8 Implementation of Mitigation Measures and EM&A Requirements

8.1 EM&A Requirements

Environmental Monitoring and Audit (EM&A) requirements have been discussed in the relevant sections. In general, in view of the nature and relatively small scale of the project, the EM&A is not required for the Construction Phase, while environmental monitoring work required for the EM&A programmes of this project is already in place or will be implemented under Lamma Power Station Extension Environmental Permit or environmental licenses for the operation of the existing Lamma Power Station. Such monitoring works are considered adequate for this Project. Hence, no additional EM&A activities are required.

The current Lamma Power Station EM&A programs that are relevant to this project include:

Air

· Operation and maintenance of Continuous Emission Monitoring (CEM) System at stack to continuously monitoring the pollutants at the flue gas;

· Transmitting the on-line CEM data to EPD's office through the telemetry system;

· Manual stack particulate sampling (at least once a year for units L1 to L8);

· Operation and maintenance of an ambient air monitoring network on the southern part of Hong Kong Island (Mt. Austin Rd, Queen Mary Hospital, Victoria Rd, Ap Lei Chau, Chung Hom Kok) and north Lamma Island (Pak Kok San Tsuen);

· Operation and maintenance of dust monitoring stations around Lamma Power Station;

· Reporting the manual stack sampling result, emission data and validated CEM data to EPD;

· Monitoring dust contamination on vegetation at Lamma Village;

· Reporting the ambient air monitoring and dust monitoring results to EPD;

Water

· Monitoring the quality of wastewater discharged from the FGD WWTP plant and ash lagoon;

· Monitoring the quality of marine water around the ash lagoon;

· Reporting the waste water and marine water monitoring results to EPD.

Noise

· Operation and maintenance of on-line noise monitoring network and reporting results to EPD;

· Action/Limit levels set for the noise monitoring parameters.

8.2 Mitigation Measures

Mitigation measures have been discussed in the relevant sections. They are summarised in the Implementation Schedule provided in Table 8.1

Table 8.1 Implementation Schedule

EIA Ref.	Environmental Protection Measures	Location/Duration of Measures/Timing of Completion of Measures	Implementation Agent		Implementation Stage						Relevant Legislation & Guidelines
					Des	C		O		Dec
LAND CONTAMINATION –CONSTRUCTION PHASE
Annex B	· Cleaning of oil tanks, oil separator sump, associated pipelines, structures prior to demolition. Oily water and sludge collected from the cleaning shall be collected and disposed of as chemical waste at Government chemical waste treatment facility. (The storage and handling of the chemical waste shall follow requirements described in the Waste Management Section below)	Within the construction site/during the demolition activities	Contractor			ü					Waste Disposal Ordinance
Annex B	Handling of contaminated soil shall follow the following control measures. · Segregate potentially contaminated soil excavated around Oil Tank No.5 and stockpiling. · Stockpile shall be contained (eg soil will be stored on a liner sheet and covered with HDPE sheets). · Vehicles containing any excavated materials shall be suitably covered to limit potential dust emissions or contaminated wastewater run-off, and truck bodies and tailgates shall be sealed to prevent any discharge during transport or during wet conditions. · Records of the quantities of wastes generated and disposed of will be maintained. Contaminated soil shall be treated in accordance with EPD’s Guidance Notes for Investigation and Remediation of Contaminated Sites of Petrol Filling Stations Boatyards, and Car/Repair/Dismantling Workshops, May 1999 and reused at the Lamma Power Station & Lamma Extension areas.	Within the Lamma Power Station/Lamma Extension during excavation works	Contractor			ü					EPD’s Guidance Notes for Investigation and Remediation of Contaminated Sites of Petrol Filling Stations Boatyards, and Car/Repair/Dismantling Workshops, May 1999
Annex B	Potentially contaminated ingress groundwater, run off in the tanks and sump area encountered during the demolition and construction shall be collected and recharged to the Site.	Within the construction site/during the demolition and construction periods	Contractor			ü					Water Pollution Control Ordinance
Annex B	Control measures to minimise the contacts of the workers with the contaminated materials and to ensure safe work environments during the remediation works are proposed as follows: · Carry out health and safety risk assessment prior to commence any remediation work. · Provide and enforce uses of appropriate personal Protective Equipment (PPE) to staff who would be involved in the tanks and sump cleaning and contaminated area (BH3) remediation works. · Use bulk earth-moving excavator equipment to minimise construction workers' potential contact with contaminated materials. · Prepare appropriate control measures and procedures for entering a confined space when entering the tanks/excavation pits. · Maintain basic hygiene standards. · Establish reporting procedures if any workers fall ill during the remediation works. · The works shall be stopped or discontinued when any typhoon signal number 3; yellow, red or black storm signals are hoisted. All stockpile materials (if any) shall be covered immediately by tarpaulin or other similar protective and waterproof materials.	Within the construction site/during the demolition and remediation activities	Contractor			ü					Health and safety controls as stipulated under the Factories And Undertakings Ordinance And Occupational Safety and Health Regulation
LAND CONTAMINATION –OPERATIONAL PHASE
	· No land contamination envisaged during the operational phase and no mitigation measures required
AIR QUALITY – CONSTRUCTION PHASE The following dust control measures stipulated in the Air Pollution Control (Construction Dust) Regulation are recommended:
S.3.6.1	· The area at which demolition work takes place should be sprayed with water prior to, during and immediately after the demolition activities so as to maintain the entire surface wet;	Within the construction site/Throughout the construction period		Contractor			ü					Air Pollution Control (Construction Dust) Regulation
S.3.6.1	· Dust screens or sheeting should be provided to enclose the structure to be demolished to a height of at least 1 m higher than the highest level of the structure;	Within the construction site/Throughout the construction period		Contractor			ü					Air Pollution Control (Construction Dust) Regulation
S.3.6.1	· Any dusty materials should be wetted with water to avoid any fugitive dust emission;	Within the construction site/Throughout the construction period		Contractor			ü					Air Pollution Control (Construction Dust) Regulation
S.3.6.1	· All temporary stockpiles should be wetted or covered by tarpaulin sheet to prevent fugitive emissions;	Within the construction site/Throughout the construction period		Contractor			ü					Air Pollution Control (Construction Dust) Regulation
S.3.6.1	· All the dusty areas and roads should be wetted with water;	Within the construction site/Throughout the construction period		Contractor			ü					Air Pollution Control (Construction Dust) Regulation
S.3.6.1	· All the dusty materials transported by lorries should be covered entirely by impervious sheet to avoid any leakage; and	Within the construction site/Throughout the construction period		Contractor			ü					Air Pollution Control (Construction Dust) Regulation
S.3.6.1	· The falling height of fill materials should be controlled.	Within the construction site/Throughout the construction period		Contractor			ü					Air Pollution Control (Construction Dust) Regulation
AIR QUALITY – OPERATIONAL PHASE Since the project will significantly reduce SO2 and Particulate emissions and the NOx emissions from the L4 and L5 Units will remain unchanged, no mitigation measures are required.
WATER QUALITY – CONSTRUCTION PHASE The following mitigation measures should be implemented during the construction:
Construction Runoff and Drainage
S 4.6.1	· Exposed soil areas should be minimised to reduce the contamination of runoff and erosion.	Within the construction site/Throughout the construction period		Contractor			ü					EPD Practice Note for Professional Persons, Construction Site Drainage (ProPECC PN 1/94)
S 4.6.1	· Silt removal facilities, channels and manholes should be maintained and the deposited silt and grit should be removed regularly to ensure they are functioning properly at all times.	Within the construction site/Throughout the construction period		Contractor			ü					EPD Practice Note for Professional Persons, Construction Site Drainage (ProPECC PN 1/94)
S 4.6.1	· Temporary covers (i.e. tarpaulin) should also be provided to minimise the generation of high SS runoff.	Within the construction site/Throughout the construction period		Contractor			ü					EPD Practice Note for Professional Persons, Construction Site Drainage (ProPECC PN 1/94)
S 4.6.1	· A licensed waste collector will collect the chemical waste as well as the used water from diesel tank purging. The used water will then be transported to a facility licensed to receive chemical waste, such as Chemical Waste Treatment Centre at Tsing Yi.	Within the construction site/Throughout the construction period		Contractor			ü					EPD Practice Note for Professional Persons, Construction Site Drainage (ProPECC PN 1/94)
WATER QUALITY – OPERATIONAL PHASE Although no unacceptable water quality impact is anticipated during the operational phase, the following measures are recommended:
S 4.6.2	· The operational plant effluent from the FGD plants should be reused as much as possible in order to minimise discharge to the WWTP.	Control room/throughout the operational year		HEC					ü			-
S 4.6.2	· Maintenance of the WWTP should be performed regularly to ensure the effluent from the WWTP would not exceed the current requirements stipulated in the WPCO licence for Ash Lagoon.	WWTP/throughout the operational year		HEC					ü			-
WASTE MANAGEMENT – CONSTRUCTION PHASE Wherever practicable, inert materials should be segregated from other wastes to avoid contamination thereby ensuring acceptability at public filling areas and avoiding the need for disposal at landfill.
C&D Materials
S 5.6.1	Measures taken in the Planning Design Stages to Reduce the Generation of C&DM · Avoidance and minimization, that is, reduction of waste generation through changing or improving practices and design; · Reuse of materials, thus avoiding disposal (generally with only limited reprocessing); · Recovery and recycling, thus avoiding disposal (although reprocessing may be required); and · Treatment and disposal, according to relevant law, regulations, guidelines and good practice.	Within the construction site/Throughout the construction period		Contractor			ü					Waste Disposal Ordinance WBTC No. 25/99 Incorporation of Information on Construction and Demolition Material management in PWSC Papers
S 5.6.2	Recommended Construction Phase Measures for the Reduction of C&DM Generation · The Contractor should recycle as much of the C&DM as possible on-site. Public fill and construction waste should be segregated and stored in different containers or skips to facilitate reuse or recycling of materials and their proper disposal. Surplus public fill should be reuse on-site for reclamation, or delivered to public fills area /other reclamation site by barge for reuse. The construction waste should be collected by Contractor and transported to landfills for disposal. · The use of wooden hoardings shall not be allowed. An alternative material, which can be reused or recycled, for example, metal (aluminium, alloy, etc) shall be used.	Within the construction site/Throughout the construction period		Contractor			ü					Waste Disposal Ordinance WBTC 32/92, The Use of Tropical Hard Wood on Construction Site WBTC No. 2/93, Public Dumps
Chemical Waste The Contractor for the construction works should be registered with the EPD. Chemical waste should be handled in accordance with the Code of Practice on the Packaging, Handling and Storage of Chemical Wastes as follows.
S 5.6.3	Containers used for storage of chemical wastes should: · be suitable for the substance they are holding, resistant to corrosion, maintained in a good condition, and securely closed; · have a capacity of less than 450 L unless the specifications have been approved by the EPD; and · display a label in English and Chinese in accordance with instructions prescribed in Schedule 2 of the Regulations	Within the construction site/Throughout the construction period		Contractor			ü					Waste Disposal (Chemical Waste) (General) Regulation Code of Practice on the Packaging, Labelling and Storage of Chemical Wastes
S 5.6.3	The storage area for chemical wastes should: · be clearly labelled and used solely for the storage of chemical waste; · be enclosed on at least 3 sides; · have an impermeable floor and bunding, of capacity to accommodate 110% of the volume of the largest container or 20% by volume of the chemical waste stored in that area, whichever is the greatest; · have adequate ventilation; · be covered to prevent rainfall entering (water collected within the bund must be tested and disposed of as chemical waste, if necessary); and · be arranged so that incompatible materials are appropriately separated.	Within the construction site/Throughout the construction period		Contractor			ü					Waste Disposal (Chemical Waste) (General) Regulation Code of Practice on the Packaging, Labelling and Storage of Chemical Wastes
S 5.6.3	Disposal of chemical waste should be: · via a licensed waste collector; and · to a facility licensed to receive chemical waste, such as the Chemical Waste Treatment Facility which also offers a chemical waste collection service and can supply the necessary storage containers	Within the construction site/Throughout the construction period		Contractor			ü					Waste Disposal (Chemical Waste) (General) Regulation Code of Practice on the Packaging, Labelling and Storage of Chemical Wastes
General Refuse
S 5.6.4	· General refuse should be stored in enclosed bins separately from construction and chemical wastes. Recyclables (ie paper and aluminium can and plastic bottles) should be stored separately to facilitate subsequent recycling. A reputable waste collector should be employed by the Contractor to remove general refuse from the site, separately from construction and chemical wastes, on a daily basis to minimise odour, pest and litter impacts. The burning of refuse on construction sites is prohibited by law.	Within the construction site/Throughout the construction period		Contractor			ü					Waste Disposal Ordinance
S 5.6.4	· Aluminium cans are often recovered from the waste stream by individual collectors if they are segregated and made easily accessible. As such, separate, labelled bins for their deposit should be provided if feasible.	Within the construction site/Throughout the construction period		Contractor			ü					Waste Disposal Ordinance
S 5.6.4	· Office wastes can be reduced through the recycling of paper if volumes are large enough to warrant collection. Participation in a local collection scheme should be considered if available. In addition, waste separation facilities for paper, aluminium cans, plastic bottles etc., should be provided.	Within the construction site/Throughout the construction period		Contractor			ü					Waste Disposal Ordinance
Management of Waste Disposal
S 5.6.5	· The contractor should open a billing account with EPD in accordance with the Waste Disposal (Charges for Disposal of Construction Waste) Regulation for the payment of disposal charges. Every waste load transferred to government waste disposal facilities such as public fill, sorting facilities, landfills or transfer station would required a valid “chit” which contain the information of the account holder to facilitate waste transaction recording and billing to the waste producer. A trip-ticket system should also be established in accordance with Works Bureau Technical Circular No. 21/2002 to monitor the disposal of solid wastes at transfer station/landfills, and to control fly-tipping. The billing “chit” and trip-ticket system will be included as one of the contractual requirements and implemented by the contractor.	Within the construction site/Throughout the construction period		Contractor			ü					Waste Disposal (Charges for Disposal of Construction Waste) Regulation, December 2005 WBTC No 5/99, Trip-ticket System for Disposal of Construction and Demolition Material
S 5.6.5	· A recording system for the amount of waste generated, recycled and disposed of (including the disposal sites) should be established during the construction stage.	Within the construction site/Throughout the construction period		Contractor			ü					WBTC No 5/99, Trip-ticket System for Disposal of Construction and Demolition Material
Staff Training
S 5.6.6	· Training should be provided to workers on the concepts of site cleanliness and on appropriate waste management procedures, including waste reduction, reuse and recycling at the beginning of the Contract.	Within the construction site/Throughout the construction period		Contractor			ü					-
NOISE – CONSTRUCTION PHASE In the view that the proposed Project is in small scale, and in addition to the residential developments shielded from construction noise to varying degrees by the intervening hill (Kam Lo Hom) and the existing plants, and considerable separation distance between the NSR and the Project, the noise generated during the construction stage is not expected to be a concern. Hence, no further mitigation measures are required.
NOISE – OPERATIONAL PHASE Based on a worst-case scenario, the operational noise levels due to additional equipment will comply with the noise criterion and will have insignificant contribution to the cumulative operational noise of the Lamma Power Station. Therefore, the plant noise associated with the retrofit plant is not expected to give rise to unacceptable environmental impacts. Hence, no further mitigation measures are required.
VISUAL – CONSTRUCTION AND OPERATIONAL PHASES No mitigation measures are required.