10.1.1.1
Site inspections should be conducted regularly to ensure that appropriate environmental protection
and pollution control mitigation measures are properly implemented for the construction works activities associated with the KTE project,
as they are one of the most effective
tools to enforce the environmental protection requirements at the works sites and works areas.
10.1.1.2
Regular site inspections should be carried out and
led by the ER and attended by the Contractor and ET at least once every week. The areas of inspection should
not be limited to the environmental conditions and pollution control and
mitigation measures within the works sites and works areas. Instead, it should also review the environmental conditions of
locations that are beyond the boundary of the works sites and works areas likely to be affected directly or indirectly by the
construction
site activities. During the inspection, the following
information should be referred to:
·
The
EIA and EM&A recommendations on the environmental protection and
pollution control mitigation measures;
·
Ongoing
results of the EM&A programme;
·
The works progress and programme;
·
Proposals of individual
works methodologies (which should include the proposal of the associated pollution control measures);
·
Contract
specifications on environmental protection and pollution prevention control;
·
The relevant environmental protection
and pollution control legislation; and
·
Previous
site inspection findings undertaken by the ET and/or others.
10.1.1.3
The Contractor should keep the ER and ET updated with
all the relevant environmental related information on the
construction contract to carry out the site inspections. The
inspection findings and associated recommendations for improvements to
the environmental protection and pollution control and outcome of the
improvement should be recorded and followed up by the Contractor in an agreed
time-frame.
10.1.1.4
The ER, ET and Contractor should also carry out ad hoc site inspections if significant
environmental problems are identified.
Inspections may also be required subsequent to the receipt of environmental complaints, or as part of the investigation work, as specified
in the Event and Action Plans for the
EM&A programme.
10.2
Compliance with Statutory and Contractual Requirements
10.2.1.1
There are contractual requirements and
legislation in
10.2.1.2
To ensure the works are in compliance with the
contractual requirements, all method statements of major works should be
submitted by the Contractor to the ER for approval and to the ET for vetting so as to ensure
whether sufficient environmental
protection and pollution control measures have been incorporated. The EMIS is included
in Appendix 1.1.
10.2.1.3
The ER and ET should also review the progress and
programme of the construction
works in order to check that the relevant
environmental legislation has
not been violated and that any foreseeable potential for
violating laws can be prevented.
10.2.1.4
The Contractor should provide the update of the
relevant documents to the ER and ET, so that the checking can be carried out in good time. Such documents should at least include
the updated works progress reports, works programme, application letters for environmental licenses / permits, and all valid licenses/ permits. The Contractor’s site diary and environmental
records should also be available for inspection by the relevant parties.
10.2.1.5
The ER and ET should advise the Contractor of any
non-compliance with the
contractual and legislative
requirements on the
environmental protection and
pollution control so
that they can timely take the follow-up action as appropriate. If it would
still be insufficient to comply with the the environmental protection and
pollution control requirements, The ER and ET should provide further advice to the
Contractor to take remedial action to resolve the problems.
10.2.1.6
Upon the
receipt of such advice, the Contractor should undertake the immediate action to remedy the situation. The ER should follow up to ensure that
appropriate action has been taken in order to satisfy the contractual and legal requirements.
10.3
Environmental Complaints
10.3.1.1
Complaints should be referred to the ET for action,
who should
undertake the following procedures upon the receipt of complaints:
(i)
To log the complaints and dates of receipt onto the complaint
database to be kept by the Contractor and inform the ER, ET and IEC
immediately;
(ii)
To investigate with the ER and Contractor the
complaints to determine their validity, and assess whether the source of the
problems is due to the construction works activities;
(iii)
To identify the mitigation measures if the
complaints are valid and due to the construction works of the KTE project;
(iv)
To advise the Contractor if mitigation measures are
required;
(v)
To review the Contractor’s responses to the
identified mitigation measures, and the updated situation;
(vi)
To undertake the additional monitoring and audit in
order to verify the situation if necessary, and review that the circumstances
leading to the complaints would not recur;
(vii)
If the complaint is referred by the EPD, to submit
interim report to the EPD on the status of the complaint investigations and
follow-up action within the time frame assigned by the EPD; and
(viii)
To record the complaints, investigations,
subsequent action and findings in the monthly EM&A reports.
10.3.1.2
During the complaint investigation, the Contractor
and ER should co-ordinate with the ET to
provide all the necessary
information and assistance for the completion of the
investigation. If mitigation measures
are identified to be required, the Contractor should
promptly implement such measures and the ER should ensure that the
measures have been carried out properly.
A flow chart of the complaint response procedures is shown in Appendix 10.1.