This
EIA Study has focused on the assessment and mitigation of the potential impacts
associated with the construction and operation of the Project. One of the key outputs has been the identification
of mitigation measures to be undertaken in order to ensure that residual impacts comply with regulatory
requirements plus the requirements of the EIAO TM. 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
17) may be tracked and its effectiveness assessed.
17.1.1
Implementation of EIA Findings and
Recommendations
Sections 4 to 14
have, where appropriate, identified and recommended the implementation of
mitigation measures to reduce 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 CAPCO and the Government 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 construction.
The
required format for the Implementation Schedule (Annex 17) is specified in the EIA Study Brief. The format requires the specification of
implementation agent(s), timing, duration and location for each of the
recommended mitigation measures.
Apart from the mitigation measures identified in the EIA, there are also
procedures for other requirements to be included within the finalised
Implementation Schedule. Prior to
the issue of an Environmental Permit, there is an EIA Determination
Period. During this period the EIA
Report is reviewed and commented upon by both the public and professional
bodies. Where recommendations are
made and accepted by either the Advisory Council on the Environment (ACE) or
its EIA subcommittee, these measures will be included within the Implementation
Schedule, where appropriate.
17.1.2
Statutory Requirements
As
the Project constitutes a Designated Project under the EIAO, an Environmental Permit must be obtained before construction
or operation of the LNG terminal and associated facilities.
Upon
approval of the EIA Report, CAPCO can apply for an Environmental Permit. If the application is successful, the
Environmental Permit may, have conditions attached to it, which must be
complied with. In addition, CAPCO
and its appointed Contractor(s) must also comply with other controlling
environmental legislation and guidelines, which are discussed within the
specific technical chapters of this report.
17.2
Environmental
Management Plan
CAPCO’s construction Contractors will be
contractually bound 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
To
evaluate a contractor’s commitment, each contract bidder shall be required to
produce a preliminary EMP as part of the tendering process. The skeletal EMP will indicate the
determination and commitment of the contractor and indicate how the contractor
intends to meet the environmental performance requirements laid out in the
EIA. Upon Contract Award, the
successful bidder(s) will be required to submit a draft and final version of
the EMP for approval by CAPCO prior to the commencement of the work.
The
EPD requires the submittal for approval of an EM&A Manual prior to the
commencement of construction. The
EM&A Manual defines 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 construction 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.
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 during the construction phase. The EM&A team, the
Contractor(s) team and the CAPCO’s representatives
are included;
·
A
broad construction programme indicating those activities for which specific
mitigation is required 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 (typically, 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 reduced 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, as needed, to accommodate the progression of the construction
programme.
17.3.1
Objectives of EM&A
The
objectives of carrying out EM&A for the Project include:
·
Providing
baseline information against which any short or long term environmental impacts
of the projects can be determined;
·
Providing
an early indication should any of the environmental control measures or
practices fail to achieve the acceptable standards;
·
Monitoring
the performance of the Project and the effectiveness of mitigation measures;
·
Verifying
the environmental impacts identified in the EIA ;
·
Determining
Project compliance with regulatory requirements, standards and government
policies;
·
Taking
remedial action if unexpected results or unacceptable impacts arise; and
·
Providing
data to enable an environmental audit to be undertaken at regular intervals.
The
following sections summarise the recommended EM&A requirements and further
details are provided in the EM&A Manual.
The
EIA study concluded that no air sensitive receivers will be affected by
construction dust through the implementation of mitigation measures to reduce
dust levels. During the operational
phase, emissions will be controlled by integrated measures, regular
inspections, and relevant emissions licenses. Emissions from construction or operation
phase are not predicted to yield concentrations that would lead to significant
air quality impacts. However, dust
monitoring is recommended at the
Regular
site inspections will also be carried out during the construction phase in
order to ensure that the mitigation measures are implemented and are working
effectively.
The EIA study of the Project concluded that
no sensitive receivers will be affected by construction noise. Based upon this, no noise monitoring is
necessary during the construction phase.
However, audit of the construction noise is planned. Regular site inspections will be carried
out to audit the compliance of the Contractor with regard to noise control,
contract conditions, and to recommend further mitigation measures if found to
be necessary.
No operational phase noise impacts were
predicted at sensitive receiver locations and hence no operational phase
monitoring is required.
Regular site inspections will be carried
out during the construction phase in order to ensure conformity with the
regulatory requirements.
17.6.1
Construction Phase
The EIA indicated that water quality
monitoring will be required during the construction phase for the following
activities:
·
Dredging
works for the seawall construction and backfilling works at the reclamation
area at Black Point; and,
·
Dredging
works for the approach channel and turning basin.
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(s)), 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
operations 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, working methods and mitigation measures, are undertaken. Before construction work commences four
consecutive weeks of baseline monitoring will be undertaken at stations next to
the dredging areas.
The
full details of the EM&A programme for water quality is presented in the
EM&A Manual for this Project.
17.6.2
Operation
Phase
As no unacceptable impacts have been
predicted to occur during the operation of the LNG terminal at
In
order to ensure that the construction Contractor(s) has implemented the
recommendations of the EIA Report, regular site audits will be conducted of the
waste streams, to determine if wastes are being managed in accordance with the
approved procedures and the site Waste Management Plan. The audits will look at all aspects of
waste management including waste generation, storage, recycling, transport and
disposal. An appropriate audit
programme will be undertaken with the first audit conducted at the commencement
of the construction works. Routine
weekly site inspections will also include waste management.
The
EIA study concluded that the impact on the natural habitats is considered to be
low and no adverse residual impact is expected after the implementation of the
mitigation measures. However,
transplantation will be conducted for Pitcher Plants and Bamboo Orchids prior
to the commencement of construction works.
Regular site inspections will be carried out during the construction
phase in order to ensure that the mitigation measures are implemented and are
working effectively.
During
the operational phase, adverse impacts are not expected to occur. Therefore, no terrestrial ecology
monitoring will be required for either the construction or operational phase.
The
dredging operations have been shown to proceed at rates that maintain
environmental impacts to within acceptable levels. Monitoring and audit activities designed
to detect and mitigate any potential unacceptable impacts to water quality will
serve to protect against unacceptable impacts to marine ecological resources. 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. In addition a
marine mammal monitoring programme has been developed. The EM&A Manual provides details of
the marine mammals monitoring to be undertaken to ensure that the recommended
mitigation measures are carried out.
During
the operational phase, adverse impacts are not expected to occur. Therefore, no marine ecology monitoring
will be required for the operational phase.
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. Since the impacts to 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 Landscape and Visual
Assessment of the EIA recommended a series of mitigation measures for the
construction phase to ameliorate the landscape and visual impacts of the project. Details of all the recommended
mitigation measures are included within the Implementation Schedule provided in
Annex
17.
Implementation
of the mitigation measures for landscape and visual resources recommended by
the EIA will be monitored through the site audit programme.
During
the operational phase, adverse impacts are not expected to occur. Therefore, no landscape and visual
monitoring will be required for the operational phase.
Marine Archaeology:
No
impact to marine archaeology is predicted and hence no EM&A is required.
Land Based Archaeology:
The EIA has recommended that mitigation measure for impacted cultural
heritage resources is undertaken prior to construction of the project.
The
recommended mitigation measure is to undertaken a photographic and cartographic
recording for two building structures at Terrace 1, a WWII cave at Terrace 2
and a stone structure at Terrace 3 due to direct impact of the sites from site
formation works for the development to preserve the sites by record. AMO should
be liaised to ensure their recording requirements are fulfilled.
The
details of the watching brief are presented in the EM&A Manual.
17.13
Hazard to Life,
Land Contamination Prevention
Appropriate measures to reduce land
contamination, hazard to life and environmental risk have been
recommended. A design phase audit
is recommended to ensure that the design of the Project, including the spill
response plan, comprise the necessary elements to control, detect, contain,
clean up, handle and dispose any material that could lead to contaminated land
or pose a risk to life or the environment.
Full
details of the EM&A requirements are presented in the EM&A Manual.