3. air quality

Introduction

3.1 In this section, the requirements, methodology, equipment, monitoring locations, criteria and protocols for the monitoring and audit of air quality impacts during the construction phase of the proposed Project are described. The EIA Report has identified that construction dust is the only concern, and dust emission from the site shall be audited during the construction phase.

Air Quality Parameters

3.2 The EIA Report predicted that air quality impacts on the air sensitive receivers are within the dust criteria during construction phase. Regular impact monitoring is considered not necessary and environmental audit of the site is required.

3.3 Environmental audit of dust generation from the site shall be carried out by the ET to ensure that any deteriorating air quality could be readily detected and timely action taken to rectify the situation. Ad-hoc monitoring is recommended at sensitive receivers when required by the ER/ IC(E), or on receipt of complaint.

3.4 One-hour and 24-hour TSP levels should be measured for the ad hoc monitoring to indicate the impacts of construction dust on air quality. The 24-hour TSP levels shall be measured by following the standard high volume sampling method as set out in the Title 40 of the Code of Federal Regulations, Chapter 1 (Part 50), (Appendix B). Upon approval of the ER, 1-hour TSP levels can be measured by direct reading methods which are capable of producing comparable results as that by the high volume sampling method, to indicate short event impacts.

3.5 All relevant data including temperature, pressure, weather conditions, elapsed-time meter reading for the start and stop of the sampler, identification and weight of the filter paper, and any other local atmospheric factors affecting or affected by site conditions, etc., shall be recorded down in detail. A sample data sheet is shown in Appendix B.

Monitoring Equipment

3.6 High volume samplers (HVSs) in compliance with the following specifications shall be used for carrying out the 1-hour and 24-hour TSP monitoring:

a) 0.6 - 1.7 m³per minute adjustable flow range;

b) equipped with a timing / control device with +/- 5 minutes accuracy for 24 hours operation;

c) installed with elapsed-time meter with +/- 2 minutes accuracy for 24 hours operation;

d) capable of providing a minimum exposed area of 406 cm²;

e) flow control accuracy: +/- 2.5% deviation over 24-hour sampling period;

f) equipped with a shelter to protect the filter and sampler;

g) incorporated with an electronic mass flow rate controller or other equivalent devices;

h) equipped with a flow recorder for continuous monitoring;

i) provided with a peaked roof inlet;

j) incorporated with a manometer;

k) able to hold and seal the filter paper to the sampler housing at horizontal position;

l) easily changeable filter; and

m) capable of operating continuously for a 24-hour period.

3.7 The ET is responsible for provision of the monitoring equipment. They shall ensure that sufficient number of HVSs with an appropriate calibration kit are available for carrying out the baseline monitoring, and ad hoc monitoring. The HVSs shall be equipped with an electronic mass flow controller and be calibrated against a traceable standard at regular intervals. All the equipment, calibration kit, filter papers, etc., shall be clearly labelled.

3.8 Initial calibration of dust monitoring equipment shall be conducted upon installation and thereafter at bi-monthly intervals. The transfer standard shall be traceable to the internationally recognised primary standard and be calibrated annually. The concerned parties such as IC(E) shall properly document the calibration data for future reference. All the data should be converted into standard temperature and pressure condition.

3.9 The flow-rate of the sampler before and after the sampling exercise with the filter in position shall be verified to be constant and be recorded in the data sheet as mentioned in Appendix B.

3.10 If the ET proposes to use a direct reading dust meter to measure 1-hour TSP levels, he shall submit sufficient information to the IC(E) to prove that the instrument is capable of achieving a comparable result to the HVS. The instrument should also be calibrated regularly, and the 1-hour sampling shall be determined periodically by the HVS to check the validity and accuracy of the results measured by direct reading method.

Laboratory Measurement / Analysis

3.11 A clean laboratory with constant temperature and humidity control, and equipped with necessary measuring and conditioning instruments to handle the dust samples collected, shall be available for sample analysis, and equipment calibration and maintenance. The laboratory should be HOKLAS accredited.

3.12 If a site laboratory is set up or a non-HOKLAS accredited laboratory is hired for carrying out the laboratory analysis, the laboratory equipment shall be approved by the ER and the measurement procedures shall be witnessed by the IC(E). Any measurement performed by the laboratory shall be demonstrated to the satisfaction of the ER and IC(E). The IC(E) shall regularly audit the measurement performed by the laboratory to ensure the accuracy of measurement results. The ET Leader shall provide the ER with one copy of the Title 40 of the Code of Federal Regulations, Chapter 1 (Part 50), (Appendix B) for his reference.

3.13 Filter paper of size 8" x 10" shall be labelled before sampling. It shall be a clean filter paper with no pinholes, and shall be conditioned in a humidity-controlled chamber for over 24-hours and be pre-weighed before use for the sampling.

3.14 After sampling, the filter paper loaded with dust shall be kept in a clean and tightly sealed plastic bag. The filter paper shall then be returned to the laboratory for reconditioning in the humidity-controlled chamber followed by accurate weighing by an electronic balance with readout down to 0.1 mg. The balance shall be regularly calibrated against a traceable standard.

3.15 All the collected samples shall be kept in a good condition for 6 months before disposal.

Monitoring Locations

3.16 Ad-hoc dust monitoring locations shall be monitored at sensitive receivers when required by the ER/ IC(E) or on receipt of compliant. Alternative monitoring locations shall be proposed by the ET leader, and approved by the ER and agreed by IC(E).

3.17 Should alternative monitoring locations be proposed, the proposed sites should, as far as practicable:

a) be at the site boundary or such locations close to the major dust emission source;

b) be close to the sensitive receptors; and

c) take into account the prevailing meteorological conditions.

3.18 The ET shall agree with the ER in consultation with the IC(E) on the position of the HVS for the installation of the monitoring equipment. When positioning the samplers, the following points shall be noted:

a) a horizontal platform with appropriate support to secure the samplers against gusty wind should be provided;

b) no two samplers should be placed less than 2 meters apart;

c) the distance between the sampler and an obstacle, such as buildings, must be at least twice the height that the obstacle protrudes above the sampler;

d) a minimum of 2 meters of separation from walls, parapets and penthouses is required for rooftop samplers;

e) a minimum of 2 meters separation from any supporting structure, measured horizontally is required;

f) no furnace or incinerator flue is nearby;

g) airflow around the sampler is unrestricted;

h) the sampler is more than 20 meters from the dripline;

i) any wire fence and gate, to protect the sampler, should not cause any obstruction during monitoring;

j) permission must be obtained to set up the samplers and to obtain access to the monitoring stations; and

k) a secured supply of electricity is needed to operate the samplers.

Baseline Monitoring

3.19 Baseline monitoring shall be carried out at the designated baseline monitoring locations shown in Table 3.1 for at least 14 consecutive days prior to the commissioning of the construction works to obtain daily 24-hour TSP samples. The selected baseline monitoring stations should reflect baseline conditions at the impact stations. One-hour sampling should also be done at least 3 times per day while the highest dust impact is expected. The proposed locations of the baseline monitoring stations are shown in Figure 3.1.

Table 3.1 Baseline Monitoring Location

Identification No	Location
AM1	Village house near Kwu Tung Road
AM2	Village house near San Tin Highway

3.20 During the baseline monitoring, there should not be any construction or dust generation activities in the vicinity of the monitoring stations. Before commencing baseline monitoring, the ET shall inform the IC(E) of the baseline monitoring programme such that the ER can conduct on-site audit to ensure accuracy of the baseline monitoring results.

3.21 In case the baseline monitoring cannot be carried out at the designated monitoring locations during the baseline monitoring period, the ET Leader shall carry out the monitoring at alternative locations that can effectively represent the baseline conditions at the impact monitoring locations. The alternative baseline monitoring locations shall be approved by the ER and agreed with the IC(E).

3.22 In exceptional cases, when insufficient baseline monitoring data or questionable results are obtained, the ET shall liaise with the IC(E) and EPD to agree on an appropriate set of data to be used as a baseline reference and submit to ER for approval.

3.23 Ambient conditions may vary seasonally and shall be reviewed once every three months. When the ambient conditions have changed and a repeat of the baseline monitoring is required to be carried out for obtaining the updated baseline levels, the monitoring should be conducted at times when the Contractor's activities are not generating dust, at least in the proximity of the monitoring stations. Should change in ambient conditions be determined, the baseline levels and, in turn, the air quality criteria, should be revised. The revised baseline levels and air quality criteria should be agreed with the IC(E) and EPD.

Monitoring of Construction Air Quality Impact

3.24 The ET shall carry out ad-hoc impact monitoring when required by the ER or IC(E) during the course of the Works. Before commencing monitoring, the ET shall inform the IC(E) of the impact monitoring programme such that the IC(E) can conduct on-site audit to ensure accuracy of the impact monitoring results.

3.25 In case of non-compliance with the air quality criteria, additional monitoring as specified in the Action Plan in the following section, shall be conducted within 24 hours after the result is obtained. This additional monitoring shall be continued until the excessive dust emission or the deterioration in air quality is rectified.

Environmental Quality Performance Limits

3.26 The baseline monitoring results form the basis for determining the air quality criteria for the impact monitoring. The ET shall compare the impact monitoring results with air quality criteria set up for 1-hour TSP. Table 3.2 shows the air quality criteria, namely Action and Limit levels to be used.

Table 3.2 Action / Limit Levels for Air Quality

Parameters

Action

Limit

1-hour TSP Level in mg m^-3

For baseline level £ 384 mg m^-3, Action level = (baseline level ´ 1.3 + Limit level)/2;

For baseline level > 384 mg m^-3, Action level = Limit level

500 mg m^-3

Event and Action Plan for Construction Air Quality

3.27 Should non-compliance of the air quality criteria occur, actions in accordance with the Action Plan in Table 3.3 should be carried out.

Table 3.3 Event / Action Plan for Air Quality

EVENT

ACTION

IC(E)

CONTRACTOR

ACTION LEVEL

1. Exceedance for one sample

1. Identify source, investigate the causes of exceedance and propose remedial measures;

2. Inform IC(E) 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.

1. Rectify any unacceptable practice;

2. Amend working methods if appropriate.

2. Exceedance for two or more consecutive samples

1. Identify source;

2. Inform IC(E) and ER;

3. Advise the ER on the effectiveness of the proposed remedial measures;

4. Repeat measurements to confirm findings;

5. Increase monitoring frequency to daily;

6. Discuss with IC(E) and Contractor on remedial actions required;

7. If exceedance continues, arrange meeting with IC(E) and ER;

8. If exceedance stops, cease additional monitoring.

1. Check monitoring data submitted by ET;

2. Check Contractor’s working method;

3. Discuss with ET and Contractor on possible remedial measures;

4. Advise the ET 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. Ensure remedial measures properly implemented.

1. Submit proposals for remedial 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, investigate the causes of exceedance and propose remedial measures;

2. Inform ER, Contractor and EPD;

3. Repeat measurement to confirm finding;

4. Increase monitoring frequency to daily;

5. Assess effectiveness of Contractor’s remedial actions and keep IC(E), EPD and ER informed of the results.

1. Check 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. Ensure remedial measures properly implemented.

1. Take immediate action to avoid further exceedance;

2. Submit proposals for remedial actions to IC(E) 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.Notify IC(E), ER, Contractor and EPD;

2.Identify source;

3.Repeat measurement to confirm findings;

4.Increase monitoring frequency to daily;

5.Carry out analysis of Contractor’s working procedures to determine possible mitigation to be implemented;

6.Arrange meeting with IC(E) and ER to discuss the remedial actions to be taken;

7.Assess effectiveness of Contractor’s remedial actions and keep IC(E), EPD and ER informed of the results;

8.If exceedance stops, cease additional monitoring.

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

2. Review Contractor’s remedial actions whenever necessary to assure 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. In consolidation with the IC(E), agree with the Contractor on the remedial measures to be implemented;

4. Ensure remedial measures properly implemented;

5. 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 IC(E) 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.