This EIA Study has focused on the prediction and mitigation
of the potential impacts associated with the construction and operation of the
Project. One of the key outputs
has been recommendations on the mitigation measures to be adopted in order to
ensure that residual
impacts comply with regulatory requirements plus the requirements of the EIAO
TM. The findings and
recommendations of this EIA will form the basis on which CEDD’s environmental
performance will be judged during the detailed design, construction and
operation of the Project. To
ensure effective and timely implementation of the mitigation measures, it is
considered necessary to develop Environmental Monitoring and Audit (EM&A)
procedures and mechanisms by which the Implementation Schedule (Annex E) may be tracked and its
effectiveness assessed.
This EIAFSS Report
has, where
appropriate, identified and recommended the implementation of mitigation
measures in order to minimise the potential construction and operational
impacts of the Project. These
findings and recommendations form the primary deliverable from the whole EIA
process. Once endorsed by the EPD,
they will form an agreement between the Project Proponent (ie CEDD) and the EPD
as to the measures and standards that are to be achieved. It is, therefore, essential that
mechanisms are put in place to ensure that the mitigation measures prescribed
in the Implementation Schedule are fully and effectively implemented during
dredging, backfilling and capping.
As the Project constitutes a Designated
Project under the EIAO by virtue of Item C (Reclamation, Hydraulic and Marine
Facilities, Dredging and Dumping), Item C.10 (A Marine Dumping Area) and C.12
(A Dredging Operation Exceeding 500,000 m3) of Part I of Schedule 2,
an Environmental Permit must be obtained before construction or
operation of the facility.
Upon approval of the EIA Report, CEDD can apply for an
Environmental Permit. If the
application is successful, the Environmental Permit will, in most
circumstances, have conditions attached to it, which must be complied with. In addition, CEDD and its appointed
Contractors must also comply with all other controlling environmental
legislation and guidelines, which are discussed within the specific technical
chapters of this report. Failing
to comply with these legislative requirements could lead to prosecution under
the various Pollution Control Ordinances.
For construction and operation of the Contaminated Mud
Disposal Facility, it is envisaged that the contractual documentation will
require CEDD’s Contractors to define mechanisms for achieving the environmental
requirements. This will most
likely be achieved by requiring the Contractor to produce and implement an
Environmental Management Plan (EMP).
EMP’s are similar in nature to safety or quality plans and
provide details of the means by which the Contractor (and all subcontractors
working for the Contractor) will implement the recommended mitigation measures
and achieve the environmental performance standards defined both in Hong Kong
environmental legislation and in the Implementation Schedule (Annex E). A primary reason for adopting the EMP
approach is to make sure that the Contractor is fully aware of his
environmental responsibilities and to ensure his commitment to achieving the
specified standards.
The EMP approach is grounded on the principle that the
Contractor shall define the means by which the environmental requirements of
the EIA process, and the contractual documentation shall be met. In the first instance, each Tenderer
shall be required to produce a preliminary EMP for submission as part of the
tendering process; the skeletal EMP will demonstrate the determination and
commitment of the organisation and indicate how the environmental performance
requirements laid out in the available EIA documentation will be met. It is recommended that this aspect be
included as a specific criterion in the assessment of tender documents; this
will act as a clear indication to all Tenderers of CEDD’s commitment to the
minimisation and management of environmental impacts. Upon Contract Award, the successful Tenderer shall be
required to submit a draft and final version of the EMP for the approval of
CEDD prior to the commencement of the works.
The EM&A Manual has the same purpose of defining the
mechanisms for implementing the EM&A requirements specific to each phase of
the work.
The EM&A Manual provides a description of the
organisational arrangements and resources required for the EM&A programme
based on the conclusions and recommendations of this EIA. The EM&A Manual stipulates details
of the monitoring required, and actions that shall be taken in the event of
exceedances of the environmental criteria. In effect, the EM&A Manual forms a handbook for the
on-going environmental management during construction and operation of the
proposed contaminated mud disposal facility.
The EM&A Manual comprises descriptions of the key
elements of the EM&A programme including:
·
appropriate
background information on the construction of the Project with reference to
relevant technical reports;
·
organisational
arrangements, hierarchy and responsibilities with regard to the management of
environmental performance functions during the construction phase to include
the EM&A team, the Contractor’s team and the CEDD’s representatives;
·
a
broad works programme indicating those activities for which specific mitigation
is required, as recommended in the EIA, and providing a schedule for their
timely implementation;
·
descriptions
of the parameters to be monitored and criteria through which performance will
be assessed including: monitoring frequency and methodology, monitoring
locations (in the first instance, the location of sensitive receivers as listed
in the EIA), monitoring equipment lists, event contingency plans for
exceedances of established criteria and schedule of mitigation and best
practice methods for minimising adverse environmental impacts;
·
procedures
for undertaking on-site environmental performance audits as a means of ensuring
compliance with environmental criteria; and
·
reporting
procedures.
The EM&A Manual will be a dynamic document which will
undergo a series of revisions to accommodate the progression of the works
programme.
The objectives of carrying out EM&A for the Project
include:
·
to
provide baseline information against which any short or long term environmental
impacts of the projects can be determined;
·
to
provide an early indication should any of the environmental control measures or
practices fail to achieve the acceptable standards;
·
to
monitor the performance of the Project and the effectiveness of mitigation
measures;
·
to
verify the environmental impacts predicted in the EIA Study;
·
to
determine Project compliance with regulatory requirements, standards and
government policies;
·
to
take remedial action if unexpected problems or unacceptable impacts arise; and
·
to
provide data to enable an environmental audit to be undertaken at regular
intervals.
The following sections summarise the recommended EM&A
requirements, further details are provided in the separate EM&A Manual.
Water quality monitoring will
be required for the following activities:
·
Dredging
of each Pit;
·
Backfilling
of each Pit with Contaminated Mud; and
·
Capping
of each Pit with Uncontaminated Mud and/or Natural Uncontaminated Soil.
Water quality monitoring
results will be compared to Action and Limit levels to determine whether
impacts associated with the works are acceptable. An Event and Action Plan provides procedures to be
undertaken when monitoring results exceed Action or Limit levels. The procedures are designed to ensure
that if any significant exceedances occur (either accidentally or through
inadequate implementation of mitigation measures on the part of the
Contractor), the cause is quickly identified and remedied, and that the risk of
a similar event re-occurring is reduced.
Action and Limit levels will
be used to determine whether modifications to the works activities are
required. Action and Limit levels
are environmental quality standards chosen such that their exceedance indicates
potential deterioration of the environment. Exceedance of Action levels can result in an increase in the
frequency of environmental monitoring, modification of operations and
implementation of the proposed mitigation measures. Exceedance of Limit levels indicates a greater potential deterioration
in environmental conditions and may require the cessation of works unless
appropriate remedial actions, including a critical review of plant and working
methods, are undertaken. Before
works commence one month of baseline monitoring should be undertaken at
stations in the vicinity of the Pits and in Reference areas.
A monitoring programme
examining sediment quality will also be instituted to verify the EIA
predictions and ensure that there is no build-up in contamination adjacent to
the pits.
The full details of the
EM&A programme for water and sediment quality is presented in the EM&A
Manual for this Project.
The dredging and disposal
operations have been shown to proceed at rates that maintain environmental
impacts to within acceptable levels.
Actual impacts during the lifetime of the facility will be monitored by
recording impacts to water quality.
Monitoring and audit activities designed to detect and mitigate any
unacceptable impacts to water quality will also serve to protect against
unacceptable impacts to marine ecological resources.
In addition to the water
quality monitoring programme, monitoring of sediment toxicity is recommended to
ensure that the disposal activities are not causing sediments adjacent to the
pits to become toxic to marine life.
This programme will employ standard techniques for sediment toxicity
testing which are detailed in full in the EM&A Manual.
The EIA has indicated that
benthic fauna are expected to recolonise the pits following capping with
uncontaminated mud and/or natural uncontaminated soil. In order to verify this assessment a
benthic recolonisation programme has also been recommended. The full details of the EM&A
programme for marine ecology are presented in the EM&A Manual.
The water quality monitoring
programme will provide management actions and supplemental mitigation measures
to be employed should impacts arise, thereby ensuring the environmental
acceptability of the Project. As
impacts to the fisheries resources and fishing operations are small and of
short duration, the development and implementation of a monitoring and audit
programme specifically designed to assess the effects on commercial fisheries
resources is not deemed necessary.
The EIA has indicated that the
consumption of seafood collected within the vicinity of the pits does not pose
an unacceptable public health risk to any of the sub-populations of
concern. In order to verify the
predictions of the EIA a programme of monitoring the concentration of
contaminants of concern in seafood is recommended. The data from such a programme would also be of value to
determining the risks to the Indo-Pacific Humpback Dolphin.
Consequently, a risk
assessment should be performed at least on an annual basis to verify that no
unacceptable risk are occurring to either human health or marine mammals as a
result of consuming prey species from the waters in the vicinity of the pits of
North Lantau.
The full details of the
EM&A programme for assessing hazard to the health of humans and marine
mammals are presented in the EM&A Manual.
As no adverse noise impact is expected, noise
EM&A is not considered necessary.
As no cultural heritage impact is expected, EM&A for
cultural heritage is not considered necessary.