1
Introduction
1.1
Purpose of the Manual
This Environmental Monitoring and Audit (EM&A) Manual
(“the Manual”) has been prepared by ERM-Hong
Kong, Limited (ERM) on behalf of the Civil Engineering and Development
Department (CEDD) of the Hong Kong Special Administrative Region (SAR)
Government. The Manual is a
supplementary document of the Environmental Impact Assessment (EIA) Study of
the Detailed Site Selection Study for a Proposed Contaminated Mud Disposal
Facility within the Airport East/East of Sha Chau Area (Agreement CE 12/2002
(EP)) (hereafter referred to as the Project).
The Manual has been prepared in accordance with the EIA
Study Brief (No. ESB-095/2001) and the Technical Memorandum of the
Environmental Impact Assessment Process (EIAO TM). The purpose of the Manual is to provide
information, guidance and instruction to personnel charged with environmental
duties and those responsible for undertaking EM&A work during construction
and operation. It provides
systematic procedures for monitoring and auditing of potential environmental
impacts that may arise from the works.
1.2
Project Description
1.2.1
Background to the Study
From December 1992 to November 1997, a
series of purpose-dredged seabed pits at East Sha Chau (Contaminated Mud Pits
(CMPs) I to III) were used to dispose of dredged contaminated mud in Hong
Kong. In 1996, as the capacity in
these pits began to dwindle, the Hong Kong Government commissioned a study to
examine the need for continued marine disposal of dredged material in Hong Kong
in order to manage ongoing contaminated sediment arisings ([1]). The study reviewed potential land-based options in Hong Kong
including strategic landfills, treatment of materials, and the incorporation of
contaminated dredged material into land reclamation projects, but found each to
have inherent drawbacks. The
study's review of environmental monitoring data collected at CMPs I-III from
1992-1995 concluded that there was no evidence of contaminant impacts on biota
due to disposal, and that contaminants in dredged materials had been
successfully contained. The study
therefore recommended continued disposal in capped seabed pits in the East Sha
Chau area as the preferred option. This finding led the Hong Kong Government to
commission an EIA evaluating the use of disused borrow pits in the East Sha
Chau area as the next contaminated mud disposal facility. This facility, known as CMP IV,
consisted of three pits (CMP IV a, b and c) which had been dredged for sand
during construction of the new airport at Chek Lap Kok and represented a total
capacity of approximately 30 million cubic metres. The CMP IV EIA study ([2]) formulated an environmental
design for disposal operations, which included specifications for disposal
rates, cap thickness, and backfilling level. The Study concluded that impacts to water quality, marine
ecology, air and noise were expected to be maintained within acceptable limits
under the specifications of the agreed Operations Plan. The CMP IV EIA Report was endorsed by
the Advisory Council on the Environment (ACE) in March 1997.
In December 1997, disposal operations
commenced in CMP IVa in conjunction with an environmental monitoring programme
that encompassed water and sediment chemistry, fisheries assessment, tissue and
whole body analysis, and benthic recolonisation studies. A review of the collection and analysis
of the environmental data from the first 38 months of operations demonstrated
that there had not been any adverse environmental impacts resulting from
disposal activities ([3]).
Capacity to dispose of contaminated mud
is currently predicted to be exhausted by early 2009 with the completion of
backfilling of CMP IV at East of Sha Chau. When CMP IV is full, a new environmentally acceptable
disposal capacity for essential arisings will be required. A capacity of 8 Mm3 is
needed to provide disposal capacity up to 2015. The assignment Strategic
Assessment and Site Selection Study for Contaminated Mud Disposal (Agreement CE
105/98) recommended a Contained Aquatic Disposal facility (CAD - capped
seabed pit such as those already used at East of Sha Chau) at Airport
East ([4]).
Although members of ACE had no objection
to proceeding with the recommended EIA, they considered that all sites, in
particular remaining portions of East of Sha Chau, and other disposal options,
in particular a confined disposal facility (CDF – material confined within an
artificial island) should still be considered. To meet these requirements of ACE, the present study
identified the most suitable sites and disposal option within both the Airport
East and East of Sha Chau areas and, secondly it evaluated the environmental
acceptability of impacts associated with construction and operation of these,
through an EIA, and thirdly, based on a comparison of the outcomes of the two
EIAs, a preferred disposal facility is recommended.
The conclusion of the Study was that both of the proposed
facilities could be operated in an environmentally acceptable manner.
As part of the Study requirements, this Project specific
EM&A Manual has been prepared to provide further details of the specific
EM&A requirements that have been recommended during construction and
operation of the Project. In
particular, the requirements for ensuring compliance with mitigation measures
specified for water quality, marine ecology and fisheries are defined.
1.2.2
The Project
The Project is classified
as a Designated Project by virtue of Item C (Reclamation, Hydraulic and Marine
Facilities, Dredging and Dumping), Item C.10 (A Marine Dumping Area) and C.12
(A Dredging Operation Exceeding 500,000 m3) of Part I of Schedule 2
under the Environmental Impact Assessment
Ordinance (Cap. 499) (EIAO).
The works that are the subject of the EIA Study include the
construction and operation phases of the Project. The key components of the Project include the following:
i.
Dredging
of a series of seabed pits within the proposed facility boundaries (Figures
1.2a and 1.2b);
ii.
Backfilling
each dredged pit with contaminated mud that has been classified as requiring
Type 2 disposal in accordance with ETWBTC 34/2002 ([5]); and,
iii.
Capping
each backfilled pit with uncontaminated mud effectively isolating the
contaminated mud from the surrounding marine environment.
1.2.3
Construction Programme
Once the EIA Report has been formally approved by
Government, CEDD will obtain an Environmental Permit (EP) for construction of
the Project. Once the EP has been
obtained the first pit is expected to be dredged during 2008 in order to be
ready to receive contaminated mud in early 2009. According to the arisings estimates, the fourth pit at the
East of Sha Chau Facility will be backfilled and capped during the first half
of 2015 (Figure 1.2c). It
should be noted that should the rate at which contaminated mud arises change
(either increasing or decreasing) then the fourth pit may be capped earlier and
the South Brothers pits activated before end 2015. The tentative construction programme is presented in Figure
1.2d. It should be noted that
the timeline presents predicted timeframes for each works component.
Figure 1.2c Tentative Programme of
Works for Option 1
Figure 1.2d Tentative
Programme of Works for Option 2
There is a possibility that capacity will be reached at the
East of Sha Chau Facility before predicted, this is dependant upon arisings of
contaminated mud over the next 10 years. Concurrent projects in the South Brothers area are due to be
finished by 2009, after which, the South Brothers facility may be utililsed if
there is a need to provide further disposal capacity. Monitoring stations have been included in this EM&A
manual to reflect monitoring at whichever pit is active. In addition to the South Brothers
facility being required due to increased arisings of contaminated mud,
uncertainties in developments in the area may also require the facility to come
into operation as presented in Figure 1.2e.
Figure 1.2e Tentative
Programme of Works for Option 3
This
manual has been written and designed to cover all of the above options (Figures
1.2c – 1.2e).
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1.3
Background to the EM&A Programme
The construction and operational impacts resulting from the
implementation of the Project are specified in the EIA Report. The EIA Report also specifies
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 (Annex A). The EIA recommends that environmental
monitoring will be necessary to assess the effectiveness of measures
implemented to mitigate potential water quality, marine ecology and fisheries
impacts during the construction and operation of the proposed facility. Regular environmental auditing is also
recommended to ensure that potential impacts from other sources are adequately
addressed through the implementation of the mitigation measures defined in the
EIA Report.
This Manual provides the EM&A requirements that have
been recommended in the EIA Report in order to ensure compliance with the
specified mitigation measures.
1.4
The Scope of the EM&A Programme
The scope of this EM&A programme is to:
·
establish
baseline water quality levels at specified locations;
·
implement
monitoring and inspection requirements for water quality monitoring programme;
·
establish
baseline sediment quality levels at specified locations;
·
implement
monitoring and inspection requirements for sediment quality monitoring
programme;
·
establish
baseline sediment toxicity levels at specified locations;
·
implement
monitoring and inspection requirements for sediment toxicity monitoring
programme;
·
establish
baseline body burden levels in marine biota at specified locations;
·
implement
monitoring and inspection requirements for the body burden (marine biota)
monitoring programme;
·
liaise
with, and provide environmental advice (as requested or when otherwise
necessary) to site staff on the comprehension and consequences of the
environmental monitoring data;
·
identify
and resolve environmental issues and other functions as they may arise from the
works;
·
check
and quantify the Contractor's overall environmental performance, implementation
of Event and Action Plans (EAPs), and remedial actions taken to mitigate
adverse environmental effects as they may arise from the works;
·
conduct
monthly reviews of monitored impact data as the basis for assessing compliance
with the defined criteria and to ensure that necessary mitigation measures are
identified 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 other environmental
issues deemed to be relevant to the construction and operation process;
·
conduct
regular site inspections of a formal or informal nature to assess:
-
the
level of the Contractor’s general environmental awareness;
-
the
Contractor’s implementation of the recommendations in the EIA;
-
the
Contractor’s performance as measured by the EM&A;
-
the
need for specific mitigation measures to be implemented or the continued usage
of those previously agreed;
-
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; and
-
Details
of the methodology of implementing the capping works through using excavated
soil can be found in Annex C.
1.4.1
Environmental
Management Plan (EMP)
To
ensure effective implementation and reporting on compliance with the stated
mitigation measures, as well as the monitoring and auditing requirements and
remedial actions defined in the EIA, an appropriate contractual and supervisory
framework needs to be established.
The basis of the framework within which implementation should be managed
overall is through the preparation of EMPs by the Contractor(s).
An EMP is similar in nature to
a quality plan and provides details of the means by which the Contractor (and
all subcontractors working to the Contractor) will implement the recommended
mitigation measures and achieve the environmental performance standards defined
in Hong Kong environmental legislation, the contract and in the EIA
documentation. The primary reason
for adopting the EMP approach is to make the Contractor aware of his
environmental responsibilities and to be pro-active about the commitment to
achieve the standards specified, rather than relying on the EM&A programme.
The EMP also provides opportunities
for the Contractor to draw upon the strength of other institutional processes
such as ISO 9000/14000 to ensure that the achievement of the required standards
and fulfilment of commitments are documented.
The contractual requirement
for an EMP would generally comprise appropriate extracts from (and references
to) the EIA Report and EM&A Manual, and include such typical elements as
the relevant statutory environmental standards, general environmental control
clauses and specific environmental management clauses, as well as an outline of
the scope and content of the EMP.
In drafting the documentation, due consideration should be given to the
predictive nature of the EIA process and the consequent need to manage and
accommodate the actual impacts arising from the construction process. In particular, the Contractor must be
placed under a clear obligation to identify and control any implications
arising from changes to the working methods assumed in the EIA, or to the
progress rates and other estimates made during the preliminary design phase.
1.5
Objectives of the EM&A Programme
The objectives of the EM&A programme are as
follows:
1.
To monitor and report on the environmental impacts
of the dredging operations associated with the construction of the disposal pits;
2.
To monitor and report on the environmental impacts
due to capping operations of the exhausted pits;
3.
To monitor and report on the environmental impacts
of the disposal of contaminated marine sediments in the active pits and
specifically to determine:
·
changes/trends caused by disposal activities in the
concentrations of contaminants in sediments adjacent to the pits;
·
changes/trends caused by disposal activities in the
toxicity of sediment adjacent to the pits;
·
changes/trends caused by disposal activities in the
concentrations of contaminants in tissues of demersal marine life adjacent to
and remote from the pits;
·
impacts on water quality and benthic ecology caused
by the disposal activities and capping works
·
the risks to human health and dolphin of eating
seafood taken in the marine area around the active pits.
4.
To monitor and report on the environmental impacts
of the disposal operation and specifically to determine whether the methods of
disposal are effective in minimising the risks of adverse environmental
impacts.
5.
To monitor and report on the benthic recolonisation
of the capped pits including previous ones and specifically to determine the
difference in infauna between the capped pits and adjacent sites.
6.
To assess the impact of a major storm (Typhoon
Signal No. 8 or above) on the containment of any uncapped or partially capped
pits.
7.
To design and continually review the operation and
monitoring programme and:
·
to make recommendations for changes to the operation
that will rectify any unacceptable environmental impacts; and
·
to make recommendations for changes to the
monitoring programme that will improve the ability to cost effectively detect
environmental changes caused by the disposal activities.
8.
To establish numerical decision criteria for
defining impacts for each monitoring component.
9.
To provide supervision on the field works and
laboratory works to be carried out by contractors/laboratories.
The specific objectives of each component are
discussed in the relevant sections of this EM&A Manual.
1.6
Organisation and Structure of the EM&A
1.6.1
General
The Civil Engineering and Development Department (CEDD)
shall appoint an Environmental Team (ET) to conduct the monitoring and auditing
works and to provide specialist advice on the undertaking and implementation of
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, preferably with a
minimum of seven years relevant experience in impact assessments and impact
monitoring programmes.
To maintain strict control of the EM&A process, the ET
shall also appoint independent auditor(s) to verify and validate the
environmental performance of the Contractor and the ET.
1.6.2
Project Organisation
The roles and responsibilities of the various parties
involved in the EM&A process are further expanded in the following sections
and in Figure 1.6a. The ET
Leader shall be responsible for, and in charge of, the Environmental Team; and
shall be the person responsible for executing the EM&A requirements.
Contractor
Reporting to CEDD, the Contractor shall:
·
work
within the scope of the construction 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 CEDD;
·
provide
information/advice to the ET 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.
Civil Engineering and
Development Department (CEDD)
CEDD 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;
·
comply
with the agreed Event and Action Plan in the event of any exceedance; and
·
instruct
the Contractor to follow the agreed protocols or those in the Contract
Specifications in the event of exceedances or complaints.
Environmental Team
The duties of the Environmental Team (ET) and Environmental
Team Leader (ET Leader) are to:
·
monitor
the various environmental parameters as required by this or subsequent
revisions to the EM&A Manual;
·
assess
the EM&A data and review the success of the EM&A programme determining
the adequacy of the mitigation measures implemented and the validity of the EIA
predictions as well as identify any adverse environmental impacts before they
arise;
·
conduct
regular site inspections and to investigate and inspect the Contractor's
equipment and work methodologies with respect to pollution control and
environmental mitigation, monitor compliance with the environmental protection
specifications in the Contract, and to anticipate 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;
·
review
Contractor’s working programme and methodology, and comment as necessary;
·
investigate
and evaluate complaints, and identify corrective measures;
·
advice
to the Contractor on environmental improvement, awareness, enhancement matters,
etc, on site;
·
employ
an Independent Auditor(s) to audit the results of the EM&A works carried
out by the ET;
·
report
on the environmental monitoring and audit results and the wider environmental
issues and conditions to the Contractor, CEDD and the EPD; and
·
adhere
to the agreed protocols or those in the Contract Specifications in the event of
exceedances or complaints.
The ET shall be led and managed by the ET leader. The ET leader shall have relevant
education, training, knowledge, experience and professional qualifications
subject to the approval of the Director of Environmental Protection. Suitably qualified staff shall be
included in the ET, and ET should not be in any way an associated body of the
Contractor.
1.7
Structure of the EM&A Manual
The remainder of the Manual is set out as follows:
·
Section 2 sets out the EM&A general
requirements;
·
Section
3 details the
methodologies, parameters to be tested and the requirements for the marine
water quality monitoring for the dredging, backfilling and capping operations
at the active pits;
·
Section
4 details the
methodologies, parameters to be tested and the requirements for sediment
quality monitoring for the backfilling activities at the active pits;
·
Section
5 details the
methodologies, parameters to be tested and the requirements for sediment
toxicity quality monitoring for the backfilling activities at the active pits;
·
Section
6 details the
methodologies, parameters to be tested and the requirements for marine biota
monitoring for the backfilling activities at the active pits;
·
Section 7 details the requirements for Human Health
and Dolphin Risk Assessment;
·
Section
8 details the
requirements for benthic re-colonisation assessment;
·
Section
9 details the
methodologies, parameters to be tested and the requirements for the assessment
of impacts due to major storms; and
·
Section 10 details the EM&A reporting
requirements.
The EM&A Manual is an evolving document that should be
updated to maintain its relevance as the Project progresses. It is suggested that the first revision
to the EM&A Manual takes place when the detailed design phase of the
Project has been completed. The primary
focus for reviews of the EM&A Manual will be to ensure the impacts
predicted and the recommended mitigation measures remain consistent and
appropriate to the manner in which the works are to be carried out.