9.
SITE ENVIRONMENTAL AUDIT
9.1.1
Site
inspection provides a direct means to trigger and enforce the specified
environmental protection and pollution control measures. It shall be undertaken
routinely to inspect the construction activities in order to ensure that
appropriate environmental protection and pollution control mitigation measures
are properly implemented. The site inspection is one of the most effective
tools to enforce the environmental protection requirements on the construction
site.
9.1.2
The
ET Leader shall be responsible for formulating of the environmental site
inspection, deficiency and action reporting system, and for carrying out the
site inspection works. He shall
submit a proposal on the site inspection, deficiency and action reporting
procedures to the Contractor for agreement and to the ER for approval.
9.1.3
Regular
site inspections shall be carried out at least once per week. The areas of
inspection shall not be limited to the environmental situation, pollution
control and mitigation measures within the site; it should also review the
environmental situation outside the works area which is likely to be affected,
directly or indirectly, by the site activities. The ET Leader shall make
reference to the following information in conducting the inspection:
(a)
the
EIA recommendations on environmental protection and pollution control
mitigation measures;
(b)
on-going
result of the EM&A programme;
(c)
works
progress and programme;
(d)
individual
works methodology proposals (which shall include proposal on associated
pollution control measures);
(e)
the
contract specifications on environmental protection;
(f)
the
relevant environmental protection and pollution control laws; and
(g)
previous
site inspection results.
9.1.4
The
Contractor shall update the ET Leader with all relevant information of the
construction contract for him to carry out the site inspections. The inspection
results and its associated recommendations on improvements to the environmental
protection and pollution control works shall be submitted to the ER, the
Contractor and IEC within 24 hours, for reference and for taking immediate
action. The Contractor shall follow the procedures and time-frame as stipulated
in the environmental site inspection, deficiency and action reporting system
formulated by the ET Leader to report on any remedial measures subsequent to
the site inspections.
9.1.5
The
ET shall also carry out ad hoc site
inspections if significant environmental problems are identified. Inspections
may also be required subsequent to receipt of an environmental complaint, or as
part of the investigation work, as specified in the Action Plan for
environmental monitoring and audit.
9.2
Compliance with Legal and
Contractual Requirements
9.2.1
There
are contractual environmental protection and pollution control requirements as
well as environmental protection and pollution control laws in
9.2.2
In
order that the works are in compliance with the contractual requirements, all
the works method statements submitted by the Contractor to the ER for approval
shall be sent to the ET Leader for vetting to see whether sufficient
environmental protection and pollution control measures have been included.
9.2.3
The
ET Leader shall also review the progress and programme of the works to check
that relevant environmental laws have not been violated, and that any
foreseeable potential for violating the laws can be prevented.
9.2.4
The
Contractor shall regularly copy relevant documents to the ET Leader so that the
checking work can be carried out. The document shall at least include updated
Work Progress Reports, updated Works Programme, any application letters for
different licences / permits under the environmental protection laws, and copies
of all the valid licences / permits. The site diary shall also be available for
the ET Leader's inspection upon his request.
9.2.5
After
reviewing the document, the ET Leader shall advise the ER, the Contractor and
IEC of any non-compliance with the contractual and legislative requirements on
environmental protection and pollution control for them to take follow-up
actions. If the ET Leader's review
concludes that the current status on licence/permit application and any
environmental protection and pollution control preparation works may not cope
with the works programme or may result in potential violation of environmental
protection and pollution control requirements, he shall also advise the
Contractor and the ER accordingly.
9.2.6
Upon
receipt of the advice, the Contractor shall undertake immediate action to correct
the situation. The ER shall follow up to ensure that appropriate action has
been taken in order to satisfy contractual and legal requirements.
24-hour Dedicated Hotline for Public
Complaints and Enquiries
9.3.1
The Contractor shall set up a
24-hour hotline dedicated to the Project to receive and respond to complaints
or enquiries from the public, the media and community groups throughout the
construction period of the Project. The Contractor shall display conspicuously
the telephone number of the 24-hour hotline on the construction site(s) at all
vehicular site entrances/exits or at a convenient location for public
information at all times.
Environmental Complaints
9.3.2
Complaints
shall be referred to the ET Leader for carrying out complaint investigation
procedures. The ET Leader shall undertake the following procedures upon receipt
of any complaints:
(a)
log
complaint and date of receipt onto the complaint database and inform the IEC
immediately;
(b)
investigate
the complaint to determine its validity, and to assess whether the source of
the problem is due to works activities;
(c)
identify
mitigation measures in consultation with the IEC if a complaint is valid and
due to works;
(d)
advise
the Contractor accordingly if mitigation measures are required;
(e)
review
the Contractor's response on the identified mitigation measures, and the
updated situation;
(f)
if
the complaint is transferred from EPD, submit interim report to EPD after
endorsement by IEC on status of the complaint investigation and follow-up
action within the time frame assigned by EPD;
(g)
undertake
additional monitoring and audit to verify the situation if necessary, and
review that circumstances leading to the complaint do not recur;
(h)
report
the investigation results and the subsequent actions to the complainant (If the
source of complaint is EPD, the results should be reported within the time
frame assigned by EPD); and
(i)
record
the complaint, investigation, the subsequent actions and the results in the
monthly EM&A reports.
9.3.3
During
the complaint investigation work, the Contractor and ER shall cooperate with
the ET Leader in providing all the necessary information and assistance for
completion of the investigation. If mitigation measures are identified in the
investigation, the Contractor shall promptly carry out the mitigation. The ER
shall ensure that the measures have been carried out by the Contractor.
9.3.4
A
flow chart of the complaint response procedures is shown in Figure
9.1. A sample complaint log form is shown in Appendix B.