This EIA Study has focused on the assessment and
mitigation of the potential impacts associated with the construction and
operation of the Project. One of
the key outputs has been the identification of mitigation measures to be
undertaken so that residual impacts comply with regulatory requirements
including the EIAO TM. To confirm effective and timely
implementation of the mitigation measures, it is considered necessary to
develop Environmental Monitoring and Audit (EM&A) procedures and mechanisms
by which the Implementation Schedule (Annex 14A) may be tracked
and its effectiveness assessed.
14.1.1
Implementation of EIA Findings &
Recommendations
Sections 4 to 12
have, where appropriate, identified and recommended the implementation of
mitigation measures to reduce the potential construction and operational
impacts of the Project. These
findings and recommendations form the primary deliverable from the whole EIA process. Once endorsed by the EPD, they will form
an agreement between CAPCO and the Government as to the measures and standards
that are to be achieved. It is
therefore essential that mechanisms are put in place to verify that the
mitigation measures prescribed in the Implementation
Schedule (Annex 14A) are fully and
effectively implemented during construction.
The required format for the Implementation Schedule is specified in the EIA Study Brief. The format requires the specification of
implementation agent(s), timing, duration and location for each of the
recommended mitigation measures.
Apart from the mitigation measures identified in the EIA, there are also
procedures for other requirements to be included within the finalised
Implementation Schedule. Prior to
the issue of an Environmental Permit, there is an EIA Determination
Period. During this period the EIA
Report is reviewed and commented upon by both the public and professional
bodies. Where recommendations are
made and accepted by either the Advisory Council on the Environment (ACE) or
its EIA subcommittee, these measures will be included within the Implementation
Schedule, where appropriate.
14.1.2
Statutory Requirements
As the Project constitutes a Designated Project under
the EIAO, an Environmental Permit
must be obtained before construction or operation of the Gas Receiving Stations
(GRSs) and submarine gas pipelines.
Upon approval of the EIA Report, CAPCO can apply for
an Environmental Permit. If the
application is successful, the Environmental Permit may, have conditions
attached to it, which must be complied with. In addition, CAPCO and its appointed
Contractor(s) must also comply with other controlling environmental legislation
and guidelines, which are discussed within the specific technical chapters of
this Report.
The EPD requires the submittal of an EM&A Manual
prior to the commencement of construction for approval. The EM&A Manual defines the
mechanisms for implementing the EM&A requirements specific to each phase of
the work. The EM&A Manual
provides a description of the organisational arrangements and resources
required for the EM&A programme based on the conclusions and
recommendations of this EIA. It
stipulates details of the construction monitoring required and actions that
shall be taken in the event of exceedances of the
environmental criteria. In effect,
the EM&A Manual forms a handbook for the on-going environmental management
during construction.
The EM&A Manual comprises descriptions of the key
elements of the EM&A programme including:
·
Appropriate
background information on the construction of the Project with reference to
relevant technical reports;
·
Organisational
arrangements, hierarchy and responsibilities with regard to the management of
environmental performance during the construction phase. The EM&A team, the Contractor(s)
team and the CAPCO’s representatives are included;
·
A
broad construction programme indicating those activities for which specific
mitigation is required and providing a schedule for their timely
implementation;
·
Descriptions
of the parameters to be monitored and criteria through which performance will
be assessed including: monitoring frequency and methodology, monitoring
locations (typically, the location of sensitive receivers as listed in the
EIA), monitoring equipment lists, event contingency plans for exceedances of established criteria and schedule of
mitigation and best practice methods for reduced adverse environmental impacts;
·
Procedures
for undertaking on-site environmental performance audits as a means of ensuring
compliance with environmental criteria; and
·
Reporting
procedures.
The EM&A Manual will be a dynamic document which
will undergo a series of revisions, as needed, to accommodate the progression
of the construction programme.
14.2.1
Objectives of EM&A
The objectives of carrying out EM&A for the
Project include:
·
Providing
baseline information against which any short or long term environmental impacts
of the projects can be determined;
·
Providing
an early indication should any of the environmental control measures or practices
fail to achieve the acceptable standards;
·
Monitoring
the performance of the Project and the effectiveness of mitigation measures;
·
Verifying
the environmental impacts identified in the EIA;
·
Determining
Project compliance with regulatory requirements, standards and government
policies;
·
Taking
remedial action if unexpected results or unacceptable impacts arise; and
·
Providing
data to enable an environmental audit to be undertaken at regular intervals.
The following sections summarise the recommended
EM&A requirements and further details are provided in the EM&A Manual.
The EIA study concluded that no air sensitive
receivers (ASRs) will be affected by construction dust through the
implementation of mitigation measures to reduce dust levels. During the operation phase, emissions
will be controlled by integrated measures, regular inspections and relevant
emissions licenses. Emissions from
construction or operation phase are not predicted to yield concentrations that
would lead to significant air quality impacts at the ASRs. Therefore, no air quality monitoring
will be required for either the construction or operation phase, aside from
that required by specific emissions licenses.
Regular site inspections and audits will be carried
out during the construction phase in order to confirm that the mitigation
measures are implemented and are working effectively.
The EIA study of the Project concluded that no
existing noise sensitive receiver (NSR) has been identified within the 300 m Study
Area, and no planned NSR has been identified within 2 km from the Project
Site. This applies to both the
proposed GRSs and submarine gas pipelines. Based upon this, no noise monitoring is
necessary for both the construction and operation phases.
Regular site inspections and audits will be carried
out during the construction phase in order to verify compliance with the
regulatory requirements and conformity of the Contractor with regard to noise
control and contract conditions.
14.5.1
Construction Phase
A number of operational constraints and standard site
practice measures for marine construction activities have been recommended to
reduce potential impacts to water quality sensitive receivers. Regular site inspections and audits will
be carried out during the construction phase in order to confirm that these
measures are implemented and are working effectively.
The EIA indicated that water quality monitoring will
be required during the construction phase for the following activities:
·
Dredging
works for the seawall construction and backfilling works at the reclamation
area at Black Point Power Station (BPPS);
·
Dredging/
jetting works for the submarine gas pipelines in
·
Monitoring
in
Water quality monitoring results will be compared to
Action and Limit levels to determine whether impacts associated with the works
are acceptable. An Event and Action
Plan provides procedures to be undertaken when monitoring results exceed Action
or Limit levels. The procedures are
designed to confirm that if any significant exceedances
occur (either accidentally or through inadequate implementation of mitigation
measures on the part of the Contractor(s)), the cause is quickly identified and
remedied, and that the risk of a similar event re-occurring is reduced.
Action and Limit levels will be used to determine
whether modifications to the operations are required. Action and Limit levels are
environmental quality standards chosen such that their exceedance
indicates potential deterioration of the environment. Exceedance of
Action levels can result in an increase in the frequency of environmental
monitoring, modification of operations and implementation of the proposed
mitigation measures. Exceedance of Limit Levels indicates a greater potential
deterioration in environmental conditions and may require the cessation of
works unless appropriate remedial actions, including a critical review of
plant, working methods and mitigation measures, are undertaken. Before construction work commences four
consecutive weeks of baseline monitoring will be undertaken at stations identified
as detailed in the EM&A Manual.
The full details of the EM&A programme for water
quality are presented in the EM&A Manual for this Project.
14.5.2
Operation Phase
As no unacceptable impacts have been predicted to
occur during the operation of the GRSs at BPPS,
monitoring of impacts to marine water quality during the operation phase is not
considered necessary.
A Waste Management Plan will be devised which
incorporates mitigation measures that have been proposed in the EIA Report to
avoid or reduce potential adverse environmental impacts associated with
handling, collection and disposal of waste arising from the construction and
operation of this Project. Proposed
measures are based on good management, control and site practices.
In order to confirm that the construction
Contractor(s) has(have) implemented the recommendations of the EIA Report,
regular site inspections and audits will be conducted of the waste streams, to
determine if wastes are being managed in accordance with the approved
procedures and the site Waste Management Plan. The inspections/audits will look at all
aspects of waste management including waste generation, storage, recycling,
transport and disposal. The first
inspection/audit will be conducted at the commencement of the construction
works.
The dredging/ jetting operations have been shown to
proceed at rates that maintain environmental impacts to within acceptable
levels following application of mitigation measures. The mitigation measures designed to
mitigate impacts to water quality to acceptable levels (compliance with
assessment criteria) are expected to mitigate impacts to marine ecological
resources and thus specific measures are not deemed necessary.
Specific mitigation measures have been established to
reduce impacts to marine mammals which include restrictions on vessel speed,
the use of pre-defined and regular routes by construction traffic. Marine Mammal exclusion zones will be
implemented during the dredging/ jetting works off Black Point waters. Additional marine mammal monitoring will
also be implemented during the pre-construction, construction and
post-construction phases of the Project.
The EM&A Manual provides complete details of the marine mammal
monitoring programme.
The water quality monitoring programme will provide
management actions and supplemental mitigation measures to be employed should
impacts arise, thereby ensuring the environmental acceptability of the Project.
During the operation phase, adverse impacts are not
expected to occur. Therefore, no
marine mammal monitoring will be required for the operation phase.
The mitigation measures designed to mitigate water
quality impacts to acceptable levels (compliance with assessment criteria) are
expected to mitigate impacts to fisheries resources. Since the impacts to fisheries resources
and fishing operations are small and of short duration, the development and
implementation of a monitoring and audit programme specifically designed to
assess the effects on commercial fisheries resources is not deemed necessary.
The water quality monitoring programme will provide
management actions and supplemental mitigation measures to be employed should
impacts arise, thereby ensuring the environmental acceptability of the Project.
To confirm that the seabed affected by the pipeline
works has returned to its original configuration, a geophysical survey will be
conducted following completion of pipeline works.
The Landscape and Visual Assessment of the EIA
recommended a series of mitigation measures for the construction phase to
mitigate the landscape and visual impacts of the Project. Details of all the recommended
mitigation measures are included within the Implementation Schedule provided in
Annex 14A.
Implementation of the mitigation measures for
landscape and visual resources recommended by the EIA will be monitored through
the site inspection and audit programme.
During the operation phase, adverse impacts are not
expected to occur. Therefore, no
landscape and visual monitoring will be required for the operation phase.
The EIA study of the Project concluded that
terrestrial sites of cultural heritage/ archaeological potential are not
identified within the Project Site.
Findings of the Marine Archaeological Investigation also concluded that
no marine sites of cultural heritage/ archaeological value are present in
waters surrounding Black Point and along the proposed pipeline corridor. No impact to cultural heritage and
archaeology is thus predicted and hence no EM&A is required.
The EIA study concluded that no unacceptable risks
are foreseen as a result of the operation of the GRSs
and submarine gas pipelines. No
mitigation measures are thus deemed necessary and no monitoring will be
required for the construction and operation phases.