EM&A MANUAL

FOR

DECOMMISSIONING OF WEST PORTION OF THE MIDDLE ASH LAGOON AT TSANG TSUI, TUEN MUN

Prepared By:

Allied Environmental Consultants Ltd.

TABLE OF CONTENT

1. Introduction

1.1. Purpose of the Manual

1.2. Project description

1.3. Construction Programme

1.4. Project Organization

1.5. Structure of this Manual

2. Air Quality Impact

2.1. Introduction

2.2. Monitoring during Construction Phase

2.3. Site Audit

3. Health Impact

3.1. Introduction

3.2. Monitoring of Radon Concentration

3.3. Mitigation Measures of Radon

4. Noise Quality Impact

4.1. Introduction

5. Water Quality Impact

5.1. Introduction

5.2. Water Quality Parameters

5.3. Monitoring Stations

5.4. Baseline Monitoring

5.5. Impact Monitoring

5.6. Field Log

5.7. Monitoring Equipment

5.8. Laboratory Measurement / Analysis

5.9. Event and Action Plan

5.10 Site Audits

5.11 Mitigation Measures

6. Waste Management Implications

6.1. Introduction

6.2. Waste Management and Control

7. Land Contamination

7.1. Introduction

8. Ecological Impact

8.1. Introduction

8.2. Impact Mitigation for Terrestrial Ecology

9. Landfill gas Hazard Assessment

9.1. Introduction

9.2. Monitoring and Measurement of Landfill Gas

10. Site Environmental Audit & Environmental Complaints

10.1. Site Inspection

10.2. Compliance with Legal and Contractual Requirements

10.3. Environmental Complaints

11. Reporting

11.1. General

11.2. Baseline Monitoring Report

11.3. Monthly EM&A Reports

11.4. Quarterly EM&A Summary Reports

11.5. Final EM&A Review Report

11.6. Data Keeping

11.7. Interim Notifications of Environmental Quality Limit Exceedances

List of Tables

Table 1.1 Construction Programme

Table 5.1 Proposed Water Quality Monitoring Stations

Table 5.2 Proposed Water Quality Monitoring Frequency and Parameters

Table 5.3 Analytical Methods to be Applied to Water Quality Samples

Table 5.4 Action and Limit Level for Water Quality

Table 5.5 Event and Action Plan for Water Quality

Table 8.1 Ecological Monitoring and Audit Requirement

Table 8.2 Trigger and Action Levels for monitoring of the created freshwater ponds

Table 9.1 Action in the event of landfill gas detected in confined areas

List of Figures

Figure 1.1 Site Location of the Project

Figure 1.2 Project Organization

Figure 5.1 Locations of Water Quality Monitoring Stations

Figure 9.1 Consultation Zone of the Proposed WENT Landfill Extensions

Figure 10.1 Environmental Complaint Flow Diagram

List of Appendices

Appendix 3.1 ¡§Protocol of Radon Measurement for Non-residential Building¡¨ of EPD ProPECC Note PN 1/99 ¡§Control of Radon Concentration in New Buildings¡¨

Appendix 5.1 Sample Field Log Data Sheet

Appendix 9.1 Landfill Gas Hazard Assessment Guidance Note - Chapter 8 Hazards Arising During Construction

Appendix 10.1 Implementation Schedule

Appendix 11.1 Incident Report on Action Level or Limit Level Non-compliance

1. Introduction

1.1. Purpose of the Manual

1.1.1. The Environmental Monitoring and Audit (EM&A) Manual is to guide the setup of an EM&A programme to ensure compliance with the recommendations of the Environmental Impact Assessment (EIA) Study and to assess the effectiveness of the recommended mitigation measures as well as to identify any further need for additional mitigation measures or remedial action.

1.1.2. This manual outlines the monitoring and audit programme for the decommissioning of West Portion of the Middle Ash Lagoon at Tsang Tsui, Tuen Mun (hereinafter known as the ¡§Project¡¨). It aims to provide systematic procedures for monitoring, auditing and minimizing environmental impacts associated with the decommissioning and construction works of the Project.

1.1.3. Hong Kong Environmental regulations and the Hong Kong Planning Standards and Guidelines have served as environmental standards and guidelines in the preparation of this Manual. In addition, the EM&A Manual has been prepared in accordance with the requirements stipulated in Annex 21 of the Technical Memorandum on the Environmental Impact Assessment Ordinance (EIAO (TM)).

1.1.4. The Manual contains the following information:

¡P Responsibilities of the Contractor, the Engineer Representative (ER), the Independent Consultants (IC), Environmental Team (ET), the Independent Environmental Checker (IEC) and Project Proponent (FEHD) with respect to the environmental monitoring and audit requirements during the course of the Project;

¡P Project organization for the Project;

¡P The basis for, and description of the broad approach underlying the EM&A programme;

¡P Requirements with respect to the construction programme schedule and the necessary environmental monitoring and audit programme to track the varying environmental impact;

¡P Details of the methodologies to be adopted, including all field laboratories and analytical procedures, and details on quality assurance and quality control programme;

¡P Definition of action and limit levels;

¡P Establishment of event and action plans;

¡P Requirements for reviewing pollution sources and working procedures required in the event of non-compliance with the environmental criteria and complaints;

¡P Requirements for presentation of environmental monitoring and audit data and appropriate reporting procedures; and

1.1.5. An Environmental Team (ET) shall be appointed to conduct the monitoring works and to provide specialist advice on the undertaking and implementation of environmental responsibilities. The ET will be led and managed by the ET leader. Suitably qualified staff will be included in the ET, and ET should not be in any way an associated body of the Contractor(s). For the purpose of this manual, the ET Leader, who will be responsible for, and in charge of, the ET, is referred to as the person delegated the role of executing the EM&A requirements.

1.1.6. To maintain strict control of the EM&A process, an Independent Environmental Checker (IEC) will be engaged to verify and validate/ audit the environmental performance of project¡¦s Contractor(s). Sufficient and suitably qualified professional and technical staff will be employed by the IEC, as required under the EM&A programme for the duration of the Project.

1.2. Project description

Project Scope

1.2.1. The Project consists of the Subject Site with a total area of about 30,000m2 (3.0 hectares). It comprises 2.7ha of dry PFA platform and 0.3ha of low zone along the northern boundary, which generally contain water. In accordance with the latest available information, there is no plan that the 0.3ha low zone will be filled up. The area is considered as a man-made water channel and will be left intact. Thus, decommissioning work would include construction of retaining structure to stabilise the PFA slope along this man-made water channel. Figure 1.1 depicts the site layout.

1.2.2. The decommissioning of the Middle Ash Lagoon at Tsang Tsui, Tuen Mun will provide buildable land for future developments.

1.2.3. The decommissioning works in the Project shall mainly involve the following:

¡P Covering of 1m thick general fill above the final PFA surface with minor levelling works

¡P Formation of Construction Access Road (North) by filling and levelling followed by layering of a 1m thick general fill above the final PFA surface to proposed levels

¡P Formation of part of the Construction Access Road (South) by layering of a 1m thick general fill above the final PFA surface to proposed levels, followed by levelling and slope works along the road section approaching to the Site

1.2.4. In addition, associate works in the Project, which will not involve decommissioning, include the following:

¡P Minor reinstating works on part of the existing access road to form the Construction Access Road (South)

¡P Construction of retaining structure for slope stabilization along the edge of existing water channel near the north site boundary

¡P Installation of surface drainage outfall system for discharging the surface water out of the complete buildable land at the north-west corner of the Subject Site

¡P Installation of site hoarding and temporary surface drainage system

1.2.5. The Project addressed in this EIA Report is classified as designated projects under Item 8 of Part II, Schedule 2 of the Environmental Impact Assessment Ordinance (EIAO),i.e. decommissioning of a waste disposal facility for pulverized fuel ash, furnace bottom ash or gypsum.

Site Location

1.2.6. The Project is to provide buildable land for future developments. Other than the Subject Site, the remaining Middle Ash Lagoon area will be taken over by EPD as an extension of WENT Landfill (WLES). According to the approved EIA report from EPD for the Development of the Integrated Waste Management Facilities (IWMF) Phase 1 (application no. EIA 201/2011), the area directly to the east of the Subject Site is one of the potential sites for the IWMF Phase 1. Further to the east in the East Lagoon, a Sludge Treatment Facilities (STF) development is currently under construction.

1.3. Construction Programme

1.3.1. The decommissioning and construction in this project will commence in September 2015. The proposed completion date is tentatively scheduled for March of 2016. The tentative programme is shown in Table 1.1.

Table 1.1 Construction Programme

Activity Description	Anticipated Date
Commencement of decommissioning project*	September 2015
Completion of decommissioning project	March 2016

1.4. Project Organization

1.4.1. The roles and responsibilities of the various parties involved in the construction phase EM&A process and the implementation of the EM&A programme are outlined below. The proposed project organization and lines of communication during construction phase with respect to environmental protection works is shown in Figure 1.2.

Construction Phase

Engineer Representative (ER)

1.4.2. Engineer Representative (ER) is responsible for overseeing the construction works of the Project undertaken by the Contractor, and for ensuring that they are undertaken by the Contractor in accordance with the specification and contractual requirements. The responsibilities for ER include the followings:

¡P Monitor the Contractor¡¦s compliance with contract specifications, including the implementation and operation of the environmental mitigation measures and ensure their effectiveness, and other aspects of the EM&A programme;

¡P Monitor the Contractor¡¦s, the ET¡¦s and the IEC¡¦s compliance and ensure that the requirements in the Environmental Permit (EP) and EM&A Manual are fully complied with;

¡P Provide assistance to the ET as necessary in the implementation of the EM&A programme;

¡P Participate in joint site inspection undertaken by the ET and the IEC;

¡P Comply with the agreed Event/Action Plan in the event of any exceedance; and

¡P Adhere to the procedures for carrying out complaint investigation.

Contractor

1.4.3. The term ¡§Contractor¡¨ should be taken to mean all construction contractors and sub-contractors, working on site at any one time. The Contractor should also be responsible for the following tasks:

¡P Work within the scope of the relevant contract and other tender conditions;

¡P Provide assistance to the ET in carrying out monitoring;

¡P Participate in the site inspections undertaken by the ET and IEC, and undertake any corrective actions;

¡P Provide information/advice to the ET regarding works activities which may contribute, or be continuing to the generation of adverse environmental conditions;

¡P Submit proposals on mitigation measures in case of exceedances of action or limit levels in accordance with the event/action plans;

¡P Implement measures to reduce impact where action or limit levels are exceeded; and

¡P Adhere to the procedures for carrying out complaint investigation.

Independent Environmental Checker (IEC)

1.4.4. The Independent Environmental Checker (IEC) should not be in any way an associated body of the Contractor for the Project. The responsibilities for IEC should include the followings:

¡P Advise the ER on environmental issues related to the project, independent from the management of construction works, but empowered to audit the environmental performance of construction and operation;

¡P Provide proactive advice to the Employer of the Project on environmental matters;

¡P Review and audit all aspects of the EM&A programme, including the implementation of environmental mitigation measures, submission relating to the EP and EM&A, and any other submission required under the EP and EM&A Manual;

¡P Review and verify the monitoring data and all submissions relating to or under the EP and EM&A Manual submitted by the ET, including but not limited to the EM&A reports;

¡P Monitor the implementation of the EM&A programme and the overall level of environmental performance being achieved;

¡P Arrange and conduct regular, at least monthly site inspections of the works during construction phase, and ad hoc inspections if significant environmental problems are identified;

¡P Comply with the agreed event / action plan in the event of any exceedance;

¡P Check and ensure the procedures for carrying out complaint investigation being followed and check the effectiveness of corrective measures;

¡P Feedback audit results to ET by signing off relevant EM&A perform;

¡P Ensure the impact monitoring is conducted at the correct locations at the frequency identified in the EM&A Manual;

¡P Check that the mitigation measures are effectively implemented; and

¡P Report the works conducted, the findings, recommendation and improvement of the site inspections, the findings, recommendation, and improvement after reviewing the ET¡¦s and the Contractor¡¦s works, and any advices to the ER and the Employer of the Project on a monthly basis.

Environmental Team (ET)

1.4.5. The Environmental Team (ET) shall not be in any way an associated body of the Contractor, and shall be responsible to conduct the EM&A programme. The ET should be managed by the ET Leader. The ET Leader shall be a person who has at least 7 years¡¦ experience in EM&A and have relevant professional qualifications. Suitably qualified staff should be included in the ET, and resources for the implementation of the EM&A programme should be allocated in time under the Contract, to enable fulfillment of the Project¡¦s EM&A requirements as specified in the EM&A Manual during construction of the Project. The ET shall report to the ER and the duties of ET shall include the followings:

¡P Monitor and audit various environmental parameters as required in this EM&A Manual;

¡P Analyze the environmental monitoring and audit data and review the success of EM&A programme to cost-effectively confirm the adequacy of mitigation measures implemented and the validity of the EIA predictions and to identify any adverse environmental impacts arising;

¡P Carry out regular site inspection to investigate and audit the Contractor¡¦s site practice, equipment and work methodologies with respect to pollution control and environmental mitigation, and effect proactive action to pre-empt problems;

¡P Monitor compliance with conditions in the EP, environmental protection, pollution prevention and control regulations and contract specifications;

¡P Audit environmental monitoring data and site environmental conditions;

¡P Report on the environmental monitoring and audit results to EPD, the ER, the IEC and the Contractor or their delegated representative;

¡P Recommend suitable mitigation measures to the Contractor in the case of exceedance of action or limit levels in accordance with the event and action plans;

¡P Liaise with the IEC on all environmental performance matters and timely submit all relevant EM&A proforma for approval by the IEC;

¡P Advise the Contractor on environmental improvement, awareness, enhancement matters, etc., on site;

¡P Adhere to the procedures for carrying out complaint investigation; and

¡P Timely submit the EM&A Reports to the EPD.

1.4.6. Sufficient and suitably qualified professional and technical staff should be employed to ensure full compliance with their duties and responsibilities, as required under the EM&A programme during the construction phase of the Project.

1.5. Structure of this Manual

1.5.1. Following this introductory section, the structure of the EM&A Manual is set out below:

¡P Section 2 details the requirement for impact monitoring for dust during the construction phase;

¡P Section 3 details the radon measurement requirements with regard to human health risk as recommended in the EIA;

¡P Section 4 details the requirements for impact monitoring for noise during the construction phase;

¡P Section 5 details the requirements for baseline and impact monitoring for water quality during the construction phase;

¡P Section 6 details the audit requirements with regard to waste management issues as well as the waste control and mitigation measures recommended in the EIA;

¡P Section 7 details the requirements for monitoring of land contamination;

¡P Section 8 details the requirements for monitoring and audit the ecological impacts during the construction phases;

¡P Section 9 details the requirements for monitoring of landfill gas during the construction phase;

¡P Section 10 details the requirements on site environmental audit and the environmental complaints handling procedure; and

¡P Section 11 details the EM&A reporting requirements.

2. Air Quality Impact

2.1. Introduction

2.1.1. This section presents the requirements, methodology, equipment, criteria and protocols for the monitoring and audit of air quality impacts during the construction phase of the Project.

2.1.2. The objective of the air quality monitoring include the following:

¡P To identify the extent of construction dust impacts;

¡P To determine the effectiveness of mitigation measures to control dust emission from activities during construction phase;

¡P To audit the compliance of the Contractor with regard to dust control, contract conditions and the relevant dust impact criteria;

¡P To recommend further mitigation measures if found to be necessary; and

¡P To comply with action and limit levels for air quality as defined in this Manual.

2.1.3. During construction phase of the Project, dust impacts would be the major air quality impacts.

2.2. Monitoring during Construction Phase

2.2.1. With the implementation of practicable dust suppression measures stipulated in the Air Pollution Control (Construction Dust) Regulation, adverse construction dust impact at Air Sensitive Receivers (ASRs) is not expected during construction of the Project. In view of the large separation distance of the nearby ARSs from the Project Site, no dust monitoring is considered necessary. Yet, regular site environmental audits during the construction phase of the Project as described in Section 11 of this Manual should be conducted to ensure that the recommended dust suppression measures are implemented properly.

2.2.2. Mitigation measures for dust control have been recommended in the EIA Report and are listed below:

¡P Dust Suppression by watering of construction area at least 10 times per working day;

¡P Provide covering of 50% of open area with impervious materials or concrete paving;

¡P Limited working period to 180 days;

¡P Provision pavement to Construction access road with concrete paving and provide wheel washing facility at entrance and exit;

¡P Skip hoist for material transport should be totally enclosed by impervious sheeting;

¡P Vehicle washing facilities should be provided at every vehicle exit point;

¡P The area where vehicle washing takes place and the section of the road between the washing facilities and the exit point should be paved with concrete, bituminous materials or hardcore;

¡P Where a site boundary adjoining a road, streets or other areas accessible to the public, hoarding of not less than 2.4, high from ground level should be provided along the entire length except for a site entrance or exit;

¡P Every main haul road should be paved with concrete and kept clear of dusty materials or sprayed with water so as to maintain the entire road surface wet;

¡P The portion of road leading only to a construction site that is within 30m of a designated vehicle entrance or exit should be kept clear of dusty materials;

¡P Every stock of more than 20 bags of cements should be covered entirely by impervious sheeting placed in an area sheltered on the top and the 3 sides;

¡P All dusty materials should be sprayed with water prior to any loading, unloading or transfer operation so as to maintain the dusty materials wet;

¡P Every vehicle should be washed to remove any dusty materials from its body and wheels before leaving the construction sites;

¡P The load of dusty materials carried by vehicles leaving a construction site should be covered entirely by clean impervious sheeting to ensure dusty materials do not leak from the vehicle;

¡P Provision of wind shield and dust extraction units or similar dust mitigation measures at the loading points, and use of water sprinklers at the loading area where dust generation is likely during the loading process of loose material, particularly in dry seasons/ periods;

¡P Imposition of speed controls for vehicles on unpaved site roads. Ten kilometres per hour is the recommended limit;

¡P Where possible, routing of vehicles and positioning of construction plant should be at the maximum possible distance from ASRs; and

¡P Instigation of an environmental auditing program to monitor the construction process in order to enforce controls and modify method of work if dusty conditions arise.

2.2.3. The Contractor shall be responsible for the design and implementation of these measures.

2.3. Site Audit

2.3.1. Implementation of regular site audits should be implemented to ensure that the recommended mitigation measures are to be properly undertaken during proposed construction works. Site audits also act to provide an effective control of any malpractices and therefore achieve continual improvement of environmental performance on site.

2.3.2. Site Audits shall be carried out by the ET and shall be based on the mitigation measures for air pollution recommended in the implementation schedule as presented in Appendix 10.1. In the event where the recommended mitigation measures are not fully or properly implemented, deficiency shall be recorded and reported to the site management. Actions are to be carried out to:

¡P Investigate the problems and the causes;

¡P Issue action notes to the Contractor who is responsible for the works;

¡P Implement remedial and corrective actions immediately;

¡P Re-inspect the site conditions upon completion of the remedial and corrective actions; and

¡P Record the event and discuss with the Contractor for preventive actions.

3. Health Impact

3.1. Introduction

3.1.1. According to the health risk assessment, there is no significant Chemicals of Potential Concern (COPC) and radiological hazard to the workers during the construction phase for the Project. However, baseline measurement and monitoring of radon concentration during the decommissioning is recommended.

3.2. Monitoring of Radon Concentration

Monitoring during Construction Phase

3.2.1. The indoor radon concentration at site office shall be measured by professional persons in accordance with EPD ProPECC Note PN 1/99 ¡§Control of Radon Concentration in New Buildings¡¨ to ensure that the radon concentration complies with the guideline value.

Measurement of Radon Concentration

3.2.2. The measurement locations, measurement protocol, measurement criteria, report and documentation described in Appendix 2 of ¡§Protocol of Radon Measurement for Non-residential Building¡¨ of EPD ProPECC Note PN 1/99 ¡§Control of Radon Concentration in New Buildings¡¨ shall be followed. The protocol is enclosed in Appendix 3.1 of this EM&A Manual for information. Should the measured indoor radon level exceed that of the standard, mitigation measures should be undertaken according to the practice note.

3.3. Mitigation Measures of Radon

3.3.1. Under the ¡§As Low As Reasonably Achievable¡¨ Principle (ALARA Principle), recommended measures shall be considered during the design, decommissioning and construction of the Project, as listed below:

¡P Provision of soil cover beneath the buildings on top of ash lagoon prior to construction works to reduce the level of radon influx; and

¡P Sufficient ventilation of the interior of the site office through natural ventilation to enhance air exchange rate in the buildings.

4. Noise Quality Impact

4.1. Introduction

4.1.1. No noise sensitive receiver (NSR) was identified within 300m from the boundary of the Subject Site. Construction and operation noise monitoring is therefore not considered necessary.

5. Water Quality Impact

5.1. Introduction

5.1.1. This section describes the requirements for the monitoring and audit of water quality impacts from the Project during the construction phase. Pollution sources arising from the Project during the construction are mainly associated with land-based activities which include drainage and construction site-runoff, sewage effluent produced by workforce, wastewater generated from general construction activities, and PFA contaminated runoff.

5.1.2. The EIA Report has assessed the water quality impacts caused by the decommissioning and construction activities of the Project. Mitigation measures have been recommended in the EIA Report to ensure compliance with relevant legislative requirements.

5.1.3. Regular inspections were recommended to be undertaken to inspect the construction activities and work areas and also the proper implementation of the recommended mitigation measures. Water quality monitoring at the water quality monitoring stations were recommended during the entire works, in order to ensure that there are no adverse water quality impacts to the water sensitive receivers.

5.1.4. Should there be discharges from the Subject Site during decommissioning and construction works, the discharge waters would be required to comply with the terms and conditions as stipulated in the discharge license, issued by EPD, under the Water Pollution Control Ordinance (WPCO). As stipulated by the discharge license, the Contractor may be required to conduct water quality monitoring to monitor the quality/quantity of the discharge to show compliance with the conditions of the license. Such monitoring would not form part of the EM&A programme.

5.2. Water Quality Parameters

5.2.1. Dissolved Oxygen (DO), turbidity, suspended solids (SS) level and pH should be monitored at designated water quality monitoring stations in the Tsang Kok stream.

5.2.2. With regard to the potential marine water quality impact, heavy metals including aluminium, chromium and cadmium, which have the greatest tendency to leach from the lagoon PFA into the seawater, should be monitored.

5.2.3. Parameters such as DO, turbidity and pH should be measured in situ were as SS and heavy metals should be determined by laboratory analysis.

5.3. Monitoring Stations

5.3.1. The proposed water quality monitoring stations are listed in Table 5.1 and shown in Figure 5.1. For the stream water quality monitoring, a monitoring station should be set in stream course upstream of the works areas which should act as a control station (C1), and two impact monitoring stations (S1 and S2) should be located in Tsang Kok stream and downstream of the work areas. Two control stations (C2 and C3) should be set in the outer marine water and two impact monitoring stations (M1 and M2) should be located adjacent to the Middle Ash Lagoon in the Deep Bay WCZ. The location set out for control and impact monitoring may change after the issuance of this manual. Should such case occur, the ET leader shall propose updated monitoring locations and seek approval from the IEC and EPD prior to commencement of water quality monitoring.

Table 5.1 Proposed Water Quality Monitoring Stations

Station	Description	Easting	Northing	Parameters
C1	Control Station for the Tsang Kok Stream water quality monitoring	809963	830960	DO, Turbidity, SS, pH
S1	Impact monitoring stations for Tsang Kok Stream	809996	831056
S2		810159	831098
C2	Control station for marine water quality monitoring	808783	831904	Metals (aluminium, chromium, cadmium)
C3		810045	832206
M1	Marine water adjacent to the Middle Ash Lagoon	809403	831561
M2		809772	831659

5.3.2. For stream water quality monitoring, measurements should be taken at mid-depth layer.

5.3.3. For marine water monitoring stations, sampling shall be taken at three water depths, namely 1m below water surface, mid-depth and 1m above seabed, except at where the water depth less than 6m, the mid-depth station may be omitted. Should the water depth be less than 3m, only the mid-depth station will be monitored.

5.3.4. Aside from the associated monitoring parameter at each control and impact monitoring stations, the followings should also be recorded and monitored:

¡P Monitoring location/ position;

¡P Monitoring time;

¡P Water depth;

¡P Water temperature;

¡P Weather conditions;

¡P Sea Condition;

¡P Tidal stage; and

¡P Works underway at the construction site during measurement.

5.4. Baseline Monitoring

5.4.1. The baseline conditions in the stream course should be established and agreed by EPD prior to commencement of construction works. The purpose of baseline monitoring is to establish ambient conditions prior to the commencement of the works and to demonstrate the suitability of the proposed impact and control monitoring stations. The baseline conditions shall be established by measuring the water quality parameters in Table 5.2.

5.4.2. The baseline monitoring for the stream course should be taken at all designated monitoring stations at Tsang Kok Stream. The measuring frequency shall be three days per week, for at least four weeks prior to the commencement of works. There should not be any construction works in the vicinity of the stations during the baseline monitoring. The interval between two sets of monitoring shall not be less than 36 hours.

5.4.3. The baseline monitoring of marine water shall be done in a similar fashion as to the baseline monitoring for the stream course. The measuring frequency shall also be done three days per week, for at least four weeks, at mid-flood and mid-ebb tides prior to the commencement of construction works. Similarly, there should not be any construction works in the vicinity of the stations during the baseline monitoring. The interval between two sets of monitoring shall not be less than 36 hours.

5.4.4. The Contractor shall notify EPD on the baseline monitoring schedule at least one week prior to the commencement of baseline monitoring. Should there be any changes in the monitoring schedule; the Contractor shall notify the EPD immediately.

5.4.5. Laboratory analysis shall be carried out in a HOKLAS or other international accredited laboratory. A baseline monitoring report shall be prepared and submitted to EPD for approval at least 4 weeks prior to the commencement of the construction works. The baseline monitoring report should be certified by the IEC before submission to EPD.

5.5. Impact Monitoring

Stream Water Quality Monitoring

5.5.1. During the course of construction works, impact monitoring shall be undertaken three days per week with sampling and measurement at all designated water quality monitoring stations at Tsang Kok Stream. The interval between two sets of monitoring shall not be less than 36 hours except where there are exceedances of Action or Limit levels, in which case the monitoring frequency will be increased. Table 5.2 shows the proposed monitoring frequency and water quality parameters. Upon completion of the above construction works, the monitoring exercise at the designated monitoring locations shall be continued in the same manner as the impact monitoring for four weeks.

5.5.2. In each sampling event, duplicate in-situ measurements should be carried out. The monitoring probes should be retrieved out of water after the first measurement and then redeployed for the second measurement. Where the difference in value between the first and second readings of DO, turbidity or pH is more than 25% of the value of the first reading, the reading should be discarded and further readings should be taken.

5.5.3. Proposed water quality monitoring schedule shall be faxed to EPD on or before the first day of the monitoring month. EPD shall also be notified immediately for any changes in schedule by fax. If the monitoring data collected at the designated stations indicate that the Action or Limit Levels as shown in Table 5.4 are exceeded, appropriate actions should be taken in accordance with the Event and Action Plan in Table 5.5.

Marine Water Quality Monitoring

5.5.4. During the course of construction works, impact monitoring shall be undertaken three days per week at mid-flood and mid-ebb tides with sampling and measurement at all designated water quality monitoring stations in the Deep Bay WCZ. The interval between two sets of monitoring shall not be less than 36 hours except where there are exceedances of Action and /or Limit levels, in which case the monitoring frequency will be increased. Table 5.2 shows the proposed monitoring frequency and water quality parameters. Upon completion of the above construction works, the monitoring exercise at the designated monitoring locations is continued in the same manner as the impact monitoring for four weeks.

5.5.5. Proposed water quality monitoring schedule shall be faxed to EPD on or before the first day of the monitoring month. EPD shall also be notified immediately for any changes in schedule by fax. If the monitoring data collected at the designated stations indicate that the Action or Limit Levels as shown in Table 5.4 are exceeded, appropriate actions should be taken in accordance with the Event and Action Plan in Table 5.5.

Table 5.2 Proposed Water Quality Monitoring Frequency and Parameters

Activities	Monitoring Frequency	Key Parameters	Monitoring Stations
During the 4-week baseline monitoring period	Three days per week	Suspended Solids (SS), Turbidity and Dissolved Oxygen (DO), pH	C1, S1, S2
		Metals (aluminium, chromium, cadmium)	C2, C3, M1, M2
During the course of decommissioning and construction works	Three days per week	Suspended Solids (SS), Turbidity and Dissolved Oxygen (DO), pH	C1, S1, S2
		Metals (aluminium, chromium, cadmium)	C2, C3, M1, M2
During 4-week period after completion of decommissioning and construction works	Three days per week	Suspended Solids (SS), Turbidity and Dissolved Oxygen (DO), pH	C1, S1, S2
		Metals (aluminium, chromium, cadmium)	C2, C3, M1, M2

Notes:

1. DO, turbidity and pH should be measured in situ whereas SS and metals should be determined by laboratory.

5.6. Field Log

5.6.1. During any monitoring event, relevant data including monitoring location/ position, time, water depth, sampling depth, pH, salinity, DO saturation, water temperature, tidal stages, weather conditions and any special phenomena or work underway shall be recorded.

5.6.2. A sample data sheet is shown in Appendix 5.1 for reference.

5.7. Monitoring Equipment

Dissolved Oxygen and Temperature Measuring Equipment

5.7.1. Instrument used for in situ measurement should be a portable and weatherproof DO measuring instrument complete with cable and sensor, and use a DC power source. The equipment should be capable of measuring:

¡P A DO level in the range of 0 ¡V 20 mg/L and 0 ¡V 200% saturation; and

¡P A temperature of 0 ¡V 45 degree Celsius.

Turbidity Measurement Instrument

5.7.2. The instrument shall be a portable, weatherproof turbidity-measuring instrument. The equipment shall use a DC power source. It shall have a photoelectric sensor capable of measuring turbidity between 0 ¡V 1000 NTU (e.g. Hach model 2100P or an approved similar instrument).

Water Depth Detector

5.7.3. A portable, battery-operated echo sounder shall be used for the determination of water depth at each designated monitoring station. This unit can either be handheld or affixed to the bottom of the work boat. The same vessel is to be used throughout the monitoring programme.

pH Measurement Instrument

5.7.4.  The instrument should consist of a potentiometer, a glass electrode, a reference electrode and a temperature-compensating device.  It should be readable to 0.1pH in a range of 0 to 14.  Standard buffer solutions of at least pH 7 and pH 10 should be used for calibration of the instrument before and after use.

Location of Monitoring Site

5.7.5. A hand-held or boat-fixed type digital Global Positioning System (GPS) with way point bearing indication or other equivalent instrument of similar accuracy shall be provided and used during monitoring to ensure monitoring vessel is at the correct location before taking measurements.

Sampler

5.7.6. A water sampler is required during monitoring. The sampler should comprise of a transparent PVC cylinder, with a capacity of not less than 2 litres, and can be effectively sealed with latex cups at both ends. The sampler shall have a positive latching system to keep it open and prevent premature closure until released by a messenger when the sampler is at the selected water depth (e.g. Kahlsico Water Sampler or an approved similar instrument).

Sampling Containers and Storage

5.7.7. Water samples for suspended solids (SS) and heavy metals measurements should be stored in high density polythene bottles with no preservative added, packed in ice (cooled to 4^oC without being frozen) and delivered to the laboratory and analysed as soon as possible after collection. Sufficient samples should be collected to achieve the detection limit stated in Section 5.8.

Calibration of in-situ Instruments

5.7.8. All in-situ monitoring instrument should be checked and calibrated before use. DO meter, turbidimeter and pH measurement instrument should be certified by a laboratory accredited under HOKLAS or any other international accreditation scheme, and subsequently re-calibrated at three monthly intervals throughout all stages of the water quality monitoring. Responses of sensors and electrodes should be checked with certified standard solutions before each use. Wet bulb calibration for a DO meter should be carried out before measurement at each monitoring station.

5.7.9. Sufficient stocks of spare parts should be maintained for replacements when necessary. Backup monitoring equipment should also be made available so that monitoring can proceed uninterrupted even when some equipment is under maintenance, calibration, etc.

5.8. Laboratory Measurement / Analysis

5.8.1. Analysis of suspended solids (SS) and heavy metals should be carried out in a HOKLAS or other international accredited laboratory. Sufficient water samples should be collected at the monitoring stations for carrying out the laboratory determinations. The determination work should start within 24 hours after collection of the water samples. The analyses should follow the American Public Health Association (APHA) Standard Methods for the Examination of Water and Wastewater or an equivalent method subject to the approval of EPD. Analytical methods and detection limits for SS and heavy metals are presented in Table 5.3.

Table 5.3 Analytical Methods to be Applied to Water Quality Samples

Parameters	Analytical Method	Detection Limit
Suspended Solids	APHA 2540D^(i)	1 mg/L
Cadmium	APHA 20e 3111B^(i)	0.5 µg/L
Chromium	APHA 20e 3111D^(i)	1 µg/L
Aluminum	APHA 3500-AI-D^(i)	20 µg/L

Note:

(i). APHA American Public Health Association Standard Methods for the Examination of Water and Wastewater

5.8.2. The testing of SS and metals should be HOKLAS accredited (or if not, approved by EPD) and comprehensive quality assurance and control procedures in place in order to ensure quality and consistency in results.

5.8.3. Detailed testing methods, pre-treatment procedures, instrument use, Quality Assurance/Quality Control (QA/QC) details (such as blank, spike recovery, number of duplicate samples per batch, etc.), detection limits and accuracy shall be submitted to EPD for approval prior to commencement of monitoring programme. The QA/QC shall be in accordance with the requirement of HOKLAS or international accredited scheme. The QA/QC results shall be reported. EPD may also request the laboratory to carry out analysis of known standards provided by EPD for quality assurance.

5.8.4. Additional duplicate samples may be required by EPD for inter laboratory calibration. Remaining samples after analysis shall be kept by the laboratory for 3 months in case repeat analysis is required. If in-house or non-standard methods are proposed, details of the method verification may also be required to submit to EPD. In any circumstance, the sample testing shall have comprehensive quality assurance and quality control programmes. The laboratory shall prepare to demonstrate the programmes to DEP or his representatives when requested.

5.9. Event and Action Plan

5.9.1. The water quality assessment criteria, namely Action and Limit Levels, are shown in Table 5.4. The levels are based on the results of baseline monitoring and WQO of the relevant water control zone. They are set up to ensure that any deterioration of water quality is readily detected and timely action is taken to rectify the situation. Should the monitoring results of the water quality parameters at any designated monitoring stations indicate that the water quality assessment criteria are exceeded, the actions in accordance with the Event and Action Plan summarized in Table 5.5 shall be carried out.

5.9.2. The ET leader should assess the potential impacts on the water sensitive receivers based on the monitoring data. The performance of the environmental management system (i.e. of the overall EM&A programme) should be reviewed by the ET leader on a quarterly basis. Quarterly EM&A summary reports, together with any recommendations to improve the performance of the EM&A programme should be included in the finding of this review.

Table 5.4 Action and Limit Level for Water Quality

Parameters	Action	Limit
DO in mg/L	≤5%-ile of baseline data	≤4 mg/L
SS in mg/L	≥95%-ile of baseline data or 120% of control station¡¦s SS on the same day of measurement	≥ 99%-ile of baseline or 130% of control station¡¦s SS on the same day of measurement
Turbidity in NTU	≥95%-ile of baseline data or 120% of control station¡¦s turbidity on the same day of measurement	≥ 99%-ile of baseline or 130% of control station¡¦s turbidity on the same day of measurement
pH	≤5%-ile or ≥95%-ile of baseline data	pH ≤6 or pH ≥9
Metals	≥95%-ile of baseline data	≥99%-ile of baseline

Note:

1. For DO, non-compliance of the water quality limits occurs when monitoring result is lower than the limits.

2. For metals, SS and turbidity, non-compliance of the water quality limit occurs when monitoring result is higher than the limits.

Table 5.5 Event and Action Plan for Water Quality

Event	ET Leader	IEC	ER	Contractor
Action level being exceeded by one sampling day	¡P Repeat in-situ measurement to confirm findings; ¡P Identify source(s) of impact; ¡P Inform IEC and Contractor; ¡P Check monitoring data, all plant, equipment and Contractor's working methods; ¡P Discuss mitigation measures with IEC and Contractor; ¡P Repeat measurement on next day of exceedance.	¡P Discuss with ET and Contractor on the ¡P mitigation measures ¡P Review proposals on mitigation ¡P measures submitted by Contractor and ¡P advise the ER accordingly ¡P Assess the effectiveness of the ¡P implemented mitigation measures.	¡P Discuss with IEC on the proposed ¡P mitigation measures; ¡P Make agreement on the mitigation ¡P measures to be implemented;	¡P Inform the ER and confirm notification of the non-compliance in writing; ¡P Rectify unacceptable practice; ¡P Check all plant and equipment; ¡P Consider changes of working methods; ¡P Discuss with ET and IEC and propose mitigation measures to IEC and ER; ¡P Implement the agreed mitigation measures.
Action level being exceeded by more than one consecutive sampling days	¡P Repeat in-situ measurement to confirm findings; ¡P Identify source(s) of impact; ¡P Inform IEC and Contractor; ¡P Check monitoring data, all plant, equipment and Contractor's working methods; ¡P Discuss mitigation measures with IEC and Contractor; ¡P Ensure mitigation measures are implemented; ¡P Prepare to increase the monitoring frequency to daily; ¡P Repeat measurement on next day of exceedance.	¡P Discuss with ET and Contractor on the ¡P mitigation measures ¡P Review proposals on mitigation ¡P measures submitted by Contractor and ¡P advise the ER accordingly ¡P Assess the effectiveness of the ¡P implemented mitigation measures.	¡P Discuss with IEC on the proposed ¡P mitigation measures; ¡P Make agreement on the mitigation ¡P measures to be implemented; ¡P Assess the effectiveness of the implemented mitigation measures.	¡P Inform the ER and confirm notification of the non-compliance in writing; ¡P Rectify unacceptable practice; ¡P Check all plant and equipment; ¡P Consider changes of working methods; ¡P Discuss with ET and IEC and propose mitigation measures to IEC and ER within 3 working days; ¡P Implement the agreed mitigation measures.

Event	ET Leader	IEC	ER	Contractor
Limit level being exceeded by one sampling day	¡P Repeat in-situ measurement to confirm findings; ¡P Identify source(s) of impact; ¡P Inform IEC, contractor and EPD; ¡P Check monitoring data, all plant, equipment and Contractor's working methods; ¡P Discuss mitigation measures with IEC, ER and Contractor; ¡P Ensure mitigation measures are implemented; ¡P Increase the monitoring frequency to daily until no ¡P Exceedance of Limit level.	¡P Discuss with ET and Contractor on the mitigation measures ¡P Review proposals on mitigation measures submitted by Contractor and advise the ER accordingly ¡P Assess the effectiveness of the implemented mitigation measures.	¡P Discuss with IEC, ET and Contractor on the proposed mitigation measures; ¡P Request Contractor to critically review the working methods; ¡P Make agreement on the mitigation measures to be implemented; ¡P Assess the effectiveness of the implemented mitigation measures.	¡P Inform the ER and confirm notification of then on-compliance in writing; ¡P Rectify unacceptable practice; ¡P Check all plant and equipment; ¡P Consider changes of working methods; ¡P Discuss with ET and IEC and propose mitigation measures to IEC and ER within 3 working days; ¡P Implement the agreed mitigation measures.
Limit level being exceeded by more than one consecutive sampling days	¡P Repeat in situ measurement to confirm findings; ¡P Identify reasons for non-compliance and source(s) of impact; ¡P Inform IEC, contractor and EPD; ¡P Check monitoring data, all plant, equipment and Contractor's working methods; ¡P Discuss mitigation measures with IEC, ER and Contractor; ¡P Ensure mitigation measures are implemented; ¡P Increase the monitoring frequency to daily until no exceedance of Limit level.	¡P Discuss with ET and Contractor on the mitigation measures ¡P Review proposals on mitigation measures submitted by Contractor and advise the ER accordingly ¡P Assess the effectiveness of the implemented mitigation measures.	¡P Discuss with IEC, ET and Contractor on the proposed mitigation measures; ¡P Request Contractor to critically review the working methods; ¡P Make agreement on the mitigation measures to be implemented; ¡P Assess the effectiveness of the implemented mitigation measures; ¡P Consider and instruct, if necessary, the Contractor to slow down or stop all or part of the construction activities until no exceedance of Limit Level.	¡P Inform the ER and confirm notification of the non-compliance in writing; ¡P Rectify unacceptable practice; ¡P Check all plant and equipment; ¡P Consider changes of working methods; ¡P Discuss with ET, IEC and ER and propose mitigation measures to IEC and ER within 3 working days; ¡P Implement the agreed mitigation measures; ¡P As directed by ER, to slow down or to stop all or part of the construction activities.

5.10. Site Audits

5.10.1. Regular site audits should be implemented to ensure that the recommended mitigation measures are to be properly undertaken during proposed construction works. Site audits also acts to provide an effective control of any malpractices and therefore achieve continual improvement of environmental performance on site.

5.10.2. Site Audits shall be carried out by the ET and shall be based on the mitigation measures for water pollution recommended in the implementation schedule as presented in Appendix 10.1. In the event where the recommended mitigation measures are not fully or properly implemented, deficiency shall be recorded and reported to the site management. Actions are to be carried out to:

¡P Investigate the problems and the causes;

¡P Issue action notes to the Contractor who is responsible for the works;

¡P Implement remedial and corrective actions immediately;

¡P Re-inspect the site conditions upon completion of the remedial and corrective actions; and

¡P Record the event and discuss with the Contractor for preventive actions.

5.11. Mitigation Measures

5.11.1. Recommended mitigation measures for water quality control have been recommended in the EIA Report and listed in the implementation schedule given in Appendix 10.1.

5.11.2. In the event where complaints or non-compliance / area of improvement being observed, the ET and Contractor should review the effectiveness of these mitigation measures, design alternative or additional mitigation measures as appropriate and propose to the IEC for approval and implement these alternative or additional measures.

6. Waste Management IMplications

6.1. Introduction

6.1.1. Waste management would be the Contractor¡¦s responsibility to ensure that all wastes produced during the construction phase of the Project are handled, stored and disposed of in accordance with good waste management practices and the relevant regulations and requirements.

6.1.2. Waste materials generated from construction activities, such as construction and demolition (C&D) materials and general refuse, are recommended to be audited at regular intervals (at least once a month) to ensure that proper storage, transportation and disposal practices are being implemented. 

6.1.3. Monitoring of waste management practices will ensure that these solid wastes generated during construction will not be disposed of at the nearby coastal waters. The Contractor would be responsible for the implementation of the mitigation measures to minimize waste or redress problems arising from the waste materials.

6.2. Waste Management and Control

6.2.1. Mitigation measures for waste management as recommended in the EIA Report are summarized below. With proper handling, storage and disposal of waste arisings during the construction phase of the Project, the potential to cause adverse environmental impacts would be minimized.   

Good Site Practices

6.2.2. Adverse impacts related to waste management are not expected to arise, provided that good site practices are strictly followed. Recommendations for good site practices during the construction activities include the followings:

¡P Nomination of an approved person, such as a site manager, to be responsible for good site practices, including arrangements for collection and effective disposal to an appropriate facility, of all wastes generated at the site;

¡P Training of site personnel in proper waste management and chemical handling procedures;

¡P Provision of sufficient waste disposal points and regular collection of waste;

¡P Appropriate measures to minimize windblown litter and dust during transportation of waste by either covering trucks or by transporting wastes in enclosed containers;

¡P Regular cleaning and maintenance programme for drainage systems, sumps and oil interceptors;

¡P Proper storage of general refuse in enclosed bins or compaction units, separated from C&D material;

¡P Appropriate waste management should be implemented in accordance with the ETWB TC(W) No 19/2005;

¡P Employment of a reputable waste collector for removal of general refuse from the site, separated from C&D material; and

¡P Recording system for the amount of wastes generated, recycled and disposed of (including the disposal sites), if necessary, should be proposed.

6.2.3. A trip-ticket system should be implemented in accordance with Development Bureau Technical Circular (Works) No. 6/2010 for proper record of the quantity of C&D material generated on-site. Construction Waste Disposal Charging Scheme under the Waste Disposal Ordinance also applies to control the disposal of construction waste. Good management and control will prevent the generation of significant amounts of waste.

Waste Reduction Measures

6.2.4. Good management and control can prevent the generation of a significant amount of waste. Waste reduction is best achieved at the planning and design stage, as well as by ensuring the implementation of good site practices. Recommendations to achieve waste reduction include the followings:

¡P The design of the works should minimize the amount of C&D material to be generated;

¡P Excavated soil should be reused on site as far as possible, e.g. for backfilling, in order to minimize the amount of public fill to be disposed off-site;

¡P Segregation and storage of different types of waste in different containers, skips or stockpiles to enhance reuse or recycling of materials and their proper disposal;

¡P Encourage collection of aluminum cans by individual collectors by providing separate labeled bins to enable this waste to be segregated from other general refuse generated by the work force;

¡P Any unused chemicals or those with remaining functional capacity should be recycled;

¡P Maximizing the use of reusable steel formwork to reduce the amount of C&D material;

¡P Prior to disposal of C&D waste, it is recommended that wood, steel and other metals should be separated for re-use and/or recycling to minimize the quantity of waste to be disposed of to landfill;

¡P Proper storage and site practices to minimize the potential for damage or contamination of construction materials; and

¡P Plan and stock construction materials carefully to minimize amount of waste generated and avoid unnecessary generation of waste.

6.2.5. In addition to the above measures, specific mitigation measures are recommended below for the identified waste so as to minimize environmental impacts during handling, transportation and disposal of the waste.

C&D Material

6.2.6. The C&D materials should be re-used on-site for filling works efficiently to minimize the net amount of C&D materials generated from the Project. Filling works would include site formation, backfilling and access road construction. Engineer Representative should remind Contractors that all PFA would be required to be totally reused within the site boundary. Additionally, open stockpiles of construction materials (e.g. aggregates sand and fill material) and excavated material on sites shall be covered with tarpaulin or similar fabric during rainstorms.

Chemical Wastes

6.2.7. Plant/equipment maintenance schedule should be designed to optimize maintenance effectiveness and to minimize the generation of chemical wastes. Chemical waste should be properly stored and transported off-site for treatment by a licensed collector. The Contractor should register with the EPD as a Chemical Waste Producer and to follow the guideline stated in the Code of Practice on the Packaging, labeling and storage of chemical waste. Where possible, chemical wastes (e.g. waste lube oil) should be recycled by licensed treatment facilities.

6.2.8. Good quality containers compatible with the chemical wastes should be used, and incompatible chemicals should be stored separately. Appropriate labels should be securely attached on each chemical waste container indicating the corresponding chemical characteristics of the chemical waste (such as explosive, flammable, oxidizing, irritant, toxic, harmful, or corrosive). 

6.2.9. The Contractor should use a licensed collector to transport and dispose of the chemical wastes, to either the Chemical Waste Treatment Centre at Tsing Yi, or another licensed facility, in accordance with the Waste Disposal (Chemical Waste) (General) Regulation.

General Refuse

6.2.10. All recyclable materials (separated from the general waste) should be stored on-site in appropriate containers with cover prior to collection by a local recycler for subsequent reuse and recycling. Residual, non-recyclable, general waste should be stored in appropriate containers to avoid odour. Regular collection should be arranged by an approved waste collector in purpose-built vehicles that minimise environmental impacts during transportation.

Waste Management Plan

6.2.11. Waste materials generated from construction activities, such as construction and demolition (C&D) materials and general refuse, are recommended to be audited at regular intervals (at least once a month) to ensure that proper storage, transportation and disposal practices are being implemented. 

6.2.12. A Waste Management Plan (WMP), which becomes part of the Environmental Management Plan (EMP), shall be prepared to describe the arrangement for avoidance, reuse, recovery and recycling, storage, collection, treatment and disposal of different categories of waste to be generated from the construction activities of the Project. 

6.2.13. A WMP should be developed by the Contractor and submitted to the Engineer Representative for approval. The WMP should be prepared and implemented in accordance with ETWB TCW No.19/2005.

6.2.14. A recording system for the amount of wastes generated, recycled and disposed (including the disposal sites) should be adopted.

6.2.15. In order to monitor the disposal of C&D material at public filling facilities and landfills and to control fly-tipping, a trip-ticket system should be adopted.

7. Land Contamination

7.1. Introduction

7.1.1. Based on the assessment in the EIA Report, it is determined that there is no impact from land contamination. Monitoring is therefore not considered necessary.

8. Ecological Impact

8.1. Introduction

8.1.1. Based on the assessment in the EIA Report, the overall impacts to terrestrial and freshwater habitats are ranked as low. As the Project would not involve any marine works, no direct marine or intertidal habitat loss from the Project is anticipated. With implementation of good site practice and regular water quality monitoring during the construction stage, no marine ecological monitoring is required.

8.2. Impact Mitigation for Terrestrial Ecology

8.2.1. To minimise the potential disturbance to the breeding activitiesof Little Grebe, hoarding of not less than 2.4m high should be set up as a mitigation measure along the construction site boundary including the boundary of the works areas between the Middle and West Ash Lagoons, and between the northern edge of the PFA platform and the 30m wide channel to shield the Little Grebe, if any, from the disturbance of human activities during decommissioning phase. The hoarded area should be inspected weekly for any damage by illegal access and to evaluate the effectiveness of the measures. Damage sighted should be reported to the site manager and damaged hoarding should be repaired by the Contractor as soon as possible.

8.2.2. To prevent contaminated surface runoff entering the water channel, silt fences shall be erected. Permanent fencing shall be erected along the top of the embankment as a physical barrier to minimize the human disturbance to the Little Grebes.

8.2.3. Vegetation such as trees, shrubs and groundcovers shall be planted during both design and construction stages along the embankment to reduce the slope¡¦s susceptibility to surface erosion and slump falls.

8.2.4. Good site practices and precautionary measures would also be implemented to avoid encroachment onto the nearby natural habitats, minimise disturbance to wildlife, and ensure good air and water quality. These include but not are limited to the followings:

¡P Regular checking should be undertaken to ensure that the work site boundaries are not exceeded and that no damage occurs to surrounding areas;

¡P Implementation of mitigation measures specified in ProPECC PN 1/94 to control site runoff and drainage at all work sites during construction;

¡P Implementation of noise control measures at all construction sites to reduce impacts of construction noise to wildlife habitats adjacent works areas;

¡P Implementation of dust control measures at all construction sites to minimise dust nuisance to adjacent wildlife habitats during construction activities;

¡P Construction debris and spoil should be covered up and/or properly disposed of as soon as possible to avoid being washed into nearby waterbodies by rain;

¡P Coverage of filled slopes and materials with tarpaulin sheet;

¡P Construction effluent, site run-off and sewage should be properly collected and/or treated. Wastewater from a construction site should be managed with the following approach in descending order;

¡P Placement of sand bags at fencing near the watercourse;

¡P Proper locations for discharge outlets of wastewater treatment facilities well away from the aquatic habitats should be identified; and

¡P Supervisory staff should be assigned to station on site to closely supervise and monitor the works.

8.2.5. Construction works of retaining wall at the northern edge of ash platform and site surface drainage water system will be scheduled within non-breeding season of Little Grebe (the non-breeding season of the Little Grebe is assumed to be dry season, which is November to March in the following year, in accordance with the definition as stated in EIAO Guidance Note No. 7/2010).

8.3. Baseline Survey

8.3.1. It is noted that the Little Grebe¡¦s status and location could change from time to time even in the absence of human disturbance. Therefore, a baseline survey is recommended to update the Little Grebe condition before commencement of the decommissioning works. The survey will update the latest activities of the Little Grebe within and surrounding of the site. Subject to the baseline survey findings, the works area/phasing/scheduling will be adjusted to avoid the future Little Grebe location.

8.3.2. The baseline survey shall be conducted one month prior to the commencement of any site activities. Transect count should be conducted in the West Ash Lagoon, the remaining portion of Middle Ash Lagoon, and the 30m wide channel at the northern edge of the PFA platform in the Middle Ash Lagoon. Number of Little Grebe in each of these two areas should be recorded separately. Signs of breeding activities (e.g. courtship, nest building, brooding, chicks/juveniles etc.) in these two areas, if any, should be recorded. Location(s) of nests, if any, should be marked on maps. The habitat condition, coverage of water, any observable construction activities (e.g. PFA filling/dredging) within monitoring area, as well as any other activities should also be recorded.

8.3.3. The survey works should be conducted by qualified ecologist with at least three years of relevant experience. The result of the baseline survey shall be submitted to EPD and AFCD prior to the commencement of decommissioning works.

8.4. Impact monitoring

8.4.1. During the works period, ecological monitoring shall be undertaken to identify and evaluate any impacts with appropriate actions taken as required to address and minimise any adverse impact found.

8.4.2. Ecological monitoring in the West Ash Lagoon, the remaining portion of Middle Ash Lagoon, and the 30m wide man-made water channel should be conducted monthly throughout construction until completion of construction. Transect count should be carried out to record number of Little Grebe. Coverage of open water area in the West Ash Lagoon, the remaining portion of Middle Ash Lagoon, and the 30m wide water channel shall be estimated. Signs of breeding (e.g. nests, recently fledged juveniles) of Little Grebe shall also be recorded. Location(s) of nests, if any, should be mapped. If breeding activities are observed (e.g. courtship, nest building, brooding, chicks/juveniles etc.) in the 30m water channel, no works along this channel should be allowed to avoid potential disturbance.

8.4.3. Should signs of breeding be observed, the mitigation measures including effectiveness of the hoarding, human access to the west ash lagoon and water quality control etc. would be thoroughly inspected and reviewed to ensure minimal impacts to the breeding population.

8.4.4. The programme and method of construction would be carefully reviewed to investigate the practicable measures to minimise impact to the breeding birds through careful phasing of construction works and rescheduling to commence the works near the water channel in a later stage. The mitigation measures including effectiveness of the hoarding, human access to the west ash lagoon and water quality control etc. would also be thoroughly inspected and reviewed to ensure minimal impacts to the breeding population.

8.4.5. In addition to Little Grebe, the habitat condition, coverage of water, any observable construction activities (e.g. PFA filling/dredging) within monitoring area, as well as any other activities shall also be recorded.

8.4.6. The survey works should be conducted by qualified ecologist with at least three years of relevant experience. The monthly monitoring report should be submitted to EPD and AFCD for information.

9. Landfill gas Hazard Assessment

9.1. Introduction

9.1.1. The landfill gas hazard assessment undertaken in the EIA Study identified the risk as Medium for the Project during construction phase. As such, gas monitoring shall be conducted to ensure safe environment for workers on site. Since the Project is located next to the proposed WENT Landfill Extension, the landfill consultation zone shall be taken into consideration; the WENT Landfill Extension consultation zone is attached in Figure 9.1. Reference to Appendix 9.1 and Appendix 10.1 shall be made for all construction workers on-site to inform them of the hazards of working nearby landfill site and the safety measures to be undertaken.

9.2. Monitoring and Measurement of Landfill Gas

9.2.1. Landfill gas monitoring should be undertaken during ground works construction and in all excavations. The Safety Officer should be notified if such works is required, and subsequently to conduct more rigorous monitoring before, during, and after excavated works to ensure gas levels are within action level.

9.2.2. Intrinsically safe portable gas detectors with appropriate calibration certificates should be used during excavation or when working in any confined spaces, which have the potential for presence of LFG and risk of explosion or asphyxiation.  The monitoring equipment should alarm, both audibly and visually, when the concentrations of the following gases were exceeded:

¡P CH4: > 10% of the Lower Explosion Limit (LEL);

¡P CO2: > 0.5% by volume; and

¡P O2: < 19% by volume

Monitoring Location

9.2.3. With reference to Appendix 9.1 Guidance Notes for Landfill Gas Hazard Assessment, the following monitoring requirements shall be carried out.

9.2.4. For excavations between 300mm and 1m, measurements should be carried out:

¡P Directly after the excavation has been completed; and

¡P Periodically whilst excavation remains open during the progress of works.

9.2.5. For excavations deeper than 1m, measurements should be carried out:

¡P At ground level before excavation commences;

¡P Immediately before any worker enters the excavation;

¡P At the beginning of each working day for the entire period the excavation remains open; and

¡P Periodically whilst excavation remains open during the progress of works.

9.2.6. For excavations less than 300mm, monitoring may be omitted, at the discretion of the Safety Officer or other appropriately qualified person.

Action Level

9.2.7. The action required with detected measurements in excavation is listed in Table 9.1. The Safety Officer or other appropriately qualified persons is responsible for carrying out all actions needed depending on the measurements.

Table 9.1 Action in the event of landfill gas detected in confined areas

Parameter	Measurement	Action
Oxygen	<19%	Ventilate to restore oxygen to > 19 %
	<18%	1. Stop works 2. Evacuate personnel/prohibit entry 3. Increase ventilation to restore oxygen to > 19 %
Methane	> 10 % LEL* (i.e. > 0.5 % by volume)	1. Prohibit hot works 2. Ventilate to restore methane to < 10% LEL
	> 20 % LEL (i.e. > 1 % by volume)	1. Stop works 2. Evacuate personnel/prohibit entry 3. Increase ventilation to restore methane to < 10 % LEL
Carbon Dioxide	>0.5%	Ventilate to restore carbon dioxide to <0.5%
	>1.5%	1. Stop works 2. Evacuate personnel/prohibit entry 3. Increase ventilation to restore carbon dioxide to <0.5%

Note: LEL: Lower Explosive Limit ¡V concentration in air below which there is not enough fuel to continue an explosion

10. Site Environmental Audit & Environmental Complaints

10.1. Site Inspection

10.1.1. Site inspections provide a direct means to assess and confirm that the Contractor(s)¡¦s environmental protection and pollution control measures are in compliance with the contract specifications. The site inspection will be undertaken routinely by the ET to verify that appropriate environmental protection and pollution control mitigation measures are properly implemented in accordance with the EIA. In addition, the ET will be responsible for defining the scope of the inspections, detailing any deficiencies that are identified, and reporting any necessary action or additional mitigation measures that were implemented as a result of the inspection.

10.1.2. Regular site inspections will be carried out by the ET each month. The IEC will also undertake monthly site audit to assess the performance of the Contractor(s). The areas of inspection will not be limited to the site area and should also include the environmental conditions outside the site which are likely to be affected, directly or indirectly, by the site activities. The ET will make reference to the following information while conducting the inspections:

10.1.3. The EIA and EM&A recommendations on environmental protection and pollution control mitigation measures;

¡P Ongoing results of the EM&A programme;

¡P Work progress and programme;

¡P Individual works methodology proposals;

¡P The contract specifications on environmental protection;

¡P The relevant environmental protection and pollution control laws; and

¡P Previous site inspection results.

10.1.4. The Contractor(s) will update the ET with relevant information on the construction works prior to carrying out the site inspections. The site inspection results will be submitted to the IEC, Project Team and the Contractor(s) within 24 hours. Should actions be necessary, the ET will follow up with recommendations on improvements to the environmental protection and pollution control works and will submit these recommendations in a timely manner to the IEC, Project Team and the Contractor(s). They will also be presented, along with the remedial actions taken, in the monthly EM&A report. The Contractor(s) will follow the procedures and time frame stipulated in the environmental site inspection for the implementation of mitigation proposal and the resolution of deficiencies in the Contractor(s)¡¦ EMS. An action reporting system will be formulated and implemented to report on any remedial measures implemented subsequent to the site inspections.

10.1.5. Ad hoc site inspections will also be carried out by the ET and site audits by the IEC if significant environmental issues are identified. Inspections and audits 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.

10.2. Compliance with Legal and Contractual Requirements

10.2.1. There are contractual environmental protection and pollution control requirements as well as environmental protection and pollution control laws in Hong Kong with which the construction activities will comply.

10.2.2. In order that the works are in compliance with the contractual requirements, the works method statements submitted by the Contractor(s) to Project Team for approval will be sent to the ET for review. The implementation schedule of mitigation measures is summarized in Appendix 10.1.

10.2.3. The ET will also review the progress and programme of the works to check the regulatory compliance.

10.2.4. The Contractor(s) will regularly copy relevant documents to the ET so that the checking and auditing work can be carried out. The relevant documents are expected to include at a minimum the updated Work Progress Reports, the updated Works Programme, the application letters for different licence/permits under the environmental protection laws and all valid licences/permits. The site diary will also be available for the ET inspection upon request.

10.2.5. After reviewing the document, the ET will advise the IEC, Project Team and the Contractor(s) of any non-compliance from the contractual and legislative requirements on environmental protection and pollution control for follow-up actions. The ET will also advise the IEC, the Contractor(s) and Project Team on the current status on licence/permit applications and any environmental protection and pollution control preparation works that may not be suitable for the works programme or may result in potential nonconformity of environmental protection and pollution control requirements.

10.2.6. Upon receipt of the advice, the Contractor(s) will undertake immediate action to remedy the situation. The ET, IEC and Project Team will follow up to confirm that appropriate action will be taken by the Contractor(s) in order that the environmental protection and pollution control requirements are fulfilled.

10.3. Environmental Complaints

10.3.1. All environmental complaints should be referred to the ET leader for further action. The ET leader should undertake the following procedures upon/receipt of any complaints:

¡P Log complaint and date of receipt into the complaint database and inform the IEC immediately;

¡P Investigate the complaint and discuss with the Contractor(s) and Project Team to determine its validity and to assess whether the source of the issue is due to works activities;

¡P (If a complaint is considered valid due to the works, the ET will identify mitigation measures in consultation with the Contractor(s), Project Team and IEC;

¡P If mitigation measures are required, the ET will advise the Contractor(s) accordingly;

¡P Review the Contractor(s)'s response on the identified mitigation measures and the updated situation;

¡P If the complaint is transferred from EPD, an interim report will be submitted to EPD on the status of the complaint investigation and follow-up action within the time frame assigned by EPD;

¡P Undertake additional monitoring and audit to verify the situation if necessary and confirm that any valid reason for complaint does not recur;

¡P Report the investigation results and the subsequent actions on the source of the complaint for responding to complainant. If the source of complaint is EPD, the results should be reported within the time frame assigned by EPD; and

¡P Record the complaint, investigation, the subsequent actions and the results in the Monthly EM&A Reports.

10.3.2. A flowchart indicating the complaint handling procedures is presented in Figure 10.1.

11. Reporting

11.1. General

11.1.1. The EM&A reporting shall be carried out in paper based plus electronic submission upon agreeing forma wither and EPD. All the monitoring data (baseline and impact) shall also be submitted in CD-ROM.

11.1.2. Types of reports that the ET Leader should prepare and submit include baseline monitoring report, monthly EM&A report, quarterly EM&A summary report and final EM&A review report. In accordance with Annex 21 of the EIAO-TM, a copy of the monthly, quarterly summary and final review EM&A reports should be made available to the Director of Environmental Protection.

11.2. Baseline Monitoring Report

11.2.1. The ET Leader should prepare and submit a Baseline Environmental Monitoring Report within 10 working days of completion of the baseline monitoring. Copies of the Baseline Environmental Monitoring Report should be submitted to the Contractor, the IEC, the ER and the EPD. The ET leader shall liaise with the relevant parties on the exact number of copies they require. The report format and baseline monitoring data format should be agreed with the EPD prior to submission.

11.2.2. The baseline monitoring report should include at least the followings:

¡P Executive summary;

¡P Brief project background information;

¡P Drawings showing locations of the baseline monitoring stations;

¡P Monitoring results together with the following information:

¡± Monitoring methodology;

¡± Equipment used and calibration details;

¡± Parameters monitored;

¡± Monitoring locations (and depths);

¡± Monitoring date, time, frequency and duration;

¡P Details on influencing factors, including;

¡± Major activities, if any, being carried out on the site during the period;

¡± Weather conditions during the period;

¡± Other factors which might affect the results;

¡P Determination of the Action and Limit Levels for each monitoring parameter and statistical analysis of the baseline data;

¡P Revision for inclusion in the EM&A manual; and

¡P Comments recommendations and conclusions

11.3. Monthly EM&A Reports

Introduction

11.3.1. The results and findings of all EM&A work required in the Manual should be recorded in the monthly EM&A reports prepared by the ET leader. The EM&A report should be prepared and submitted within 10 working days of the end of each reporting month, with the first report due the month after construction commences. Each monthly EM&A report should be submitted to the following parties: the Contractor, the IEC, the ER, the AFCD and the EPD. Before the submission of the first EM&A report, the ET leader should liaise with parties on the required number of copies and format of the monthly reports in both hard copy and electronic form.

11.3.2. The ET leader should review the number and location of monitoring stations and parameters every six months, or on as needed basis, in order to cater for any changes in the surrounding environment and the nature of works in progress.

First Monthly EM&A Report

11.3.3. The first monthly EM&A report shall include at least the following:

i. Executive Summary (1-2 pages):

¡± Breaches of Action and Limit Levels;

¡± Compliant log;

¡± Notifications of any summons and successful prosecutions;

¡± Reporting changes; and

¡± Future key issues.

ii. Basic project information:

¡± Project organization including key personnel contact names and telephone numbers;

¡± Programme;

¡± Management structure, and;

¡± Works undertaken during the month.

iii. Environmental status:

¡± Works undertaken during the month with illustrations (such as location of works, daily excavation and filling rate, etc); and

¡± Drawings showing the project area, any environmental sensitive receivers and the locations of the monitoring and control stations (with co-ordinates of the monitoring locations).

iv. A brief summary of EM&A requirements including:

¡± All monitoring parameters;

¡± Environmental quality performance limits (Action and Limit Levels);

¡± Event-Action Plans;

¡± Environmental mitigation measures, as recommended in the project EIA study final report; and

¡± Environmental requirements in contact documents.

v. Implementation status;

¡± Advice on the implementation status of environmental protection and pollution control / mitigation measures, as recommended in the project EIA.

vi. Monitoring results (in both hard and soft copies) together with the following information:

¡± Monitoring methodology;

¡± Name of laboratory and types of equipment used and calibration details;

¡± Parameters monitored;

¡± Monitoring locations;

¡± Monitoring date, time, frequency, and duration;

¡± Weather conditions during the period;

¡± Any other factors which might affect the monitoring results; and

¡± QA/QC results and detection limits.

vii. Report on non-compliance, complaints, and notifications of summons and successful prosecutions:

¡± Record of all non-compliance (exceedances) of all the environmental quality performance limits (Action and Limit levels);

¡± Record of all complaints received (written or verbal) for each media, including locations and nature of complaints investigation, liaison and consultation undertaken, actions and follow-up procedures taken, results and summary;

¡± Record of all notification of summons and successful prosecutions for breaches of current environmental protection / pollution control legislation, including location ands and nature of the breaches, investigation, follow-up actions taken, results and summary;

¡± Review of the reasons for and the implications of non-compliance, complaints, summons and prosecutions including review of pollution sources and working procedures; and

¡± Descriptions of the actions taken in the event of non-compliance and deficiency reporting and any follow-up procedures related to earlier non-compliance.

viii. Others

¡± An account of the future key issues as reviewed from the works programme and work method statements;

¡± Advice on the solid and liquid waste management status; and

¡± Comments (for examples, effectiveness and efficiency of the mitigation measures), recommendations (for example, any improvement in the EM&A programme) and conclusions.

Subsequent EM&A Reports

Subsequently monthly EM&A reports shall include the following:

i. Executive summary (1 -2 pages)

¡± Breaches of Action and Limit Levels;

¡± Complaint logs;

¡± Notifications of any summons and successful prosecutions; and

¡± Reporting changes; and<future key issues.

ii. Environmental status:

¡± Works undertaken during the month with illustrations (such as locations of works, etc.); and

¡± Drawing showing the project area, any environmental sensitive receivers and the locations of the monitoring and control stations.

iii. Implementation status:

¡± Advice on the implementation status of environmental protection and pollution control and mitigation measures, as recommended in the project EIA.

iv. Monitoring results (in both hard and soft copies) together with the following information:

¡± Monitoring methodology

¡± Names of types of equipment used and calibration details;

¡± Parameters monitored;

¡± Monitoring locations;

¡± Monitoring date, time, frequency, and duration;

¡± Weather conditions during the period;

¡± Any other factors which might affect the monitoring results; and

¡± QA / QC results and detection limits.

v. Report on non-compliance, complaints, and notifications of summons and successful prosecutions:

¡± Record of all non-compliance (exceedances) of the environmental quality performance limits (action and limit levels);

¡± Record of all complaints received (written or verbal) for each media, including locations and nature of complaints investigation, liaison and consultation undertaken, actions and follow-up procedures taken, results and summary;

¡± Record of all notification of summons and successful prosecutions for breaches of current environmental protection / pollution control legislation, including locations and nature of the breaches, investigation, follow-up actions taken,, results and summary;

¡± Review of the reasons for and the implications of non-compliance, complaints, summons and prosecutions including review of pollution sources and working procedures; and

¡± Description of the actions taken in the event of non-compliance and deficiency reporting and any follow-up procedures related to earlier non-compliance.

vi. Others

¡± An account of the future key issues as reviewed from the works programme and work method statements;

¡± Advice on the solid and liquid waste management status; and

¡± Comments (for examples, effectiveness and efficiency of the mitigation measures), recommendations (for example, any improvement in the EM&A programme) and conclusions.

vii. Appendix

¡± Action and limit levels;

¡± Graphical plots of trends of monitored parameters at key stations over the past four reporting periods for representative monitoring stations annotated against the following:

¡± Major activities being carried out on site during the period;

¡± Weather conditions during the period; and

¡± Any other factors that might affect the monitoring results

¡± Monitoring schedule for the present and next monitoring period;

¡± Cumulative statistics on complaints, notifications of summons and successful prosecutions; and

¡± Outstanding issues and deficiencies.

11.4. Quarterly EM&A Summary Reports

11.4.1. The quarterly EM&A summary report which should generally be around 5 pages should contain at least the following listed information. Apart from these, the first quarterly summary report should also confirm that the monitoring work is proving effective and that it is generating data with the necessary statistical power to categorically identify or confirm the absence of impact attributable to the works.

i. Up to half a page executive summary;

ii. Basic project information including a synopsis of the project organization, programme, contacts of key management, and a synopsis of works undertaken during the quarter;

iii. A brief summary of EM&A requirements including:

¡± Monitoring parameters;

¡± Environmental quality performance limits (actions and limit levels); and

¡± Environmental mitigation measures, as recommended in the project EIA Final Report;

iv. Advice on the implementation status of the environmental protection and pollution control / mitigation measures, as recommended in the project EIA Final Report, summarized in the updated implementation schedule;

v. Drawings showing the project area, any environmental sensitive receivers and the locations of the monitoring and control stations;

vi. Graphical plots of any trends in monitored parameters over the past four months (the last month of the previous quarter an d the present quarter) for representative monitoring stations annotated against:

¡± The major activities being carried out on site during the period;

¡± Weather conditions during the period; and

¡± Any other factors which might affect the monitoring results;

vii. Advice on the solid and liquid waste management status;

viii. A summary of non-compliance (exceedances) of the environmental quality performance limits (action and limit levels);

ix. A brief review of the reasons for and the implications of any non-compliance, including a review of pollution sources and working procedures;

x. A summary description of actions taken in the event of non-compliance and any follow-up procedures related to any earlier non-compliance;

xi. A summarized record of all complaints received (written or verbal) for each media, liaison and consultation undertaken, actions and follow-up procedures taken;

xii. Comments (for examples, a review of the effectiveness and efficiency of the mitigation measures); recommendations (for example, any improvement in the EM&A programme) and conclusions for the quarter; and

xiii. Proponents¡¦ contacts and any hotline telephone number for the public to make enquires.

11.5. Final EM&A Review Report

11.5.1. The termination of EM&A programme shall be determined on the following basis:

i. Completion of construction activities and insignificant environmental impacts of the remaining outstanding construction works;

ii. Trends analysis to demonstrate the narrow down of monitoring exceedances due to construction activities and the return of ambient environmental conditions in comparison with baseline data; and

11.5.2. The final EM&A report should include, inter alia, the following information:

i. An executive summary;

ii. Drawings showing the project area, any environmental sensitive receivers and the locations of the monitoring and control stations;

iii. Basic project information including a synopsis of the project organization, contacts of key management, and a synopsis of work undertaken during the entire construction period;

iv. A brief summary of EM&A requirements including:

¡± Monitoring parameters;

¡± Environmental quality performance limits (action and limit levels); and

¡± Environmental mitigation measures, as recommended in the project EIA Final Report; and

¡± Event-Action Plans.

v. A summary of the implementation status of environmental protection and pollution control/mitigation measures, as recommended in the project EIA Report, summarized in the updated implementation schedule;

vi. Graphical plots of the trends of monitored parameters over the construction period for representative monitoring stations against:

¡± The major activities being carried out on site during the period;

¡± Weather conditions during the period; and

¡± Any other factors which might affect the monitoring results

vii. A summary of non-compliance (exceedances) of the environmental quality performance limits (actions and limit levels);

viii. A brief review of the reasons for and the implications of non-compliance including review of pollution sources and working procedures as appropriate;

ix. A summary description of the actions taken in the event of non-compliance and any follow-up procedures related to earlier non-compliance;

x. A summary record of all complaints received (written or verbal) for each media, liaison and consultation undertaken, actions and follow-up procedures taken;

xi. A summary record of all notifications of summons and successful prosecutions for breaches of the current environmental protection/pollution control legislations, locations and nature of the breaches, investigation, follow-up actions taken and results;

xii. A review of the validity of EIA predictions and identification of shortcomings in EIA recommendations;

xiii. Comments (for examples, a review of the effectiveness and efficiency of the mitigation measures and of the performance of the environmental management system, that is, of the overall EM&A programme); and

xiv. Recommendations and conclusions (for example, a review of success of the overall EM&A programme to cost-effectively identify deterioration and to initiate prompt effective mitigation action when necessary).

11.6. Data Keeping

11.6.1. No site-based documents (such as monitoring field records, laboratory analysis records, site inspection forms, etc.) are required to be included in the monthly EM&A reports. However, any such document should be well kept by the ET leader and be ready for inspection upon request. All relevant information should be clearly and systematically recorded in the document. Monitoring data should also be recorded in magnetic media form, and software copy must be available upon request. Data format should be agreed with EPD. All documents and data should be kept for at least one year following completion of the construction contract.

11.7. Interim Notifications of Environmental Quality Limit Exceedances

11.7.1. With reference to the Event and Action Plan, when the environmental quality performance limits are exceeded, the ET leader should immediately notify the IEC and EPD, as appropriate. The notification should be followed up with advice to IEC and EPD on the results of the investigation, proposed actions and success of the actions taken, with necessary follow-up proposals. A sample template for the interim notification is presented in Appendix 11.1.