2
EM&A GENERAL REQUIREMENTS
2.1
Introduction
In this section, the general requirements of the EM&A programme for the Project are presented with reference to the relevant findings from the EIA Report that has formed the basis of the scope and content of the programme.
2.2 Construction Phase EM&A
General
The
environmental issues, which were identified during the EIA process and are
associated with the construction phase of the Project, will be addressed through
the monitoring and controls specified in this EM&A Manual and in the
construction contracts. Appendix E
lists out the measures required during the construction and operational phases
of the project.
During the construction phases of the Project, air quality, noise quality, water
quality, waste, ecology and landscape and visual will be subject to EM&A, with
environmental monitoring being undertaken for air quality, noise, water quality
and ecology. Monitoring of the
effectiveness of the mitigation measures will be achieved through the
environmental monitoring programme as well as through site inspections. The inspections will include within their
scope, mechanisms to review and assess the Contractor(s)’s environmental
performance, ensuring that the recommended mitigation measures (Appendix
E) 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 Report.
Environmental Monitoring
The
environmental monitoring work throughout the Project period will be carried out
in accordance with this EM&A and reported by the ET. Monitoring works will comprise of
quantitative assessment of physical parameters such as air quality, noise and
water quality impacts which also form an important part of the whole monitoring
programme. The monitoring programme
will be conducted at the chosen representative sensitive receivers in the
vicinity of the construction site.
Action and Limit Levels
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, HKPSG
or Environmental Quality Objectives established by the EPD. If these are exceeded, works will not
proceed without appropriate remedial action, including a critical review of
plant and working methods.
Event and Action Plans
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.
Site Inspections
In
addition to monitoring of air quality, noise, water quality and ecology as a
means of assessing the ongoing performance of the Contractor, the ET will
undertake site inspections and audits of on-site practices and procedures twice
per month. 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 Report and EM&A
Manual. The IEC will undertake
monthly site inspection and audit to assess the performance of the Contractor.
Whilst the audit and inspection programme will undoubtedly complement the
monitoring activity with regard to the effectiveness of controlling impacts to
air quality, noise, water quality and ecology, the criteria against which the
audits will be undertaken will be derived from the Clauses within the Contract
Documents which seek to enforce the recommendations of the EIA Report and the
established management systems.
The
findings of site inspections and audits will be made known to the Contractor at
the time of the inspection to enable the rapid resolution of identified
non-conformities. Non-conformities,
and the corrective actions undertaken, will also be reported in the monthly EM&A
Reports.
Section 10
of this Manual presents details of the scope and frequency of on-site
inspections and defines the range of issues that the audit protocols will be
designed to address.
Enquiries, Complaint and Requests for
Information
Enquiries, complaints and requests for information may occur from a wide range
of individuals and organisations including members of the public, Government
departments, the press and television media and community groups.
Enquiries concerning the environmental effects of the construction works,
irrespective of how they are received, will be reported to CEDD/ER and directed
to the ET which will set up procedures for the handling, investigation and
storage of such information. The
following steps will then be followed:
1)
The ET Leader will notify CEDD/ER of the nature of the
enquiry.
2)
An investigation will be initiated to determine the validity
of the complaint and to identify the source of the issue.
3)
The Contractor will undertake the following steps, as
necessary:
·
investigate and identify source of the issue;
·
if considered necessary by CEDD/ER following consultation
with the IEC, undertake additional monitoring to verify the existence and
severity of the alleged complaint;
·
liaise with EPD to identify remedial measures;
·
liaise with the IEC to identify remedial measures;
·
implement the agreed mitigation measures;
·
repeat the monitoring to verify effectiveness of mitigation
measures; and
·
repeat review procedures to identify further practical areas
of improvement if the repeat monitoring results continue to substantiate the
complaint.
4)
The outcome of the investigation and the action taken will be
documented on a complaint log (Appendix
B). A formal response to
each complaint received will be prepared by the Contractor within five working
days and submitted to ER, in order to notify the concerned person(s) that action
has been taken.
5)
Enquires which trigger this process will be reported in the
monthly reports which will include results of inspections undertaken by the
Contractor, and details of the measures taken, and additional monitoring results
(if deemed necessary). It should be
noted that the receipt of complaint or enquiry will not be, in itself, a
sufficient reason to introduce additional mitigation measures.
The
complainant will be notified of the findings, and audit procedures will be put
in place to ensure that the issue does not recur.
Reporting
Baseline, construction phase and post-construction phase monitoring, monthly,
quarterly and final reports will be prepared and certified by the ET Leader and
verified by the IEC. The reports
will be submitted to the Contractor, ER and EPD.
The monthly reports will be prepared and submitted within two weeks of
the end of each calendar month.
Cessation of EM&A
The
cessation of EM&A programme is subject to the satisfactory completion of the
EM&A Final Review Report, agreement with the IEC and approval from EPD.
2.3
Operational Phase EM&A
Ecology, water quality and landscape & visual monitoring will be required during
the post-construction and/or operational phase of the Project. Details are described in the corresponded
sections.