3                    CONSTRUCTION PHASE AIR QUALITY

 

3.1              Background

 

Whilst fugitive dust impacts are not anticipated, a construction dust monitoring programme is recommended to ensure compliance with the relevant criterion during the construction works.  Monitoring of dust levels, in terms of Total Suspended Particulates (TSP), should be conducted every six days throughout the construction period at ASRs A4 (No. 101 Lung Mei Tsuen) and A6 (No. 79 Lo Tsz Tin Tsuen).  Figure 3.1 shows the locations of the construction phase air quality monitoring.

 

In accordance with the recommendations of the EIA, mitigation measures have been proposed during the construction phase of the Project. Details of the mitigation measures are presented in Appendix E Implementation Schedule.

 

3.2              Air Quality Parameters

 

1-hour and 24-hour TSP levels shall be measured to indicate the impacts of construction dust on air quality.  The 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 BUpon 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.  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 C.

 

3.3              Monitoring Equipment

 

High volume sampler (HVS) in compliance with the following specifications shall be used for carrying out the 1-hr and 24-hr TSP monitoring:

 

a)      0.6-1.7 m3/min (20-60 SCFM) 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 (63 in2);

e)      flow control accuracy: +/- 2.5% deviation over 24-hr 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)        easy to change the filter; and

m)   capable of operating continuously for 24-hr period.

 

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.

 

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 recognized primary standard and be calibrated annually.  The calibration data shall be properly documented for future reference by the concerned parties such as the IEC.  All the data shall be converted into standard temperature and pressure condition.  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 down in the data sheet in Appendix C.

 

If the ET Leader proposes to use a direct reading dust meter to measure 1-hr TSP levels, he shall submit sufficient information to the IEC to prove that the instrument is capable of achieving a comparable result as that of the HVS and may be used for the 1-hr sampling.  The instrument shall also be calibrated regularly, and the 1-hr sampling shall be determined periodically by HVS to check the validity and accuracy of the results measured by direct reading method.

 

Wind data monitoring equipment shall also be provided and set up at conspicuous locations for logging wind speed and wind direction near to the dust monitoring locations.  The equipment installation location shall be proposed by the ET Leader and agreed with the ER in consultation with the IEC.  For installation and operation of wind data monitoring equipment, the following points shall be observed:

 

a)            the wind sensors shall be installed on masts at an elevated level 10m above ground so that they are clear of obstructions or turbulence caused by the buildings;

b)            the wind data shall be captured by a data logger.  The data recorded in the data logger shall be downloaded periodically for analysis at least once a month;

c)            the wind data monitoring equipment shall be re-calibrated at least once every six months; and

d)            wind direction shall be divided into 16 sectors of 22.5 degrees each.

 

3.4              Laboratory Measurement/Analysis

 

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 shall be HOKLAS accredited or other internationally accredited laboratory.

 

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 in consultation with the IEC.

 

Measurement performed by the laboratory shall be demonstrated to the satisfaction of the ER and the IEC.  IEC shall conduct regular audit to 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.

 

Filter paper of size 8"x10" shall be labelled before sampling. It shall be a clean filter paper with no pin holes, and shall be conditioned in a humidity controlled chamber for over 24-hr and be pre-weighed before use for the sampling.

 

After sampling, the filter paper loaded with dust shall be kept in a clean and tightly sealed plastic bag.  The filter paper is then 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.

 

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

 

The status and locations of dust sensitive receivers may change after issuing this manual.  If such cases exist, the ET Leader shall propose updated monitoring locations and seek approval from ER and agreement from the IEC.  When alternative monitoring locations are proposed, the following criteria, as far as practicable, shall be followed:

 

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

b)                  close to the sensitive receptors; and

c)                  take into account the prevailing meteorological conditions.

 

The ET Leader shall agree with the ER in consultation with the IEC the position of the HVS for 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 shall be provided;

b)                  no two samplers shall be placed less than 2 metre 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 metres of separation from walls, parapets and penthouses is required for rooftop samplers;

e)                  a minimum of 2 metre 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 metres from the dripline;

i)                    any wire fence and gate, to protect the sampler, shall 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.

 

3.5              Baseline Monitoring

 

The ET Leader shall carry out baseline monitoring at all of the designated monitoring locations for at least 14 consecutive days prior to the commissioning of the construction works to obtain daily 24-hr TSP samples. 1-hr sampling shall also be done at least 3 times per day while the highest dust impact is expected.  Before commencing the baseline monitoring, the ET leader shall inform the IEC of the baseline monitoring programme such that the IEC can conduct on-site audit to ensure accuracy of the baseline monitoring results.  During the baseline monitoring, there shall not be any construction or dust generation activities in the vicinity of the monitoring stations.  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 which 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 IEC.

 

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

 

Ambient conditions may vary seasonally and shall be reviewed at three monthly intervals.  If the ET Leader considers that the ambient conditions have been changed and a repeat of the baseline monitoring is required to be carried out for obtaining the updated baseline levels, the monitoring shall be 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, shall be revised.  The revised baseline levels and air quality criteria shall be agreed with the IEC and EPD.

 

3.6              Impact Monitoring

 

The ET Leader shall carry out impact monitoring during the course of the Works.  For regular impact monitoring, the sampling frequency of at least once in every six-days, shall be strictly observed at all the monitoring stations for 24-hr TSP monitoring. For 1-hr TSP monitoring, the sampling frequency of at least three times in every six-days shall be undertaken when the highest dust impact occurs.  Before commencing the baseline monitoring, the ET leader shall inform the IEC of the impact monitoring programme such that the IEC can conduct on-site audit to ensure accuracy of the impact monitoring results.

 

The specific time to start and stop the 24-hr TSP monitoring shall be clearly defined for each location and be strictly followed by the field operator.  In case of non-compliance with the air quality criteria, more frequent monitoring exercise, as specified in the Action Plan, 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.

 

3.7              Event and Action Plan for Air Quality

 

The baseline monitoring results form the basis for determining the air quality criteria for the impact monitoring. The ET Leader shall compare the impact monitoring results with air quality criteria set up for 24-hour TSP and 1-hour TSP.  Table 3.1 shows the air quality criteria, namely Action and Limit levels to be used.  Should non-compliance of the air quality criteria occur, actions in accordance with the Action Plan in Table 3.2 shall be carried out.

 

n addition to the dust monitoring, regular site audits (at a frequency of not less than once every two weeks) are recommended to ensure that appropriate dust control measures are implemented and good site practices are adopted throughout the construction period.

Table 3.1 Action and Limit Levels for Air Quality Monitoring

Parameters

Action

Limit

24 Hour TSP Level in mg m-3

For baseline level <200 mg m-3, Action Level = (Baseline level * 1.3 + Limit Level/2);

For baseline level >200 mg m-3, Action Level = Limit Level

260

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

 

Table 3.2   Event and Action Plan for Air Quality

EVENT

ACTION

ET

IEC

ER

Contractor

Action Level Exceedance for One Sample

1.      Identify source(s) of impact;

2.      Inform the IEC and the ER;

3.      Repeat measurement to confirm findings;

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

Action Level Exceedance for Two or More Consecutive Samples

1.        Identify source(s) of impact;

2.        Inform the IEC and ER;

3.        Repeat measurement to confirm findings;

4.        Increase monitoring frequency to daily;

5.        Discuss with IEC and Contractor on remedial action required;

6.        If exceedance continues, arrange meeting with IEC and ER;

7.        If exceedance stops, cease additional monitoring

 

1.  Checking 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.  Supervisor 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 actions to IEC within 3 working days of notification;

2.      Implement the agreed proposals;

3.      Amend proposal if appropriate

Limit Level Exceedance for One Sample

1.       Identify source(s) of impact;

2.       Inform the EPD and the ER;

3.       Repeat measurement to confirm findings;

4.       Increase monitoring frequency to daily;

5.       Assess effectiveness of Contractor’s remedial actions and keep IEC, EPD and ER informed of 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 IEC within 3 working days of notification;

3.        Implement the agreed proposals

4.        Amend proposal if appropriate

Limit Level Exceedance for Two or More Consecutive Samples

1.       Notify IEC, ER, Contractor and EPD;

2.       Identify source(s) of impact;

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 IEC and ER to discuss the remedial actions to be taken;

7.       Assess effectiveness of Contractor’s remedial action and keep IEC, 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 consultation with the IEC, 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 IEC 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

ET – Environmental Team, IEC – Independent Environment Checker, ER – Engineer Representative