15.
ENVIRONMENTAL
MONITORING AND AUDIT
15.1.1
The
development of appropriate environmental monitoring and audit (EM&A)
programmes and methodologies are a vital part of the environmental management
and control of the Project. This chapter
provides an outline of the EM&A requirements for the Project, highlighting
the environmental parameters to be monitored, timing of the monitoring work and
the frequency of the monitoring and audit work. A detailed scope of work will be provided in
the EM&A Manual, prepared in accordance with Annex 21 of the TMEIA and
EPD’s EM&A Guidelines for Development
Projects in
15.1.2 The broad objectives of the monitoring and audit process are:
(i) to clarify and identify sources of pollution, impact and nuisance from the works;
(ii) to establish a record of change associated with the implementation of a project;
(iii) to verify all or selected parameters measured are in compliance with legal and contract specifications, internal policies and standards;
(iv) to provide an early warning system for impact prevention;
(v) to provide a database of environmental parameters against which to determine any short term or long term environmental impacts;
(vi) to propose timely, cost-effective and viable solutions to actual or potential environmental issues;
(vii) to setup event and action plans and determine the degree and scope of any necessary remedial measures in case of exceedance of compliance, for which environmental monitoring forms the basis, or the recommendation of environmental controls in the event that the environmental objectives are not achieved;
(viii) to monitor performance of the mitigation
measures and to assess their
effectiveness and, whenever necessary, identify any further need for additional
measures;
(ix) to verify the EIA predicted impacts and
compare the impact predictions with actual impacts for the purpose of assessing
accuracy of impact predictions in EIA;
(x) to
collate information and evidence for use in public and Government consultation;
and
(xi) to
audit the environmental performance.
15.2.1
In
accordance with the EIA, EM&A procedures are required during the design,
construction and operational phases of the project implementation only and a
summary of the requirements for each of the environmental parameters is
detailed in Table 15.1 below.
Table 15.1 Summary
of EM&A Requirements
|
Parameter |
EM&A Phase |
||
|
Design Phase |
Construction Phase |
Operational Phase |
|
|
Air Quality |
- |
Y |
- |
|
Noise |
- |
Y |
- |
|
Water Quality |
- |
Y |
Y |
|
Ecology |
- |
Y |
- |
|
Landscape and Visual |
Y |
Y |
Y |
|
Cultural Heritage |
- |
Y |
- |
|
Hazard to Life |
Y |
- |
Y |
|
Fuel Spillage Risk |
Y |
- |
Y |
|
Fisheries |
- |
- |
- |
|
Land Contamination |
Y |
- |
Y |
|
Waste |
- |
Y |
- |
15.2.2
The
EM&A works during the design phase shall comprise an iterative audit
process of specific design elements by a suitably qualified auditor(s). This role could be filled by the Independent
Checker (Environment). The
specifications for certain risk and spill control mitigation measures will be
required to be designed during the detailed design phase of the project. These items will include:
¨
land
and marine spill response plan;
¨
pipeline
leak detection and automatic shut-off system;
¨
pipeline
rock armour protection;
¨
tank
high level shut-off;
¨
tank
bunding;
¨
tank
leak drainage isolation and containment system;
¨
on-site
fire fighting equipment;
¨
jetty
protection; and
¨
emergency shut down valves for fuel delivery.
15.2.3
In
addition, the landscape design drawings and dolphin exclusion zone during
dredging in the
15.2.4
It
should be noted that as the percussive piling for the jetty has already been
completed under the previous EP, the following recommendations of the previous
EIA (April 2002) have already been carried out:
¨
dolphin
acoustic monitoring;
¨
dolphin
exclusion zone;
¨
underwater noise monitoring to supplement visual dolphin
surveillance;
¨
pre-construction
abundance monitoring;
¨
piling
acoustic decoupling methods; and
¨
bubble
jacket trial, design and use.
15.2.5
The
design audit shall be undertaken as and when the relevant design aspects are
produced and the Design Auditor will be required to prepare a Design Audit
Report at the end of the detailed design which will confirm that the
requirements of the EIA have been fully taken into account in the project
design. The Design Audit report should
be submitted to EPD, AFCD and the proponent at least. Other relevant parties should be identified
at the time of issue.
15.2.6 During the construction phase, the EM&A requirements are divided into environmental monitoring and/or project auditing in the form of site inspection and supervision. The environmental monitoring will be conducted in three distinct stages, as follows:
(i) baseline (pre-construction);
(ii) construction phase impact; and
(iii) operational phase impact.
15.2.7
Environmental
monitoring and audit for water quality during the construction phase is
recommended in order to ensure all proposed mitigation measures are implemented
and effective. Obtaining a suitable and representative
baseline data set will be critical to the whole monitoring and audit process
because it forms the standard against which environmental impacts are assessed. Thus, baseline monitoring for water quality
will be required prior to the start of construction. This parameter will also be subject to audit
through site supervision.
15.2.8
Site
supervision and procedures audit will be required during the construction phase to ensure the proper
handling, storage, transportation and disposal of the various waste arisings
from the project.
15.2.9 Post construction dolphin abundance monitoring will be required to ensure the effectiveness of the mitigation measures undertaken during the piling for the jetty. As some construction activities commenced in November 2005, before the Judgement of the Court of Final Appeal of July 2006, the pre-construction abundance monitoring was undertaken in late 2005 and the results are provided in Appendix F3. As such, the post-construction dolphin abundance monitoring will be required to be undertaken for a period of 28 days prior to operation of the PAFF.
15.2.10 Monitoring in the form of regular site inspections shall also be required to ensure dust and noise levels are kept to a minimum and ecological measures in the form of tree transplantation and establishment are being implemented and are effective. EM&A for landscape resources will extend through the construction phase into the operational phase to ensure that the planting/replanting has been effective.
15.2.11 As detailed in Section 3, the initial phase of the tank farm development will comprise 8 tanks which will be operational from 2009. However, the ultimate capacity of the tank farm is proposed to be 12 tanks and future expansion of the facility will commence after 2025 when the initial capacity has been reached. The tanks will be built taking into account the latest technology, standards and statutory requirements. In order to ensure that the required mitigation measures are undertaken at that time, it is recommended that a review of the EIA report be undertaken at the planning stage for the future expansion if the latest technology, industrial standards and statutory requirements have changed by that time.
15.2.12 In
addition, in order to ensure the on-going adequacy of the fuel spill
contingency plan and that it is being implemented as required, it is proposed
that an Environmental Management System be set up for the operational phase of
the project to allow regular audits of the systems/mitigation measures incorporated
in the project and the fuel spill contingency plan.
15.2.13 The details of monitoring are discussed in the following
sections and summarised in Table 15.2 below.
Table 15.2: Framework
for Environmental Monitoring Plan
|
Monitoring |
Period |
Parameters |
Monitoring Frequency |
Responsibility |
|
Noise Dust Waste |
Baseline |
n/a |
n/a |
n/a |
|
Construction Phase Impact |
Routine supervision of construction works |
As per site inspection schedule |
Environmental Team |
|
|
Water |
Baseline |
Measurements of suspended solids, turbidity, dissolved oxygen and pH. |
Baseline data daily on both flood and ebb tides for at least one week
before the start of the construction. |
Environmental Team |
|
Construction Phase Impact |
Survey of drainage channels in area of construction site. Measurements
of suspended solids, turbidity, dissolved oxygen and pH. |
Daily when marine construction works are being undertaken within 1000m
of the Lung Kwu Chau and |
Environmental Team |
|
|
|
Operational Phase Impact |
Suite of parameters including but not limited to TPH and PAH to be
determined by the Franchisee within 3 month so the commencement of the PAFF |
Routine to be determined by the Franchisee within 3 months of the
commencement of the PAFF |
Franchisee |
|
Ecology |
Construction Phase Impact |
250m Dolphin Exclusion Zone Works will be restricted to a daily maximum of 12 hours within daylight hours Avoidance of
calving season (March to August) Post Marine
Construction Dolphin Abundance Monitoring |
During dredging in During dredging in During dredging in 28 days worth after all marine works are completed |
Dolphin Specialist(s) / underwater acoustic specialist as members of
the Environmental Team) |
|
Landscape/ Visual Resources Landscape/ Visual Resources |
Design |
Detailed landscape proposals and specifications |
As and when designs are produced. |
Auditor(s) designated by the Design Consultants |
|
Baseline |
Walkover tree survey and vegetation identification. |
Once immediately prior to construction works. |
Landscape Architect (member of the Environmental Team) |
|
|
|
Construction Phase Impact |
Survey of protection measures for trees and landscaping. |
Twice a month during construction works |
Landscape Architect (members of the Environmental Team) |
|
|
Operational Phase Impact |
Survey of coverage and growth of plantings. |
Once every two months for one year after the completion of the
construction works |
Landscape Architect (members of the Environmental Team) |
|
Cultural
Heritage |
Construction Phase Impact |
Watching brief during dredging within 25m of subsurface anomalies SS1
and SS2 |
During dredging period only |
Marine Archaeologist (members of the Environmental Team) |
|
Hazard to Life Fuel Spill Risk Land
Contamination |
Design |
Specifications for: -
land and marine spill
response plan; -
pipeline leak detection
and automatic shut-off system; -
pipeline rock armour
protection; -
tank high level shut-off; -
tank bunding; -
tank leak drainage
isolation and containment system; -
on-site fire fighting
equipment; -
jetty fenders; and fuel delivery emergency shut down valves. |
As and when designs are
produced. |
Auditor(s) designated by the Design Consultants |
|
|
Operational Phase |
Prepare an Environmental
Management Plan to ensure the on-going adequacy of the fuel spill contingency
plan and that it is being implemented as required and that the above
mitigation measures have been incorporated and are effective. For future development
phase, review of EIA report to ensure
that the required and latest standards an legislation are taken account in
the design of future tanks. (required only if the standards and guidelines
have changed by that time). |
EMP should be prepared
within 3 months of the operation of the PAFF Audits should be
undertaken at least once every 24 months. Once during planning stage
for future (phase II) tank construction |
Franchisee |
|
|
|
Regular inspections and audits
will be undertaken during the operational phase of the facility: -
inspections of the tank
farm, jetty and pipelines; -
inspection of the whole
sub sea pipelines; -
Health, Safety and
Environmental audit of the facility -
inspection of the
structural integrity of the tanks |
Twice per year Every 5 to 10 years once every 3 years Once per year |
Franchisee |
15.3.1.1 Baseline water quality monitoring of
the marine environment in the study area will be carried out daily on both
flood and ebb tides for a period of 1 week to measure suspended solids,
turbidity, dissolved oxygen and pH at all monitoring stations.
15.3.2
Landscape/Visual Resources
15.3.2.1 Baseline monitoring for the
landscape will comprise a walkover vegetation survey of the vegetation and
trees on the site. Representative
vegetation types will be identified along with typical species composition.
15.4
Construction Phase Impact Monitoring
15.4.1
Action and Limit Levels
15.4.1.1 Monitoring stations will be set up
at representative sensitive receivers and the results will be used to ensure
compliance with determined performance criteria, based upon specific action and
limit levels. The definition of these are as follows:
·
the Action Level represents a level at
which some appropriate action will be required to prevent conditions
deteriorating to the extent that statutory or guide criteria are breached; and
·
the Limit Level represents the upper limit
permitted and is generally equivalent to the statutory levels specified in
legislation.
15.4.1.2 The construction phase monitoring
and relevant audit criteria for water quality are highlighted below. Action plans will be developed for use in the
event of exceedances, or non conformities in the case of ecology, landscape and
visual and waste, and these will be included in the EM&A Manual.
15.4.1.3 Action plans and audit criteria are
not relevant to the noise, air, waste, cultural heritage and landscape and
visual EM&A. However, the
supervision methodology is highlighted below.
15.4.2.1 Daily surveys are to be undertaken
for marine water quality on both flood and ebb tides while dredging activities
are being undertaken within 1000m of the
15.4.2.2 Any noticeable change to water
quality should be recorded, investigated and remedial actions shall be
undertaken to reduce impacts. The key assessment parameters are dissolved
oxygen and suspended sediment and thus Action and Limit Levels based on the
assessment criteria are identified for these.
However, turbidity can also provide valuable instantaneous information
on water quality and thus an Action Limit is also recommended for this
parameter to facilitate quick responsive action in the event of any apparent
unacceptable deterioration attributable to the works. The proposed Action and Limit Levels are
shown in Table 15.3.
Table 15.3: Action and Limit Levels for Water Quality
|
Parameters |
Action (mg/L) |
Limit (mg/L) |
|
DO in mg/L (Depth Average & Bottom) |
Depth Average 4.5 mg/L; and upstream control stations’ mean D.O. (at the same tide of the same day) Bottom 2.5 mg/L; and upstream control stations’ mean D.O. (at the same tide of the same day) |
Depth Average 4.0 mg/L; and upstream control stations’ mean D.O. (at the same tide of the same day) Bottom 2.0 mg/L; and upstream control stations’ mean D.O. (at the same tide of the same day) |
|
Suspended Solids (depth averaged) |
30 mg/L; and 130% of upstream control stations’ mean SS (at the same tide of the
same day) |
39mg/L; and 130% of upstream control stations’ mean SS (at the same tide of the
same day) |
|
Turbidity in NTU (depth averaged) |
130% of upstream control stations’ mean Turbidity (at the same tide of
the same day) |
N/A |
Notes:
- For DO, non-compliance of
the water quality limits occurs when monitoring result is lower than the
limits.
- For SS, non-compliance of
the water quality limits occurs when monitoring result is higher than the
limits.
- All the figures given in
the table are for reference only and these may be amended with the agreement of
DEP.
- “Depth Averaged” is
calculated by taking the arithmetic mean of the in-situ parameters readings at
all three depths. For suspended solids
“depth averaged” is calculated by combining all three samples into one mixed
sample which is analysed to produce a physical arithmetic mean.
15.4.3.1 Supervision of the construction
works should be undertaken on a weekly basis during site inspections to ensure
that waste material is being properly stockpiled and handled and that measures
as recommended in the EIA are being undertaken to minimise noise and dust. Any malpractice should be reported and
remedial measures recommended. Review of the waste documents shall be
undertaken on a weekly basis to ensure waste management is being undertaken in accordance with the
Waste Management Plan.
15.4.4.1 The landscape construction works will be closely monitored to ensure all measures specified to promote the healthy establishment of plants are undertaken fully and that any defects or omissions are rectified at the earliest opportunity and before the end of the construction period.
15.4.4.2 The protection provided to all trees identified will be monitored throughout the construction period to ensure that it is kept in a good condition. Any damage by the Contractor or by other parties to the protection of the trees will be noted for remedial action.
15.4.4.3 Operations relating to the supply of specialist plant material (including the collecting, germination and growth of plants from seed) will be monitored to ensure that plants will be available in time to be used within the construction works.
15.4.4.4 The progress of the engineering works will be regularly reviewed on site to identify the earliest opportunities for the landscape works to be undertaken.
15.4.5.1 A 250m dolphin exclusion zone will be applied to all dredging within the marine park and along the entire pipeline. A qualified dolphin specialist will ensure that no dolphins are within the exclusion zone for a period of 30 minutes before dredging can commence. In addition, dredging works should be restricted to a daily maximum of 12 hours within daylight hours except for the section crossing Urmston Road Channel and should not be undertaken in the main calving season between March and August along the whole pipeline.
15.4.5.2 In addition, a monitoring programme is required to span a period of 28 days prior to operation of the PAFF. An action plan has also been defined to indicate that should dolphin numbers be significantly different (i.e., at least 30% reduction taking into account naturally occurring alterations to distribution patterns such as due to seasonal change and the difference is of statistical significance at an alpha level of 0.05) to the pre-construction activity following the 28 days post-construction monitoring, recommendations for a further 28 days monitoring will be required. This action plan is detailed in the EM&A Manual. The monitoring specification is detailed in Section 7 and the EM&A Manual.
15.4.5.3 It should be noted that as some construction activities commenced in November 2005, before the Judgement of the Court of Final Appeal of July 2006, the pre-construction abundance monitoring was undertaken in late 2005 and the results are provided in Appendix F3.
15.4.6
Cultural Heritage
15.4.6.1 A watching brief for two sub sea anomalies has been recommended by the result of the Marine Archaeological Investigation detailed in Appendix G. This should be undertaken by a specialist marine archaeologist as part of Environmental Team and should comprise:
¨ Dredge operators to be made aware of the potential presence of cultural heritage material. The operators would be required to report to the AMO any unusual resistance and/or recovery of timbers, anchors or other wreck related material Any obstacles encountered during the dredging that are of timber should be reported to the maritime archaeologist. The obstacle should be avoided and not removed until it has been assessed by the marine archaeologist as to whether the obstacle is of cultural heritage importance;
¨ A marine archaeologist shall be on board the dredging barge during dredging within 25m either side SS1 and SS2 (Figure 5a and 5b, MIA Task 4.1, Appendix G) in the event of any unusual resistance occurring or blockages which requires the dredge head to be bought on deck for cleaning and examination; and
¨ Dredging to cease in the nominated area SS1 after 3 metres of sediment removal and after 1 metre for SS2. A dive survey will then be undertaken to examine the trench for possible cultural remains.
15.4.6.2 During the course of the watching brief, if the targets are identified as being potentially archaeologically important, then an immediate marine archaeological impact assessment in accordance with EIAO TM Annex 19 will be required to be undertaken by a qualified marine archaeologist. In addition, it is recommended that any changes, additions or alterations to the dredging method and alignment should be further assessed by a marine archaeologist to determine if any further assessment is required.
15.5
Operational Impact Monitoring
15.5.1
Post
construction monitoring is limited to monitoring landscaping to ensure the
viability of the planting/replanting.
Site inspections shall be undertaken once every 2 months for the first
year of operation.
15.5.2
In
order to ensure the on-going adequacy of the fuel spill contingency plan and
that it is being implemented as required, it is proposed that an Environmental
Management System be set up for the operational phase of the project to allow
regular audits of the systems/mitigation measures incorporated in the project
and the fuel spill contingency plan. The Environmental Management System shall
be developed within 3 months of the commencement of the operation of the PAFF
and it is recommended that audits are undertaken at least every 24 months and
the audits should be undertaken by an environmental specialist appointed
by the Franchisee.
15.5.3 Also, the following regular inspections and audits will be undertaken by the Franchisee during the operational phase of the facility:
¨
two
inspections every year of the tank farm, jetty and pipelines including one
undertaken pursuant to the Joint Inspection Group (JIG) explained above;
¨
inspection
of the whole sub sea pipelines every 5 to 10 years;
¨
Health,
Safety and Environmental audit of the facility once every 3 years; and
¨
inspection
of the structural integrity of the tanks once per year.
15.5.4 In addition, it is recommended that the Franchisee undertake some routine monitoring of water quality in the vicinity of the PAFF site to check the effectiveness of the proposed precautionary measures implemented for on-site spill control. The details of the monitoring to be undertaken will be prepared by the Franchisee as part of the PAFF Operations Manual and the details will be agreed with the relevant authorities within 3 months of the commencement of operation of the PAFF. However, the monitoring should include but not be limited to the parameters of TPH and PAH and reference should be made to the existing monitoring programme undertaken for the fuel tank farm on the HKIA platform.
15.5.5
In
order to ensure that the required design measures are taken into account during
the planning and design for the future tank development, a review of the EIA
report will also be undertaken at the planning stage for the future expansion
(around 2025 as required). The review is
required only if the latest technology, standards and
statutory requirements are deemed to have changed by that time. The review should be undertaken by an
environmental specialist appointed by the Franchisee at that time.
15.6.1
In
respect of the design phase EM&A, the Consultant commissioned to undertake
the Design and Construct contract will be required to designate an auditor(s)
to undertake an environmental audit of the design of these measures in order to
ensure that the recommendations of the EIA have been fully and properly
specified. The design audit shall be
undertaken as and when the relevant design aspects are produced. The Consultant shall use suitably qualified
staff to undertake the audit.
15.6.2
During
the construction and operational phase of the project, an Environmental Team
Leader (ETL) is to be employed by the Contractor. He shall ensure the Contractor’s compliance
with the project’s environmental performance requirements during construction
and undertake the post construction EM&A works and his responsibilities
will include field measurements, sampling, analysis of monitoring results,
reporting and auditing. The ETL shall be
approved by the ER and shall be competent and shall have at least 7 years
relevant environmental monitoring and audit experience on projects of a similar
scale and nature.
15.6.3
The
ETL will require suitably qualified support staff (the Environmental Team,
(ET)) to carrying out the EM&A programme.
Both the ETL and members of the ET shall be independent and shall not be
in any way connected to the Contractor’s company. Due to the specialist nature of some of the
EM&A works required for this project, the ET should comprise professionals
proficient to undertake the tasks involved.
Thus, the ET should include personnel experienced in noise and dust
mitigation, water quality monitoring, supervision of waste management,
compensatory tree planting, underwater acoustic monitoring and dolphin spotting
and supervision.
15.6.4
Accordingly,
a Registered Landscape Architect, as defined by the Landscape Architect’s
Registration Board, will be required on the ET to monitor and audit the
landscaping installation works. In addition, a marine archaeologist to the
acceptability of the AMO will be
required to undertake the recommendations defined by the Marine Archaeological
Investigation.
15.6.5
In
addition to the ETL, an Independent Environmental Checker (IEC) shall advise
the ER on environmental issues related to the project. The role of the Checker shall be independent
from the management of construction works, but the Checker shall be empowered
to audit the environmental performance of the construction activities and
operational mitigation. The IEC shall
have project management experience in addition to the requirements of the ETL
specified in Section 15.6.2 and the appointment of the IEC will be subject to
the approval of the ER. The IEC may
require specialist support staff in order to properly carry out his duties.
15.7.1
Deliverables
during the design phase will comprise a Design Audit Report at the end of the
detailed design which will confirm that the requirements of the EIA have been
fully taken into account in the project design.
Construction and operational reporting will be in the form of the
baseline survey report and regular and summary EM&A Reports which should be
prepared in accordance with the requirements of Annex 21 of the TMEIA. It is recommended that EM&A Reports are
issued monthly and bi-monthly for the construction and operational stages respectively. Further details on the contents of these
reports is provided in the EM&A Manual.
15.8.1 The recommended mitigation measures specified in this EIA report have been summarised in the Environmental Mitigation Implementation Schedules provided in Appendix B for air, water quality, waste, ecology, landscape and visual, cultural heritage, contaminated land and fuel spill risk