in a clean plastic envelope and sealed.

· All monitoring information is to be recorded on a standard data sheet.

· Filters are to be sent to a HOKLAS accredited laboratory for analysis.

Maintenance and Calibration

· The HVS and its accessories are to be maintained in good working condition, such as replacing motor brushes routinely and checking electrical wiring to ensure a continuous power supply.

· HVSs are to be calibrated at a bi-monthly intervals using GMW-25 Calibration Kit throughout all stages of the air quality monitoring.

1-hour TSP Monitoring

Field Monitoring

3.2.2 The measuring procedures of the 1-hour dust meter are to be in accordance with the Manufacturer’s Instruction Manual as follows:

· Set POWER to “ON”, push BATTERY button, make sure that the meter’s indicator is in the range with a red line and allow the instrument to stand for about 3 minutes (Then, the air sampling inlet has been capped).

· Push the knob at MEASURE position.

· Push “O-ADJ” button. (Then meter’s indication is 0).

· Push the knob at SENSI ADJ position and set the meter’s indication to S value described on the Test Report using the trimmer for SENSI ADJ.

· Pull out the knob and return it to MEASURE position.

· Push “START” button.

Maintenance and Calibration

· The 1-hour TSP meter would be checked at 3-month intervals and calibrated at 1-year intervals throughout all stages of the air quality baseline monitoring.

3.2.3 As per the approved EM&A Manual, dust monitoring stations are located as shown in Figure 2.1 Location of Air Quality (Dust) Monitoring Station.

3.3 Monitoring Equipment

3.3.1 The equipment used for air quality (dust) monitoring is listed in Table 3‑1.

Table 3‑1 TSP Monitoring Equipment

Equipment	Model
HVS Sampler	Greasby GMWS 2310 Accu-vol system
Calibrator	Tisch TE-5025A
1-hour TSP Dust Meter	TSI Model 8520 Dust Trak Aerosol Monitor

3.4 Equipment Calibration

3.4.1 The calibration frequencies of the monitoring equipment are provided in Table 3‑2.

Table 3‑2 Equipment Calibration Frequencies

Equipment	Calibration Frequency	Latest Calibration Date
High Volume Sampler Greasby GMWS 2310 Accu-vol system	Every two months	4 November 2008
1-hour TSP Dust Meter TSI Model 8520 Dust Trak Aerosol Monitor	Every six months	14 July 2008

Equipment

Calibration Frequency

Latest Calibration Date

High Volume Sampler

Greasby GMWS 2310 Accu-vol system

Every two months

4 November 2008

1-hour TSP Dust Meter

TSI Model 8520 Dust Trak Aerosol Monitor

Every six months

14 July 2008

3.4.2 The calibration certificates are included in Appendix F.

3.5 Results of Impact Monitoring

Air Quality (1-hr TSP)

3.5.1 Results of 1-hour TSP level are summarised in Table 3‑3. Detailed results, including weather conditions, and graphical presentations are included in Appendix E.

Table 3‑3 Results of 1-Hour TSP Impact Monitoring

Monitoring Station	1-hour TSP Range (µg/m³)	Action Level (µg/m³)	Limit Level (µg/m³)
A1	163-248	345	500

3.5.2 No exceedance of Action / Limit Levels for 1-hr TSP was recorded in the reporting month.

Air Quality (24-hr TSP)

3.5.3 Results of 24-hour TSP level are summarised in Table 3‑4. Detailed results, including weather conditions, and graphical presentations are included in Appendix E.

Table 3‑4 Results of 24-Hour TSP Impact Monitoring

Monitoring Station	24-hour TSP Range (µg/m³)	Action Level (µg/m³)	Limit Level (µg/m³)
A1	33-169	179	260

3.5.4 Control on dust emission tightened followed the exceedance event on 27 Nov 2008. Recommendations on improvement were given to the Contractor during the weekly site inspections. No further exceedance of Action / Limit Levels for 24-hr TSP was recorded in the reporting month.

Item	Description	Date of Application/ Submission	Status
1.	Environmental Permit (EP No. EP-121/2002)	4 Feb 2002	Valid
2.	Billing Account under Waste Disposal (Charges for Disposal of Construction Waste) Regulation (Ref. No.: 7006285)	Approved on 16 Nov 2007	Valid
3.	Waste Management Plan	v2.3 approved on 25 Jul 2008 v3.1 submitted to RE on 8 Jan 2008	v2.3: valid v3.2: pending submission to EPD for approval
4.	Registration as a Chemical Waste Producer under Waste Disposal (Chemical Waste) (General) Regulation (Ref. No.: WPN-5292-320-C3459-01)	2 Nov 2007	Approved by EPD on 26 Nov 2007
5.	Effluent Discharge Licence (Ref. No.: EP760/320/0128821)	Variation of License submitted on 10 Nov 2008	Approved by EPD on 5 Jan 2009 which superseded the previous licence
6.	Notification pursuant to Section 3(1) of the Air Pollution Control (Construction Dust) Regulation (Form NA)	EPD notified on 15 Jan 2008	Valid
7.	Notification of commencement of asbestos abatement work pursuant to Section 73 of the Air Pollution Control Ordinance	EPD notified on 4 Feb 2008	Valid. Approved by EPD on 5 Mar 2008.
New submissions
	No new submissions

4.3 Waste Management Status

4.3.1 The C&D material & general refuse generated by the Project in the reporting month are shown in Table 4‑2. A trip ticket system has been implemented for all off-site waste disposals. (It was recorded that 0 m³ of ACM and 10.71 m³ DCM have been generated from the site while 142.5 m³ of ACM was disposed of in Dec 2008. No DCM waste has been disposed off-site.)

Table 4‑2 Monthly Summary Waste Flow Table for 2008

Month	Actual Quantities of Inert C&D Materials Generated Monthly										Actual Quantities of C&D Wastes Generated Monthly
	Total Quantity Generated		Broken Concrete		Reused in the Contract		Reused in other Projects		Disposed of at Public Fill		Metals		Paper/ Cardboard		Plastics		Chemical waste		Others (e.g. refuse)
	(In tons)		(In tons)		(In tons)		(In tons)		(In tons)		(In ‘000 kg)		(In ‘000 kg)		(In ‘000 kg)		(In ‘000 kg)		(In ‘000 m³)
	Est.	Act.	Est.	Act.	Est.	Act.	Est.	Act.	Est.	Act.	Est.	Act.	Est.	Act.	Est.	Act.	Est.	Act.	Est.	Act.
Jan	0	0	-	0	-	0	-	0	0	0	0	0	0.1	0	0.1	0	0	0	0.250	0.0585
Feb	0	0	-	0	-	0	-	0	0	0	0	0	0.1	0	0.1	0	0	0	0.250	0.063
Mar	0	0	-	0	-	0	-	0	0	0	0	0.47	0.1	0	0.1	0	0	0	0.125	0.018
Apr	0	0	-	0	-	0	-	0	0	0	0	0	0.1	0	0.1	0	0	0	0.125	0.0045
May	0	0	-	0	-	0	-	0	0	0	0	3.2	0.1	0	0.1	0	0	0	0.125	0
June	0	0	-	0	-	0	-	0	0	0.0225	0	8.1	0.1	0	0.1	0	0	0.297	0.125	0.0135
Jul	0	0	-	0	-	0	-	0	0	0	0	0	0.1	0	0.1	0	0	14.35	0.125	0.009
Aug	0	0	-	0	-	0	-	0	0	0.018	0	0	0.1	0	0.1	0	120	8.529	0.125	0.009
Sep	0	0	-	0	-	0	-	0	0	0.0716	0	9	0.1	0.018	0.1	0.005	120	18.707	0.125	0.018
Oct	0	0	-	0	-	0	-	0	0	0.395	0	16.12	0.1	0	0.1	0	120	37.057	0.125	0.018
Nov	0	0	-	0	-	0	-	0	0	0.128	0	16.9	0.1	0.005	0.1	0	120	103.313	0.125	0.032
Dec	0		-		-		-		0	1.076	0	79.5	0.1		0.1		120	5.6	0.125	0.018
Total	0	0	-	0	-	0	-	0	0	1.711	0	133.29	1.2	0.023	1.2	0.005	600	187.853	1.750	0.315.

5. AUDIT FINDINGS

5.1 Site Environmental Audit

5.1.1 Site inspection is to be carried out on a weekly basis to monitor proper implementation of environmental pollution control and mitigation measures for the Project. In this reporting month, one monthly site inspection was carried out jointly by the ER, Contractor, ETL and IEC on 17 December 2008 and additional weekly site inspections were carried out by the ER, Contractor and ET on 4, 11, 24 & 31 Dec 2008.

5.1.2 Major findings provided by ET and those jointly provided by the ET and IEC on 13 November 2008 from the site inspection are summarised in Table 5‑1 below.

Table 5‑1 Summary of Environmental Site Inspections

Date of Inspection	Major Observations	Action(s)
4 Dec 2008	In response to the exceedance event, the contractor has undertaking more frequent watering and sweeping of debris. It was recommended that the coverage of area watered could be increase, including covered stockpiles, and debris/ dust should be swept more frequently.	The condition of stockpile area outside the incineration plant has improved as the ground was swept and cleaned.
11 Dec 2008	The area near to the chimney remained dusty and should be watered and the floor should be cleaned.	Floor clean has been carried out and a stationary sprinkler has been provided to suppress dust.
	There was accumulated surplus dust in the area between the stockpile and the incineration plant. It is suggested to sweep the floor and clean all dusty material.	Demolition of Reception Bay in progress; the issue will be reviewed later.
	Sediment in the gully near to the chimney was observed. The Contractor was reminded to clean the sediment trapped regularly.	Sediment trapped in the gully was removed.
17 Dec 2008	Concrete pavement broken due to operation of crane should be reinstated as soon as possible after work to prevent exposure of soil.	Demolition of Reception Bay in progress; the issue will be reviewed later.
	The Contractor was reminded to cover the stockpiles with tarpaulin properly as some portions were exposed to air.	The covering of stockpiles by tarpaulin has been improved by Contractor.
24 Dec 2008	-	-
31 Dec 2008	Debris was observed on the 1/F of Incineration Plant. The contractor was suggested to provide rubbish bin and maintain good housekeeping of the site.	The Contractor will clear all debris and maintain better housekeeping. Rubbish bin will be provided.

5.2 Site Effluent Discharge/WPCO Effluent Discharge

5.2.1 A WPCO effluent discharge licence was granted by EPD on 10 March 2008 and subsequently the Contractor has applied for variation of licence conditions on 15 March 2008. EPD has granted the new discharge licence on 8 July 2008. The foul water from toilets of Contractor’s & Engineer’s site offices in Portion B would be temporarily stored in storage tank and then collected and disposed by a sewage collector.

5.2.2 No effluent discharge sample was collected in this reporting month. The issue will be followed-up in the up-coming reports.

Parameters	Total no. of Measurements	Action Level Exceedance	% of Action Level Exceedance	Limit Level Exceedance	% of Limit Level Exceedance
Air Quality	25	0	0%	0	0%

Table B‑1 Event and Action Plan for Air Quality

EVENT	ACTION
1. Exceedance for one sample	1. Identify source 2. Inform IEC and ER 3. Repeat measurement to confirm finding 4. Increase monitoring frequency to daily	1. Check monitoring data submitted by ET 2. Check Contractor’s working method	1. Notify Contractor 2. Check monitoring data and Contractor's working methods	1. Rectify any unacceptable practice 2. Amend working methods if appropriate
2. Exceedance for two or more consecutive samples	1. Identify source 2. Inform IEC and ER 3. Repeat measurements to confirm findings 4. Increase monitoring frequency to daily 5. Discuss with Contractor , IEC and ER for remedial actions required 6. If exceedance continues, arrange meeting with IEC and ER 7. If exceedance stops, cease additional monitoring	1. Checking monitoring data submitted by ET 2. Check Contractor’s working method 3. Discuss with ET and Contractor on possible remedial measures 4. Advise the ER on the effectiveness of the proposed remedial measures 5. Supervise implementation of remedial measures	1. Confirm receipt of notification of failure in writing 2. Notify Contractor 3. Check monitoring data and Contractor's working methods 4. Discuss with IEC and Contractor on potential remedial actions 5. Ensure remedial actions properly implemented	1. Submit proposals for remedial actions to ER within 3 working days of notification 2. Implement the agreed proposals 3. Amend proposal if appropriate
LIMIT LEVEL
1. Exceedance for one sample	1. Identify source 2. Inform ER and EPD 3. Repeat measurement to confirm finding 4. Increase monitoring frequency to daily 5. Assess effectiveness of Contractor's remedial actions and keep IEC, EPD and ER informed of the results	1. Checking monitoring data submitted by ET 2. Check Contractor’s working method 3. Discuss with ET and Contractor on possible remedial measures 4. Advise the ER on the effectiveness of the proposed remedial measures 5. Supervise implementation of remedial measures	1. Confirm receipt of notification of failure in writing 2. Notify Contractor 3. Check monitoring data and Contractor's working methods 4. Discuss with ET Leader and Contractor potential remedial actions 5. Ensure remedial actions properly implemented	1. Take immediate action to avoid further exceedance 2. Submit proposals for remedial actions to ER within 3 working days of notification 3. Implement the agreed proposals 4. Amend proposal if appropriate
2. Exceedance for two or more consecutive samples	1. Identify source 2. Inform IEC, ER and EPD the causes & actions taken for the exceedances 3. Repeat measurement to confirm findings 4. Increase monitoring frequency to daily 5. Investigate the causes of exceedance, Contractor’s working procedures to identify possible mitigation 6. Arrange meeting with IEC and ER to discuss the remedial actions to be taken 7. Assess effectiveness of Contractor's remedial actions and keep IEC, EPD and ER informed of the results 8. If exceedance stops, cease additional monitoring	1. Discuss amongst ER, ET and Contractor as the potential remedial actions 2. Review Contractor’s remedial actions whenever necessary to ensure their effectiveness and advise the ER accordingly 3 Supervise the implementation of remedial measures	1. Confirm receipt of notification of failure in writing 2. Notify Contractor 3. Carry out analysis of Contractor's working procedures with IEC to determine possible mitigation to be implemented 4. Discuss amongst Environmental Team Leader and the Contractor potential remedial actions 5. Review Contractor's remedial actions whenever necessary to assure their effectiveness 6. If exceedance continues, consider what portion of the work is responsible and instruct the Contractor to stop that portion of work until the exceedance is abated	1. Take immediate action to avoid further exceedance 2. Submit proposals for remedial actions to ER within 3 working days of notification 3. Implement the agreed proposals 4. Resubmit proposals if problem still not under control 5. Stop the relevant portion of works as determined by the ER until the exceedance is abated

EVENT

ACTION

IEC

CONTRACTOR

ACTION LEVEL

1. Exceedance for one sample

1. Identify source

2. Inform IEC and ER

3. Repeat measurement to confirm finding

4. Increase monitoring frequency to daily

1. Check monitoring data submitted by ET

2. Check Contractor’s working method

1. Notify Contractor

2. Check monitoring data and Contractor's working methods

1. Rectify any unacceptable practice

2. Amend working methods if appropriate

2. Exceedance for two or more consecutive samples

1. Identify source

2. Inform IEC and ER

3. Repeat measurements to confirm findings

4. Increase monitoring frequency to daily

5. Discuss with Contractor , IEC and ER for remedial actions required

6. If exceedance continues, arrange meeting with IEC and ER

7. If exceedance stops, cease additional monitoring

1. Checking monitoring data submitted by ET

2. Check Contractor’s working method

3. Discuss with ET and Contractor on possible remedial measures

4. Advise the ER on the effectiveness of the proposed remedial measures

5. Supervise implementation of remedial measures

1. Confirm receipt of notification of failure in writing

2. Notify Contractor

3. Check monitoring data and Contractor's working methods

4. Discuss with IEC and Contractor on potential remedial actions

5. Ensure remedial actions properly implemented

1. Submit proposals for remedial actions to ER within 3 working days of notification

2. Implement the agreed proposals

3. Amend proposal if appropriate

LIMIT LEVEL

1. Exceedance for one sample

1. Identify source

2. Inform ER and EPD

3. Repeat measurement to confirm finding

4. Increase monitoring frequency to daily

5. Assess effectiveness of Contractor's remedial actions and keep IEC, EPD and ER informed of the results

1. Checking monitoring data submitted by ET

2. Check Contractor’s working method

3. Discuss with ET and Contractor on possible remedial measures

4. Advise the ER on the effectiveness of the proposed remedial measures

5. Supervise implementation of remedial measures

1. Confirm receipt of notification of failure in writing

2. Notify Contractor

3. Check monitoring data and Contractor's working methods

4. Discuss with ET Leader and Contractor potential remedial actions

5. Ensure remedial actions properly implemented

1. Take immediate action to avoid further exceedance

2. Submit proposals for remedial actions to ER within 3 working days of notification

3. Implement the agreed proposals

4. Amend proposal if appropriate

2. Exceedance for two or more consecutive samples

1. Identify source

2. Inform IEC, ER and EPD the causes & actions taken for the exceedances

3. Repeat measurement to confirm findings

4. Increase monitoring frequency to daily

5. Investigate the causes of exceedance, Contractor’s working procedures to identify possible mitigation

6. Arrange meeting with IEC and ER to discuss the remedial actions to be taken

7. Assess effectiveness of Contractor's remedial actions and keep IEC, EPD and ER informed of the results

8. If exceedance stops, cease additional monitoring

1. Discuss amongst ER, ET and Contractor as the potential remedial actions

2. Review Contractor’s remedial actions whenever necessary to ensure their effectiveness and advise the ER accordingly

3 Supervise the implementation of remedial measures

1. Confirm receipt of notification of failure in writing

2. Notify Contractor

3. Carry out analysis of Contractor's working procedures with IEC to determine possible mitigation to be implemented

4. Discuss amongst Environmental Team Leader and the Contractor potential remedial actions

5. Review Contractor's remedial actions whenever necessary to assure their effectiveness

6. If exceedance continues, consider what portion of the work is responsible and instruct the Contractor to stop that portion of work until the exceedance is abated

1. Take immediate action to avoid further exceedance

2. Submit proposals for remedial actions to ER within 3 working days of notification

3. Implement the agreed proposals

4. Resubmit proposals if problem still not under control

5. Stop the relevant portion of works as determined by the ER until the exceedance is abated

Table C‑2 Implementation Schedule of Recommended Mitigation Measures From the EIA

No.	Activity	Mitigation/EIA Recommendations	Responsibility for Implementation	Location/Duration completion of measures	Implementation Stage	Relevant Guidelines Legislation	Implementation Status ^
1	Ash Disposal
I	Treatment	Reconfirm extent of contaminated ash deposits by sampling for dioxins and furans. Handling, transportation and disposal of the ash waste in line with relevant regulations. Collection, immobilisation and testing of waste for disposal to landfill shall be carried out according to the relevant regulations and recommendations of the EIA including immobilisation by collection and mixing the ash material with cement. Pilot mixing and TCLP tests should establish the ratio of cement to ash to the satisfaction of EPD. Ash waste to be treated and placed into steel drums lined with plastic sheeting. The drums should be adequately sealed and in new or good condition. Prior agreement of the disposal criteria from EPD and agreement to disposal from the landfill operator must be obtained.	CEDD’s Contractor	KCIP work areas. Duration of the ash removal	A@	1, 10, EIA	P
II	Disposal	To monitor the disposal of waste at landfills, a “trip-ticket” system (WBTC No. 5/99) for all solid waste transfer/disposal operations should be implemented. The system should be included as a contractual requirement, and monitored by the Environmental Team and audited by the Independent Checker (Environment).	CEDD’s Contractor	As above	A	1, 5, 9	ü
III	Asbestos Removal	An asbestos abatement programme should be submitted to EPD for approval prior to the commencement of the asbestos abatement work.	CEDD and Contractor	As above	A	4	ü
2	Demolition
A1	Non-blasting Methodology	Demolition by Non-Blasting Methodology Only. All structures and buildings should be demolished and removed prior to demolition of chimneys	CEDD	KCIP work areas. Duration of the demolition	C#	8	ü
A2	Waste Management Plan.	A Waste Management Plan shall be submitted to EPD for approval. The Waste Management Plan shall include, but not be limited to, the findings of the Waste Management Paper of the EIA, the types, quantities, disposal methods, timing, and locations of final disposition, responsibilities for implementation and the possible recycling and reuse of wastes generated.	CEDD and Contractor	Prior to commencement of the demolition works	Prior to C#	1	ü
B	Material Storage	Covers for dusty stockpiles and control of dust emissions from construction (demolition) works requires appropriate dust control measures to be implemented in accordance with the requirements in the Air Pollution Control (Construction Dust) Regulation.	CEDD’s Contractor	KCIP work areas. Duration of the demolition	C	4	ü
C	Vehicle movement	Haul road watering, vehicle wheel wash prior to exit. Where practical, access roads should be protected with crushed gravel.	CEDD’s Contractor	As above	C	4	P
D	Plant maintenance	All plant shall be maintained to prevent any undue air emissions.	CEDD’s Contractor	As above	Prior to start of works	4	ü
E	Demolition Techniques	Selection of non-blasting demolition techniques to minimise noise and vibration.	CEDD’s Contractor	As above	C	8	ü
F	Plant maintenance	All plant shall be maintained to prevent any undue noise nuisance.	CEDD’s Contractor	As above	C	2, 3	ü
G	Wheel wash	All wheel wash water shall be diverted to a sediment pit.	CEDD’s Contractor	As above	C	5	P
H	Sediment control	Sediment removal facilities shall provided and be maintained and excavated as necessary to prevent sedimentation of channels. Perimeter channels should be provided. Works should be programmed for the dry season where feasible. Environmental guidelines for the handling and disposal of discharges from construction sites, as stipulated in the Practice Note for Professional Persons, Construction Site Drainage (ProPECC PN 1/94) to be followed.	CEDD’s Contractor	As above	C	5, 12	N/A
I	Surface water diversion	All clean surface water shall be diverted around the site.	CEDD’s Contractor	As above	C	5, 12	X
J	Fuel can storage	All fuel cans shall be placed within a bunded area. Any fuel spills shall be mopped up as necessary.	CEDD’s Contractor	As above	C	5,6	ü
K	Material, plant movement & fuel can filling.	Any fuel or oil spills shall be excavated and disposed of.	CEDD’s Contractor	As above	C	6,7	ü
L	Generators	All generators shall be placed within a bunded area. Any fuel spills shall be mopped up as necessary.	CEDD’s Contractor	As above	C	5,6,7	ü
M	Material containers	All empty bags and containers shall be collected for disposal.	CEDD’s Contractor	As above	C	6,7	ü
N	Worker generated litter and Waste	Litter receptacles shall be placed around the site. Litter shall be taken regularly to the refuse collection points. Chemical toilets (or suitable equivalent) should be provided for workers. Any canteens should have grease traps.	CEDD’s Contractor	As above	C	6	ü
O	Neighbourhood nuisance	All complaints regarding construction works shall be relayed to the environmental team.	CEDD’s Contractor	As above	C	1, 6	ü
P	Legal requirements	Different types of waste should be segregated, stored, transported and disposed of in accordance with the relevant legislative requirements and guidelines	CEDD’s Contractor	As above	C	1,6	ü
Q	On-site separation	On-site separation of municipal solid waste and construction/demolition wastes shall be conducted in order to minimise the amount of solid waste to be disposed to landfill.	CEDD’s Contractor	As above	C	1, 11	ü
R	Temporary storage area	Separated wastes should be stored in different containers, skips, or stockpiles to enhance reuse or recycling of materials and encourage their proper disposal.	CEDD’s Contractor	As above	C	1, 11	ü
S	Record of wastes	Records of quantities of wastes generated, recycled and disposed (with locations) shall be kept.	CEDD’s Contractor	As above	C	1, 9	ü
T	Trip-ticket system	To monitor the disposal of waste at landfills and control fly-tipping, a “trip-ticket” system under WBTC N0.5/99 for all solid waste transfer/disposal operations should be implemented. The system should be included as a contractual requirement, and monitored by the Environmental Team and audited by the Independent Checker (Environment).	CEDD’s Contractor	As above	C	1, 9	ü
3	Soil Remediation Phase
U	B, C, D, F, G, I, J, K, L, M, N, O, P, Q, R, S and T as above	As above (see W for soil remediation).	As above	As above	R	As above	N/A
V	De-watering	Collect and recycle extracted groundwater and leachate by mixing with cement for soil remediation. Environmental guidelines for the handling and disposal of discharges from construction sites, as stipulated in the Practice Note for Professional Persons, Construction Site Drainage (ProPECC PN 1/94) to be followed. Any surplus groundwater and leachate requiring disposal to be disposed of under the relevant legislation or treated to meet the standards given in Table 9a of the WPCO TM.	CEDD’s Contractor	KCIP work areas. Duration of the soil remediation	R	5	N/A
W	Immobilisation	Immobilisation and testing of waste soil shall be carried out according to the relevant regulations and recommendations of the EIA including immobilisation by collection and mixing the contaminated soil material with cement. Pilot mixing and TCLP tests should verify the effectiveness and establish the ratio of cement to soil to the satisfaction of EPD. Reassurance confirmatory sampling shall be carried out to confirm the extent of contamination. Soil waste to be cast in blocks and replaced in the ground. Extracted soils and materials and stabilisation/solidification to be conducted in bunded area to prevent surface run-off. See also item 2(H) above. Final soil decontamination report to be submitted to EPD.	CEDD’s Contractor	As above	R	1, 10	N/A
4	Monitoring and Audit	To be carried out in accordance with the Schedule in the EM&A Manual.	CEDD*/ Contractor/ RSS	KCIP works areas During demolition and at end of demolition throughout execution of Remediation Action Plan	C	1	ü

* Normally undertaken by a specialist monitoring team employed directly by the proponent and audited by the Independent Checker (Environment)

@ A = during ash removal (before demolition)

# C = during construction (i.e. demolition phase).

* R = during soil remediation phase (after demolition)

^ Implementation Status:

ü implemented

Ï not implemented

P partially implemented

X rectified by Contractor

N/A not applicable

1. Environmental Impact Assessment Ordinance Technical Memorandum (EIAO)

2. Noise Control Ordinance

3. The ProPECC Note PN2/93 (Construction Noise daytime limits)

4. Air Pollution Control Ordinance (APCO)

5. Water Pollution Control Ordinance (WPCO)(Cap. 358)

6. Waste Disposal Ordinance (Cap 354)

7. Waste Disposal (Chemical Waste)(General) Regulation (Cap 354)

8. Draft Code of Practice on Demolition of Buildings (BD, 1998)

9. Works Bureau Technical Circular No. 5/99, Trip-ticket System for Disposal of Construction and Demolition Material

10. Guidance Notes for Investigation and Remediation of Contaminated Sites

11. Works Bureau Technical Circular No. 5/98, On Site Sorting of Construction Waste on Demolition Sites

12. ProPECC Note PN 1/94Construction Site Drainage

Table C‑3 Event Contingency Plan for Environmental Complaints

Step	Day	Action	Contractor	ER	ET	IEC
1	1	Party receiving complaint shall create a new complaint record. If the Contractor receives a complaint, he shall pass the information to the ER.	¨	¨	¨
2	1	ER to ensure details of complaint provided to Contractor (if complaint not originally received by the Contractor), ET and IEC		¨
3	2	Within 1 working day after the receipt of the Notification of Complaint, provide ER relevant works site information, e.g. types and locations of construction works.	¨			à
4	2	Investigate the complaint to determine its validity, and to assess whether the source of the problem is due to the works activities. Report the validity of the complaint to ER.				¨à
5	2	If complaint is valid and due to works, ER shall notify the Contractor. If complaint is invalid or not due to works, Go to Step 12.		¨
6	2	Propose mitigation measures to ER within 1 working day of the receipt of the Notification.	¨			à
7	2	Review and agree with the proposed mitigation measures and make recommendations where necessary.		¨à		¨à
8	2	Implement the mitigation measures once they have been agreed.	¨
9	4	Audit the implementation of the proposed mitigation measures on site within 2 working days after measures have been agreed.		¨à		¨à
10	-	Undertake additional monitoring to verify the situation where necessary.			¨
11	4	Report the investigation results and subsequent actions taken to ER within 2 working days after the implementation of mitigation measures.	¨		¨
12	5	Respond to the complainant within 1 working day after receiving the investigation report.		¨
13	25	If no further comments or complaints are received from the complainant within 20 working days after responding to the complainant, close the complaint record. If the complainant has further comments or complaints on the same issue, notify other parties on the same day and go to step 2.		¨		¨à

¨ Action Party

à Enter comments/ proposals into appropriate complaint record where applicable

Parameters	Descriptions	Locations	Frequencies	Duration
Air Quality	24-Hour TSP	1 Location - A1	Once every 6 days	During dust generating construction works
Air Quality	1-Hour TSP	1 Location - A1	3 times every 6 days	During dust generating construction works
Waste	On-Site Waste Audit	Active Work Sites	Weekly	During Construction
Waste	On-Site Waste Inspection	Active Work Sites	Weekly	During Construction
Wastewater	On-Site Wastewater Audit	Active Work Sites	Weekly	During Construction
General Site Conditions	Environmental Site Inspection	Works areas and areas affected by works	Weekly	During Construction

Complaints Logged		Summons Served		Successful Prosecutions
Dec 2008	Cumulative	Dec 2008	Cumulative	Dec 2008	Cumulative
0	0	0	0	0	0

Monitoring Station	Action Level (mg/m³)	Limit Level (mg/m³)
A1	179	260