1. 12. Environmental Monitoring and Audit (EM&A) Requirement

12.1. Introduction

12.1.1. The section elaborates the requirements of EM&A for the Project, based on the assessment and mitigation measures of the potential impacts associated with the decommissioning and construction phases of the Project.

12.1.2. In accordance with the requirements as stipulated in Annex 21 of the EIAO (TM), it is necessary to conduct the Environmental Monitoring and Audit (EM&A) programme during the decommissioning and construction phases of the Project and to define the relevant scope of EM&A requirements, including:

· Provision of a database to determine any short- or long-term environmental impacts of the Project;

· Confirmation of the validity of any assumptions made in the design of the Project;

· Provision of an early indication that any of the environmental control measures or other operation practices are failing to achieve the required standards;

· Provision of data to determine the effectiveness of any mitigation or control measures implemented through amendments in procedures during the life of the Project;

· Provision of data to enable an environmental audit of the construction works to be undertaken; and

· Assessment of compliance with the environmental and pollution control.

12.1.3. The following sections summarise the recommended EM&A requirements. Details of EM&A are provided in the EM&A Manual.

12.2. Project Organization

12.2.1. A project organisation consisting of the Engineer Representative (ER), Independent Environmental Checker (IEC), Environmental Team (ET), Project Proponent (FEHD) and Contractor should be established to take on the responsibilities for environmental protection for the Project.

12.2.2. The IEC will be appointed by the Project Proponent to conduct independent auditing on the overall EM&A programme including environmental and operation monitoring, implementation of mitigation measures, EM&A submissions, and any other submission required under the Environmental Permit (EP). The organisation, responsibilities of respective parties and lines of communication with respect to environmental protection works are given in the EM&A Manual.

12.3. EM&A Manual and Implementation Schedule

12.3.1. EM&A is an important aspect in the EIA process which specifies the timeframe and responsibilities for the implementation of environmental mitigation measures. The requirements on environmental monitoring (including baseline and impact monitoring) are given in the EM&A Manual. The Environmental Mitigation Implementation Schedule (EMIS) of the proposed mitigation and protective measures during the decommissioning and construction phase of the Project for different environmental issues are detailed in Appendix 12.1.

12.3.2. Monthly site audits will be undertaken jointly by the site representative of Project Team and the Contractor during the decommissioning and related activities to ensure that dust control, construction waste, site runoff and ecology are managed in accordance with the good site practices described in previous Sections.

12.3.3. A project specific EM&A Manual to the Project is prepared with reference to the latest design information available and EPD’s generic EM&A Manual. The Project specific EM&A Manual highlights the following issues:

· Organisation, hierarchy and responsibilities of the Contractor, Project Proponent, ET, IEC and ER with respect to the EM&A requirements during construction phase of the Project;

· Information on project organisation and programming of construction activities;

· Requirements with respect to the construction schedule and necessary EM&A programme to track the varying environmental impacts;

· Procedure for undertaking on-site environmental audits;

· Definition of Action and Limit Levels;

· Establishment of Event and Action Plans;

· Requirements of reviewing pollution sources and working procedures required in the event of non-compliance of environmental criteria and complaints;

· Requirements for reviewing the EIA predictions, implementation of mitigation measures, and effectiveness of environmental protection and pollution controls measures adopted; and

· Presentation of requirements for EM&A data and appropriate reporting procedures.

12.3.4. An EMIS has been prepared and included in the EM&A Manual to summarise all the required mitigation measures that need to be implemented during the construction phase of the Project. The implementation responsibilities are also identified in the EMIS which is also included in the EM&A Manual for submission to EPD.

12.3.5. The Contractor should review the mitigation measures and EMIS with respect to the design developments and construction methodology. In case the Contractor needs to update the mitigation measures and EMIS, the EM&A Manual should be updated accordingly. The Contractor should seek EPD’s prior approval on these amendments before construction commences.

12.4. EM&A Programme

12.4.1. Detailed requirements of the EM&A programme are described in the EM&A Manual. Measurements and activities are summarised as follows:

· Baseline monitoring on radon, stream water, marine water and ecology;

· Impact monitoring on radon, stream water, marine water and ecology;

· Remedial actions in accordance with the Event and Action Plan within the timeframe in case the specified criteria in the EM&A Manual were exceeded;

· Logging and keeping records of monitoring results; and

· Preparation and submission of Monthly, Quarterly and Annual EM&A Reports.

12.5. Method Statements

12.5.1. The environmental aspects of working methods should be controlled through checking of the Contractor’s method statements which should be submitted and approved by the IEC prior to the works commence. The Project Proponent should specify an arrangement whereby the method statements would be scrutinised and signed off by the IEC before approval.