The Hongkong Electric Co., Ltd.
LAMMA POWER STATION
NAVIGATION CHANNEL IMPROVEMENT
ENVIRONMENTAL IMPACT ASSESSMENT
(APPENDIX 6)
Environmental Monitoring & Audit Manual
(Construction Phase)
January
2003
TABLE
OF CONTENT
1.2.1 Background to the
Project
1.3 Objectives of the Environmental Monitoring and Audit Programme
1.4 The Scope of the Environmental Monitoring and Audit Programme
1.5 Structure of the EM&A Manual
2 ORGANISATION AND STRUCTURE OF THE
EM&A Programme
2.2.2 Engineer or Engineer’s
Representative
2.2.4 Independent Environmental Checker
3.7 Enquiries, Complaints and Requests for Information
4.6.1 Quality Assurance and Quality
Control
4.7 Marine Water Quality Monitoring Locations
5.3 Objectives of The Waste Audit
6.2 Compliance with Legal and Contractual Requirements
7.2 Baseline Monitoring Report
7.5 Record of Sounding Surveys
7.6 Electronic Reporting of EM&A
Information
7.8 Interim Notification of Environmental Quality Limit Exceedances
Annexes
Annex
A Reporting
Documentation
Annex
B Implementation
Schedule
The purpose of this Environmental Monitoring and Audit (EM&A) Manual is to provide information, guidance and instruction to personnel charged with environmental responsibilities and undertaking environmental monitoring and auditing work during the Lamma Power Station Navigation Channel Improvement (the Project). It provides systematic procedures for the monitoring and auditing of potential environmental impacts that may arise from the works.
1.2.1 Background to the Project
As the total dredging volume
exceeds 500,000m3, the dredging operation of the Channel improvement
is a designated project according to the Environmental Impact Assessment (EIA)
Ordinance. Schedule 2, Part I, C.12.
The EIA report for the Project was prepared in response to the
Environmental Impact Assessment Study Brief No. ESB-078/2001 issued by EPD on
23 July 2001.
The EIA study concluded that no
unacceptable or insurmountable impacts were expected from the proposed
development, provided that the recommended mitigation measures in the EIA
Report are adopted and implemented.
This EM&A Manual was prepared
as per the mitigation measures and environmental monitoring requirements
recommended in the EIA report.
The Hongkong
Electric Company Limited (HEC) is proposing to improve the existing navigation
channel in order to provide a safe shipping access to and from the Lamma Power
Station. The work involves re-deepening
the existing channel by dredging to a water depth of –16 mPD approximately with
an estimated total dredging volume of 2.98 million m3.
The Channel was first dredged to
–15.9 mPD (approximately) in 1981.
Maintenance of the Channel by means of dredging down to about –16.5 mPD
level was carried out in 1989-1990.
To cope with the updated vessel operation, the turning basin of the
Channel was enlarged by extending 250m southward in early 2001.
The Project Area is illustrated
in Figure 1.1. The grey area shows the limit of the Channel where dredging
will be required under this Project.
According to the latest bathymetric survey of the Channel, there is
already sufficient water depth in the remaining section of the Channel in the
south (beyond the grey area in Figure 1.1) and no dredging will be
required.
The dredging options for the
Project are continuous dredging using grab dredgers
with cage-type silt curtains or
intermittent dredging using one Trailer Suction Hopper Dredger (TSHD). Either one of two dredging options will be deployed. The dredging work is tentatively
scheduled to take place from May to December 2003. Marine vessels will transport the dredged sediments to the
mud disposal sites approved by the Marine Fill Committee for disposal.
1.3
Objectives of the Environmental Monitoring and Audit Programme
The environmental impacts resulting from the Lamma Power Station Navigation Channel Improvement are studied and presented in the EIA Report. The Report also specifies the mitigation measures that need to be implemented to ensure compliance with the required environmental criteria; these mitigation measures and their implementation requirements are presented in the Implementation Schedule contained in Annex B of this Manual. The EIA Report recommends that environmental monitoring should be carried out for water quality. In addition, environmental audits for water quality and waste management issues are also required.
This Manual provides specific details of the EM&A requirements that have been recommended to ensure compliance with the mitigation measures specified in the EIA Report.
The main objectives of this EM&A programme are to:
· provide a database against which any short or long term environmental impacts of the Project can be determined;
· provide early indication should any of the environmental control measures or practices fail to achieve acceptable standards;
· monitor the performance of the Project and the effectiveness of the mitigation measures;
· verify the environmental impacts predicted in the EIA Study;
· determine the Project’s compliance with regulatory requirements, standards and government policies;
· take remedial action if unexpected problems or unacceptable impacts arise; and
· provide data against which environmental audits may be undertaken.
1.4
The Scope of the Environmental Monitoring and Audit Programme
The scope of this EM&A programme is to:
· establish baseline water quality levels at specified locations and review these baseline levels at specified period acceptable to the Authority;
· implement water quality impact monitoring programmes;
· implement audit requirements to address water quality and waste issues;
· liaise with and provide environmental advice (as requested or when otherwise necessary) to site staff on the comprehension and consequences of the EM&A programme;
· identify and resolve environmental issues and other functions as they may arise from the works;
· check and quantify the Contractor's overall environmental performance, implement Event and Action Plans (EAPs), and recommend and implement remedial actions to mitigate adverse environmental effects as they may arise from the works;
· conduct regular reviews of monitored impact data as the basis for assessing compliance with defined criteria and to ensure that necessary mitigation measures are identified, designed and implemented, and to undertake additional ad hoc monitoring and auditing as required by special circumstances;
· evaluate and interpret all environmental monitoring data to provide an early indication should any of the environmental control measures or practices fail to achieve the acceptable standards, and to verify the environmental impacts predicted in the EIA;
· manage and liaise with other individuals or parties concerning any other environmental issues deemed to be relevant to the construction process;
· conduct regular site audits of a formal or informal nature to assess:
- the level of the Contractors’ general environmental awareness,
- the Contractors’ implementation of the recommendations in the EIA Report,
- the Contractors’ performance as measured by the EM&A programme,
- the need for specific mitigation measures to be implemented or the continued usage of those previously agreed; and
- to advise the site staff of any identified potential environmental issues.
· submit regular EM&A reports which summarise project monitoring and auditing data, with full interpretation illustrating the acceptability or otherwise of any environmental impacts and identification or assessment of the implementation status of agreed mitigation measures.
1.5
Structure of the EM&A Manual
Following this introductory Section, the remainder of the Manual is set out as follows:
· Section 2 presents the organisation and structure for the management of the EM&A programme, outlines the various parties involved in the EM&A process, the notes and responsibilities of key individuals;
· Section 3 presents the EIA findings and sets out the EM&A general requirements;
· Section 4 details the requirements for baseline and impact monitoring for water quality, and lists relevant monitoring equipment, locations, compliance and Event and Action Plans (EAPs);
· Section 5 details the audit requirements with regard to waste management issues;
· Section 6 describes the scope and frequency of site auditing; and
· Section 7 details the EM&A reporting requirements.
In addition, Annex A provides samples for EM&A Reporting Documentation, and Annex B presents the summary of mitigation measures recommended in the EIA Report in the form of an Implementation Schedule.
The Project requires that the Engineer appoint an Environmental Team (ET) before the commencement of construction of the Project. The roles of the ET are to conduct the monitoring and auditing works and to provide specialist advice to the Engineer on the undertaking and implementation of his environmental responsibilities.
The ET shall have previous relevant experience with managing similarly sized EM&A programmes and the Environmental Team Leader (ET Leader) shall be a recognised environmental professional, who has at least seven years relevant experience in environmental monitoring and auditing or environmental management.
To maintain strict control of the EM&A process, an independent environmental consultant shall be appointed to act as an "Independent Environmental Checker" (IEC) before the commencement of construction of the project. The IEC is to verify and validate the environmental performance of the Contractor and the Environmental Team. The IEC shall have at least seven years’ experience in EM&A or environmental management.
The Chief Engineer (Projects) (thereafter called CE(P)) is the official contact person between EPD and HEC. CE(P) shall be authorized to sign all submissions to the EPD in accordance with the requirements of the EM&A Manual.
The Engineer of HEC shall appoint appropriate members of the Project and resident site staff to manage and supervise the work of the Contractor, the Environmental Team (ET) Leader and its various specialist teams and other professional delegates.
An Environmental Team will be established in-house to implement the environmental monitoring work as required by this EM&A Manual.
An Independent Environmental Checker (IEC) will be appointed by HEC to audit and verify the overall environmental performance of the construction site and assess the effectiveness of the ET.
The organisation and management structure for the EM&A programme
is illustrated in Figure 2.1. The specific roles
and responsibilities of the various parties involved in the EM&A process
outlined above are further expanded upon in the following sections.
Reporting to the Engineer, the Contractor shall:
· work within the scope of the contract and other tender conditions;
· provide assistance to the ET in conducting the required environmental monitoring;
· participate in the site inspections undertaken by the ET, as required, and undertake any corrective actions instructed by the Engineer;
· provide information/advice to the ET or IEC regarding works activities which may contribute, or be contributing to the generation of adverse environmental conditions;
· implement measures to reduce impact where Action and Limit levels are exceeded; and
· take responsibility and strictly adhere to the guidelines of the EM&A programme and complementary protocols developed by their project staff.
2.2.2 Engineer or Engineer’s Representative
The Engineer or Engineers Representative (ER) shall:
· monitor the Contractor's compliance with contract specifications, including the effective implementation and operation of environmental mitigation measures and other aspects of the EM&A programme;
· engage an ET to undertake the monitoring, laboratory analysis and reporting of the environmental monitoring and audit requirements outlined in this Manual;
· comply with the agreed Event and Action Plans in the event of any exceedance;
· employ an Independent Environmental Checker IEC to audit the results of the EM&A works carried out by the ET; and
· instruct the Contractor to follow the agreed protocols or those in the Contract Specifications in the event of exceedances or complaints.
The duties of the Environmental Team (ET) and Environmental Team Leader (ET Leader) are to:
· implement the EM&A programmes in accordance with the EM&A requirements as contained in this EM&A Manual;
· monitor the various environmental parameters as required by this or EM&A Manual;
· prepare Baseline Monitoring Report, Monthly EM&A reports and Final EM&A summary report for submission to the Authority;
· collect, analyse and statistically evaluate the EM&A monitoring data, with reference to the EIA Study recommendations, and to review the success of the EM&A programme by determining the adequacy of the mitigation measures implemented and the validity of the EIA predictions. Emphasis should be placed on identifying and resolving any adverse environmental impacts before they arise;
· conduct site inspections/investigate and inspect the Contractor's equipment and work methodologies with respect to pollution control and environmental mitigation, and to identify environmental issues that may require mitigation before the problem arises;
· audit the environmental monitoring data and report the status of the general site environmental conditions and the implementation of mitigation measures resulting from site inspections;
· certify the environmental acceptability of permanent and temporary works, relevant design, plans and submissions;
· monitor compliance with environmental protection clauses/specifications in the Contract;
· regularly review the project program and methodologies and comments as necessary;
· report on the environmental monitoring and audit results and the wider environmental issues (such as compliance with environmental and pollution prevention and control regulations) and conditions to the Engineer;
· adhere to the agreed protocols (contained in this EM&A Manual and/or those in the Contract Specifications) in the event of exceedances or complaints. For complaints, this will comprise the investigation of all complaints, and the evaluation and identification of suitable corrective measures;
· liaise with the IEC on all environmental issues performance matters, and the timely submission of relevant deliverables;
· advise the Contractor on environmental improvements, awareness, enhancement matters etc; and
· certify if necessary any additional mitigation measures or alternative measures that are required to be undertaken by the Contractor as the corrective actions to prevent adverse environmental impact arising from the Project.
2.2.4 Independent Environmental Checker
An Independent Environmental Checker (IEC) shall be appointed to independently audit and verify the overall environmental performance of the works and to assess the effectiveness of the ET in their duties. The IEC, who shall be independent from the management of the Project, shall advise the Engineer on the environmental issues related to the Project. The main objectives will be to:
· audit the overall EM&A programme including the implementation of all environmental mitigation measures, submissions relating to EM&A, and other submissions required under the Environmental Permit (EP);
· validate and confirm the accuracy of the monitoring results, monitoring equipment, monitoring locations, monitoring procedures and locations of sensitive receivers;
· conduct random site inspections;
· review the effectiveness of environmental mitigation measures and project environmental performance;
· review and verify the monthly EM&A Reports, Baseline Monitoring Report and Final EM&A Summary Report prepared by ET;
· verify the environmental acceptability of permanent and temporary works, relevant design plans and submissions, if any, under the EP;
· verify, if necessary, any additional mitigation measures or alternative measures to be undertaken by the Contractor as corrective actions to prevent adverse environmental impacts arising from the construction activities; and
· check complaint cases and the effectiveness of corrective measures implemented by the Contractor and the ET in case of Action/Limit level exceedance.
2.3
Project Programme
The project programme would
tentatively commence in May 2003.
The duration of the project would be about eight months. The main activity for the project is
dredging. Marine vessels will
transport the dredged sediment to the mud disposal sites approved by the Marine
Fill Committee of the Civil Engineering Department.
3.1
Introduction
In this section, the
general requirements of the EM&A programme for the Lamma Power Station Navigation Channel
Improvement Project are presented. The recommended mitigation measures and
schedule for their implementation are detailed in Annex B.
The environmental issues associated with the Project which were identified during the EIA process will be addressed through the monitoring and controls specified in the EM&A Manual and contract.
The following sub-sections summarises the EM&A requirements
recommended in the EIA Report:
Using the Lamma Channel Model constructed from the
Lamma Power Station Extension EIA, the
potential WQ impact of the proposed dredging works in terms of SS levels has been
assessed. The elevation of the SS levels in the identified Sensitive Receivers is a
deciding factor of the maximum dredging rates for the two
dredging options.
The releasing potential of
the contaminants in the seabed sediment has been ascertained from a
purpose-designed Elutriation Test.
The WQ parameters examined include nitrogen nutrients, sediment oxygen
demand, heavy metals and micro-pollutants. For nitrogen nutrients and sediment
oxygen demand, the resulting pollution elevation or oxygen depletion modelled
was compared to the relevant WQOs.
Provided the dredging rates
do not exceed the recommended maximum rates, the SS elevation and oxygen
depletion will not lead to non-compliance with the local WQOs at all the WQSRs
except in the very vicinity of the dredging locations. Currently there is no statutory WQ
standard for Hong Kong’s marine environment in terms of heavy metals or
micro-pollutants. The predicted
elevation of the heavy metals and micro-pollutants in the receiving waters has
been compared to the standards in the EU, UK, USA and Japan. The increase in those pollution levels
resulting from the proposed Channel Improvement at the recommended maximum
dredging rates is well below the lowest values of the international standards
reviewed, and is not
considered to be of any concern.
At the
recommended maximum dredging rates, the sediment deposition rates are predicted
to be less than 0.01 kg/m2/day along the west coast of Lamma Island
and less than 0.001 kg/m2/day in the proposed South Lamma water for
both dredger options. These figures are well below the
level of any ecological concern.
In view of the importance of the dredging rates in controlling WQ, the
channel would be divided into four working zones for dredging. Each one has its own maximum dredging
rate for wet and dry seasons respectively (Annex B, Table B2 & Figure B2). If dredging work is carried out in more than one zone in any
day, the lowest rate in the affected zones will apply for that day. The dredging rates for each working
zones will be reported in the Monthly EM&A Report on a daily basis to
ensure that the maximum dredging rates will not be exceeded. The reporting of daily dredging rates
should indicate the type of dredgers used, i.e. grab dredger or trailer suction
hopper dredger, and the respective sizes of grab dredgers used.
No additional WQ mitigation measures are required as long as the maximum dredging
rates for respective dredgers recommended in this EIA are not exceeded. Nevertheless, a comprehensive WQ
monitoring (discussed in Section 4) will be carried out to verify the modelling
predictions. Should the WQ monitoring during the construction work indicate that any
exceedance of the WQOs is due to the dredging work, the maximum dredging
rates would be reviewed.
Literatures and studies on the marine and
coastal ecology of the Study Area has been reviewed in detail for this EIA and
supplemented with additional field surveys conducted on 10 December 2001. Of greatest
importance are the coastal stretches and waters off southern-south western
Lamma. The Finless Porpoise was considered
to be the key species potentially affected both directly and indirectly by
works given that the southern extent of the Study Area is considered to be an
important habitat, particularly in the period from February to April. Corals in this area are
extremely sparse and patchy and already showing signs of stress. Furthermore
they did not support significant reef communities and are of low ecological
value when put into the Hong Kong context.
To protect the marine and coastal ecology, it is
recommended that monitoring and audit focus on the source of the ecological
impacts i.e. dredging works and their WQ
impacts. By ensuring WQ does not
exceed WQOs for the area then ecological impacts can be prevented. This can be accomplished through
the water quality monitoring at the sensitive receivers around the study
area. Details of the water quality
monitoring will be discussed in Section 4.
Further, to avoid disruption to the finless porpoise population in the
southeastern coastal waters of Lamma Island, some mitigation measures as shown
in Annex B would be adopted.
An effective EM&A program through the on-site inspection will be
formulated to ensure that the mitigation measures will be fully
implemented. Hence, no ecological
monitoring and audit is required.
The environmental assessment of the Project predicted that the
recommended dredging rates at various working zones would prevent exceedance of
the Water Quality Objectives (WQOs).
As the dredging works are short term, small elevations in SS across the
study area are not expected to affect fishing activities. The mitigation measures as recommended
in the Marine Ecology would also help to minimise the impacts on fisheries
activities as well. In addition,
an intensive monitoring of water quality around the study area will be used to
verify EIA predictions. Details of
water quality monitoring are discussed in Section 4. As the EM&A requirements for fisheries impact will be
similar to those recommended in Water Quality and Marine Ecology, no specific
EM&A programmes is required for fisheries.
According to the EIA report, the noise impact of
this Project on the NSRs is negligible and the cumulative noise levels are
below the noise limits during normal working hours (07:00-19:00 on normal
weekdays). The same conclusions
apply to the restricted hours of 07:00-19:00 on holidays including Sundays and
19:00-23:00 on all days. The noise
impact will also comply with the noise limit for the restricted hours of
23:00-07:00 on all days for the TSHD option and also for the grab dredgers
option by scheduling the dredgers in working zones. As such, no noise monitoring for this project in particular
is necessary. However, a daily
logbook should be maintained to record the number and type of plants deployed
for audit purpose.
In
case justified noise complaints
are
filed, a near-field noise monitoring
programme for the dredgers
will be called into
action. This is to check if the sound power levels (SWL) of
the dredgers comply with that stipulated in the CNP. Should
the SWL of dredger exceed
that quoted in the CNP, appropriate action
would be taken to
remedy the situation.
The only source of waste generation is from the
dredging works. It is estimated
that a total of 2.98 million m3 of seabed sediment will be dredged
from the Channel over a 8-month
period from May to December 2003.
The elutriation test results concluded in the EIA report have shown that the concentration of all heavy metals and organic
micro-pollutants from the samples are below the level of concern. Therefore it is concluded that
the impact from heavy metals and organic micro-pollutants leaking from dredging
materials are of negligible quantities and will not be of
any
concern to the overall WQ. The dredged materials, classified as Category L
suitable for open sea disposal by EPD (cf letter ref (23)in EP 60/GI/12-293
dated 22/8/2001), will be disposed of at designated
marine dumping sites approved by the Marine Fill
Committee of the Civil Engineering Department. The contractor would obtain a valid dumping permit from the
Authority prior to the commencement of dredging work. Detail EM&A requirements on waste management will be
discussed in Section 5.
Based on the above summaries, the predominant environmental issues subject to EM&A are water quality and waste management. A broad description of the monitoring programme for these issues is provided in the following sections. The monitoring of the effectiveness of the mitigation measures will be achieved through this process as well as through site inspections. The inspections will include within their scope, mechanisms to review and assess the Contractor’s environmental performance, ensuring that the recommended mitigation measures have been properly implemented, and that the timely resolution of received complaints are managed and controlled in a manner consistent with the recommendations of the EIA.
The monitoring of environmental impacts shall be carried out by the Environmental Team; the monitoring work will comprise water quality impacts at representative sensitive receivers or strategic locations in the vicinity of the works. The monitoring programme for the Project is presented in Sections 4. Proper waste management is also required to ensure that the contractor will follow the mitigation measures recommended in the EIA report. The specific requirements are presented in Section 5.
Action and Limit (A/L) Levels are defined levels of impact recorded by the environmental monitoring activities which represent levels at which a prescribed response is required. These levels are quantitatively defined later in the relevant sections of this manual and described in principle below:
· Action Levels: beyond which there is a clear indication of a deteriorating ambient environment for which appropriate remedial actions are likely to be necessary to prevent environmental quality from falling outside the Limit Levels, which would be unacceptable; and
· Limit Levels: statutory and/or agreed contract limits stipulated in the relevant pollution control ordinances, the Hong Kong Planning Standards and Guidelines (HKPSG) or Environmental Quality Objectives established by the EPD. If these are exceeded, works should not proceed without appropriate remedial action, including a critical review of plant and working methods.
The purpose of the Event and Action Plans (EAPs) is to provide, in association with the monitoring and audit activities, procedures for ensuring that if any significant environmental incident (either accidental or through inadequate implementation of mitigation measures on the part of the Contractor) does occur, the cause will be quickly identified and remedied, and the risk of a similar event recurring is reduced. This also applies to the exceedances of A/L criteria identified in the EM&A programme.
In addition to monitoring water quality levels as a means of assessing the ongoing performance of the Contractor, the ET shall undertake regular site inspections and audits of on-site practices and procedures. The primary objective of the inspection and audit programme will be to assess the effectiveness of the environmental controls established by the Contractor and the implementation of the environmental mitigation measures recommended in the EIA.
Whilst the audit and inspection programme will undoubtedly complement the monitoring activity with regard to the effectiveness of water quality control, the criteria against which the audits shall be undertaken shall be derived from the clauses within the Contract Documents which seek to enforce the recommendations of the EIA and the established management systems.
The findings of site inspections and audits shall be made known to the Contractor at the time of the inspection to enable the rapid resolution of identified non-compliances. Non-compliances and the corrective actions undertaken shall also be reported in the monthly EM&A Reports.
Section 6 of this Manual presents details of the scope and frequency of on-site inspections and defines the range of issues that the audit protocols should be designed to address.
3.7
Enquiries, Complaints and Requests for Information
Enquiries, complaints and requests for information can be expected
from a wide range of individuals and organisations including members of the
public, Government departments, the press and television media and community
groups.
All enquiries concerning the environmental effects of the works, irrespective of how they are received, shall be reported to the Engineer and directed to the Contractor where necessary. The detailed complaints handling procedure is presented in Section 6.3.
Monthly reports shall be prepared by the Environmental Team and
verified by the Independent Environmental Checker. The monthly reports shall be prepared
and submitted within 2 weeks of the end of each calendar month. Additional details on reporting
protocols are presented in Section 7.
The EM&A work will be reviewed taking into account the experience
gained and the actual environmental conditions as and when required.
The ET shall continue to carry out EM&A work until the completion of the navigation channel improvement works.
In this section, the requirements, methodology, equipment, monitoring locations and mitigation measures for the monitoring and audit of water quality impacts from the Project are presented.
4.2
Methodology and
Criteria
Based on the recommendation in the
EIA report, marine water quality monitoring shall be carried out to ensure that
any deteriorating water quality is readily detected and that timely action is
taken to rectify the situation.
The appropriate water quality mitigation measures are outlined in the
Implementation Schedule (in Annex B of this EM&A Manual).
The objectives of the water quality monitoring programme are as follows:
· to determine the effectiveness of the operational controls and mitigation measures employed, and the need for supplementary mitigation measures; and
· to check compliance with relevant WQOs;
Parameters to be measured in situ are:
· Dissolved oxygen (DO) (% saturation);
· Dissolved oxygen (DO) (in mgL-1);
· Temperature (oC);
· Turbidity (NTU);
· Salinity (ppt);
· pH; and
· Water depth (m).
Parameter to be measured in the laboratory is:
· suspended solids (mg L-1);
In addition to the water quality parameters, other relevant data shall also be measured and recorded as follows:
· monitoring location/position;
· measurement depth;
· time;
· weather conditions,
·
sea conditions (where appropriate);
·
tidal stage (where appropriate);
· special phenomena and work activities at the site.
A sample monitoring record sheet is shown in Annex A.
For water quality monitoring, the following equipment shall be used to carry out the monitoring:
(a) Dissolved Oxygen and Temperature Measuring Equipment
The instrument shall be a portable, weatherproof dissolved oxygen measuring instrument complete with cable, sensor, comprehensive operation manuals, and shall be operable from a DC power source. It shall be capable of measuring:
· dissolved oxygen levels in the range of 0 - 20 mg L-1 and 0 - 200% saturation; and
· a temperature of 0 - 45 degrees Celsius.
It shall have a membrane electrode with automatic temperature compensation complete with a cable of not less than 25 m in length. Sufficient stocks of spare electrodes and cables shall be available for replacement where necessary. (For example, YSI model 59 metre, YSI 5739 probe, YSI 5795A submersible stirrer with reel and cable or an approved similar instrument).
(b) Turbidity Measurement Equipment
Turbidity within the water shall be measured in-situ by the nephelometric method. The instrument shall be a portable, weatherproof turbidity-measuring unit complete with cable, sensor and comprehensive operation manuals. The equipment shall be operated from a DC power source, it shall have a photoelectric sensor capable of measuring turbidity between 0 - 1000 NTU and shall be complete with a cable with at least 25 m in length (Hach 2100P or an approved similar instrument).
(c) Water Depth Gauge
A portable, battery-operated echo sounder approved by the authority shall be used for the determination of water depth at each designated monitoring station. This unit shall either be hand-held or affixed to the bottom of the work boat if the same vessel is to be used throughout the monitoring programme.
(d) Salinity Measurement Instrument
A portable salinometer capable of measuring salinity in the range of 0 - 40 ppt shall be provided for measuring salinity of the water at each monitoring location.
(e) pH Measuring Instrument
A portable pH meter shall be provided for measuring pH of the water at each monitoring location.
(f) Water Sampling Equipment
A water sampler, consisting of a transparent PVC or glass cylinder of not less than two litres which can be effectively sealed with cups at both ends, shall be used (Kahlsico Water Sampler 13SWB203 or an approved similar instrument). The water sampler shall have a positive latching system to keep it open and prevent premature closure until released by a messenger when the sampler is at the selected water depth.
Water samples for SS
measurements shall be transferred directly to high density polythene sample bottles, packed in ice (cooled to 4 O C without being frozen),
and delivered to a HOKLAS laboratory as soon as possible after collection.
Should changes to the sampling equipment be required, approval from EPD
should be sought prior to their implementation.
(g) Positioning Device
A hand-held or boat-fixed type Global Positioning System (GPS) Receiver shall be used during monitoring to ensure the monitoring vessel is at the correct location before taking measurements.
(a) All measuring equipment shall be checked, calibrated and maintained at intervals as recommended by the equipment manufacturers throughout all stages of the monitoring programme.
(b) Sufficient stocks of spare parts shall be maintained for replacements when necessary. Backup monitoring equipment shall also be made available so that monitoring can proceed uninterrupted even when equipment is under maintenance or calibration.
All laboratory work shall be carried out in a HOKLAS accredited laboratory. Water samples of about 1,000 mL shall be collected at the monitoring and control stations for carrying out the laboratory determinations. The determination work shall start within 24 hours after collection of the water samples. The analyses shall follow the standard methods according to Table 4.6a and as described in APHA Standard Methods for the Examination of Water and Wastewater, 17th Edition, unless otherwise specified.
Table 4.6a Analytical
Method to be Applied to Marine Water Quality Samples
Determinant |
Standard Method |
Suspended solids |
APHA
2540D |
|
|
4.6.1 Quality Assurance and Quality Control
Field Logs
Field logs are maintained for all survey works, noting the date of the survey, equipment used, survey date personnel and a record of all activities and observations. Field logs are retained for the duration of the Project and archived on completion.
In-situ measured data recorded from the instruments and will be transferred into Microsoft Excel format. Both soft-copy on disk and hardcopy are retained for records. Any deviation from the standard procedures shall be noted in the log and the reason for the deviation recorded. In addition, field logs shall contain notes of events or activities in the vicinity of the monitoring location which might give rise to anomalous values being measured.
Sampling
All samples will be assigned with a unique code which shall be attached to the sample container or written directly on the container.
Measurement Procedures
All in-situ monitoring equipment shall be checked and calibrated throughout all stages of the monitoring, or as required per the manufacturers specification. Certificate(s) of Calibration specifying the instrument being functional for the designed purpose will be attached to the monitoring reports. Response of sensors and electrodes will be checked with certified standard solutions before each use. Wet bulb calibration for a dissolved oxygen meter will be carried out before measurement at each monitoring location.
Transport of Samples
All samples transferred from one sub-contractor to another are accompanied by Chain of Custody (COC) sheets. Missing or damaged samples are notified to ET following logging of the samples into the laboratory QA system. Sample of the COC form can be found in Annex C.
Laboratory Testing
Quality assurance is provided during the processing of sampling and the subsequent analytical procedures. The laboratory operates its own in-house Quality Assurance and Quality Control Procedures in which all methods used are referenced or fully documented.
In addition to the laboratory’s own Quality Assurance and Quality
Control Procedures, “blind” duplicate samples of marine waters are submitted on
a routine basis for analysis alongside the normal samples. The sample code for the “blind”
duplicates should not be identifiable by the laboratory. Approximately one “blind” duplicate should
be submitted for every ten standard samples. Samples to be duplicated on any one sampling occasion should
be selected at random. As a means of identifying
any systematic errors, the testing regime shall also include, as a minimum, the
analyse of the followings:
·
laboratory
blanks;
·
batch
duplicates;
·
matrix
spikes;
·
laboratory
standards; and,
·
certified
reference materials.
All water testing parameters should be analyzed using method based on the “Standard Methods for the Examination of Water and Wastewater” APHA or other international methods accepted by EPD.
Table 4.6b Detection
Limit of Suspended Solid
Parameter |
Detection Limit |
Suspended Solid |
1.0 mg/L |
|
|
4.7
Marine Water Quality Monitoring Locations
The water quality monitoring stations are shown in Figure 4.1. Seven Sensitive Receiver (SR) Stations as recommended in the EIA report have been chosen on the basis of their proximity to the dredging and filling operations and thus the greatest potential for water quality impacts, as detailed in Table 4.7a. The monitoring locations are:
a) SR6 representing the sub-tidal assemblages at Pak Kok (north Lamma);
b) SR7 representing the sub-tidal assemblages at Shek Kok Tsui (north west Lamma);
c) SR10 representing the existing power station intakes (only for SS measurement);
d) SR11 representing Hung Shing Ye beach;
e) SR12 representing Lo So Shing beach; and
f) SR14 and SR15 representing the south Lamma water.
Table 4.7a Locations
of Marine Water Quality Monitoring Stations
Station |
Easting |
Northing |
SR6 |
830 150 |
811 500 |
SR7 |
829 004 |
810 903 |
SR10 |
829 194 |
808 600 |
SR11 |
830 119 |
808 650 |
SR12 |
830 386 |
807 189 |
SR14 |
829 977 |
805 758 |
SR15 |
829 566 |
804 545 |
As detailed in Table 4.7b, three Control Stations as recommended in the EIA report have been selected, namely CS1, CS2 and CS3, to facilitate comparison of the water quality of the SR stations with ambient water quality conditions. Details of the control stations are as follows:
a) CS1 representing the ambient WQ conditions during the ebb tide;
b) CS2 representing the ambient WQ in West Lamma Channel, outside the main tidal stream passing through the Project Area; and
c) CS3 representing the ambient WQ conditions during the flood tide.
Monitoring data from these Control Stations can be used as upstream and downstream controls for the SR stations. Locations of control stations shall be subject to change depending on the location and timing of dredging and other marine works projects in the Study Area. Any proposal for changes to the locations of control/impact stations shall be subject to EPD approval.
Table 4.7b Locations
of Marine Water Quality Control Stations
Station |
Easting |
Northing |
CS1 |
828 000 |
813 492 |
CS2 |
825 000 |
808 000 |
CS3 |
829 000 |
802 000 |
The locations of water quality monitoring are depicted in Figure 4.1.
Water quality monitoring results from SR stations should be compared to baseline monitoring results, control stations’ results and EPD’s Water Quality Objectives (WQO) for the Southern Water Control Zone (SWCZ). The standards stated in the WQOs are as follows:
· Suspended Solids (SS): SS should not be raised above ambient levels by an excess of 30% nor cause the accumulation of SS which may adversely affect aquatic communities.
·
Dissolved
Oxygen (DO): DO within 2m of the bottom should not
be less than 2 mg/L for 90% of the samples; depth averaged DO should not be
less than 4 mg/L for 90% of the samples during the whole year.
4.8
Baseline Conditions
Baseline conditions of various water
quality parameters such as DO, SS and Turbidity will be established
prior to the commencement of the works.
Baseline monitoring will be performed at all designated Control and SR
stations, 3-days per week, at mid-flood and mid-ebb tides, for 4 weeks before the
initiation of marine works. There
should not be any marine construction activities in the vicinity of the
stations during the baseline monitoring.
In order to take into account the
seasonal variations of the baseline DO level, separate baseline DO levels for
the dry and the wet seasons will be derived both from the baseline data
obtained prior to the commencement of works and EPD’s routine monitoring data
in the study area over the last 5 years.
EPD monitoring data measured at
the same water control zone in which the sensitive receivers are located would
be applied to the impact stations.
For SR6, the Action and Limit levels would be calculated from MWQ
results at WM1 while that for SR7-SR15, data at SM5-7 would be used.
Based on the above approach, the
Action Levels of SR6 and SR7-15 would be calculated from the 5th
percentile of MWQ results at WM1 and SM5-7 respectively. Similarly, the Limit Levels of SR6 and
SR7-15 would be calculated from the 1st percentile of MWQ results at
WM1 and SM5-7 respectively or the WQO for DO in non-FCZ.
Details of the monitoring parameters for the project are stated in Section 4.3. The monitoring should be carried out following the requirements presented in Section 4.11.
Impact monitoring for seawater quality at SRs and Control Stations should be performed on
three days per week, at mid-flood and mid-ebb tides. In case of exceedances of Action and or Limit Levels, monitoring
frequency may need to be increased.
The locations for impact monitoring should be the same as those
for baseline monitoring. Details of the monitoring parameters are stated in Section 4.3. The monitoring should be carried out following the
requirements presented in Section 4.11.
To verify the assumed bulking factors stipulated in
EIA report, a sounding survey will be carried out two months after the commencement of
dredging work. Additional sounding
surveys should be carried out for every three months after the initial sounding
survey. The measured bulking factor obtained from the sounding surveys will be adopted for the dredging work. The actual dredging rate will
then be determined accordingly.
4.10
Post-Project Monitoring
Upon completion of all dredging activities, a post-project WQ monitoring
shall be carried out for 4 weeks.
Post-project monitoring for seawater quality at SRs and Control Stations should be performed on
three days per week, at mid-flood and mid-ebb tides. The locations for impact monitoring, impact parameters and requirements should be the
same as those for impact monitoring.
The following requirement should be followed for the baseline, impact and post-dredging monitoring.
a)
Sampling should take place under
non-exceptional conditions with respect to the tides, weather and season. No dredging work will be
carried out when typhoon signal no.3 or above is hoisted. No sampling
should be carried out when typhoon signal No.3 or above or black rainstorm
signal is hoisted. The make-up sampling work
would immediately be scheduled to ensure the water quality.
b) At least one duplicate in-situ measurement and water sample for laboratory analyses are required for all sampling locations.
c) The interval between two sets of monitoring shall not be less than 36 hours except where there are exceedances of Action and/or Limit levels, in which case the monitoring frequency will be increased.
d)
All measurements shall be carried out
at three water depths, namely, 1 m below water surface, mid-water depth, and 1
m above seabed as appropriate to the derivation of Action and Limit
levels. If the water depth is less
than 6 m, the mid-depth measurement may be omitted. If the depth is less than 3 m, only the mid-depth
measurement needs to be taken. All
parameters should be measured on each monitoring day.
e)
At
each measurement depth, two consecutive measurements would be taken. The probes would be retrieved out of
the water after the first measurement and then redeployed for the second measurement. When the
difference in value between the first and second measurement of on-site
parameters is more than 25% of the value of the first reading, the reading
shall be discarded and further readings shall be taken.
f)
Monitoring
schedule should reach EPD at least one week prior to the commencement of
monitoring.
Water quality monitoring
results will be evaluated against Action and Limit levels as shown in Table 4.12a.
Exceedances of the Action and Limit Levels may, as necessary, result in
changes to the monitoring and dredging operations, potentially involving
increased monitoring and implementation of appropriate mitigation measures.
Table 4.12a Action and Limit levels for Water Quality
Parameters |
Action |
Limit |
DO in mg/ L (Surface, Middle and Bottom). |
Surface and Middle 5%-ile of baseline and last 5
years’ MWQ in Hong Kong for surface and middle layers. |
Surface and Middle 4 mg/L or 1%-ile of baseline and last 5
years’ MWQ in Hong Kong for surface and middle layers. |
|
Bottom 5%-ile of baseline and last 5
years’ MWQ in Hong Kong for bottom layer. |
Bottom 2 mg/L or 1%-ile of baseline and last 5
years’ MWQ in Hong Kong for bottom layer. |
SS in mg/L (depth-averaged) |
95%-ile of baseline data or 120% upstream control
station's SS at the same tide of the same day |
99%-ile of baseline, or 130% of upstream control
station's SS at the same tide of the same day. For SR10, the SS limit is 100 mg/L |
Turbidity (Tby) in NTU (depth-averaged) |
95%-ile of baseline data or 120% of upstream
control station’s Tby at the same tide on the same day |
99%-ile of baseline data or 130% of upstream
control station’s Turbidity at the same tide on the same day |
Notes: ·
“Depth-averaged” is calculated by taking the arithmetic mean of the reading of all three depths; ·
In order to take into account the seasonal variations of the baseline
DO level, separate baseline DO levels for the dry and the wet seasons would be derived both from the baseline data obtained
prior to the commencement of works and EPD’s routine monitoring data in the
study area over the last 5 years. |
||
·
For DO, non-compliance of the water quality limits occurs when
monitoring result is lower than the limits. ·
For SS and Turbidity, non-compliance of the water quality limits
occurs when monitoring result is higher than the limits. ·
All the figures given in the table subject to revision pending
results of the baseline monitoring and subsequent approval by EPD. ·
Whichever of the two criteria is greater, except DO which will
take the lower of the two criteria, shall be used as the Action and Limit levels.
Subject to approval from EPD. |
Should the monitoring
results of the water quality parameters at any designated monitoring stations
indicate that the water quality criteria have been exceeded, the actions in accordance
with the Event and Action Plans in Table 4.13a shall be carried out.
Sources of impact will be identified by comparing the data from the
Control and Impact Stations as well as site observations on special activities and abnormalities. If both the Control
and Impact Stations show exceedences of the Action and Limit Levels then the
recorded exceedences would not be attributed to the works and mitigation
measures would not need to be implemented. In this case it may still be recommended that the monitoring
frequency be increased at both Control and Impact Stations to provide
additional confirmation on the finding that the exceedences are not
attributable to the works. If, however,
exceedences are found at the Impact Stations and not at the Control Stations
then suitable mitigation measures should be devised, as the impacts would be attributed to
the works.
Details of all the recommended mitigation measures are included within the Implementation Schedule (in Annex B of this EM&A Manual).
In order to ensure that water resources are adequately protected it will be necessary to undertake audits to ensure the effective implementation of the recommended mitigation measures and to ensure compliance with the EIA report’s assumptions and recommendations.
Table4.13a Event and Action Plans for Water Quality
Exceedance |
ET Leader |
IEC |
Engineer |
Contractor |
Action level exceeded on one sampling day |
Verbally inform the Contractor, and IEC. Repeat in-situ measurement to confirm findings; Identify source(s) of impact; Check monitoring data, all plant, equipment and Contractor's
working methods; Discuss mitigation measures with IEC, Engineer and Contractor; Repeat measurement on next day of exceedance. |
Provide feedback to the Engineer on the remedial
actions proposed by the ET / Contractor Advise Engineer on the effectiveness of the
proposed remedial measures Verify the implementation of the remedial measures |
Discuss with Contractor the proposed mitigation
measures; Make agreement on the mitigation measures to be
implemented; Assess the effectiveness of the implemented
mitigation measures. |
Inform the Engineer and confirm notification of
the non-compliance in writing; Rectify unacceptable practice; Check all plant and equipment; Consider changes of working methods; Propose and discuss mitigation measures with Engineer; Implement the agreed mitigation measures. |
Action level exceeded on more than one consecutive
sampling day |
Repeat in-situ measurements to confirm findings; Identify source(s) of impact; Inform Contractor and IEC; Check monitoring data, all plant, equipment and
Contractor's working methods; Discuss mitigation measure with IEC, Engineer and Contractor; Ensure mitigation measures are implemented; Prepare to increase the monitoring frequency to
daily; Repeat measurement on next day of exceedance. |
Provide feedback to the Engineer on the remedial
actions proposed by the ET / Contractor Advise Engineer on the effectiveness of the
proposed remedial measures Verify the implementation of the remedial measures |
Discuss with ET and Contractor on the proposed
mitigation measures; Make agreement on the mitigation measures to be
implemented; Assess the effectiveness of the implemented
mitigation measures. |
Inform the Engineer and confirm notification of the
non-compliance in writing; Rectify unacceptable practice; Check all plant and equipment; Consider changes of
working methods; Propose mitigation measures to Engineer within 3
working days and discuss with ET and Engineer; Implement the agreed mitigation measures. |
Limit level exceeded on one sampling day |
Verbally inform the Contractor, IEC and the EPD of
the exceedance; Repeat in-situ measurement to confirm findings; Identify source(s) of impact; Check monitoring data, all plant, equipment and
Contractor's working methods; Discuss mitigation measure with IEC, Engineer and Contractor; Ensure mitigation measures are implemented; Increase the monitoring frequency to daily until
no exceedance of Limit level. |
Provide feedback to the Engineer on the remedial
actions proposed by the ET / Contractor Advise Engineer on the effectiveness of the
proposed remedial measures Verify the implementation of the remedial measures |
Discuss with Contractor on the proposed mitigation
measures; Request Contractor to critically review the
working methods; Make agreement on the mitigation measures to be
implemented; Assess the effectiveness of the implemented
mitigation measures. |
Inform the Engineer and confirm notification of
the non-compliance in writing; Rectify unacceptable practice; Check all plant and equipment; Consider changes of
working methods; Propose mitigation measures to Engineer within 3
working days and discuss with Engineer; Implement the agreed mitigation measures. |
Limit level exceeded by more than one consecutive
sampling day |
Repeat in-situ measurement to confirm findings; Identify source(s) of impact; Inform Contractor, IEC and EPD; Check monitoring data, all plant, equipment and
Contractor's working methods; Discuss mitigation measure with IEC, Engineer and Contractor; Ensure mitigation measures are implemented; Increase the monitoring frequency to daily until
no exceedance of Limit level for two consecutive days. |
Provide feedback to the Engineer on the remedial
actions proposed by the ET / Contractor Advise Engineer on the effectiveness of the
proposed remedial measures Verify the implementation of the remedial measures |
Discuss with Contractor on the proposed mitigation
measures; Request Contractor to critically review the
working methods; Make agreement on the mitigation measures to be
implemented; Assess the effectiveness of the implemented
mitigation measures; Consider and instruct, if necessary, the
Contractor to slow down or to stop all or part of the marine works until no
exceedance of the Limit Level. |
Inform the Engineer and confirm notification of
the non-compliance in writing; Rectify unacceptable practice; Check all plant and equipment; Consider changes of
working methods; Propose mitigation measures to Engineer within 3
working days and discuss with Engineer; Implement the agreed mitigation measures.. As directed by the Engineer, to slow down or to
stop all or part of the marine work |
In this section, EM&A recommendations, methodology, audit of
waste management and reporting are presented.
In order to ensure that the Contractor has implemented the
recommendations of the EIA, the ET shall conduct site audits of the waste generated from the Project (viz. dredged mud), to determine if the waste is being managed in accordance with the approved
procedures. The scope of the waste
management audits is presented below.
5.3
Objectives of The Waste Audit
The aims of the waste management audit will include, but are not limited to, the following:
· ensuring that the wastes arising from works are handled, stored, collected, transferred and disposed of in an environmentally acceptable manner and comply with the relevant requirements under the Waste Disposal Ordinance (WDO) and its regulations, and the Dumping at Sea Ordinance (DASO);
· ensuring that the Contractor properly implements the appropriate environmental protection and the Implementation Schedule (Annex B) to minimise and control the potential for waste impacts.
The Contractor is responsible for waste control within the working site, removal of waste material produced by the working site and the implementation of any
mitigation measures to avoid or minimise potential adverse impacts associated
with waste arising from the Project.
The Contractor should also ensure that the necessary waste disposal
permits or licences are obtained from appropriate authorities in accordance
with the various Ordinances. The Contractor should
follow the procedures in the approved method statements, recommendations in the
EIA report and the EM&A Manual.
One set of relevant documents including the Environmental Permit for the
Project and dumping permit will be kept at site for reference at any time.
The ET should also regularly inspect and audit the waste management
practices on site with reference to the recommendations given in the Implementation Schedule in Annex B. The ET inspection results and their
associated recommendations on improvements to the waste management shall be
submitted to the Engineer for follow up action.
The inspection results with the remedial actions taken by the
Contractor, if any, will be represented in the Monthly EM&A reports.
Disposal of uncontaminated dredged mud has provisionally been assigned to East Tung Lung
Chau, East of Ninepins and East Sha Chau Pit CMP IVb. According to the letter from the Marine Fill Committee of the Civil
Engineering Department (CED) dated 9th May 2002 regarding allocation
of Disposal Capacity for Cateogroy L Sediment, in the
dry season from
beginning October to mid-March, the dredged material
should be disposed of at the East Tung Lung Chau disposal site for up to 50,000
m3/day (in hopper) and the remaining volume should be
disposed of at the East Sha Chau Pit CMP IVb. East Ninepin site should be used for the disposal of the
dredged material in the wet season from mid-March to the end of September only.
If the dredged muds are disposed
of at East Tung Lung Chau disposal areas, HEC is required to carry out
environmental monitoring in accordance with the EM&A
Manual for Backfilling of Marine Borrow
Areas at East Tung Lung Chau. The
monitoring shall include bathymetric surveys, water quality monitoring and
ecological monitoring. As the
monitoring work is carried out under the separate EM&A Manual already
endorsed by the Authority, the monitoring results will not be reported under
this EM&A Manual. Instead, the
monitoring reports shall be submitted to EPD separately and copied to the Fill
Management Division of the CED at agreed intervals.
Barges should be fitted with
tight fitting seals to their bottom openings to prevent leakage of materials
during the transport process.
Barges should not be filled to a
level which will cause overflow of materials during loading and transportation.
The monthly EM&A reports shall contain the results of the waste management practices being implemented on site. These include the site inspection results and records of daily dredged materials.
Site inspections provide a direct means to track and ensure the enforcement of specified environmental protection and pollution control measures. The inspections should be undertaken routinely by the ET to ensure that appropriate environmental protection and pollution control mitigation measures are properly implemented. Additionally, the ET shall be responsible for defining the scope of the inspections, detailing any deficiencies that are identified, and reporting any necessary action or mitigation measures that were implemented as a result of the inspection.
Site inspections shall be carried out once per week. The areas of inspection should include the general environmental conditions in the vicinity of the site and pollution control and mitigation measures within the site; it should also review the environmental conditions outside the site area which are likely to be affected, directly or indirectly, by site activities. The ET shall make reference to the following information in conducting the inspections:
· the environmental protection and pollution control mitigation measures included in this EM&A Manual;
· ongoing results of the EM&A programme;
· works progress and programme;
· individual works method statements which shall include proposals on associated pollution control measures;
· the relevant environmental protection and pollution control laws; and
· previous site inspection results.
The ET inspection results and their associated recommendations on improvements to the environmental protection and pollution control works shall be submitted to the Engineer within 24 hours, for reference and for taking immediate action. They shall also be presented, along with the remedial actions taken, in the monthly EM&A report. The Contractor shall follow the procedures and time frames stipulated in the environmental site inspection for the implementation of mitigation proposals and the resolution of deficiencies in the Contractor’s EMS. An action reporting system shall be formulated and implemented to report on any remedial measures implemented subsequent to the site inspections.
Ad hoc site inspections shall also be carried out by the ET Leader if significant environmental problems are identified. Inspections may also be required subsequent to receipt of an environmental complaint, or as part of the associated investigation work.
In addition to the ET’s
inspection, the IEC shall also conduct random site inspections in order to
verify the Contractor’s environmental performance and appropriate
implementation of the required practices and mitigation measures. These inspections will also be an
important source of data collection to allow the IEC to undertake an up-to-date
and informed review of the information and data contained within the monthly
EM&A reports.
6.2
Compliance with Legal and Contractual Requirements
The Contractor shall comply with environmental protection and pollution control requirements stipulated in this EM&A Manuals well as Hong Kong environmental protection and pollution control laws.
The ET Leader shall review the progress and programme of the works to check that relevant environmental laws have not been violated, and that any foreseeable potential for violating the laws can be prevented.
The Contractor shall also regularly copy relevant documents to the ET Leader so that the checking work can be carried out. The relevant documents are expected to include the updated Work Progress Reports, the updated Works Programme, the application letters for different licences/permits under the environmental protection laws, and all the valid licences/permit. The site diary shall also be made available, upon request, to the ET Leader during his site inspection.
After reviewing the documentation, the ET Leader shall advise the Engineer and the Contractor of any non-compliance with the contractual and legislative requirements on environmental protection and pollution control for them to take follow-up actions. If the ET Leader's review concludes that the current status on licence/permit application and any environmental protection and pollution control preparation works is incompatible with the works programme or may result in potential violation of environmental protection and pollution control requirements by the works in due course, he shall also advise the Contractor and the Engineer accordingly.
Upon receipt of the advice, the Contractor shall undertake immediate action to remedy the situation. The Engineer shall follow up to ensure that appropriate action has been taken by the Contractor in order that the environmental protection and pollution control requirements are fulfilled.
HEC has already established a formal procedure for handling complaints on environmental matters against Lamma Power Station to ensure that appropriate actions will be taken to handle the complaints properly. Similar to other existing specific EM&A programs for the Power Station, handling of complaints will generally follow the established procedure and only those identified to be related to the Navigation Channel Improvement work will be reported in this EM&A report. A flow chart outlining the complaints handling procedure is shown in Figure 6.1 and briefly described below.
Complaints can be received via various channels and can generally be
classified into
verbal and written complaints. Details
of complaints shall be logged into a complaints register by the ET. Information to be recorded shall
include the name, address & contact number of the complainant and also the
date, time & nature of the complaint.
When a verbal complaint is received which obviously does not concern HEC, the party receiving the complaint shall directly reply to the complainant accordingly or via Public Affairs Department (PA) unless it is lodged via EPD in which case it shall be referred to CE(P) or his representative for a formal reply.
Any verbal complaint which may concern HEC or written complaint
shall be referred to the ET who shall then coordinate a detailed
investigation. Where appropriate,
the party receiving the complaint shall also take immediate temporary remedial
action to alleviate the problem or prevent it from deteriorating. After the investigation is completed, the party receiving the
complaint shall reply to the
complainant accordingly or via PA unless it
is lodged via EPD for which the reply shall be made by CE(P).
Replies to written complaints shall be formal in writing signed by the nominated responsible officer. In all replies, whether verbal or written, the complainant shall be informed of the investigation results and the subsequent remedial actions taken. When the investigation reveals that the complaint is not justified, the complainant shall also be informed, together with the reasons for arriving at such a conclusion. The details of the replies shall be referred to the ET for logging into the complaints register.
When a complaint is referred to the ET for a detailed investigation, the ET shall:-
a) Where necessary arrange a verbal or written acknowledgement to the complainant advising that an investigation is underway.
b) Coordinate an investigation to determine the validity of the complaint and to identify the source of the problem.
c) Arrange monitoring to verify the existence and severity of the complaint if necessary.
d) Propose mitigation measures if necessary.
e) Arrange additional monitoring, audit and inspections as necessary to verify the status and effectiveness of the mitigation measures.
f) Arrange interim replies to the complainant if necessary.
g) Record the relevant information in the complaints register.
h) Log the details of the complaint and report the actions taken to investigate, resolve and respond to the complaint in the monthly EM&A Report.
During the complaint investigation work, the relevant
Department(s) shall cooperate with the ET in providing all necessary information and
assistance. If mitigation measures
are necessary, the relevant
Department(s) shall ensure that the measures are promptly carried out.
A pending-complaint review system (such as regular evaluation in routine Working Committee Meetings) shall be operated to ensure timely follow-up of outstanding complaints.
The normal contact telephone and fax numbers at HEC for complaints are:-
Party |
Attention |
Telephone |
Fax |
Generation
Division |
Central Control Room No.1 |
2982 6410 |
2982 6504 |
System Control
Department |
Customer
Emergency Services Centre (24 hours) |
2555 4999 |
2555 6637 |
Figure 6.1. Complaints
Handling Procedure
The primary reporting function, undertaken within the EM&A programme, will be the issuance of formal exceedance notifications, corrective actions and ongoing feedback between the ET Leader, the Contractor and the Engineer. Reporting will be driven by the results of the monitoring and audit programme and will be recorded through written correspondence, site inspections and minutes and notes of meetings.
In addition, periodic reviews of the EM&A process and subsequent revisions to the EM&A Manual, as appropriate, will be prepared and circulated to relevant personnel within the Contractor’s Project Team as a means of gauging site staff and contractor performance. The periodic reviews will comprise the Monthly EM&A Reports. These reports will be copied to the EPD for comment. The exact details of the frequency, distribution and time frame for submission shall be agreed with the EPD prior to the commencement of the works.
7.2
Baseline Monitoring Report
The ET Leader shall prepare and submit a Baseline Environmental
Monitoring Report at least 2 weeks before the commencement of the works
that would affect the monitoring results.
Copies of the Baseline Report shall be submitted to all parties for
agreement; including the Engineer, IEC and the EPD. Two hard copies and one soft copy of the Baseline Monitoring
Report shall be submitted to EPD.
The submissions shall be certified by the ET leader and verified by the
IEC. The report shall include the
following elements:
i) drawings showing locations of the baseline monitoring stations;
ii) monitoring results (in both hard and soft copies) together with the following information:
· monitoring methodology;
· equipment used and calibration details;
· parameters monitored;
· monitoring locations (and depth);
· monitoring date, time, frequency and durations;
iii) details on influencing factors, including;
· major activities, if any, being carried out on the site during the period;
· weather conditions during the period;
· other factors which might affect the results;
iv) determination of action and limit levels for each monitoring parameter and statistical analysis of the baseline data;
v) revisions for inclusion in the EM&A Manual
Monthly EM&A Reports shall be prepared and certified by the ET Leader. The reports shall be verified by the IEC and submitted to the EPD with one hard copy and one soft copy within 2 weeks of the end of each month after works commence. The ET Leader shall liaise with the relevant parties to confirm the format of monthly reports in both hard copy and electronic format. The report shall include the following elements:
i) 1-2 pages executive summary;
ii) basic project information including a synopsis of the project organisation, programme and management structure, and the work undertaken during the month;
iii) a brief summary of EM&A requirement including:
· all monitoring parameters;
· environmental quality performance limits;
· Event-Action Plan;
· environmental mitigation measure, as recommended in the EIA report;
· Environmental requirements in contract documents;
iv) advice on the implementation status of the environmental protection, mitigation and pollution control measures, as recommended in the EIA report, summarised in the updated implementation schedule;
v) drawing showing the project area, any environmental sensitive receivers and the locations of the monitoring and control stations;
vi) monitoring results (in both hard and softcopies) together with the following information:
· monitoring methodology;
· equipment used and calibration details;
· parameters monitored;
· monitoring locations (and depth);
· monitoring date, time, frequency and durations;
vii) graphical plots of trends of monitored parameters over the past reporting periods for representative monitoring stations annotated against the following:
· major activities being carried out on the site during the period;
· weather conditions during the period; and
· any other factors which might affect the monitoring results;
viii) a summary of non-compliance (exceedances) of the environmental quality performance limits;
ix) a review of the reasons for and the implications of non-compliance including review of pollution sources and working procedures;
x) a description of the actions taken in the even of non-compliance and deficiency reporting and any follow-up procedure taken and summary of complaints;
xi) a summary record of all complaints received (written or verbal) for each media, including location and nature of complaints liaison and consultation undertaken, actions and follow-up procedures taken and summary of complaints;
xii) a summary record of notification of summons, successful prosecutions for breaches of environmental protection/pollution control legislation, and actions taken to rectify such breaches;
xiii) a forecast of the work programme, impact predications and monitoring schedule for the next three months; and
xiv) comments, recommendations and conclusions for the monitoring period.
The EM&A programme shall be terminated upon completion of dredging
and post-dredging monitoring. Copies
of the final
EM&A Summary Report shall be submitted to all
parties for agreement; including the Engineer, IEC and the EPD. Two hard copies and one soft copy of
the final EM&A
Summary Report shall be submitted to EPD. The submissions shall be certified by
the ET leader and verified by the IEC.
The final
EM&A summary report shall include the following:
a)
an
executive summary;
b)
basic
project information including a synopsis of the project organisation,
programme, contacts of key management, and a synopsis of work undertaken during
the entire construction period;
c)
a
brief summary of EM&A requirement including:
·
monitoring
parameters;
·
environmental
quality performance limits (Action and Limit levels); and
·
environmental
mitigation measures, as recommended in the project EIA study final report;
d)
advice
on the implementation status of environmental protection and pollution
control/mitigation measures, as recommended in the project EIA study report,
summarised in the updated implementation status proformas;
e)
drawings
showing the projects area, any environmental sensitive receivers and the
locations of the monitoring and control stations;
f)
graphical
plots of the trends of monitored parameters over the construction period for
representative monitoring stations annotated against;
·
the
major activities being carried out on Site during the period;
·
weather
conditions during the period;
·
any
other factors which might affect the monitoring results; and
·
the
return of ambient environmental conditions in comparison with baseline data;
g)
compare
and contrast the EM&A data with the EIA predictions and annotate with
explanation for any discrepancies;
h)
provide
clear-cut decisions on the environmental acceptability of the project with
reference to the specific impact hypothesis;
i)
advice
on the solid and liquid waste management status;
j)
a
summary of non-compliance (exceedances) of the environmental quality
performance limits (Action and Limit levels);
k)
a
brief review of the reasons for and the implications of non-compliance
including review of pollution sources and working procedures;
l)
a
summary description of the actions taken in the event of non-compliance and
follow-up procedures related to earlier non-compliance;
m)
a
summary record of all complaints received (written or verbal) for each media,
liaison and consultation undertaken, actions and follow-up procedures taken;
n)
review
the monitoring methodology adopted and with the benefit of hindsight, comment
on its effectiveness (including cost effectiveness);
o)
a summary
record of notifications of summons and successful prosecutions for breaches of
the current environmental protection/pollution control legislations, locations
and nature of the breaches, investigation, follow-up action taken and results;
p)
review
the practicality and effectiveness of the EIA process and EM&A programme
(e.g. effectiveness and efficiency of the mitigation measures), recommend any
improvement in the EM&A programme; and
q)
a
conclusion to state the return of ambient and/or the predicted scenario as per
EIA findings.
7.5
Record of Sounding Surveys
Record
of sounding surveys on the navigation channel shall be submitted to EPD for
reference upon completion of the dredging works.
7.6
Electronic Reporting of EM&A
Information
To
facilitate public inspection of the Baseline Monitoring Report and monthly
EM&A Reports via the EIAO Internet Website and at the EIAO Register Office,
electronic copies of these Reports shall be prepared in Hyper Text Markup
Language (HTML) (version 4.0 or later) and in Portable Document Format (PDF
version 4.0 or later), unless otherwise agreed by EPD and shall be submitted at
the same time as the hard copies to EPD.
For the HTML version, a content page capable of providing hyperlink to
each section and sub-section of these Reports shall be included in the
beginning of the document.
Hyperlinks to all figures, drawings and tables in these Reports shall be
provided in the main text from where the respective references are made. All graphics in these Reports shall be in
interlaced GIF format unless otherwise agreed by EPD. The content of the electronic copies of these Reports must
be the same as the hard copies.
All
environmental monitoring data in the Baseline Monitoring and the monthly
EM&A shall be made available to the public via internet access in the form
of a website, in the shortest possible time and in no event later than two
weeks after the relevant environmental monitoring data are collected or become
available, unless otherwise agreed with EPD. HEC shall notify EPD in writing the internet address where
the environmental monitoring data are to be placed. The internet address and the relevant environmental
monitoring data shall be made available to the public via the EIAO Internet
Website and the EIAO Register Office.
The
internet website shall enable user friendly public access to the monitoring
data and with features capable of:
i) providing
access to environmental monitoring data collected since the commencement of
works;
ii) searching
by date;
iii) searching
by types of monitoring data; and
iv)
hyperlinks
to relevant monitoring data after searching.
All documents and records, in both paper and electronic format, pertaining to this EM&A programme will be retained by the ET Leader as part of the Project files and will be subject to appropriate data handling procedures. All documents and data shall be kept up to 1 year after the completion of the Project.
7.8
Interim Notification of Environmental Quality Limit Exceedances
Interim notifications of exceedances of
Limit levels will be reported both verbally and in writing to
the EPD as soon as practicable. The Monthly Reports
will contain all available details concerning exceedances and complaints, their
causes and those steps taken to control impacts and prevent their recurrence.